Caption: 100-year 'sustainable' hardwood Annual Allowable Cuts for the Duck Mountain (FMU 13). Sources were TetrES (1995) for the LP/TetrES HSG and Forestry Branch 'Massaged' AACs, and Manitoba Forestry Branch (2004) for the Forestry Branch AAC.Caption: 100-year 'sustainable' hardwood Annual Allowable Cuts for the Duck Mountain (FMU 13). Sources were TetrES (1995) for the LP/TetrES HSG and Forestry Branch 'Massaged' AACs, and Manitoba Forestry Branch (2004) for the Forestry Branch AAC.
Eco-Journal, v.16.4, September/October 2006
By Dan Soprovich, Bluestem Wildlife
In an April 5, 2005 article ('Province cuts back on harvesting of forests'), Winnipeg Free Press reporter Ms Helen Fallding observed that Manitoba Conservation had "drastically cut back" the amount of wood that Louisiana-Pacific Canada Ltd. could log from the forests of west-central Manitoba. However, the article was short on important detail and was misleading.
The Winnipeg Free Press article indicated that the Manitoba government had implemented a 25% reduction in the Annual Allowable Cut of hardwoods (deciduous trees) for the Mountain Forest Section. This reduction is of considerable interest in relation to the conclusions and assertions of Louisiana-Pacific and their 'environmental' consultants prior to the Environmental Licensing of the Louisiana-Pacific forestry development, and the assertions, conclusions, recommendations, and approvals of the government-of-the-day (i.e., the bureaucrat/politico symbiosis-of-the-day) and 'independent' Clean Environment Commission of the time.
The Annual Allowable Cut (AAC) represents the Manitoba Forestry Branch-defined 'sustainable' amount of wood fibre that can be cut on an annual basis. The primary focus of the AAC is to provide fibre to the forestry industry, as opposed to being designed to allow for the forest to be sustained. This point is perhaps illustrated by a statement in the recent report on the wood supply analysis for the Duck and Porcupine Mountains (Manitoba Forestry Branch 2004) ... "The Forestry Branch has adopted a more open and consultative approach, jointly discussing key modelling inputs with the industry prior to inclusion into the analysis model." There is no mention of seeking the input or approval of groups within Manitoba Conservation that represent interests other than the forestry industry, or consideration of the interests and input of ENGOs, First Nations, and the many other owners and users of public forest lands.
Furthermore, when one recognizes that the raison d'etre of the Forestry Branch is principally to supply fibre to the forestry industry, when one understands the degree of decision-making power resident within the Forestry Branch, and when one observes present government practices (e.g., addressing protected areas needs within Forest Management License Areas subject to the collection of new inventory data to quantify implications to the forestry industry), one is left to conclude that the focus of the Department of Conservation, and by extension the political arm of government, is on fibre supply.
While the 25% reduction in the hardwood AAC for the Mountain Forest Section is factually correct, in terms of making relevant comparison, the number is misleading. The Mountain Forest Section consists of five Forest Management Units (FMUs), whereas the new AACs were calculated only for the Duck Mountain (FMU 13) and Porcupine Mountain (FMU 14). Therefore, the relevant comparisons are to the government AACs at the time of the overallocation to Louisiana-Pacific for these two FMUs. When these comparisons are made, we observe that the initial government allocation for FMU 13 was 36.1% greater than the new AAC, and that the difference for FMU 14 was 30.4%.
While AACs have not been recalculated for the other three FMUs of the Mountain Forest Section, we can expect that these will also drop once calculated, because many of the problems inherent to the overallocations in FMUs 13 and 14 were also inherent to the AACs for the other three FMUs (e.g., liberal assumptions respecting the size of trees that Louisiana-Pacific would use, ridiculously high growth and yield assumptions on the part of Louisiana-Pacific and their consultants). Indeed, in light of the major reductions for the two FMUs that have been examined, it would be irresponsible not to reevaluate the AACs of the other FMUs in the Mountain Forest Section.
It is important to understand that Repap Manitoba Inc. (now Tolko Industries Ltd.) was responsible for management of the two northern FMUs in the Mountain Forest Section, and that the environmental impact assessment and review process for Louisiana-Pacific's Forest Management License Area related only to FMUs 10, 11, and 13. It is therefore of greatest relevance to closely examine the numbers that pertain to FMU 13.
For FMU 13, the 1995 government allocation ('Forestry Branch 'Massaged' AAC (1995)') was 545,691 m3 of hardwoods annually (i.e., Provincial AAC Crown Open Land and Crown Restricted Land; Table 8-1; TetrES 1995), and Louisiana-Pacific proposed to cut 542,530 m3 of hardwoods per year. Louisiana-Pacific and their consultants concluded that 597,125 m3 of hardwoods ('LP/TetrES HSG AAC (1995)') could be sustainably cut each year for the next 100 years (i.e., HSG Sustainable Crown Land; Table 8-1; TetrES 1995), with no 'significant' impact on the environment. Less than a decade later, the Manitoba government has now reduced the allocation to 348,823 m3 of hardwoods per year ('Forestry Branch AAC (2004)'; i.e., Net Harvest Volume; Table 14; Manitoba Forestry Branch 2004). This represents a 36.1% reduction, or, looking at this from another perspective, an original government allocation that was about 56.4% greater than what should have been allocated.
In relation to what Louisiana-Pacific and their consultants concluded was sustainable over a 100-year period (i.e., 597,125 m3 per year), the new Manitoba government AAC represents a drop of 41.6%. Or, looking at this from another perspective, the amount that Louisiana-Pacific and their consultants indicated was sustainable over a 100-year period was about 71.2% greater than what should have been allocated (see chart).
The recalculated AAC establishes a number of matters. Of significant importance, it can now be considered a truth that the 'Concerned Citizens of the Valley', First Nation peoples, environmentalists, and the many other concerned citizens of the area and other parts of Manitoba were correct when they argued that the allocation to Louisiana-Pacific was a major overallocation, and that an allocation of that magnitude would result in substantive environmental damage to the forest ecosystems of the area. And it can now be considered a truth that Louisiana-Pacific, their highly paid consultants (e.g., some $5.5 million for the development of Louisiana-Pacific's 'Forest Management Plan' per a presentation by Louisiana-Pacific's Mr. Barry Waito; Swan Valley Star & Times May 24, 2005), and government were very wrong in this matter.
Some nine years after the fact, the recalculated AAC represents tacit admission by government that 'the little people' were right. And implicit recognition that, in matters of trust, it was 'the little people' who were to be trusted. It is perhaps a positive development to witness that government is beginning to catch up to where many of us were almost a decade ago.
How could these highly paid quasi-professionals be so very wrong when so many average citizens were right? Those of us who have been 'around the block', or even a small part of the way 'around the block', will not be completely surprised by this outcome, and will be able to come up with a number of plausible explanations. And certainly, those of us who were there at the time understood some of the reasons. Given the sheer magnitude of the now established error for FMU 13, apparent so soon after public hearings on environmental impact and sustainability (especially soon in terms of 'forest' time), the need for some form of public inquiry certainly comes to mind and seems appropriate in the context of today's circumstances— e.g. to determine how the system could have gone so wrong, with the aim to make corrections to minimize the possibility of such things occurring in the future. Does not the wise stewardship of our forest ecosystems and the environment deserve this level of attention (e.g., at least comparable to the value placed on 'Gomery' and 'Crocus')? Further to this, the truth that Louisiana-Pacific's Environmental Impact Assessment was fatally flawed and essentially irrelevant can only lead to questions respecting the validity of Clean Environment Commission processes, and adversely influence the public's confidence in governmental management of the environment on our behalf.
In terms of the technical reasons for the massive overallocation by government, and the conclusions of Louisiana-Pacific and their consultants that the allocation would have no 'significant' impact on the environment, there were many problems with the original calculation of AAC by government, and the assumptions used by Louisiana-Pacific and their consultants—problems that were obvious to a number of independent observers. For example, Mr. Jim Ball, a Canadian Forest Service forester who sat on the Technical Advisory Committee on the development, in his letter of December 15, 1995 as posted to the Public Registry, wrote, "How was the FRI massaged to double the hardwood AAC?" Some of these problems were communicated to the proponent and government, but were subsequently ignored by Louisiana-Pacific and its consultants, government, and the Clean Environment Commission. For example, the Manitoba Forestry Branch based its AAC calculation on the assumption that Louisiana-Pacific and other users of hardwoods would cut and process trees down to a 7.6 cm top for an ~2.4 m log, and would log in extremely low volume stands. These assumptions were obviously liberal and wrong to the independent observer. The new AAC calculation (Manitoba Forestry Branch 2004) more realistically assumes that industry will process to a larger top diameter (e.g., for trees of Diameter at Breast Height 21-40 cm, processing to a top of 12.7 cm), and excludes the low volume stands that industry would reject logging due to low or negative returns (i.e., where the road building and other costs would not justify the low available volumes). Almost a decade after it developed the Annual Allowable Cut for Louisiana-Pacific, Manitoba Forestry Branch has utilization standards that "... now recognize log processing limitations and mill delivery specifications" (Manitoba Forestry Branch 2004).
In the original overallocation by government, the Manitoba Forestry Branch effectively ignored the influence of a number of government policies (e.g., the Forestry Branch did not explicitly account for the buffering of streams and other 'waterbodies') and environmental limitations (e.g., the Forestry Branch included trees from steep slopes that could only be logged with substantive environmental damage). The new allocation accounts for some of these factors.
Part Two will appear in a later issue of Eco-Journal.