Saturday, June 14, 2014

Comments from the area based forest tenures consultation

 The following comments are from the area based tenures consultation.
DENIS O'GORMAN from Thompson / Okanagan provides well balanced comments that are not encumbered by technical forestry details:
VOLUME TO AREA BASED FOREST TENURE
1. CONVERSION: PROS AND CONS
The current proposal is, as I understand, to enable conversion of existing replaceable volume based licenses to replaceable area based licenses (known as tree farm licenses). The primary benefit I also understand is that it creates an incentive for intensive forest management because it enables those investing effort and other resources to benefit from anticipated increases in harvestable volumes. In concept, it is increasing the commercial value of the timber rights.
On the other hand, disbenefits with area-based licenses are:
It has proven difficult and costly to make land use adjustments that are in the public interest, and
It capitalizes the harvesting rights into shareholder value but gives no assurance of either permanent commitment to BC or its communities or proportionate “rent” to the Crown.
2. CONCERNS
Stability
Many companies have had area-based licenses (TFLs) in BC. We have been witness to the departure of many: BC Forest Products, Can Cel, Columbia Cellulose, Crown Zellerbach, Eurocan, Fletcher Challenge, McMillan-Bloedel, Rayonier, and Weldwood to list a few. Long term investment decisions including forest management and intensive forestry were not delivered, nor was long term community stability. High value old growth forests were largely liquidated along with their ecosystems. The “thrifty” forests that replaced them have in many cases underperformed in both volume and quality. It is necessary to ask why some form of reserve account to deliver greater ongoing stand management can’t be put in place.
One way Street
The founding promise of TFLs was to package public timber lands along with adjacent private timberlands to help make more viable and sustainable management units capable of ensuring sustainable log supply to mills. Reductions to these TFLs, beyond a low threshold, would require compensation. Yet we witnessed no compensation when Western Forest Products private lands were removed from TFL status even without compensation for foregone taxes. It proved to be a great holding property with no commitments to manage land for forest values or due process evident.
All Values Considered
Forests have many non-timber values and these have tended to obtain greater but still insufficient recognition over time. Nominally the Forests Ministry represents all these values and some progress has been made in this. That said, the principal mind-set remains that of timber supply. Any “net downs” of a harvestable timber base are resisted. Concessions to recognition of non-timber values typically come at public cost such as offset payments against stumpage charges or direct compensation. To society, non timber values including recreation, tourism, visual protection, watershed integrity and ecosystem/species protection have and continue to rise.
Further locking in of timber as a property right would make any harvest level/land use adjustments more costly even, on a land base that is nominally Crown.
Access
Some will recall roads paid for as through stumpage, not being open to public access. I’m also aware of and deplore vandalism of machinery, recreation sites and forest stands. But I am apprehensive about potential new access barriers. Ministry enforcement capacity needs serious re-examination.
Access to what
One answer is access to special places often made scarce by past harvesting. As an example, some may recall that one of the last mountain- top hikes on Vancouver Island, Heather Mountain, was reduced to a short stroll. Were all values seriously considered? In the words of Marion Clarison from Resources for the Future, Forests for Whom and for What?, this is a question with enduring validity.
Consider for example the fragility of even designated parks now being made available for development through “research permits”. Where’s the reverse compensation to the public there?
License Conversion where it makes sense
A business case for conversion can readily be made. Security as a hedge, growth and yield “lifts” and timber value capitalization put into a saleable asset base. When would it not make sense? Perhaps where society’s land use values are changing or are not adequately resolved? Perhaps where long term commitment to a community or Province is not assured? Perhaps where access to timber supply by value-added operators is restricted? These and other questions need to be considered as part of valid timber tenure reform.
Other Tenure holders
A stated benefit of area-based tenure is that it will provide non-timber operators a land manager “so they know who to talk to about their non-timber tenures”. The question is what if anything is their leverage in such discussions? Strong tenures with concentrated economic values (e.g. mineral claims) presumably have significant leverage, heli-ski companies perhaps less, backcountry recreation tenures still less and local communities any? What if any fair process for consideration of non-timber values would be provided? This needs serious examination as part of tenure review.
3. CLOSING COMMENTS
The proposal to convert existing replaceable volume based licenses with area-based licenses does not presently address many important concerns related to ensuring the public interest in use of Crown land.
Rather than presume this proposed conversion from volume to area-based tenures is the only way to produce prospective benefits of more intensive forest management, a more comprehensive evaluation of tenure and management options should be considered including opportunities for tenure diversification and the respective enabling conditions for each.
This entails considered comparative assessment of a range of options against outcomes such as:
ability to respond to new land use demands, needs and desires (i.e. flexibility);
ability to achieve more intensive forest management;
support for greater areas of wood supply for non-timber licensees;
contribution to community stability to reinvestment; and
contribution to Crown revenue
One starting point could be identification of a full range of tenure options by an expert panel coupled with a comparative assessment of those options. The question of appropriate tenure options and their appropriate mix and either respective enabling conditions warrants in depth examination including an adequate opportunity for open public review.
Thanks for the opportunity to comment.
Denis O’Gorman
May 29, 2014

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