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The Board initiated this special investigation to address concerns
identified during the Board's investigation of a public complaint
about forest development plan (FDP) consistency with the Cariboo-Chilcotin
Land Use Plan (CCLUP). The complainant in that case believed that
several approved operational plans would result in damage to habitat
used by caribou in early winter. This special investigation looks
at the approval of two operational plans: 1) an amendment to West
Fraser Mills Ltd.'s 1999-2003 FDP (forest licence A20021) for the
area of cutting permit 61, block 1 (CP 61-1), and 2) the silviculture
prescription for CP 61-1.
There are presently about 2,500 mountain caribou in the province
and about 200-300 inhabit the mature forests and alpine areas in
the eastern portion of the Cariboo Forest Region. The CCLUP states
that these caribou are at risk and that the regional population
is of considerable provincial significance and a high provincial
wildlife priority. The CCLUP provides some general direction for
management of caribou habitat.
Proposals affecting 1,400 hectares of forest used by some caribou
in early winter were submitted for approval in FDPs, including CP
61-1. The district manager and the designated environment official
approved CP 61-1 in the licensee's 1998-2002 FDP (FDPs for that
area required joint approval by the district manager and the designated
environment official). The plan proposed evenly distributed small
clearcuts of two to five hectares.
The licensee found a similar approach, used nearby, was uneconomical,
and proposed an amendment in 1999 to clearcut the area and leave
a reserve. That request was rejected, as it did not provide for
caribou habitat.
The licensee then proposed an amendment that would retain, or potentially
retain, additional standing timber in CP 61-1. The amendment affected
256 hectares, consisting of a large clearcut unit, two partial harvest
(variable retention) units and a wildlife tree patch. The amendment
allowed for more harvesting and larger openings within CP 61-1 than
did the 1998 FDP. However, the amendment provided for retaining
poor quality trees within the clearcut "where suited."
This was described as a "wildlife tree in flux" concept
to give the licensee discretion to retain additional wildlife tree
patches in the clearcut unit, depending on operational considerations.
The amendment allowed for a broad range of potential outcomes.
The district manager approved the silviculture prescription for
CP 61-1 in May 1999 (he had sole authority to approve the silviculture
prescription). The silviculture prescription was consistent with
the amendment, but did not specify a minimum level of retention
or characteristics of retained trees. The district manager made
his approval subject to conditions, which were intended to ensure
adequate retention in the stands. The licensee began harvesting
shortly thereafter, and completed harvesting in the fall of 1999.
Of the total area of 256 hectares, 57 percent was clearcut. The
licensee completely harvested the clearcut unit, and did not retain
additional patches of poor quality trees. The district manager and
the designated environment official were both dissatisfied with
the result, as the original objective of retaining poor quality
trees for caribou habitat was not met. In contrast, the licensee
believes the result was consistent with the amendment and silviculture
prescription, which provided flexibility depending on operational
considerations.
The Board found that the operational plans complied with the Code's
requirements for managing wildlife habitat areas and ungulate winter
ranges because no such areas had been designated for the vicinity
of CP 61-1. The Board did not come to consensus on whether the plans
were consistent with the CCLUP objective of maintaining habitat
values for mountain caribou within the region.
The Board also did not reach consensus on whether it was appropriate
for the statutory decision makers to be satisfied that the amendment
to the FDP adequately managed and conserved caribou habitat values.
However, all Board members agreed that, because the FDP allowed
for a wide range of outcomes, it was important for the silviculture
prescription to address the needs of caribou by clearly stating
the desired end result.
The Board found that it was inappropriate for the district manager
to be satisfied that the silviculture prescription would adequately
manage and conserve caribou habitat values. The Code does not allow
the district manager to attach conditions to a silviculture prescription,
and the silviculture prescription did not ensure poor quality trees
would be retained in the clearcut.
The failure to achieve the decision-makers' intended end result,
and disagreement about whether the end result is in fact a failure,
demonstrate the importance of clearly stating expected results in
operational plans. It is essential that a results-based approach
to operational plans express desired outcomes in practical and measurable
terms that relate to the resource being conserved. That is especially
important when dealing with special resource values, such as wildlife
species at risk.
The Board makes a number of recommendations in the report including:
To ensure that intended end results are achieved, the Board recommends
that licensees clearly specify in their operational plans the desired
end result in practical and measurable terms and the measures necessary
to achieve those results.
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