(this is the continuation of the Tsain-Ko FSP Public Response Letter started in the post below)
Oppostition to forestry and road building around watersheds based on concerns for water users and water quality
We acknowledged the high sensitivity to this issue and have implemented the following measures for cutblocks where operations may have an impact on licensed watersworks:
- Retained a water quality expert to assess and make recommendations in cutblocks within the Ruby Lake, North Lake, and Waugh Lake watersheds.
- Postponed our harvesting within Waugh Lake watershed in order to complete a full range of planning initiatives (Shishalh Land Use Plan) and allow full consultation with the Egmont Advisory Group.
Using Equivalent Clear-cut Area as the principal indicator from the Coastal Watershed Assessment Procedure Guidebook, 1999, and combined with the other results/strategies in this FSP, the risk of road construction and cutblock harvesting to community watersheds can be managed at a level consistent with the objectives set by government. The CWAP guidebook also considers the effects of road density and the potential for mass wasting. Given advances in road construction techniques, company best practices and environmental monitoring systems, which include identifying sediment sources, prescribing sediment and erosion control measures, water quality drainage structures that provide for natural drainage, the use of geotextile fabric, rock ditches and ditch berms, rock sumps, revegetation of disturbed soils, timing of construction and deactivation of roads after use, it is felt that road density and harvesting effects are adequately managed through company BMPs and through the practice requirements of the FPPR.
The strategy also commits during the course of normal operations to utilize qualified professionals to assess terrain stability, to monitor CWAP factors and to design major stream crossing structures, which will reduce the risk of road and harvesting impacts to water quality. Risk rating (likelihood of sediment delivery or mass wasting events compbined with the consequences of those occurrences) will be done by qualified professionals such as hydrologists, foresters, engineers or geologists.
Where multiple licenses are operating in a CWS, the holder will take into consideration those factors that contribute to the overall amount of harvesting and road construction in the CWS and will n ot harvest or construct road(s) when the thresholds will be exceeded.
Logging adjacent to the Skookumchuck Provincial Park
To date, we have not completed our planning for the area; however, we offer the following comments:
- The Park both serves to provide for a robust tourist attraction and to provide for Old Growth management. The legal boundaries of the park have been established and we have determined that our harvest proposals will be at least 30m away from the nearest park boundary. It is our intentenion to have a windfirm boundary and will proscribe windthrow proofing techniques along the harvest boundary to further protect the park.
- All western red cedar and Douglas Fir veteran trees (old growth) will be left with the harvest area where safely possible.
- We have postponed our harvesting plans in Waugh Lake watershed until 2009 to allow several planning initiatives to take place (i.e. Advisory Group, Shishalh Land Use Plan).
Concerns over impacts to local recreation and tourism
We have developed a harvesting strategy that wi presented in the public meeting. This strategy was developled from past concerns about maintaining visual buffers from important recreational/tourism corridors in the Egmont area. OUr harvesting wll be consistent with this initiative.
Windthrow and visual management buffer issues for cutblock boundaries adjacent to Egmont Road shown the FSP maps (blog note: see 'Logging Maps' in right column)
We have employed a visual "thinning" of over 100m wide to help "hide" the harvesting along Egmont Road. Our advisory committee has walked some of these buffers for their input. concerns over windthrow hazard along the Egmont Road will require windthrow assessments on these corridors and potentially windfirming treatments will take place to reduce tree "sail" and silhouette of windthrow prone dominant and co-dominant coniferous (Fd, Cw, Hw) trees adjacent to the falling boundary. The treatment will consist of the removal of 30 - 70% of the tree crown (i.e. retaining 30 - 70% of the live crown) in a spiraling pattern, evenly distributed around the stem. Up to 50% of Hw can be topped, removing 30 - 50% of the live crown (i.e. retaining 50 - 70% of the live crown. Treatment of red alder is not required. All tree crown modifications shuld be done prior to feeling the block. (blog note: Fd = Douglas Fir, Cw = Western Cedar, Hw = Western Hemlock. Hemlock is very susceptible to windthrow).
Plan for other non-Egmont operating areas
Perception that the public consultation process was flawed
During the FSP consultation process, we endeavoured to seek comment from various members of the community to initially assist us with the plan. Although not perfect, the FSP process has given us a "jump point" to facilitate the community in a more meaningful and sincere manner. With help of the SCRD, we support the advisory group concept with the community and are committed to this process.
Interest in sustainable approach to forestry and logging
It is important to remember that a sustainable approach to means having a long-term tenure with meaningful long-term planning. Tsain-Ko, however, currently has a short-term tenure (five year) in order to fulfill an agreement with the Ministry of Forest and Shishalh Nation. It is our intention to be operating with the Egmont area for the long term and to be able to build on a sustainable approach (Eco-based Management) in the future. We believe with the community involvement, we can build a foundation towards this goal once a long-term agreement becomes a reality.
Comparisons with the "Courtnall" property
During our FSP consultation process, we have been compared to the harvesting on the Courtnall Property across the Skookumchuck Narrows from Egmont (blog note: See 'Friends of Egmont - Saving Egmont Point' under 'Sites Worth Visiting' in right column). This property is private land and is government by a whole different set of regulations. We feel this comparison crated community animosity against our planned development and developed unwarranted mistrust towards the shishalh Nation. On crown land, we operate within the forest and Range Practices Act legislative framework, which holds Forest Professionals and companies accountable to ensure that our harvesting will not look like the "Courtnall" property. Clearly our blocks will fit the landscape in a much more acceptable pattern, including high standards for visual, reparian and biodiversity management and reforestation. Please refer to [this website link (pdf)] which summarizes the regulatory framework government our operations.
The proposed Forest Stewardship Plan has been reviewed by yourselves and the affected First Nations. Your comments form a part of the information that was considered during preparation of the final document, which has now been submitted to the Ministry of Forests and Range with a request for approval.
Please do not hesitate to contact the undedrsigned at (604) 885-7142 or Warren Hansen, R.P.F. with Chartwell Consultants at (604) 740-7105.
Yours truly,
Cam Forrester, R.P.F.
Consulting Forester
_____________________
Chasken Management Group
Warren Hansen
Operations Forester
Chartwell Consultants Ltd.
Submitted on behalf of Ken Snedden, Sechelt Creek Contracting Ltd - Under Management Agreement of Tsain-Ko Development Corp., P.O. Box 740, Sechelt, B.C. Canada V0N 3A0. (604) 885-2273, Fax (604) 885-3490
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