STOCKING STANDARDS DISCUSSION PAPER

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1 STOCKING STANDARDS DISCUSSION PAPER THIS MATERIAL ACCOMPANIES THE WFP FSP COVERING PORTIONS OF WEST ISLAND AND CAMPBELL RIVER TIMBERLAND REGIONS, BUT DOES NOT FORM A PART OF THE FSP DECEMBER

2 Supporting information addressing Craig Wickland s and Chuck Rowan s remaining key concerns regarding Stocking Standards Concern 1) There is increased risk of government accepting poorly stocked stands as free growing. Comments from Craig Wickland: Concern with the reduction in the minimum standard (from 500 well spaced to 250 well spaced) for small openings ( ha) in size. Significant concern with respect to how standards are measured. There is increased risk of government accepting poorly stocked stands as free growing. Lack of stratification may affect operational adjustment factors contained within TSR and may affect the distribution of well spaced trees. Lack of target stocking has the affect of removing the "M" value for the standard ministry survey procedure. No alternative survey procedure has been described. Lack of target stocking allows for many more well spaced trees to be considered free growing at any one plot thus compensating for under stocked plots. There is increased risk of clumped distribution of stocking affecting operational adjustment factors used in TSR. When combined with reductions of MITD and averaging of well spaced across a standard unit there is increased risk of poorly stocked stands being considered as free growing. The possibility that the government will accept poorly stocked stands as being free growing because of a lack of target stocking, stratification, and reduced stocking in small openings are issues immaterial to the approval test for stocking standards in FPPR 26. Small areas of poor stocking may occur in the area of the FSP. These will be compensated for by areas with stocking well above that required to maintain or enhance an economically valuable supply of commercial timber from British Columbia s forests and is consistent with the Timber Supply Analysis (TSA) and forest management assumptions. Overall, these areas will average to a level of stocking that meets objectives. The operational adjustment factors in the TSA are very broad net-downs and the TSA assumes average conditions over the forest consistent with averaging stocking over a Standards Unit (SU). Despite the relevance of this concern with regard to the approval test, the occurrence of poorly stocked stands is expected to remain constant under the FSP compared with past Forest Development Plans. Additionally, although stocking in section and appendix D.3.2 of the FSP is achieved as an average over a standards unit, WFP does not intend at regeneration delay or free to grow to declare areas stocked that have sub-units within SUs that have significantly lower levels of stocking below the minimum. Paragraph (a) of the FSP proposes a stocking standard of 600 sph for a Standards Unit. Without an M + value or cap on the maximum number of trees per plot in the survey methodology. A comparison of the MoFR survey methodology with the WFP survey methodology shows that outcomes are similar if the stocking level is raised from 500 sph to 600 sph. In the three scenarios shown in Appendix A an x represents a free growing tree within a survey plot, and a o represents a tree that does not meet the free growing height requirement. Scenario 1 is called Regeneration Type: Plant with natural fill. In this scenario trees are planted on a well-spaced grid, with natural infill. Results of calculations on 6 survey plots are shown in the table to the right of the sample plots. In this situation, where all plots are well stocked, the MoFR and WFP survey methodologies yield similar results with the MoFR method finding 817 free growing sph, and the WFP survey method finding 833 free growing sph. Scenario 2 is called Regeneration Type: Poor natural. In this scenario no planting is done, and the resulting natural regeneration is sparse or clumpy. Plots 1, 2, 3, and 6 have sparse distribution of stocking. In this case, both the MoFR and WFP survey methodologies result in 1

3 identical numbers of stems per plot. Plots 4 and 5 have clumpy distribution of trees within the plot. The plot taken using the WFP method has more trees, but the number of trees counted is limited by the 2 metre spacing requirement. The 2 metre spacing requirements also limits the numbers of trees counted in plot 5, therefore the results for the MoFR and WFP survey methods are the same. Both survey methodologies result in a non-free-growing stand to the FSP stocking standard of 600 sph. Scenario 3 is called Regeneration Type: Failed plant with no fill with naturals. In this scenario planted trees are well-spaced, but sparse because of mortality. The MoFR and WFP survey methods yield identical results. The cutblock would be free growing under the Establishment to Free Growing Guidebook standard of 500 sph. The cutblock would not be free growing under the more onerous WFP FSP standard of 600 sph. These three scenarios demonstrate that the WFP survey methodology, where there is no maximum number of trees per plot, will not result in a higher risk to the crown of accepting a poorly stocked stand when the stocking level is set at 600 crop trees per hectare as per the FSP because the selected numbers of trees in a plot is limited by the 2 metre spacing requirement. Furthermore, green-up and adjacency concerns will drive early reforestation, and appropriate levels of stocking. FPPR section 65(3)(a) indicates that an existing cutblock must meet the criteria whereby at least 75% of the net area to be reforested of the existing cutblock is stocked such that the average height of the tallest 10% of the trees on the area is a minimum of 3 m and is stocked in accordance with the applicable FSP stocking standards or, if the area is on the Coast, is stocked with at least 500 trees/ha of a commercially valuable species that are at least 1.3 m in height. Large areas of poor stocking within a cutblock will make it difficult to meet these standards. Continued harvesting requires the assurance that trees meet the required green-up height and stocking requirements in legislation over the majority of the cutblock area. Additionally, Western Forest Products (WFP) is not changing internal procedures. Management practices including planting will continue at the high level occurring today. Although it is not legislated or required under an operational plan, WFP has voluntarily exceeded standards by fertilizing a large number of trees at the time of planting to ensure survival and growth. This practice occurs and will continue as the early seedling growth justifies the cost. The reduction in minimum standards for small openings from 0.1 ha to 0.5 ha has been removed from the FSP stocking standards. Concern 2) Over reliance on Hw Comments from Craig Wickland: Regardless of how regen delay is used within the analysis there is concern that an increased regen delay from previous Forest Practices Code standards will result in increased use of natural regeneration (6 year regen delay has typically been associated with natural regeneration and a 3 year regen delay associated with artificial regeneration) or a delay in planting. This combined with heavy reliance on Hw increases the risk of species conversion. The area of the FSP falls roughly 83% into the Coastal Western Hemlock (CWH) and 17% Mountain Hemlock (MH) Biogeoclimatic Ecosystem Classification (BEC). In the CWH zone western hemlock and western redcedar trees are common. Other species include amabilis fir and yellow-cedar in wetter and cooler areas; Douglas fir, grand fir, western white pine, and bigleaf maple in warmer and drier areas; red alder on disturbed sites; black cottonwood along rivers; and lodgepole pine on very dry sites. In the south, Sitka spruce occurs along coastlines and floodplains, while further north it occupies a wider variety of habitats. In the MH zone forests are dominated by Mountain Hemlock and amabalis fir. Yellow cedar, western redcedar and Douglas fir are minor components. 2

4 More specifically, within the area of the FSP, the Fd grows mainly in the CWH dm, xm, mm1, and ms2 variants. Cw is dominant in the CWH vh1 variant. A CwHw split is found in the QCI in the CWH wh1 and wh2 variants. The balance of BEC variants are dominated by Hw. That is, the CWH mm2, vh2, vm1, and vm2 variants and the MH zone. The following table illustrates the proportions of the BEC zones and variants within the area of the FSP Main species in variant Predominantly Hw/Hm Predominantly Fd Predominantly Cw Predominantly Hw/Cw % of FSP land base Based on the aforementioned grouping of BEC variants, roughly 65.7% or 2/3 of the area under the FSP is appropriate for Hw management. In the last 5 years, over 70% of cutblocks in the area of the FSP have been planted regardless of the length of the regeneration date in the Silviculture Prescription or FDP (generally 3 or 6 years). At the broadest level it is not WFPs intention to plant fewer trees, nor to rely more extensively on natural regeneration, nor to convert non-hemlock stands to hemlock. A regeneration date of 6 years, at the hectare level, does provide administrative flexibility for that circumstance where a small proportion of a cutblock requires a replant or more time to reforest naturally. A single common regeneration date of 6 years also aligns well with the single common free growing date of 20 years. The 20 year date is recognized as having value in terms of reducing administrative costs associated with amendments and revision. It is not taken as a signal to reduce the general level of reforestation or stand management. Numbers from Fall 2005 to Spring 2008 sowing requests demonstrate that, despite the over representation of Hw sites in the area of the FSP, the sowing requests have been predominantly for Cw/Yc and Fd. The following table illustrates the large proportion of Cw/Yc and Fd being sowed and subsequently planted. SU 05/SP 06 % SU 06/SP 07 % SU 07/SP 08 % Fd 60.4% 39.0% 34.2% Cw/Yc 22.2% 31.8% 30.6% Hw/Hm 11.4% 21.6% 25.6% Other Spp. 6.0% 7.6% 9.7% SU = summer, SP = spring Roughly 2/3 of the sowing requests have been for Fd and Cw/Yc. The numbers support the conclusion that the licensee has been relying on Hw natural regeneration where it is appropriate and planting areas where Cw/Yc and Fd management area desirable. It should also be noted that a large component of Hw natural regeneration is assumed in the Timber Supply Analysis as shown in the table in Section 5 of Attachment 2 in the Stocking Standards Rationale. 80.5% of the Timber Harvesting Land Based is assumed to be Hw regeneration. Three stand density conditions were assumed: 55.5% of the THLB was Hw planted plus naturals; 1.5% of the THLB was low density Hw naturals and no planting; and 23.5% of the THLB high density Hw naturals and no planting. The naturals ranged from 1200 sph to 8000 sph. Therefore, assuming that a component of Hw natural regeneration will continue in the area of the FSP is consistent with the Timber Supply Analysis. 3

5 Concern 3) Ecological acceptability of species. Comments from Craig Wickland: Over reliance of Hw across the majority of BEC site series without restrictions on use, especially with out the use of the preferred and acceptable format. On many of the site series Hw (and other species) may be not be ecologically appropriate (Example Hw on CWHms2 02 or Fd on CWHvm2 09). There is no clarification or specification of situations and circumstances where certain species may be ecologically appropriate to be managed for. Risk of species conversion to Hw on some sites. Ecological acceptability within the area of the FSP will be assured by the Free Growing test. The FRPA definition of a free growing stand means a stand of healthy trees. FPPR section 97(6) (declarations) indicates that a stand is not free growing 20 years after the commencement date if forest health factors cause it to not be free growing. The requirement to have a healthy stand at free growing, and 20 years after the commencement date, ensures that the trees that are deemed free growing will be ecologically suitable for their respective sites. Trees can be unhealthy because of genetics or site characteristics. When the trees meet the required free growing height, most signs of poor health should be displayed. The free growing status is further assured by the ability of government to deem the stand not free growing due to forest health factors up to 20 years after the commencement date. The BEC system as outlined in the Establishment to Free Growing Guidebooks does not guarantee ecologically suitability of individual trees. It is only a guide to the most reliable growing location by tree species. Foresters are trained to determine if a tree is on or off-site (in an ecologically appropriate microsite) based on an evaluation of forest health factors. A healthy tree displays a straight form, good diameter and leader growth, dark green leaf colour and no signs of pests. A tree growing off-site, or in an ecologically inappropriate location, shows signs of stress. Within any BEC site series there is a large amount of unmappable variability where further classification may not be practicable. A generally wet site will have drier hummocks, a snowy site will have protected microsites, a dry site will have damp stream sides and seepage areas. The leading site series generally indicates the site characteristic, but foresters and technicians determine the appropriate microsite to grow a tree. For example, the CWHvm2 09 site series indicates that the site characteristics are generally high elevation, wet, cold, with heavy persistent snowpack. Additionally, the site would generally have a very moist soil moisture regime and a very poor to medium soil nutrient regime. The described sites will, however, have areas that have high or rocky dry microsites. There may be sheltered areas where the snow pack is less persistent. The aspect may be variable with some south-facing microsites. The area may be transitional from the vm1 to the vm2, but showing more characteristics of the vm2, leading to that classification being used generally for the area. All of these site characteristics may make the CWH vm2 09 classification appropriate, but Fd may grow on some microsites within the area. If the Fd is grown in the typical snowy wet site it will display signs of stress. Heavy snow will break the leaders and the form will be compact or cabbage-like, high levels of moisture will lead to chlorosis, or loss of leaves, a high water table will lead to shallow rooting and the tree will likely be dwarfed, or may blow over at a young age. The poor health will be evident and a free growing declaration cannot be made. Similarly, a CWHms2 02 site is generally low elevation with moist cool winters and very dry summers. The 02 site series displays a very dry soil moisture regime and a very poor to medium soil nutrient regime. However, there may be streamside rich fresh seepage areas appropriate for Hw and Hw should not be discounted in these areas. Hw growing in the typical very dry and poor site will, by 20 years, be expected to show poor form and possibly infection by Hemlock Dwarf Mistletoe. 4

6 The legislation ensures that the health of every tree deemed as free growing must have a forest health assessment. Trees that are not grown on appropriate microsites will show signs of poor health and will not contribute to the free growing stocking. Concern 4) Inclusion of alder as a crop tree at 5 % without a strategy Comments from Craig Wickland: I still have concerns with inclusion of alder as well spaced crop trees where the intent is to manage for conifers (except where there are instances of root disease). I would expect there to be a management strategy if the intent is mixed species management. The silviculture survey procedures and FRPA free growing definition allow for some alder to remain in the stand without being considered as crop trees. The 5 % is based on 5 % of the total number of well spaced crop trees. With the more recent focus on maximizing conifer volume, brushing programs have removed many of the opportunities for mixed-wood management in younger stands. Alder has been depleted from the harvest landbase through interventions prior to free growing and at precommercial thinning stages over the last 30 years. The mixedwood strategy proposed in the FSP is to take advantage of the opportunities that naturally occurring alder provides in specific situations and on appropriate sites. Because the BEC sites where mixedwood management can occur are limited, and the alder stocking is limited to 5%, conifer volumes are not expected to decrease significantly and the total product volume (alder and conifer) and most importantly the value will not be significantly impacted. A study by Comeau and Sachs (1992) indicate total volume production increases when up to 200 sph of alder are evenly distributed throughout a high site index Douglas-fir stand. A substantial proportion of the alder harvested in Washington is harvested as a by-product of conifer logging. The proactive approach to alder management focuses on adding value to stands rather than concentrating on conifer volume production without considering a viable alternative. Where alder occurs naturally and in high enough densities to promote desirable stem form, then it may be managed as the crop tree. Managing a component of red alder in conifer stands does not mean allowing the alder to dominate where conifers are well established with good potential for stand development. The limited BEC site series where alder is a species targets both low elevation, rich site series where alder can achieve its full potential and poor sites where a component of alder can enhance nitrogen fixation, site rehabilitation, and soil stability. A further criterion for the mixedwood approach is establishment of the alder portion at a low cost compared to replacement with conifers. Examples include brush pockets and small seepage draws that otherwise (for conifer establishment) need multiple entries for replanting and brushing and roadsides that regenerate heavily to alder. Another example is in areas with high deer browse pressure where conifers require protection in tree shelters. Alder is rarely browsed and could be established at significantly lower cost while providing a valuable product in a shorter time frame. The economic rotation of Douglas fir and hemlock has decreased in the last decade to be within the merchantable life span of alder, making mixedwood management viable. The deciduous licences currently being managed by Weyerhaeuser have clearly shown the potential to manage mixed stands. At the upper age range, mixed stands over 70 years have been harvested successfully in the Sunshine Coast Forest District. The mixedwood approach focuses on: 5

7 Managing alder in voids where inadequate or no conifer has established, mortality is imminent or the site is unsuitable (difficult/uneconomic) for establishing conifers. Increasing productivity in areas poorly stocked with preferred conifers by leaving alder in small voids. Leaving low levels of alder evenly spaced in stands generally well stocked with conifer. Where candidate stands are identified following standard stocking surveys, the removal of excessive alder will be delayed as long as possible to allow better development of alder stems and to aid in identification of good crop trees as well as for forest health concerns. Because of the high market value of alder, and that mixedwood management is consistent with maintaining or enhancing an economically valuable supply of commercial timber from British Columbia s Forests, the licensee should receive credit for management in appropriate locations. Thus, the licensee had included up to a 5% component of alder within the stocking standard rather than leaving the alder as a ghost tree within the stand. Concern 5) Intermediate Cutting Situations November 29 th comments from Chuck Rowan: It is still unclear as to where and when intermediate cutting will be applied. The concern is that it is unclear as to how often intermediate cutting will be applied across the landscape and the effect on future timber supply. Intermediate cutting will not occur over 0.1% of the Timber Harvesting Land Base. Concern 6) Legal requirement to establish a Free Growing Stand November 29 th comments from Chuck Rowan: Unless there is an exemption from the requirements of FRPA 29 (1) by FPPR 44 (3) (a) to (g) it is believed that the requirements of FPPR 44 (4) would apply to these small areas, i.e. licensee is not able to build this condition into the FSP. The stocking standard for less than 0.1 ha will be no stocking. This standard will be applied to areas where there are no regeneration objectives, but are not intermediate cutting situations. Examples of these include feathering or other removal of trees for windfirming, and single stem harvesting. This type of single stem harvesting will be single entry only where there is no intention to perform a final harvest. These areas are outside of the Timber Harvesting Land Base because constraints such as terrain, visuals, or wildlife objectives take precedence over timber harvesting opportunities. WFP s intention is to limit this type of harvesting to less than 5% of the annual cut for any given license. 6

8 Appendix A 7

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