Honourable Rich Coleman
Minister of Forest and Range
PO Box 9049, Stn Prov Govt
and
Honourable Barry Penner
Minister of Environment
PO Box 9047, Stn Prov Govt
Victoria, BC V8W 9E2
February 12, 2007
Dear Ministers Coleman and Penner:
Re: Mountain Pine Beetle Salvage Logging Concerns
B.C. Nature (Federation of B.C. Naturalists) represents 50 clubs in communities from all
corners of the province. Like most residents of British Columbia, the members of BC
Nature are deeply concerned about the impact of the devastating mountain pine beetle
epidemic on the forested ecosystems of the Interior. While your government has rightly
noted that this epidemic will have a major economic impact on the people and
communities of the Interior, we wish to emphasise the wide range of possible ecological
effects and the need to address these effects by careful and thoughtful management
practices.
Unfortunately, the Government’s Mountain Pine Beetle Action Plan 2006-2011 says very
little about plans for dealing with ecological effects of both the epidemic and the follow-up
salvage operations. The rate of harvesting in lodgepole pine forests has been drastically
increased to deal with the effects of the epidemic, but we can find no explicit plans to deal
with the rapidly increasing cumulative effect of logging throughout the Interior of the
Province. While the plan understandably strives to save timber values, the ecological value
of dead trees and the ability of ecosystems to recover from insect damage are not given
sufficient attention. We are not alone in our concerns. Scientists from around the world1
have expressed concern about poorly planned salvage efforts following natural disasters.
British Columbia scientists have expressed similar concerns about the mountain pine beetle
epidemics2. Scientists have been joined by the Forest Practices Board of B.C.3,4 and by
First Nations5.
1
Lindenmayer, D.M. and R.F.Noss. 2006. Salvage logging, ecosystem processes and biodiversity
conservation. Conservation Biology. 20:949-958
2
Burton, P.J. 2006. BC Journal of Ecosystems and Management. 7 (2): 1-10; Martin, K., A. Norris
and M. Drever. 2006. Effects of bark beetle outbreaks on avian biodiversity in the British Columbia
interior: Implications for critical habitat management. BC Journal of Ecosystems and Management.
7(3): 10-24;
3
Forest Practices Board of BC 2006. Annual report for 2005-06.
4
Forest Practice Board of BC. 2006. Lodgepole pine stand structure 25 years after mountain pine
beetle attack. Special Report 32. 16p.
5
B.C First Nations Mountain Pine Beetle Action Plan, September 2005
With this in mind we wish to emphasise five points with respect to the Government’s plans
for dealing with the mountain pine beetle epidemic:
1. The scale and rate of salvage efforts is proceeding without any public discussion of the
wisdom of a headlong salvage rush. While salvage may have economic value, salvage
is not necessary for forest renewal, and it may cause more damage than the initial
ecological event.
2. The Chief Forester’s guidance letter6 on landscape level and stand structure retention
levels should be given the force of law, and the advice and concern of local scientists7
and the Forest Practices Board8 should be given a high profile in instructions to forest
licence holders. In our view the level of retention should be increased far beyond the
minimum specified in the former Forest Practices Code guidebooks. Further,
protection of the understory should be mandatory.
3. All unaffected trees should be protected in salvage logging operations. It is vital to
retain these trees for future wildlife and timber values.
4. The proliferation of logging access roads in the course of salvage operations will have
grave consequences for wildlife and water values in our forests. Full reclamation
should be mandatory to prevent long term losses.
5. More effort should be devoted to understanding the effects of the loss of tree cover on
our forested ecosystems. Part of this effort should involve systematic monitoring
efforts to watch for effects on key processes (hydrological and nutrient cycles) and key
species likely to be affected. Efforts to protect species that rely on mature lodgepole
and ponderosa pine forests should be emphasized or strengthened.
With these points in mind, we urge the Government to consult with the conservation
biologists and forest ecologists on your staff, in academia and in private practice, to revise
the Mountain Pine Beetle Action Plan in order to strengthen your declared commitment to
the sustainable management of the province’s forests. The revised plan should highlight
the conservation of long term forest values for the reasons we have outlined. The revised
Plan should be presented to the public of BC in a process that solicits and reflects public
comment and the final product made public as soon as possible. Please let us know at your
earliest convenience the steps Government is taking to revise the Action Plan and to
address our five concerns.
Yours truly
Bev Ramey, President, BC Nature / Federation of BC Naturalists
cc.
MLA Bob Simpson, Opposition Forestry Critic
MLA Shane Simpson, Opposition Critic for Environment
Snetsinger, J. 2005. Guidance on Landscape and stand level structural retention in large scale
mountain pine beetle salvage operations. Ministry of Forests and Range.
7
Klenner, W. 2006. Retention strategies to maintain habitat structure and wildlife diversity during
salvage harvesting of mountain pine beetle attack areas in the Southern Interior Forest Region. BC
Ministry of Forests and Range, Southern Interior Region. Extension Note 04.
8
Forest Practices Board of BC. 2006. Complaint Investigation 122.
6