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28th July 2019
...Continued from Part 2

Watershed Protection

In order to protect community drinking water supplies that depend on the hydrological integrity of a watershed as a whole, not just on Local Water Intakes, we suggest that the community watershed guidelines that were grandparented into the Forest and Range Practices Act in 2004 be written into the legislation governing the Private Managed Forest Lands, and that a hydrological study followed by sign-off from the relevant Regional District be required before harvesting in a community watershed can occur.[20]
When the Forest Practices Board studied community watersheds managed under the FRPA in 2014, they found that:

Requirements to protect drinking water were not clear or well understood.
Commitments made in forestry plans were not always enforceable.
Greater emphasis needed to be placed on erosion and sediment control on forestry roads.[21]
In support of the FPBís recommendations to ensure that the governmentís objectives for community watersheds are achieved, we suggest that the Private Managed Forest Lands Program:

Clarifies requirements for the protection of water.
Defines the concept of cumulative hydrological effects.
Requires publicly available harvesting plans to include hydrological analysis which includes cumulative hydrological effects.
Ensures that professional reliance assessments are meaningful.
In partnership with Regional Districts, monitors water quality in community watersheds and tracks their status.
We further recommend that members of the Private Managed Forest Lands Council urge the government to fully implement the Water Sustainability Act, which would go 60% of the way towards protecting critical community watersheds.

Ecological Restoration

We suggest that large forest land owners be required to set aside a financial reserve in a Private Managed Forest Lands Program Account for the purpose of ecological restoration following defined damage, those moneys to be foregone if the restoration does not proceed, or if the consequences of the damage before restoration have to be offset (for instance) through municipal water treatment. Carefully defined criteria will be needed to evaluate damage and create financial and legal certainty.
Other Suggested Changes
Silviculture Savings Account: Considering the uneven annual flow of income to land owners owning smaller parcels of forest, resulting in higher taxation in harvest years and lower taxation in non-harvest years, we suggest that the Ministry of Finance create a Silviculture Savings Account, similar in character to an RRSP or RESP, allowing earnings to be stored and taxed when they are withdrawn, unless the withdrawal is for a silvicultural investment.
Conservation Tax Incentive Program: Considering the ecological values that are enhanced by the practice of ecological forest management, retaining the canopy and managing a forest with the intent to restore old growth qualities, we suggest that the Ministry of Finance consider creating a Forestry Class Exemption, and/or a Conservation Tax Incentive Program similar in spirit to the Agricultural tax reduction.
Density-transfer: Considering that some private forest land owners may have no intention or desire to develop their land in accordance with their permitted residential densities, we suggest that the Ministry of Municipal Affairs develop a province-wide set of density-transfer regulations, enabling forest land owners to sell their density rights into other approved areas.
Two hectare lower limit: Considering that many small land owners may be interested to harvest timber from their forest lands in a sustainable manner, we suggest that where landowners become members of a locally established forestry association or cooperative, as is common in Finland, the lower limit for the program be reduced from 3.5 to 2 hectares.

Other Forestry-Related Suggestions

We would like consideration for these related suggestions, which may or may not fall under the Private Managed Forest Land Programís remit:

Trees as a Farm Crop: On private land classed as farmland, we suggest that the Ministry of Forests work with the Ministry of Agriculture to enable trees to be declared a farm crop for farming purposes, enabling forest-farmers to qualify for the agricultural land tax credit. The current list of qualifying crops only includes Christmas trees and the intense cultivation of plantations of poplar and willow.[22]
A Forest Thinning Incentive Program: We suggest that the Ministry of Forests work with the Ministry of Finance to develop a forest thinning incentive program to reduce fire risk, increase multi-age species representation, and advance a forest down the oldgrowth curve.
A Forest Carbon Incentive Program: We suggest that the Ministry of Forests work with the Ministry of Environment and the Ministry of Finance to develop a Forest Carbon Incentive Program, establishing regulatory mechanisms and financial incentives to reduce average carbon emissions per hectare and increase average carbon storage per hectare, to contribute to the missing 25% of emissions reductions in the provinceís CleanBC 2030 goals.[23]
Transition to Ecological Forest Management: We suggest that in light of the urgency of the climate and ecological emergencies, the Ministry of Forests work with the Pacific Institute for Climate Solutions at UVic and the UBC School of Forestry and the Ministry of Finance to develop a ten-year transition for all forests in BC to ecological forest management. The knowledge base already exists through fifty years of ecological forest management science, some of which was well-expressed in BCís old Forest Practices Code. We suggest using incentives for five years, followed by a regulatory approach if the incentives do not produce the needed results.

Contact: Guy Dauncey, President. 250-924-1445

[1] Global Deal for Nature:

[2] Private communication from Rick James, Comox Valley resident.

[3] TimberWest:

[4] Island Timberlands:

[5] Mosaic Forest Management:

[6] Managed Forest Council Annual Report, 2017/2018.

[7] Trucks 17 metres long, distance 1,819 kilometres

[8] New York City:

[9] Narwhal:

[10] Cowichan River:

[11] Carbon storage:


[13] Sierra Club:

[14] BC forest carbon emissions:

[15] Wildlife guidance:

[16] Right to Roam:

[17] Glyphosate:

[18] Glyphosate:

[19] IUCN Study:

[20] Community drinking water:

[21] Forest Practices Board:

[22] Qualifying agricultural use:

[23] CleanBC: