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AWA Response: Spray Lake Sawmills Draft 2021 Forest Management Plan

July 17, 2020

AWA submitted the following letter as part of the consultation period for Spray Lake Sawmills (SLS) draft 2021 Forest Management Plan (FMP).

A pdf copy of AWA’s letter can be downloaded here: AWA Response: Spray Lake Sawmills Draft 2021 Forest Management Plan

The consultation period for the draft FMP ends on Tuesday, July 21, 2020. The full FMP can be downloaded at https://www.spraylakesawmills.com/woodlands/forest-management-planning/

July 17, 2020

Jason Mogilefsky
Environment & Safety Supervisor, Spray Lake Sawmills
Via e-mail: jason.mogilefsky@spraylakesawmills.com

AWA Response: Spray Lake Sawmills Draft 2021 Forest Management Plan

Dear Jason Mogilefsky,

Alberta Wilderness Association (AWA) would like to offer the following comments (attached) for Spray Lake Sawmills (SLS) as part of the consultation period for the draft 2021 Forest Management Plan (FMP).

Founded in 1965, AWA works throughout Alberta to achieve more representative and connected protection of the vital landscapes that are the source of our clean water, clean air and wildlife habitat. With over 7,000 members and supporters in Alberta and across Canada, AWA remains committed to ensuring the conservation of wildlife and wild places in Alberta for generations to come.

AWA has long advocated for ecosystem-based management of Alberta’s forests, and our objective is to ensure that the landscapes and habitats located within the SLS Defined Forest Area (DFA) are managed to maintain their pristine condition for the benefit of Albertans and Alberta’s wildlife species.

Following previous submissions by AWA, we have outstanding concerns regarding a number of timber and non-timber values, foremost the removal of cold water fish from SLS’ Values, Objectives, Indicators and Targets (VOITs) and the expected deviations for Equivalent Clearcut Area (ECA) in the 10 and 20-year spatial harvest sequences (SHS).

Related to the draft FMP, AWA also requests that SLS detail if and how the May 4, 2020 announcement by Alberta Forestry[1] has impacted annual allowable cut (AAC) within the SLS DFA.

We look forward to your written response detailing how SLS will address each of AWA’s comments.

Sincerely,

ALBERTA WILDERNESS ASSOCIATION
Grace Wark
Conservation Specialist

Cc: Honourable Devin Dreeshen, Minister, Alberta Agriculture and Forestry, af.minister@gov.ab.ca

Honourable Jason Nixon, Minister, Alberta Environment and Parks, aep.minister@gov.ab.ca

Daniel Lux, Executive Director, Forest Stewardship and Trade, daniel.lux@gov.ab.ca

Ken Greenway, Director, Strategic Forest Initiatives, ken.greenway@gov.ab.ca

Chris Breen, Director, Forest Tenure, chris.breen@gov.ab.ca

Alberta Wilderness Association Review and Recommendations:
Spray Lake Sawmills Draft 2021 Forest Management Plan
July 2020

Alberta Wilderness Association (AWA) submits the following comments as part of the consultation period for Spray Lake Sawmills (SLS) draft 2021 Forest Management Plan (FMP). The sections that follow detail timber and non-timber values identified by AWA that require further attention by SLS in the management planning process, including the relevant chapters and annexes in the draft 2021 FMP.

SPECIES AT RISK
Cold Water Fish
As detailed in the draft FMP (Chapter 7), SLS is well-aware of the current condition of threatened native trout in the southern eastern slopes region, within which the SLS defined forest area (DFA) resides. AWA has outstanding concerns regarding the removal of cold water fish, in particular SARA-listed populations of westslope cutthroat trout and bull trout, from the listed species in the FMP’s Values, Objectives, Indicators and Targets (VOITs; Chapter 5).

Although SLS has drafted a Westslope cutthroat trout and bull trout recovery strategy (Chapter 7), AWA has found that the recovery strategy, and additional measures included in SLS’ 2020 Operating Ground Rules, do not provide sufficient detail on how native trout population recovery will be monitored and reported over the 10 and 20-year spatial harvest sequences (SHS). Monitoring and reporting are necessary components of native trout population recovery to ensure that populations are stable and unaffected by timber harvest processes. They also are essential to ensure the effectiveness of mitigation and avoidance strategies proposed by SLS. AWA believes excluding cold water fish from VOITs means there are no measurable targets in place to assess fish habitat recovery.

AWA requests a written explanation as to why the Planning Development Team (PDT) removed cold water fish from the VOITs, AND that SLS detail how monitoring and reporting will take place to ensure that SARA-listed native trout species are not impacted negatively by timber harvest over the 10 and 20-year SHS.

AWA requests that monitoring requirements be included within the Westslope cutthroat trout and bull trout recovery strategy (Chapter 7), in addition to reinstating cold water fish (including westslope cutthroat trout and bull trout) within VOIT 14 (Chapter 5).

Further to AWA’s concerns, the Recovery Strategy for the Bull Trout (Salvelinus confluentus), Saskatchewan-Nelson Rivers populations, in Canada has been drafted and is currently pending final approval. Consistent with AWA’s recommendations for the federal bull trout recovery strategy, AWA recommends that SLS implement a minimum riparian buffer of 100m. Internal records obtained by Fluker and Mayhood (2020) indicate that federal fisheries officials believe the minimum riparian buffer for westslope cutthroat trout (which have similar habitat requirements and occupy many of the same watercourses as bull trout) should be 100m. [2]

Relevant sections/recommendations:

Chapter 2, Section 3.13 (Non-Timber Assessments): Cold water fish excluded.
AWA recommendation: Add cold water fish to the non-timber assessment.
Chapter 3, Section 6.9.1.3 (Fisheries Hydrologic Unit Code): FSIs are developed and selected for cold water fish species based on the HUCs.
AWA recommendation: Publish the Fish Sustainability Indexes (FSI) in the 2021 FMP.
Chapter 5, Table 2-1 (VOIT Summary Table), VOIT 14 (Species at Risk), and Section 4.1.8 (Species at Risk): Cold water fish removed from the High Value Species in VOIT 14
awa recommendation: Reinstate cold water fish within VOIT 14 and add measurable objectives and targets for monitoring and reporting westslope cutthroat trout and bull trout recovery.
Chapter 7, Westslope cutthroat trout and bull trout habitat recovery strategy
awa recommendation: Add measurable objectives and targets for monitoring and reporting westslope cutthroat trout and bull trout recovery.
Annex III, Water Quality/Quantity and Fisheries Resources:
AWA recommendation: Water quality monitoring of Fish Creek, Fisher Creek, Mclean Creek, Prairie Creek, Quirk Creek, and Silvester Creek should continue during the 10 and 20-year Spatial Harvest Sequences (SHS); reports of these studies should be published regularly on the SLS website.

Grizzly Bears
As noted in the SLS FMP, Grizzly bears are designated as a threatened species in Alberta. A substantial portion of the SLS DFA (88 percent) falls within grizzly bear core and secondary habitat (Chapter 3, Table 6-8), which underscores SLS’ responsibility to support the recovery of the species.

AWA supports SLS’ approach to implement access management protocols along active resource roads and maintain road densities below the thresholds prescribed by the Alberta Grizzly Bear Recovery Plan. However, AWA requests clarification on whether the total reported road densities (Chapter 5, Table 4-12) include roads and linear features not owned by SLS. Cumulative road disturbance needs to be measured and reported in order to assess the full impacts of forestry roads to grizzly bear populations.

While not listed within the FMP, AWA does not support the proposed deviations from VOIT 14 (Chapter 5, Table 2-1), where SLS intends to decrease grizzly bear secondary habitat and increase primary sink habitat over the 10 and 20-year spatial harvest sequences (SHS). AWA believes that creating more primary sink habitat will increase mortality risk within the populations located within the DFA and significantly contribute to declining population trends. We request that SLS avoid primary and secondary grizzly bear habitat entirely. Where that is impossible, SLS should implement measures to achieve no-net loss[3] of primary and secondary grizzly bear habitat by restoring primary and secondary sink habitat.

Relevant sections/recommendations:

Chapter 5, Table 2-1 (VOIT Summary Table)
AWA recommendation: AWA does not support the proposed deviation from VOIT 14 in the 10 and 20-year SHS to decrease grizzly bear secondary habitat and increase primary sink habitat.
Chapter 5, Section 4.1.8.1 (Grizzly Bear): Grizzly Bear Habitat: Total road densities, including closed and temporary operational roads, in the portions of the grizzly bear population units overlapping the DFA, were between 0.285 and 0.412 km/km2.
AWA recommendation: AWA requests clarification on whether the total reported road densities (Chapter 5, Table 4-12) include roads and linear features not owned by SLS. Cumulative road disturbance needs to be measured and reported in order to assess the full, cumulative impacts of forestry roads to grizzly bear populations.
Chapter 7, Section 8.2.1 Grizzly Habitat Management Strategy
AWA recommendation: SLS should remove the excerpt citing personal communication with Gordon Stenhouse (June 03 2020). The statement “that there is no evidence of Grizzly Bears being limited by habitat supply” does not cite peer-reviewed literature, and diminishes the importance of high quality grizzly bear habitat and the impacts of cumulative land-use on habitat loss.

STRUCTURE RETENTION
AWA believes the 3 to 5 percent structure retention target set by SLS and Alberta Agriculture and Forestry (AAF) is considerably below what the best available evidence on adequate structure retention levels maintains is needed for biodiversity and increasing connectivity within regenerating stands.[4] AWA is also concerned that windthrow and edge effects of smaller patches may considerably reduce the potential biodiversity benefits of current structure retention measures.

In 2016, Alberta Agriculture and Forestry proposed that retaining at least 10 percent of the harvest area would ensure that forest management planning “demonstrates Alberta’s clear commitment to using sound science and implementing sustainable management principles.”[5] That government conclusion was based on an “extensive body of scientific evidence” citing International and Alberta-based research, including the EMEND experiment and the Healthy Landscapes Program.

AWA requests that SLS and Alberta Forestry undertake a review of the requirements for structure retention, and respect the scientific justification behind the minimum 10% target set by the 2016 Structure Retention Directive (Appendix I).

Relevant sections/recommendations:

Chapter 1, Section 4 (Forest Management Issues & Values)
AWA recommendation: This section should be revised to adequately capture concerns raised around structural retention by AWA and other stakeholders on multiple occasions (Chapter 2, Table 6-3).
Chapter 5, Section 2.4.4, VOIT 10 (Structure retention)
AWA recommendation: Increase structure retention target to a minimum of 10 percent by area.

WATERSHED PROTECTION
AWA has outstanding concerns regarding the forecasted hydrologic impacts to watersheds exceeding 30 percent Equivalent Clearcut Area (ECA) in the 10 and 20-year Spatial Harvest Sequences (SHS). AWA is especially concerned that 15 watersheds are expected to deviate from VOIT 25 (Water Yield Impacts) as detailed in SLS’ March 2020 Milestone 2 FMP Information Package. AWA requests that SLS take action to prevent all watersheds in the SLS DFA from exceeding 30 percent ECA in the 10 and 20-year SHS.

Relevant sections/recommendations:

Chapter 5, 4.2.1 (VOIT 25 – Water Yield Impacts [forecasted])
AWA recommendations: 1) AWA requests that SLS take action to prevent all watersheds in the SLS DFA from exceeding 30 percent ECA in the 10 and 20-year spatial harvest sequences (SHS).
2) In this section, AWA requests that SLS draw greater attention to the watersheds forecasted to exceed 30 percent ECA and the impacts of exceeding this threshold. More focus is applied to the watersheds forecasted to exceed 50 percent, which SLS states are unlikely to occur.
Chapter 7, Section 7.2 (Watershed Management)
AWA recommendations: In this section, SLS should draw greater attention to the watersheds forecasted to exceed 30 percent ECA and the impacts of exceeding this threshold.

ANNUAL ALLOWABLE CUT

Related to the draft FMP, AWA requests that SLS detail if and how the May 4, 2020 policy changes announced by Alberta Forestry[6] have impacted annual allowable cut (AAC) within the SLS DFA.

BIODIVERSITY
Relevant sections/recommendations:

Chapter 7, Section 8 (Biodiversity):
AWA recommendation: SLS should add the “protection and recovery of species at-risk within the DFA” as a biological diversity goal.

LINEAR FOOTPRINT
Relevant sections/recommendations:

Chapter 7, Section 4.10 (Seismic Lines): “The decision is a precautionary approach as several of the linear features are used by ATVs when the Public Land Use Zone (PLUZ) permits motorized recreation. Operationally, SLS will evaluate seismic lines on a case-by-case basis and reforest seismic lines that are not active trails as practicable.”
AWA recommendations: SLS should recover all seismic lines regardless of active trail use, given the ongoing contributions of seismic lines to forest fragmentation. SLS can work with the Government of Alberta and recreational groups to establish more enjoyable and less ecologically damaging trail systems (within the regional thresholds for linear disturbance).

REFORESTATION
Relevant sections/recommendations:

Chapter 7, Section 5.2.1 (Silviculture Systems): “The amount of light, moisture, and frost exposure of the forest floor following harvest are key factors that can affect reforestation success.”
AWA question: Is the amount of wind exposure considered in planning harvest areas and future reforestation success?

RESEARCH
Relevant sections/recommendations:

Chapter 8, Section 1.1 (Activities)
AWA recommendation: Are the results of SLS’ research publicly available to view and download online? Studies such as the Aquatic Ecosystem Baseline Studies would be a beneficial public resource.

SALVAGE LOGGING
Relevant sections/recommendations:

Chapter 5, 2-1 (VOIT Summary Table), VOIT 8 (Landscape Scale Biodiversity)
AWA recommendation: AWA does not support salvage logging on lands affected by natural disturbances, including wildfire and blowdown. The target to leave a minimum of 10% unsalvaged in areas of significant blowdown, allowing up to 90% salvage, will likely impair ecosystem recovery[7], contradicts Objective 1.1.1.5, and evades any plans to maintain unique successional habitats created by wildfire.

[1] https://www.alberta.ca/release.cfm?xID=71253CB1DD3E5-AF97-D91F-972ED430583647B9

[2] Fluker, S.C. and Mayhood, D. W. 2020. Environmental Stewardship of Public Lands? The Decline of Westslope Cutthroat Trout along the Eastern Slopes of the Rocky Mountains in Alberta. Public Land & Resources Review 42: 39-79.

[3] Nielsen, S.E. Stenhouse, G.B. and Boyce, M.S. 2006. A habitat-based framework for grizzly bear conservation in Alberta. Biological Conservation 130: 217-229.

[4] Gustafsson, L., et al. 2012. Retention Forestry to Maintain Multifunctional Forests: A World Perspective. BioScience 62(7): 633-645

[5] Alberta Agriculture and Forestry. March 24, 2016. Structure Retention Directive. (See Appendix I)

[6] https://www.alberta.ca/release.cfm?xID=71253CB1DD3E5-AF97-D91F-972ED430583647B9

[7] Lindenmayer, D.B., Foster, D.R., Franklin, J.F., Hunter, M.L., Noss, R.F., Schmiegelow, F.A. and D. Perry.

Salvage harvesting policies after natural disturbance. Science 303: 1303