Honourable Rich Coleman February 12, 2007 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 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 6 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.