Some reservations about The Report on the Independent Review of Forest Practices in Nova Scotia

I have expressed my basic support for the report as a whole, however is not a “free pass” on the whole report. Sooner or later we will have to deal with the reality that two Pulp Mills (perhaps not even one) AND a viable higher value wood industry AND a minimally adequate level of landscape conservation for wildlife/mixed multi-aged Acadian forest AND providing the land time to recover from severe nutrient loss/acidification over about 60% of the landscape cannot be sustained, nor can forest bioenergy function as a sustainable alternative to pulp mills as a consumer of low value wood.

I have come under a bit of fire for my basic support for the conclusions & recommendations coming out of The Report on the Independent Review of Forest Practices in Nova Scotia as expressed in two posts:
Report from the Independent Review of Forest Practices in Nova Scotia released
Post Aug 21.
All quiet on The Independent Review of Forest Practices in Nova Scotia for now
Post Aug 30, 2018.

From the 2nd post:

In my first post about the Report on the Independent Review of Forest Practices in Nova Scotia, on the day of its release (Aug 21, 2018), I complimented Prof Lahey for the clarity of his report and concluded that he has set a high standard for further discourse about Nova Scotia’s forests and forestry.

…Overall, I think the people who have been concerned about the State of Nova Scotia’s forests should be happy, very happy, with the Report, and urge MLAs to support the conclusions and recommendations.

In a very fundamental sense, the major conclusions and recommendations are the same as and to large extent build on those of Bancroft and Crossland in Restoring the Health of Nova Scotia’s Forests (2010) and of the Steering Panel for that process, i.e. in regard to a strong critique of NSDNR science as it pertains to Natural Disturbance Regimes combined with “Ecological Forestry” as the fundamental paradigm for moving forward and recognition that clearcutting is the major management issue and that there is far too much of it.

There are differences in how an Ecological Forestry paradigm would be achieved, but the goals are essentially the same…There are aspects that I find a little weak or disappointing in the Lahey Report, but they are minor compared to what I like and find well justified.

I still stand by that stance, but it’s not a “free pass” on the whole report.

The aspects I found weak or disappointing:

The very limited discussion/critique of forest biomass/bioenergy: This is an issue I had identified in my submission, but that I also predicted would not be dealt with in any depth. I had expected The Report would recommend LCAs (Life Cycle Assessments) for biomass operations, but it does not, The Report rather encourages small, regional biomass operations (Rec 35 in the Executive Summary…), but there are no brakes proposed to limit their scale. Forest Biomass/Bioenergy harvesting will remain a major contentious issue in Nova Scotia.

Forest glyphosate spraying: I don’t have as much of an issue as many do on the toxicity side (but I do, big time, with such spraying in agriculture which is probably 300X more intensive than in forestry and involves several herbicides). However, killing the hardwoods/encouraging softwoods does not make sense in the context of climate warming, an issue I think is is not even discussed in the Lahey report. I see no justifications for Rec 14 (provision of public funding for herbicides use on plantations and high production forestry).

Limited or no questioning of the longer term sustainability of wood supply for pulp mills and/or biomass: The assumption seems to be that the current level of harvesting of pulpwood/low value wood will be maintained, and that this flow of wood is necessary to make clearcutting and associated harvest of high value wood profitable, and so clearcutting is required to maintain rural economies. It is an Industrial Paradigm, not to be questioned. I am doubtful that the big mills will put the $ into plantations necessary to maintain supply (and if government does it, we lose our tariff protections with the U.S.A.). Sometime soon, e.g. within 10 years, whatever high value wood is readily available on private land will be gone.

Sooner or later we will have to deal with the reality that two Pulp Mills (perhaps not even one) AND a viable higher value wood industry AND a minimally adequate level of landscape conservation for wildlife/mixed multi-aged Acadian forest AND providing the land time to recover from severe nutrient loss/acidification over about 60% of the landscape cannot be sustained, nor can forest bioenergy function as a sustainable alternative to pulp mills as a consumer of low value wood. If we continue to prioritize markets for low value wood, eventually we will have only low value wood. Closure of the Abercrombie Mill because of its inability to address critical environmental issues could press us to deal with this reality sooner rather than later. As I predicted, The Report does not address issues related to The Mill.

I do think Prof Lahey is well aware of wood supply issues, but understands the political landscape of NS well enough to know that proposing alternatives to the pulp mills would not fly. He comments that reduced supply from Crown lands will likely increase clearcutting on private lands, but The Report pointedly does not propose direct restrictions on clearcutting on private lands. On the other hand,  The Report is calling for a number of other restrictions on private land, e.g., no whole tree harvesting (Rec 24), full implementation of the endangered species act on private lands (Rec 29), it suggests tying $ support to private woodlots to participation in a triad system (Rec 31), there would possibly be increased riparian protection (Rec 25) and increased area of wildlife clumps (Rec 26) which would work against greater clearcutting on private lands, as would carbon credits if they made attractive to private woodlot owners (Recs 32, 33).

So as I see it, intended or not, there is a subtext to the provisions or lack of provisions related to private lands which is… let the market place – operating within these restrictions – determine the wood supply and let industrial forestry fail (or pieces of it fail) if it can’t be made to work within these restrictions and given other options available to private landowners such as carbon credits.

I have taken note of and very much appreciate Conclusion #86:

…the Review team did not have the opportunity to complete the kind of analysis  of my recommendations [related to wood supply] that industry urged me to complete. If such an analysis is part of the consideration of my recommendations, it should look at benefits as well as costs and it should look at both broadly, including ecological and social considerations as well as economic ones and consider all three in the long as well as the short term. These should be compared to the costs and benefits of current forest practices, again taking ecological and social as well as economic outcomes into account for both the short and the longer term. The analysis should be completed openly and transparently. This will not only ensure its credibility but help to avoid a flawed analysis. It will, for example, prevent the kind of discrepancy that occurred in the past when DNR commissioned a review of the cost to industry of the goal of reducing clearcutting to 50 per cent or less of harvesting in five years; instead of analyzing the impact of a reduction in the percentage of harvesting done by clearcutting, it analyzed the impact of a 50 per cent reduction in the volume of harvesting, a very different thing. Openness and transparency will also help to ensure that the analysis is conducted on the basis of fair, defensible, known, and openly stated assumptions.

Very limited critique/recommendations related to soil fertility issues: Only Rec 16 addresses the soil fertility issue*,  one that I regard as critical to biodiversity and a healthy Acadian forest as are landscape level planning and restrictions on clearcutting. (View Current Issues > Calcium Depletion.) I was pleased to see in The Addendum Ch 6 Ecological Considerations Related to Forestry (Prepared by Malcolm Hunter and Chris Wedeles) a section 6.7 Impacts Related to Acid Rain and this paragraph:

There is a strong argument to be made for managing forestry very carefully in watersheds with poor buffering capacity. Positive efforts should include limiting clearcutting wherever possible and ensuring that harvest cycles are sufficiently long for nutrients to be replenished by natural processes.

The concept of addressing NS forest fertility issues at the watershed level is one I have put forward (e.g., see op-ed, 6 May 2016) and checked out as sensible with some top aquatic scientists. It’s regrettable that it didn’t make its way into the recommendations.
*”to be responsive to concerns about the potential adverse impact of forestry on Crown lands…on Sensitive soils, particularly on Crown lands in the western region”

Gender/cultural representation: I have been critical of the only all-white-male-representation amongst the advisors for the Independent Review. I see the lack of reference to a need to provide for representation of gender and cultural diversity in the “Independent Committee of Technical Experts, including members of the Review team, to annually evaluate and publicly reportr on the progress of DNR in implementinvg these recomendations… ” (Rec 44) in a similar vein. Surely such a committee should include a broader range of experience and cultural familiarity than just technical expertise in forests and forestry.

At least some, if not all, of the submissions to the Independent Review should be made publicly available: I get particularly concerned when materials that are not publicly available are cited,  e.g. a reference to “Beazley, K. 2018 (page 69 in the Addendum), for which the reference is: “Karen Beazley submission to Nova Scotia Forest Practices Review.” Unpublished white paper, March 18, 2018.” In that case I asked Prof Beazley for a copy which she forwarded to me. It contains a lot of very relevant information and comments related to landscape level planning for biodiversity. In her submission, she refers to a submission by Art Lynds which I suspect is likewise very relevant and should be amongst the public documentation for the Independent Review.

On a related note, I was very disappointed to see  citation of “Review of Reports and Recommendations Relating to Forests/Forestry (Wagner 2010)” (see pdf pages 185, 206 of the addendum), for which the reference is “Wagner, R. G. 2010. Review of Reports and Recommendations Relating to Forests/Forestry as part of Phase II of Nova Scotia’s Natural Resources Strategy Development Process. The Forest Products Association of Nova Scotia.” To learn why I am disappointed and why I think it is totally inappropriate to cite that particular study in an “Independent Review”, or at least to cite it without more context, see text under “Comments on the Phase II Recommendations related to Forestry…”  and under “In Search of Compass and Gyroscope...” at>Perspectives.

I could say a lot more about ‘what I like’ ‘what I don’t like’ in The Report, but will leave it at that for now.


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