Nina’s comments are another example of Nova Scotians taking the time to carefully examine proposed changes in forest management on our Crown lands in response to the Lahey Report and to offer thoughtful, constructive suggestions on how to improve them. The words also say, “We Care”, Please Listen to Us”.
Thank you, again, NN
Posted today on Extinction Rebellion Nova Scotia (Public Facebook Group):
Comment on the revised Silvicultural Guides for the Ecological Matrix – February 14, 2021
The overarching priority
The Government of Nova Scotia has accepted the Lahey Report and has committed to implementing its recommendations. Specifically, the Government of Nova Scotia has stated that:
- “Government accepts Professor Lahey’s Independent Review of Forest Practices in Nova Scotia and agrees with the spirit and intent of his recommendations.”
- “The key to Professor Lahey’s report is the adoption of a new paradigm — ecological forestry”.
- “Nova Scotia will protect and enhance ecosystems and biodiversity as the overarching policy priority, as they are the foundation for other values”.
- “Nova Scotia’s forest policies and operational decision making will be guided by the practice of ecological forestry through a triad model. This will represent a significant change in the way Nova Scotia’s forest will be managed and will require modelling for habitat and wood supply”[1].
The triad model points to three different approaches to different areas of Crown land:
- Protected areas, where forestry activities are prohibited
- High production areas, where timber production for the industry is prioritized
- The wider landscape or matrix on which both protection and production objectives are applicable and where forestry would generally be of a low‐intensity nature to ensure consistency with broader biodiversity conservation objectives [2]
This last, the Ecological Matrix, is intended to cover at least two thirds of forested Crown land. The draft Silvicultural Guides for the Ecological Matrix (SGEM) is specifically about implementing the ecological matrix component. Obviously, then, the SGEM must be consistent with the key recommendations of the Lahey Report as they relate specifically to this leg of the triad.
The SGEM must explicitly state, at the start, that its primary commitment is to Lahey’s key objective: protecting and enhancing ecosystems. It does not do this at present.
An improvement but…
The new SGEM is a big improvement on the two lamentable earlier drafts of Forest Management Guides it replaces. At first reading, I felt relief that we might finally have a tool that would lead to real ecological forestry practices. The inclusion of permanent reserve trees is excellent, as is the provision that there should be no forestry in particularly sensitive and biodiverse sites.
However, careful reading reveals serious problems. One glaring example is this heading: “Context of this Guide within Sustainable Forest Management in Nova Scotia”. ‘Sustainable Forest Management’ is an undefined term which appears nowhere in the Lahey report. This appears to be a part of a consistent effort throughout the SGEM to tilt ecological forestry back towards ‘production objectives,’ and away from Lahey’s recommendation for the ecological forestry matrix where forestry would generally be of a low‐intensity nature to ensure consistency with broader biodiversity conservation objectives.
Another example of a serious problem is the addition of the new and dubious categories of Zonal and Azonal areas. These have no basis in science. In the current draft of the SGEM, the default treatment for ‘Azonal’ areas judged to be too nutrient poor to regenerate well would be clearcutting. This in spite of the fact that many of these areas have become nutrient poor precisely as a result of prior clearcutting. The DLF should instead use its own scientists’ Nutrient Budget Model guidance in order to improve soil nutrients and the quality of forests growing on damaged sites. The Forest Ecosystem Classification (FEC) system is well established and should be adhered to. It is hard to avoid the suspicion that large areas of crown land forest, particularly in southwestern Nova Scotia, would be classified as ‘azonal’ and subjected to the very regime of clearcutting the Lahey report is supposed to be moving us away from. The Zonal/Azonal categories must therefore be removed from the SGEMs.
Missing
The Lahey report makes clear forests should be valued in all their dimensions and not solely as sources of fibre. The SGEMs, therefore, must acknowledge wider concerns than those of the forestry industry. It is NOT a foregone conclusion that all forests in the EM will be harvested.
Landscape level factors must be included in any review of forest harvest proposals. This element is not adequately addressed in the SGEM. Focusing on stand-by-stand prescriptions for harvesting in the Ecological Matrix makes no sense without a prior commitment to landscape level planning. Without landscape level – or watershed level – planning, it is unlikely that the needs of wildlife and, in particular, endangered species such as the Mainland moose, will be properly taken into accounts. Paltry provisions such as the ‘moose clumps’ recommended under the current Special Management Plans represent no real commitment to protecting and enhancing ecosystems. By contrast, identifying and protecting core habitat for the Mainland moose would simultaneously have a beneficial effect on other wildlife. Biologists within DLF must be allowed to take into account factors like the cumulative effects of adjacent cuts on watersheds and wildlife.
The complete absence of wildlife considerations from the SGEM indicates that they are still in the service of the forestry industry rather than being in the service of our ecosystems.
Specifically, the SGEM makes no provision for modern scientific understanding of the importance of significant buffer zones along watercourses. These should be 100m. Implementing this provision alone would hugely improve connectivity for wildlife.
Furthermore, there is no mention of a singing season in the woods, meaning a complete cessation of logging and roadbuilding activities between May 15th and the end of July in order not to destroy the nests of migrating birds. Only in this way will forestry practices come into compliance with the Migratory Bird Convention Act.
Although the Lahey report does not focus on the vital role forests play in sequestering carbon, the practice of ecological forestry is compatible with the direction we all must take in addressing the twin crises of climate change and biodiversity loss. A healthy Nova Scotia forest will conservatively sequester 500 kg/ha of carbon in trees alone. Carbon-healthy soil will store as much again, if not more. Mixed age, mixed species natural forests sequester more carbon and represent more varied and therefore more resilient ecosystems than tree plantations. Forestry practices such as clearcutting, on the other hand, destroy biodiversity and release carbon from the soil in addition to removing all the trees that were previously storing carbon.
Trapdoors
There are ‘trapdoors’ concealed within the SGEM that would lead to far more intensive harvesting in the Ecological Matrix than is recommended in the Lahey report. In order to avoid these, a baseline rule should be a maximum removal of 30% by basal area in any one harvest in the Ecological Matrix. The frequency of such removals should be tied to the rate of regeneration which is approximately 1% a year in our forests. So 30 years would pass before another 30% harvest was permitted. Any exceptions to these limits would be rare special cases subject to additional review.
It is better to define maximum extraction rates rather than talking of minimum retention rates. It is also important to move away from a focus on volume to an emphasis on value. A reduction in volume of wood from our forests is essential. There is no room for converting any further forests in the Ecological Matrix to industrial plantations. These ecological deserts fulfill none of the multiple functions of a forest other than the pulp industry’s desire for a high volume of softwood. This model, to the extent that it is viable at all in a carbon-constrained, climate change impacted world, is accommodated in the High Production Forestry leg of the triad. There is no room for it in the Ecological Matrix. The SGEMs should be crystal clear on this subject. This does not, of course, mean there is no room for forestry in the EM. A viable forestry industry will depend on growing better, healthier forests which offer higher value/lower volume timber.
It is dismaying to find that, lurking in this draft of the Restoration Keys, are provisions that would lead to high levels of forest removal followed by tree planting. This is not what the Ecological Matrix leg of the triad is about. Maintaining forest cover and supporting not only a variety of native species of trees but also all the other layers of the forest from understory shrubs to lichens to fungi is at the heart of protecting and enhancing ecosystem health. Subterfuges intended to undermine real ecological forestry raise serious questions about the probity of the Department of Lands and Forestry.
How to proceed?
It is not going to be easy to find ways to allow both ‘protection and production objectives’ in the ecological matrix while maintaining the core commitment of the Lahey report, accepted by the Government: protecting and enhancing ecosystems should be the objective (the outcome) of how we balance environmental, social, and economic objectives and values in practising forestry in Nova Scotia. (Lahey, p. iii) The effort will require good faith. This seems to be consistently lacking in the way the Department of Lands and Forestry deals with forestry and the clearly expressed priorities of Nova Scotians. As a result, the SGEM must be subject to a final independent review by forestry experts such as Dr Laura Kenefic or D. Robert Seymour.
Thirty months after the release of the Lahey report, clearcutting continues apace in forests that should form the basis for the Ecological Matrix. The public learned recently that WestFor believes it has 5 years’ worth of harvest prescriptions in its pocket. This is absurd. The climate and biodiversity crisis have lent new urgency to forestry reform in our province. According to the Intergovernmental Panel on Climate Change we have 9 years to get our act together. The Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services is just as urgent in its recommendations.
Although the draft SGEM has serious flaws which must be addressed, it is better than the current interim guidelines. As a result, the SGEM should immediately replace the existing guidelines on an interim basis while the independent review of the SGEM is completed.
In this interim period there should be an immediate moratorium on all existing clearcut-equivalent harvest approvals including Variable Retention 10-30%; Uniform Shelterwood; Overstory Removal and Salvage cuts.
Once the new and revised SGEMs have been through the proposed review and are in place, all the as yet uncut harvest prescriptions created since the Provincial Government accepted the Lahey report’s recommendations in December 2018 should be run through the new SGEM. Since the Pre-Treatment Assessment (PTA) data has already been gathered, rerunning it through the new program, when it is ready, will generate new and more ecologically appropriate harvest prescriptions.
If the transition to ecological forestry is to happen – and it must – industrial forestry can no longer be regarded as the natural manager of crown lands. In addition, industry must no longer be allowed to police itself for any infractions. Ecological forestry practices require close monitoring by a third party. Unfortunately, the Department of Lands and Forestry has forfeited the public’s trust by dragging its feet on all reforms and then playing the kind of games outlined in these comments.
It is past time for reform not just in the old Forest Management Guides but also in the management of the Department of Lands and Forestry. I very much hope that the new Premier will usher in much needed change.
He has already promised to put forward an amendment to the Crown Lands Act in the coming session of the legislature. This, and also revision of the Forests Act, is essential to implement the broader understanding of the role and value of our forests that is at the heart of the Lahey report.
[1] Government Response to the Independent Review of Forest Practices in Nova Scotia, Department of Lands and Forestry, December 2018.
[2] Lahey, W.: 2018: An Independent Review of Forest Practices in Nova Scotia, Department of Lands and Forestry, p.iii
Nina Newington MA,
Mount Hanley, NS
Member NSWOOA