Finish Line Close – Stop Old Growth Forest Now

Sample Public Comment
● Granite Creek and Fairy Creek are about to be logged by Teal Cedar
● More Old Growth is coming down
● Teal Cedar’s Management Plan #5 (MP5) is up for review
● Teal Cedar’s Tree Farm Licence (TFL) 46 expires June 30, 2022
● They need to hear from the public
● Let’s make a difference and hopefully stop this tragedy and save the Marbled
Murrelet (MaMu), a migratory seabird protected by Canada and four other countries
by treaty
● MaMu and many other threatened species will not survive without the Old Growth
● Email your public comment ASAP and not later than March 3, 2022 to:
forestryadmin@tealjones.com
● Finally, sample public comment below. Use any or all of the options below, add your
own thoughts as each Comment sent needs to be unique to be considered.

Please find here my public comment for Teal Cedar’s Management Plan #5

I find your management plan for TFL #46 completely inadequate with respect to Endangered
Species and Old Growth Forests. There is little consideration for the wildlife in TFL #46 as
outlined in Teal Cedar’s Management Plan. The Old Growth is also an integral part of the
traditional and cultural practices of Indigenous People. In addition, Teal Cedar’s Management
Plan #5 is intentionally confusing and should be withdrawn. The area of Old Growth designated
to remain is less than 10% of the Tree Farm Licence (TFL) area.

On tables 5.1 (MP5, pdf 57) and 5.22 (pdf 69) you list the total area for Old Growth
Management (OGMA) (5,700 ha) and total for MaMu (1,631 ha.), while retaining more area for
your roads (1800 ha) than MaMu. Some of the OGMA on your map, as in Cowichan, were
clearcut and are now being called a recruitment area, “future habitat.” (Teals Cedar Forest
Stewardship Plan (FSP) Supporting Information 2017 p. 11). What? In 250 years?? With so little
land reserved for MaMu (2.7%), (OGMA, 9%) and all other wildlife habitats (0.5%), MP#5 does
not comply with our Federal laws: Migratory Bird Convention Act, Species At Risk Act,
Recovery Strategies for the Marbled Murrelet and Canada-BC Agreement on Species At Risk.
The 2017 Forest Stewardship Plan (FSP) for TFL 46 expires this June. It’s not within MP#5.
What are you going to do this June when the FSP and TFL licence expire? The total areas you
commit to save of OGMA and WHA, in MP #5 (tables 5.1 and 5.22 Area Removed) you deduct
the areas removed for each category to determine the Timber Harvest Land Base, 42,566.8 ha.
By removing only 2,600 ha for OGMA and a mere 4.4 ha for Marbled Murrelet/MaMu(MP

#5pdf pg 57 and 69) you are only agreeing to remove from your timber harvestable area (THLB) a
drop in the bucket contrary to the Minister’s Order of Dec 2021 calling for the preservation of an
additional 60,000 ha of Old Growth in the province to protect the species and its habitat, a
requirement of the Migratory Bird Convention Act and the Species At Risk Act. This is
ridiculous because you’re not removing the Total Area designated for OGMA 5,700 ha or the
1,631 ha for MaMu. Other than what’s labeled area removed you leave the balance of those
categories in the Timber Harvest Land Base, why? In MP #5 for the next 5 years you actually
only commit to saving 4.4 ha or 0.0074% of TFL46 for MaMu. For OGMA you commit to
remove only 2,600 ha from the Timber Harvest Land Base (THLB) or 4.4% for OGMA from
TFL46. The remaining designated wildlife area identified for removal, No Goshawk and a plant
species, is only 0.5% of TFL46.

The area identified for both MaMu (1,627 ha) and OGMA (3,100 ha) is left in the THLB. Why?
When you filed the supporting information for your draft FSP for Chilliwack October 2021, you
acknowledged the Dec 2021 Minister’s Marbled Murrelet Order calling for 60,000 more ha of
Old Growth to be saved in BC for the MaMu and its habitat. Why did you talk about the
Ministerial order in your FSP for Chilliwack, (draft FSP pg11). Why is there no consideration for
the Ministers Marbled Murrelet Order in MP#5?

MP #5 must be denied and rejected. This comment will be copied to all individuals responsible
for your plan.

Signature,
Email address
Phone number

Additional Addresses (Teal is not required to send your comments to any government official.
We need to do it in order that the Ministries have the evidence to deny and reject Teal
Cedar's MP#5.
Please CC your comment to each of the following E-mail addresses.

Also, please bcc friendsoffairycreek@gmail.com

1. Federal Minister of Environment and Climate Change- Steven Guilbeault,
Steven.Guilbeault@parl.gc.ca and ec.minister-ministre.ec@canada.ca
2. Premier-John Horgan, premier@gov.bc.ca
3. Forest Minister-Katrine Conroy, FLNR.Minister@gov.bc.ca
4. Provincial Minister of Environment and Climate Change Strategy-George Heyman,
ENV.Minister@gov.bc.ca
5. Chief Forester-Diane Nicholls, Diane.Nicholls@gov.bc.ca
6. MFLNRO-Graham Wells, graham.wells@gov.bc.ca

7. Migratory Bird Management Biologist-Jessie Russell, jesse.russell@ec.gc.ca
8. Enviroinfo (EC) – enviroinfo@ec.gc.ca

Other Comment Options:

When you send your comment to everyone other than Teal Cedar, you might want to add that as
a taxpayer you strongly object to the shoddy organization of teals MP #5 which lacks page
numbering for the entire 187-page document, without an index for the document as a whole and
varying versions within the document that are incorporated via appendices, not to mention its
content deficiency. A cause for great concern considering that BC Government currently
subsidizes the BC timber industry 1 Million dollars a day for timber companies and the forestry
division administration of that fee, $365,000,000 to wreak havoc with our First Nation's, the
environment they rely on for traditional and cultural practices, including the climate catastrophes
we have been experiencing because of the rapid logging of Old Growth leading to flooding and
avalanches, while also significantly impairs our ability to enjoy the precious and aesthetically
appealing ancient trees, critically necessary for the survival of many of our most well-loved and
precious species at risk.

1. In MP#5 Teal Cedar describes plans to do sensitivity studies for the Northern
Goshawk. There are no plans to monitor or look for the Marbled Murrelet, in total
disregard of Premier John Horgan’s Marbled Murrelet Order signed November 19 and
issued to the public December 10, 2021.

2. Teal Cedar was clearly aware as early as October 2021 of the pending Minister's
Order to give the MaMu more protection. They also knew that the Minister was going to
require an additional 60,000 ha of Old Growth to be preserved in BC. That fact is stated
in Teal Cedar's October 22, 2021 Forest Stewardship Plan for Chilliwack. See
Supporting Information page 17/pdf 21 filed with the FSP October 22, 2021 specifically
noting the pending Marbled Murrelet Order.

3. Since they knew about Premier Horgan’s Order in October, why is there no plan to
do more for MaMu and preservation of Old Growth in Teal Cedar's Management Plan
#5?

4. Teal Cedar's MP#5 should also be rejected because of the extreme confusion
caused by your lack of any index for your entire 187 page MP#5 and also because your
lack of sequential numbering and multiple indexing not to mention intentionally blank
pages that make it impossible for most to refer to a specific part of the document in a
Comment: e.g.

If you are looking at Version C online, it is actually found under Version B
Appendix C. You may not have noticed it but in the upper right-hand corner
of each online page of the contents of Appendix C, it will read Version C –
Timber Supply Analysis Technical Report pdf 149-184.
If you are looking for Version D, it actually precedes what is identified as
Version C and is found under Appendix B of Version B (see upper-right each
page) – Information Package with all of its appendices pdf 36-147.

5. MP#5 does not contain a Forest Stewardship Plan (FSP) or even a proposed draft.
Your current FSP expires June 29, 2022. Where is it?

URGENT PLEA #2
DON’T LET TEAL CEDAR’S FSP BE APPROVED
COMMENT ON FOREST STEWARDSHIP PLAN (FSP)
DUE ON MARCH 14
Stop logging Old Growth NOW!

Teal Cedar’s Draft FSP: Comments due 3/14/2022 11:59 pm
https://tealjones.com/wp-content/uploads/2022/01/TCP-FSP-2022-Draft-with-appendices.pdf

There were hundreds of well-written Comments filed objecting to Teal Cedar’s 187-page Management Plan #5. Those comments were due March 3 and were directed to whether or not the Province should renew Teal Cedar’s Tree Farm Licence (TFL) 46. That licence expires June 30, 2022 and a decision to renew the licence has not been made.

Now, their draft FSP is open for Comment and we have another opportunity to preserve Old Growth and the forest so many of our endangered and threatened species rely on. Your help on this effort is equally critical as we work to stop clearcutting, destruction of our forest, permanent loss of the tree that is the nest for species that use the tree as their nest, loss of traditional and cultural support for the Peoples of the First Nation, loss of our ability to enjoy the beauty of this truly unique resource, trees 250 plus years of age with the obvious grandeur that they offer for tourism, the health of the environment, climate stability, serving as one of the most massive sources of carbon sequestration.

You have until March 14 to review this 51-page document and comment. This FSP needs your Comments! To assist, we offer the following for your consideration. Please write a comment that is personal to you and incorporates any of these suggestions that appeal to you. Please make your Comments as clear and plain as possible and email them to forestryadmin@tealjones.com on or before March 14, 2022 11:59 pm. When you email your Comment to Teal, we recommend you send a copy of your Comment to each of the government offices listed below to be certain that your Comment receives attention from as many as possible. This will ensure that Teal Cedar is prevented from minimizing the content of your Comment as their legal obligation is just to give the province a summary of the Comments they received.

SUGGESTIONS FOR YOUR COMMENT

To: forestryadmin@tealjones.com

The following is my Comment to Teal Cedar Products Ltd. draft FSP. This Comment is offered in response to your public notice for Comment. I have reviewed and considered your draft FSP and am requesting that it be withdrawn because it fails to comply with Federal and Provincial law. The draft FSP:

• Fails to include or incorporate the Minister’s Marbled Murrelet Order of December 10, 2021.
• In October 2021, in your draft FSP for Chilliwack, you report that the Chilliwack FSP will be modified to incorporate the Minister’s Marbled Murrelet Order which you explained would be released in December. See Supporting Information page 17/pdf 21 filed with the FSP October 22, 2021 specifically noting the pending Marbled Murrelet Order.
• You fail to acknowledge the Minister’s Marbled Murrelet Order in the December 20, 2021 draft FSP for TFL 46 when the Chilliwack FSP proves you knew about it.
• Your draft FSP fails to identify Minister’s Deferral Orders of June 2021.
• Fails to mention or include in your plan any recovery strategy for the Marbled Murrelet.
• Fails to identify or define any strategy to prevent further decline of any species at risk that populate TFL 46.
• Section 3.3.1 of your draft FSP identifies your obligation to develop a strategy for the preservation of the Marbled Murrelet but the plan is devoid of any details or specifics as to what you are going to do.
• Rather, you continue to log Old Growth, causing loss of the habitat, the nest, of the MaMu ensuring its further decline and ultimate extinction once all the Old Growth is logged.
• In MP#5 page 11 Version D, you state that the presence of Old Growth will fall sharply in the next few years. You clearly report that the only growth that will remain is that that is inaccessible to harvest.
• This Draft FSP ignores and violates, the Migratory Bird Convention Act, the Species At Risk Act, the Migratory Birds Regulations, The Recovery Strategy for the Marbled Murrelet, and a clear body of law that is committed to avoiding extinction and preservation of the MaMu, a species specifically identified as at risk of extinction.
• Fails to mention or recognize that the remaining stands of Old Growth, 250 years of age or more, 3,868 ha, per MP#5, are the nests for the Marbled Murrelet (MaMu) and other threatened species in BC. TC MP#5 Version B Appendix B, also identified as Version D – Information Package p 11/pdf 58 (Table 5.2).
• How can you take the last of the Old Growth when so little remains and you will have eliminated almost the entire suitable habitat for the Marbled Murrelet in defiance of the laws designed to protect and preserve MaMu and its habitat?
• For the sake of us all and our protected species, WITHDRAW YOUR DRAFT FSP.
• Compared to the total productive land base, 57,000 plus ha, your survey of trees remaining shows there’s a little more than 5% that are Old Growth.
• Your draft FSP fails to state any plan to monitor for or identify and protect species at risk as required under Federal or Provincial law and further fails to describe any specific strategy to achieve preservation of the designated “species” and “habitat”.
• Under the Migratory Birds Regulations, section 6, preservation of the habitat to avoid extinction led to regulations that prohibit disturbance, damage or destruction of the nest of a migratory bird.
  • “6 Subject to subsection 5(9), no person shall (a) disturb, destroy or take a nest, egg, nest shelter, eider duck shelter or duck box of a migratory bird, or (b) have in his possession a live migratory bird, or a carcass, skin, nest or egg of a migratory bird”
  • The Migratory Birds Regulations defines “nest: means the nest of a migratory bird and includes parts of the nest.” Section 2
• Your FSP failed to admit that when you log Old Growth, that constitutes a permanent and irreparable disturbance/destruction of the MaMu nest because that species and others, known to you, don’t build nests. Rather, the tree is their nest.
• There is no plan or strategy for MaMu recovery.
• There is no plan to provide additional hectarage of suitable MaMu habitat in WHA’s other than the 4.4 ha given in Teal Cedars Management Plan #5 over the next 5 years in total disregard of the Minister’s Marbled Murrelet Order of December 2021.
• There is no mention of how Teal Cedar will actually change its operations to reflect the reality of the climate emergency – despite the statement in the Teal Jones website that all of its timber operations now consider climate change.
• Similarly, there is no mention of how Teal Cedar will change its operations to reflect the biodiversity crisis or the socio-economic inequity crisis.  Forest stewardship involves more than planning when and how to maximize timber yield.
• There is no reference to the old-growth Priority Deferrals Report submitted in October 2021 and how it could affect the timber supply and provide additional old-growth preserves that will benefit MaMu.
• There is no mention of how this FSP will be compliant with the Migratory Bird Convention Act, the Migratory Bird Regulations, the Canada-BC Agreement on Species at Risk, or the BC Wildlife Act.
• There is no expressed understanding that under current laws, Teal Cedar may not disturb, much less cut down, any tree that is Old Growth, 250 years or more of age, as that tree is by definition a MaMu nest whether active or not.
• There is no mention of the Ministerial MaMu Order of December 2021, despite Teal Cedar knowing about it months before it was publicly announced, nor is there any hint of steps Teal Cedar will take in TFL 46 to comply with that Order.

Please Copy Your Comments To:

Federal Minister of Environment and Climate Change- Steven Guilbeault,	Steven.Guilbeault@parl.gc.ca
Federal Minister of Natural Resources – Jonathan Wilkinson	jonathan.wilkinson@parl.gc.ca
Premier-John Horgan	premier@gov.bc.ca
Forest Minister-Katrine Conroy	FLNR.Minister@gov.bc.ca
Provincial Minister of Environment and Climate Change Strategy-George Heyman	ENV.Minister@gov.bc.ca
Minister of Land, Water and Resource Stewardship – Josie Osborne	LWRS.Minister@gov.bc.ca
Chief Forester-Diane Nicholls	Diane.Nicholls@gov.bc.ca
MFLNRO-Graham Wells	graham.wells@gov.bc.ca
Enviroinfo (EC)	enviroinfo@ec.gc.ca

Please blind copy friendsoffairycreek@gmail.com or forward a copy to help us.