Once every five years the Canadian Standards Association (CSA) reviews its sustainable forest management certification for BC logging companies and this is a chance to let them know that logging old-growth forests, 10,000 years in the making, is not possibly sustainable as they cannot be replaced and to request that they both remove the term sustainable from the standards and to altogether refuse certification to companies that continue to log the very last ancient forests, until old-growth logging stops.
Here is a letter to the certification body from an ally, which can be used to structure and inspire original letters, addressed to: Melanie Pinatton melanie.pinatton@csagroup.org
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Dear Madam/Sir,
a) As stated on page 6 of the standard, CSA Z809-16 will be reviewed in 2021. I’m submitting this proposal for a change to be implemented to this standard when it undergoes review.
This proposal represents the views of many other individuals and organizations, who also want the changes to CSA Z809-16 requested here, and whose statements are included. Some are also making separate submissions to your review. When responding to me, please also respond to all the others who form part of this submission. They are copied on this email.
b, c) Logging of old-growth forests is NOT sustainable. Yet many forestry firms in British Columbia that conduct such logging are certified to the Sustainable Forest Management standard (Z809-16). The standard should be significantly revised, in particular, removing the word “sustainable” and any references to it, until the practice of logging old-growth trees ceases. At the same time, certification should be withdrawn from these firms that log old-growth trees.
d) Rationale
The logging of virgin, old-growth forests, which is a routine and admitted practice of certified forestry companies in British Columbia, is not sustainable, instead it is a permanent removal of old, monumental trees, a complete contradiction to the term sustainable. In addition, this practice does not meet at least one of the key criteria of the standard, namely, preserving biodiversity. Detailed justification is presented below.
Background
The history of forestry certification is described in Nickson (2015), who explains how certification arose in response to lobbying by NGOs and environmental groups leading up to and at the United Nations Conference on Environment and Development, known as the Earth Summit, held in Rio de Janeiro, June 1992. The purpose of certification was to ensure Canada was seen to be a world leader in forest management that conducted forestry in a sustainable and environmentally conscientious manner. Such certificatin would, of course, help in the marketing and sales of Canadian wood and wood products.
The word “Sustainable” in the phrase “Sustainable Forest Management” has arisen from the UN, for whom the word is fundamental and appears in virtually all of its documents relating to the environment. The UN definition of sustainable is outlined in the UN Brundtland Commission report of 1987 as “meeting the needs of the present without compromising the ability of future generations to meet their own needs. (United Nations-1)” This definition appears to have been a model for the CSA Z809-16 definition of SFM, which is: “management that maintains and enhances the long-term health of forest ecosystems for the benefit of all living things while providing environmental, economic, social and cultural opportunities for present and future generations.”
There are numerous definitions of sustainable, but virtually all include the protection of the environment. The Oxford English Dictionary (Oxford, 2019), for example, defines sustainability as “The property of being environmentally sustainable; the degree to which a process or enterprise is able to be maintained or continued while avoiding the long-term depletion of natural resources.”
The United Nations formulated17 sustainable development goals. Goal 15, Life on Land, specifically calls for “Sustainable Forest Management.” The goals were adopted by world leaders in 2016 (United Nations-2).
The framework of the CSA standard is the Criteria and Indicators for SFM, which were formulated by the Canadian Council of Forest Ministers. In 2008, CCFM released a report, A Vision for Canada’s Forests: 2008 and Beyond (CCFM, 2008), that describes the criteria and reaffirms the country’s commitment to sustainable forest management.
Old-Growth Forests Are Special
The old-growth forests growing along western B.C. are unique and treasures of nature. An old growth forest is structurally complex, at least 150 years old. In addition to live, big trees, there is also a multi-layered canopy, snags (vertical dead trees) and logs. The old-growth forests of the Pacific Northwest are perhaps the most magnificent natural phenomenon in the world and support more animal species than any other place on earth (Middleton, 1992).
Old-growth trees are monumental in both size and age, and capture the human imagination. Cathedral Grove, for example, a dramatic and accessible stand of old trees, has gigantic Douglas firs that are over 800 years in age and reach 75 metres in height and nine metres in circumference. Rich with sword ferns, moss-covered logs and witch’s hair dangling from branches, the Grove induces a feeling of spirituality and a deep closeness with nature. Cathedral Grove is one of the most beautiful natural places in western Canada, attracting about 500,000 visitors annually.
Certified Companies Log Old Growth
In British Columbia, forestry firms certified as conducting Sustainable Forest Management routinely log old-growth forest areas, many similar to Cathedral Grove in grandeur. Ancient trees are clear cut and replaced by tree farms that will be clear cut again every 60 to 80 years. That old-growth tracts including monumental trees more than 500 years in age are routinely logged by certified companies is well documented (for example, Lavoie, 2010). The permanent loss of the spirituality, beauty and tourism/recreational value of such old-growth glades flies in the face of the meaning of sustainable. The old groves are not being maintained, but destroyed forever, the complete opposite of sustainable.
Avatar Grove, a stunning natural area with monumental trees, has become such a tourism draw it has helped nearby Port Renfrew gain the reputation as the Tall Tree Capital of Canada (Patterson, 2017). But the grove was slated for logging by Teal Jones Group, which is certified to the CSA Sustainable Forest Management standard. Through its standard, the CSA tacitly approves of such action. Shockingly, the Grove would have been logged legally without seeking any permission or without even notifying the government or the public. It was only saved in 2012, when the Ancient Forest Alliance discovered that the grove was slated for cutting and together with the community mounted vigorous protest actions.
Near Port Renfrew stands Big Lonely Doug, the second largest Douglas fir in the country. It’s easy to spot because it soars like a skyscraper, alone and dramatic in a vast clear-cut dotted by immense stumps. Before logging, this area was just as majestic and spiritual as Avatar Grove (T.J.Watt, 2016), yet it was logged by Tea; Jones, a firm certified as conducting SFM without any permissions or notifications.
BC’s forestry companies depend on Old Growth
Why do BC’s forestry companies routinely log old-growth timber? Chris Harvey, a spokesperson for the Teal Jones Group, which is certified under CSA Z809-16, claimed her company does it to survive economically (Harvey, 2016). “Old growth is an absolutely essential part for us to harvest. We can’t be economically viable if we log 100% second-growth. And this is true for other companies as well.” Harvey is a registered professional forester and a member of the Technical Committee for CSA Standard Z809-16.
Harvey’s claim was verified by Priya Patel, CSA staff and member of the CSA Z809-16 Technical Committee, who wrote, “Over the past 30 years and continuing over the next twenty years or so, most licensee companies within the coastal forest area are transitioning their harvesting from old growth to second growth. …. Teal Jones is right in that it relies on this old growth forest over the next twenty or so years to transition into second growth timber. But it could not sustain its harvest on second growth timber alone right now because not enough of it is mature enough to log.” (Patel, 2016)
Not only do forestry firms acknowledge they permanently destroy majestic old-growth environments, which is NOT sustainable, but they claim they must do so for economic survival. In other words, money trumps the environment.
Shockingly, the CSA not only condones this practice, but paints it as being environmentally sound. The logging of old-growth trees makes a mockery of the CSA standard and the companies that are certified to it. Even a child can see that the king has no clothes. The CSA’s definition of Sustainable Forest Management should be recast as “management that maintains and enhances the long-term health of forest ecosystems but corporate profit and share-holder value come first.”
Violations of Z809-16 Criteria
In addition to corrupting the meaning of “sustainable,” old-growth logging violates the Standard’s criterion of ecosystem and species diversity, as the old-growth forest is replaced by monoculture plantationsthat will never reach a century in age. The B.C. Government recognizes that old-growth forests tend to have more diversity of plant and animal life … than younger forests (B.C. Government, 2020).
There are other ways in which the sustainably certified forestry companies in BC do not protect the environment. After a catastrophic flood in 2018 caused tens of millions of dollars in damage, the B.C. government and timber companies Interfor, Weyerhaeuser and Tolko are being sued by residents of Grand Forks, BC, on grounds that excessive clear-cut logging caused the devastation (Parfitt, 2020). At least one of these companies have received CSA Z809-16 certification for SFM.
Furthermore, 94% of the forest in BC is located on Crown land, and this Crown land is largely located on unceded traditional territory of many First Nations. The remaining old-growth stands are of critical importance to First Nations’ health heritage, culture and ancestral rights, which are now explicitly and legally protected under the UNDRIP Act of B.C.
Crucial Support
As demonstrated by Cathedral and Avatar Groves, old-growth trees have a value that goes far beyond dollars and cents. This is recognized by the citizens of the province, who are concerned that old-growth forests in BC are seriously endangered. The protest actions to save Avatar Grove are not unique, and similar protests to conserve old-growth trees have taken place at numerous times including the Clayoquot Sound protests, also called the War in the Woods, the largest act of civil disobedience Canadian history; at the Walbran Valley; on Cortes Island; and at Haida Gwaiiwhere anti-logging demonstrations led to establishment of Gwaii Haanas park in 1993. Very significantly, currently there are blockades at Fairy Creek near Port Renfrew on Vancouver Island. These protests graphically demonstrate that the people of B.C. value these giants.
The sentiments of several organizations and individuals are described below. These are critically important, and form an important part of this submission. Furthermore, they are only a small fraction of those that support the preservation of old-growth trees and the removal of “sustainable” from Z809-16. Many more could be listed.
Dr. Suzanne Simard, professor at University of British Columbia, made the astonishing discovery that trees communicate with each other through their root systems. A highly regarded research scientist, she has given a TED talk on the subject. She supports this submission to remove the word sustainable from the CSA standard, and said, “It makes no ecological, social or economic sense to be logging old growth forests as we grapple with the existential threats of climate change and mass extinctions.”
Adam Olsen, member of the BC Green Party and MLA for Saanich North and the Islands, said, “I … request that you add my name to your list of supporters. Thank you for taking this important initiative forward.”
The Trust for Sustainable Forestry, chaired by Ann Mortifee, is appalled that ancient forests are being clear cut and advocates that forests be restored to their old-growth splendour, vitality and diversity based on proven ecoforestry practices. The Trust is dismayed that the “Sustainable” in her Trust’s name is totally at odds with the “Sustainable” in the CSA standard. She supports this submission and is submitting an independent request to the CSA to change wording of the standard.
Dr. David Boyd, Special Rapporteur on Human Rights and Environment for the United Nations and Associate Professor of Law, Policy and Sustainability at the University of British Columbia, is a champion of the environment. He feels the “sustainable” in CSA’s standard for Sustainable Forest Management refers to economic, and not environmental, sustainability, and said, “In light of the global climate emergency and the precipitous decline of biodiversity there is absolutely no justification for continuing to allow the logging of old-growth forests in Canada.”
Dan Hager, the president of the Port Renfrew Chamber of Commerce has watched tourism zoom since the town labelled itself as the Tall Tree Capital of Canada. “Simple logic,” he said, “it’s more economical to preserve grand old trees than cut them down.” (Tammemagi, 2016) The BC Chambers of Commerce, the largest business-advocacy organization in the province, agreed, voting almost unanimously to accept Port Renfrew’s motion calling for protection for old-growth forests (Smart, 2016).
The Sierra Club of British Columbia contributed the following statement: “Under CSA standards, forest companies have destroyed ancient forests that given climate change are non-renewable and may never been seen again. Profiting on thousands of years of biological diversity for short-term financial gain is in no way sustainable. We urge CSA to remove the word “sustainable” from Standard CSA Z809-16 and recognize that ancient forests managed under this standard are at risk of being lost forever.”
Ann Coombs, B.C. resident, author and former broadcaster, said, “To state that logging old-growth trees is a “sustainable” practice shows a complete lack of responsibility and regard for one of B.C’s greatest and most definitely irreplaceable and needed natural habitats. … Will it be greed under the guise of “sustainable,” or visionary, responsible and historic leadership?”
Two major reports have recently reviewed British Columbia’s forestry situation. The first, A New Future For Old Forests — A Strategic Review of How British Columbia Manages for Old Forests Within its Ancient Ecosystems, by professional foresters Al Gorley and Garry Merkel was done at the request of the BC government and made the recommendation to “defer development in old forests where ecosystems are at very high and near-term risk of irreversible biodiversity loss.” The second report, BC’s Old Growth Forest: A Last Stand for Biodiversity,by Karen Price, Ph.D., Rachel F. Holt, Ph.D., and Dave Daust, concluded: “Apply an immediate moratorium on harvest of old (and mature) forest in any biogeoclimatic variant with less than 10% old forest remaining today.”
Although these two comprehensive reports do not address standard Z809-16, they do advise against the logging of old-growth trees, in direct contradiction to what CSA’s standard supports. Furthermore, Dr. Holt, an author of the second report, endorses this submission and has sent me an email supporting the removal of “sustainable” from Z809-16.
Devon Page, the Executive Director of Ecojustice, Canada’s largest environmental law charity, provided a particularly damning statement, suggesting that CSA’s certification is not legally sound. He stated, “Ecojustice has reviewed the Canadian Standards Association’s Sustainable
Forest Management standard (Z809-16) logging certification scheme, as well as logging conducted pursuant to that scheme. We believe that the scheme does not certify “sustainability” generally as that term is scientifically or legally understood, including because the standard purports to certify as sustainable logging of old-growth forests.”
Raincoast Conservation Foundation has studied the CSA standard CSA Z809-16 in detail, and strongly supports this submission for changes to the standard. Their letter of support, which is also being sent to the CSA, concludes, “we urge those who contribute to the design and implementation of CSA-Z809 to refuse certification to parties that continue to harvest old growth forests in Canada.”
Yves Maynard, a resident of Victoria and retired senior executive with Cogeco has studied the forest products industry and its regulatory framework in B.C. and made an extensive submission to the Old Growth Strategic Review Panel on January 30, 2020. He feels the use of the word “sustainable” and the certification process under the present CSA Z809-16 is being misused by several BC forest industry members to justify the continued clearcutting of the few primary and old growth tree stands remaining in the province and to evade liability for misleading advertising on the marketing of wood products from industrial logging of these rare and irreplaceable tree stands. He is making an independent submission to the CSA.
Barry Gates, co-chair of Ecoforestry Institute Society, is the manager of Wildwood Ecoforest on Vancouver Island where true sustainable forestry is practiced. He supports this submission to remove the word sustainable from the CSA standard.
Elizabeth May, Member of the federal Green Party and MP for supports this initiative, saying, “I am writing in support of an effort led by my constituent Hans Tammemagi to remove the word “sustainable” from the CSA forest management standards until the standard ensures that logging of old growth forest comes to an end.” She is sending her complete letter to the CSA.
The Forest Practices Board, an independent BC forestry watchdog, concluded, in response to a complaint that several monumental trees up to 1,000 years in age near Port Renfrew had been razed, that more should be done to conserve trees of exceptional size, form, age or historical significance (Forest Practices Board, 2011). The Minister of Forests … asked the Provincial Forester to recommend steps for more protection. Nothing was ever done.
Many other organizations, including Creatively United for the Planet Society, and individuals support this submission for change in CSA Z809-16.
Conclusion
In summary, companies certified as conducting Sustainable Forest Management are logging old growth forests in B.C., a permanent diminishment of a valued resource. Even a child can see this practice is the opposite of sustainable. Until BC’s forestry industry stops logging old growth timber, the term “sustainable” should be removed from the CSA certification, and the certification should be rescinded for those firms conducting this practice.
References
B.C. Government, 2020.https://engage.gov.bc.ca/oldgrowth/definition/
CCFM – Canadian Council of Forest Ministers, A Vision for Canada’s Forests: 2008 and Beyond, 2008. https://www.ccfm.org/pdf/Vision_EN.pdf
Doucette, Keith, Nova Scotia report calls for restrictions on clear-cutting, ‘ecological forestry, Globe and Mail, August 21, 2018.
Forest Practices Board, Logging Old-Growth Forest Near Port Renfrew, Complaint Investigation 10093, FPB/IRC/174, 2011.
Harvey, C, telephone conversation with Hans Tammemagi, October 20, 2016.
Lavoie, Judith, Old-growth forest ‘a sea of stumps,’ Times-Colonist newspaper, May 14, 2010.
Middleton, David, Ancient Forests – A Celebration of North America’s Old-Growth Wilderness, Chronicle Books, San Francisco, 1992.
Nickson, Elizabeth, The Failures of Forest Certification, Frontier Centre for Public Policy, 2015.
http://fcpp.org/wp-content/uploads/2015/09/Nickson-Failures-of-Forest-Certification.pdf
Oxford, Oxford English Dictionary, 2019.
Parfitt, Ben, Grand Forks flooding victims file class-action lawsuit against B.C. government, forestry companies, The Narwhal website, September 14, 2020.
https://thenarwhal.ca/grand-forks-flooding-lawsuit-b-c-government-forestry/
Patel, Priya, Email to Hans Tammemagi, Oct.31, 2016.
Patterson, Carol, Port Refrew – Tall Tree Capital of Canada, Roadstories website, 2017. https://roadstories.ca/port-renfrew/
Smart, Amy, Chamber hugs old-growth trees, Times-Colonist newspaper, June 1, 2016.
Tammemagi, Hans, An Old-Growth Battlefield, British Columbia Magazine, pg. 66-71, Fall, 2016.
United Nations-1, Academic Impact – Sustainability. https://academicimpact.un.org/content/sustainability
United Nations-2, Sustainable Development Goals.