To fill out the Province’s survey on FRPA click HERE. Suggested answers to their questions (Q1 to Q9) are below. Please copy, borrow and use these points for your feedback.

Q1: How should the Province identify opportunities and priorities….

Acknowledge that old forests store much more carbon in biomass and necromass (standing and downed wood, litter, roots and organic matter in the soil) than younger forests. Landscapes dominated by mature and older forests can store several times as much carbon as intensively managed, industrial forest landscapes.

Recognize that converting old forests to young forests through logging results releases carbon immediately and for years thereafter, and this carbon may be unrecoverable.

Permanently protect old growth (over 250 years old) in particular in wet and very wet ICH, SBS and ESSF subzones (interior wetbelt) by removing it from the Timber Harvesting Land Base.

Halt the practice of immediate industrial-scale salvage logging of beetle-killed areas; this practice destroys trees with possible genetic resistance to bark beetle outbreaks and increases emissions from forests and logging machinery.

Limit the building of new roads and landings; these surfaces constitute deforested areas that rarely get decommissioned, and their area represents a significant loss of carbon storage potential. 


Leave natural corridors for connectivity between natural habitats as the climate changes. Corridors allow for movement of plants and animals to new locations.

Respect the capacity of natural ecosystems to find their own climatically suitable composition and location.

Rethink the ‘command and control’ mindset meant to serve industrial forestry operations and not communities.

Enable decisions to be applied in light of cumulative effects. Currently, a District Manager cannot say “no” to a new road development or a new cutting permit in order to address risk to an ecosystem or a species. Change FRPA so that they have that power.

Q2: What factors should be considered in the planning of forest operations….

Forty percent of the forest fires in BC over the last 10 years were caused by humans (vehicles, smoking, etc.). Human-caused fires are preventable; create a robust plan to prevent them, including limiting human access to some areas during drought conditions.

Acknowledge that large catastrophic wildfires do not typically follow insect outbreaks, and that salvage logging is not the solution to managing wildfires.

Salvage logging (under the pretext of managing fire risk) that have experienced a bark beetle outbreak compromises the recovery of already stressed forests.

Stop spraying plantations with Glyphosate; deciduous forests (aspen, birch, alder) are natural effective fire breaks.

Q3: A vital step in landscape-level planning….

Be accurate about what “old” actually means across ecosystems. Under FRPA, biodiversity is managed by “Landscape Orders” which state how much old forest has to be kept. These orders use a definition of “old” that does not match the actual age of old forests (e.g. under the order “old” forests in the interior wetbelt are said to 120 years old but are in reality 400 to 1,600 years old).

Use the best available science for retention targets. Much of BC is placed in zones called “low” or “medium biodiversity emphasis”. In these zones, virtually no old forest is required to be kept by logging companies.

There is no tool for ensuring connectivity between habitats, i.e. keeping forest between adjacent cutblocks. For this reason, BC has tens of mega-clearcuts that exceed the infamous Bowron clearcut.

Recognize all wildlife under FRPA. Currently, FRPA allows only for the management of “Identified Wildlife”. If a species is not on that list, it does not exist. Most of BC’s wildlife species do not exist under FRPA.

Create a coordinated plan to manage the destructive effects of industrial logging. FRPA allows for zero landscape or land use planning; for this reason, there are no opportunities to choose to log some valleys and leave other valleys intact.

Make forest planning and practice regulations that are legally binding. Currently, FRPA contains “guidance” documents that are published by the Province but left to the discretion of logging companies. This guidance is rarely, if ever, followed.

Q4: How would you like to be involved….

Make FSP details public. Forest licensees do not have to share plan details with the public; their mandatory Forest Stewardship Plan (FSP) doesn’t have to define where future roads or cutblocks are going to be. The public therefore has no knowledge or ability to oppose these plans. 

Public interests ought to take precedence over and have greater weight in planning than the interests of corporate “stakeholders”. It’s time British Columbians regained control over British Columbia.

Stop allowing companies to “talk and log”. Currently, FRPA allows for some habitat protection, but only after a long and mandatory review and consultation by forest licensees, who can and do hold up the process until the lands in question have been logged.

Landscape planning must be appropriately funded to support economic alternatives to activities that destroy intact forests. Economic value generated by tourism and recreation, carbon storage, and other forest uses must be allowed to flourish.

Q5: Resource roads are a valuable asset….

Limit all new road construction to prevent invasive species incursions, minimize edge effects, habitat fragmentation, poacher access.

Deactivate problematic roads and rehabilitate them.

Values to protect are: mountain caribou, interior forest habitat, habitat connectivity, ecosystems intactness, wildlife habitat, habitat for species at risk, freshwater ecosystems.

Prevent road density from exceeding science-based thresholds known to cause wildlife to disappear.

Q6: How can the Province improve transparency….

Make FSP details public. FSPs should provide the location and any other important detail on cutblock plans and roads.

Make all Timber Supply Review (TSR) documents public.

Make all Timber Harvesting Landbase (THLB) spatial data publicly available on DataBC.

Q7: What information will help inform your feedback….

Maps showing:

• • all planned cutblocks and roads,
  • existing cutblocks and roads, including all areas of past industrial harvest,
  • remaining high-productivity primary and old growth forests,
  • habitat for all red and blue listed species and plant communities.

Q8: What additional values should be considered….

FRPA currently only allows habitat protection “without unduly reducing the supply of timber from British Columbia’s forests”. This clause prohibits habitat protection and must be removed.

Moratoria on logging should be used by the Province to ensure no values are impacted by industrial logging while analysis and planning is underway.

Science-based old-growth forest protection is needed as a management objective to ensure their long-term ecological integrity.

Don’t let logging companies claim existing parks and protected areas as old forest in their operating areas. Where logging companies are required to keep some old forest, they sometimes use existing parks and protected areas to free them these from having to retain old forest from within their operating areas (even if the parks don’t contain old forest).

Q9: In what ways should the province strengthen government oversight….

Invest in Compliance and Enforcement.

Publish contraventions and determinations of penalties for non-compliance, including the names of companies/organizations responsible.