About BCCFR

BCCFR Mission Statement

The BC Coalition for Forestry Reform is a grassroots alliance of BC communities advocating for culturally and ecologically sustainable forestry practices. We support data-driven, long term stewardship of the timber and non-timber values of BC’s forests. We advocate for forest management based on long-term landscape-level planning, a mandatory shared decision making process with local communities, careful incorporation of public needs and values, and full recognition of our forests’ non-timber values including water, wildlife, tourism, and recreation.

Background

The forestry industry is an important contributor to the BC economy. But our forests are much more than timber to be logged for profit and tax revenue. Excessive human activity, pests, disease, and fire have drastically reduced the timber supply in BC. So harvesting is now occurring deep in community watersheds and much nearer to communities. This has damaged a wide range of non-timber values, including wildlife, water quality, tourism, and recreation.

As BC’s timber supply dwindles, there has been a corresponding public outcry to the increasing social and economic cost of timber harvesting.  This resulted in the BC government’s review of how the provincial resource management process and governance.

Read the BCCFR contribution to Professional Reliance Review

BCCFR Press Release

The final report was made public in June 2018, and is available here:

Review Final Report

Our immediate goal is to ensure the review of Professional Reliance launched by the BC government results in a thorough revision of the Forest Range & Practices Act (FRPA). Key to this revision is the elimination of the current exclusive license of industry employees (Registered Professional Foresters) to draw up logging plans for their industry employers, while at the same time being responsible for protecting BC’s non-timber values. This conflict of interest is currently enshrined within a regulatory framework with no mandatory consultation or approval by the very communities and local businesses most impacted by the forest industry’s activities.

Therefore an initial aim of the BC Coalition for Forestry Reform is to assist communities in BC to get directly involved in pressuring the BC government to create the resource regulation and policies needed to ensure local communities have a strong and effective voice in forestry planning and management.

How did we get here?

Major changes in forest policy were brought into effect over a decade ago. Suddenly natural resource management and environmental protection laws were cut back at least a third, while the indispensable task of government oversight of logging operations was withdrawn. In it place a policy was adopted called Results Based Forestry, the principal strategy of which was to transfer the discretionary power over logging plans to Registered Professional Foresters (RPFs) who are hired by the harvest license holders — mainly private companies and First Nations bands. This new “streamlined” policy became known as Professional Reliance.

What professional reliance means in practice is that industry employees who are extracting timber value for their employer are also given responsibility for “protecting” the non-timber values of BC’s forests. From the onset, this conflict of interest has been an obvious concern.

In the event that the broad — some would say far too general — regulations to protect non-timber values were not met, concerned citizens could appeal to the government agency Compliance and Enforcement Program. But experience soon confirmed that C&E has very little power. Communities turned to the Forest Practices Board, but there as well the power to do anything was severely limited.

In extreme cases, one could complain to the Association of Registered Professional Foresters about work of the local company’s RPF. But this avenue ran the severe risk of making enemies within your own community.

What does BCCFR want?

We propose the following changes in the conduct of BC forestry:

  1. Forest development that is managed according to publicly available, long-term, landscape-level planning, to include a mandatory shared decision-making process with local communities.
  2. Full recognition of the timber and non-timber values of our forests including water, wildlife habitat, biodiversity, tourism, and recreation.
  3. The restoration of clear government discretionary powers with regard to approval of logging plans and practices, including an improved Forest Practices Code and accompanying guidelines.
  4. Full recognition and guidance of forestry planning on the basis of scientific data. Full recognition, for example, of global warming and adjustment of forest policies accordingly.
  5. A vigilant monitoring system, well budgeted and independent of industry control, with particular attention given to riparian zones and roads.
  6. Staffing levels and budgets adequate to support the proposed changes.

Regulatory Reform

The Process

The BCCFR contributed to the BC government’s 2017-2018 Professional Reliance Review. Our submission is here: PR Review Submission

The PR Review Final Report was released to the public on June 28, 2018. It is available here: PR Review Final Report

The PR review’s summary of stakeholder contributions (called the Engagement Summary) is available here: Engagement Summary

We are now waiting for the provincial government to take action on implementing the recommendations of the Final Report.

What the Final Report Says

The Final Report’s 137 pages confirms the experience of BCCFR members. Below are just a few examples:

Page 63 of the Final Report:
“Conflicts of interest were identified as a major issue in this review by government, professionals, Indigenous governments and communities, and stakeholders.”

Page 107, Final Report:
“The Government Actions Regulation (GAR) is an important feature of the FRPA regime because it allows the minister to make orders (GAR orders) to protect non-timber values…”
“…while similar legislation would typically grant the minister broad discretionary authority to make these orders, GAR limits the minister’s discretion by requiring strict legal tests to be met before it can be exercised. ”
“Ministry staff advised this review that these limitations have hampered considerably the effectiveness of this regulation due to disagreements between government and the forest industry over the legal meaning of these clauses”

Page 29 of Engagement Summary:
“Calls for increased transparency focused on access to information and inclusion in the decision-making process as it pertains to the natural resources sector.”
“Allow the public to participate fully in decisions, [provide] easy access to information about environmental and health decisions, including access to reports prepared by industry-hired professionals.” (representative statement taken from citizen submissions)

Page 96 of Final Report:
“The Forest and Range Practices Act (FRPA) is a somewhat unique approach to professional reliance; rather than directly relying on professionals, it places obligations on tenure holders…”
“Government’s reliance on forest tenure holders is much higher than in other natural resource legislation, primarily due to four factors:
– Limitations on the information submitted to government;
– Limitations on the discretionary authority of decision makers when approving plans and making orders;
– Elimination of approvals for cutblocks and forest roads; and
– The extent to which a tenure holder retains professional services for its operations, and accepts the opinions and recommendations of those professionals.”
“The Forest Practices Board has seen situations where forestry development was putting environmental and community values at risk, yet district managers could do little to affect the development and protect the public interest.”

Page 96 of Final Report:
“The Forest Practices Board has seen situations where forestry development was putting environmental and community values at risk, yet district managers could do little to affect the development and protect the public interest.”

Page 106 of Final Report:
“In its submission to this review the Forest Practices Board commented: ‘there is ambiguity about what responsibility individual professionals have when more than one licensee operates on the same landbase. Under the current legislative framework, one licensee may design access and harvesting to achieve certain results, including retention of wildlife habitat, only to have a subsequent licensee undermine these results by harvesting the retention areas. The Board has seen numerous examples of this.’
The situations described by the Board occur in part because of the lack of Ministry authority over forest operations discussed above. The Ministry has for many years tried to address these issues by developing a Cumulative Effects Framework. However, implementation of the framework requires greater government authority, greater willingness to use existing tools (such as objectives set by government), and commitment to land use planning.

Page 98 of Final Report:
“Some input received from professionals questioned whether the 11 FRPA values represent the full suite of objectives that should be managed for. They ask, for example, whether there should be specific objectives to protect communities from risk of wildfire, because strategies to manage that risk on provincial Crown land surrounding the communities are not necessarily carried out by tenure holders if the activity is not economic or does not meet their business needs.”

What the Final Report Recommends

We compared the recommendations contained in our submission to the PR Review against the recommendations of the Final Report. We are encouraged that the majority of our concerns have been recognized and either wholly or partially addressed by the recommendations of the Final Report.

The BCCFR’s mission and focus is to give BC’s rural communities greater input and control over how forestry planning, management, and harvesting impacts the local environment, economy, and lifestyle. In the following analysis, for each BCCFR recommendations we list the corresponding recommendations from the Final Report. Recommendations we consider critical for immediate implementation are highlighted in green.  

BCCFR Recommendation #1: Forest development must be managed according to publicly available, long-term, landscape-level planning, to include a mandatory shared decision-making process with local communities.

R22. Improve opportunities for addressing third party concerns and dispute resolution.
R24. Modernize land use planning in partnership with Indigenous governments and communities.
R25. Develop means to address capacity to engage in resource management processes.
R26. Consider engaging Indigenous governments and communities in compliance and enforcement.
R29. Include the public in processes that address natural resource management objectives and land use.
R30. Improve public notification systems.
R85. Improve forest stewardship plan content
R86. Require submission and approval of site plans

BCCFR Recommendation #2: Full recognition of the timber and non-timber values of our forests including water, wildlife habitat, biodiversity, tourism, and recreation.

R8.Restore and clarify government authority to make resource management and environmental protection decisions.
R28. Make natural resource information more consistently available.
R33. Identify opportunities to improve the quality of natural resource information to help improve professional reliance outcomes.
R87. Enhance decision maker authority by amending the approval test to include consideration of government’s objectives, Indigenous governments and communities’ interests, other rights holders (Crown tenure holders and landowners) and the public interest.
R88. Improve objectives.
R89. Improve minister’s authority to make GAR Orders: review the limitations on the minister’s authority to make orders to protect non-timber values.

BCCFR Recommendation #3: The restoration of clear government discretionary powers with regard to approval of logging plans and practices, including an improved Forest Practices Code and accompanying guidelines.

R5. Review regulations and authorizations to ensure that government’s resource management objectives are adequately expressed and made known to professionals. … The need for clear objectives is more pronounced for broadly based resource activities such as forestry.
R10. Ensure that government has authority to address problems when they arise.
R11. Review regulations, authorizations, Ministry policies and professional codes of ethics to ensure that conflicts of interest are properly disclosed and addressed.
R92. Remove compliance certification by professionals.
R93. Professional Certifications and Assurance Statements
R94. Initiate a review of professional reliance in timber pricing and measurement
R112. Improve accountability to government: Provide provincial authority to reject riparian assessments that do not follow the prescribed methodology, are carried out by unqualified individuals, or where the professional’s opinion concerning the streamside protection and enhancement area is not supported by the facts or adequately justified.

BCCFR Recommendation #4: Full recognition and guidance of forestry planning on the basis of scientific data. Full recognition, for example, of global warming and adjustment of forest policies accordingly.

R3. Review regulations and authorizations to ensure that competency requirements are aligned with the professional task or function.
R4. Government and professional organizations should collaborate to develop ways and means of addressing the need for specialized expertise within a profession. …specialist designations within a profession … certification by government agencies … specifying credentials in the regulation … Ministry approval of the professional qualifications prior to work commencing…
R6. Government and professional organizations should collaborate to identify opportunities and prioritize needs for developing guidance to professionals through practice standards and guidelines. … clarify expectations and enhance enforcement.
R7. Government should provide greater guidance concerning activities that require multi- disciplinary expertise. … more than one type of expertise to inform sound decision-making. … [prevent] questionable opinions from professionals who are actually unqualified even though they might meet the generic legal requirements of the definition of qualified professional in the regulation.
R9. Ensure that regulations and authorizations include authority to obtain and question information provided by qualified professionals (or a proponent), so agencies can carry out their regulatory role appropriately.
R12. Identify ways to promote and ensure professional independence.
R13. Expand requirements for proponent adherence to professional advice.
R14. Consider alternatives to proponent selection of professional experts.
R15. Improve and standardize requirements for professional documentation and rationale.
R16. Expand the use of professional certifications and assurance statements.
R17. Introduce requirements to ensure that professional work is current and relevant.
R90. Improve documentation and rationale: … forest plans should include a systematic, transparent and well- documented decision-making process that shows appropriate consideration of the potential impacts of harvesting, silviculture systems and roads to public and third-party interests, including documentation of the professional advice received and how it was considered.
R91. Clarify professional tasks and qualifications: given the multidisciplinary nature and forest resource management, the regulation should specify the qualifications required for certain professional tasks.

BCCFR Recommendation #5: A vigilant monitoring system, well budgeted and independent of industry control, with particular attention given to riparian zones and roads.

R1.Establish an independent Office of Professional Regulation and Oversight:
Consider establishing an Office of Professional Regulation and Oversight (the “Office”), which would be an agent of government focused on professional organization governance issues and independent from natural resource sector ministries. … Be an agent of government, independent of oversight from natural resource ministries.
R2. Legislate critical elements of professional governance …
Ensuring that professional organization duties and objects are focused on regulation of the profession and the public interest, and do not include advocacy or representation of member interests;
R18. Develop auditing programs for professional work product.
R20. Improve accountability through new liability mechanisms.
R21. Strengthen monitoring programs and consider new partnerships to enhance monitoring efforts.
R31. Establish an independent review body for natural resource practices and decisions.
R32. Standardize standing rules for appeal tribunals to allow for greater public access to remedies.
R113. Qualifications of professionals: Revise the overly broad definition of “qualified environmental professional”
R115. Clarify riparian objectives:

BCCFR Recommendation #6: Staffing levels and budgets adequate to support the proposed changes.

R23. Reinforce the importance of compliance and enforcement. … Compliance and enforcement (C & E) is a significant topic in its own right, and may warrant a separate review process. Interviews with Ministry subject matter experts point to significant capacity issues for some business areas …
R34. Identify opportunities to improve Ministry staffing levels and resources to enhance government oversight.

References

World-wide high resolution satellite images (1984-2016)

Click on this link (http://world.time.com/timelapse2/) then enter your city, town, or street address in the search field.  Zoom out to see the broader impact of the last 32 years of harvesting in your area.

Must see videos:

Conversations That Matter – Taryn Skalbania

The above interview by Taryn Skalbania, from member organization Peachland Watershed Protection Alliance, outlines the issues with Professional Reliance and current forestry regulation in BC.

The above video accurately reflects the experience and frustration every member of BCCFR has experienced when attempting, and failing, to get responsible logging practices done in their local area.

BC Government Information about the Review Process

Professional Reliance in Natural Resources

Public views sought for professional reliance in the natural resources

Reviewing BC’s Natural Resource Sector Professional Reliance Model – Terms of Reference

BC Gov News – Review of professional reliance model to ensure public interest is protected

Articles and Reports on Professional Reliance and Regulation

NOTE: The first article is written by Mark Haddock, who wrote the Final Report on the government’s professional reliance review.

Professional Reliance and Environmental Regulation in BC

Association of BC Forest Professionals – What is Professional Reliance?

Forest Practices Board Special Report: Opportunities to Improve the Forest and Range Practices Act (Dec 2017)

UBMC – Forest Policy Decision-Making: The Case for Greater Community Consultation

Focus on Victoria – New government will review “professional reliance”

Ymir logging decisions should be local

The Problem With Relying (Too Much) On Industry-Hired Professionals

It’s time to pull the plug on self-regulation in B.C.’s forest industry

Contact Information

John Horgan, Premier of BC. premier@gov.bc.ca. Phone: 250-387-1715

Doug Donaldson (MLA for Stikine). Minister of Forest, Lands, and Natural Resources Operations. doug.donaldson.mla@leg.bc.ca  Phone: 250-847-8841 (Constituency Office) (250) 387-6240 (Legislative Office)

George Heyman (MLA for Vancouver-Fairview) Minister of Environment and Climate Change Strategy. george.heyman.mla@leg.bc.ca. Phone: 604-775-2453

Andrew Weaver (MLA Oak Bay). Green Party Leader. andrew.weaver.mla@leg.bc.ca. Phone 250-472-8528

Sonia Furstenau (MLA Cowichan Valley, Independent). sonia.furstenau.mla@leg.bc.ca Phone: 250-387-8347

 

Contact Us

We are not exaggerating when we say the many organizations and community members participating in BCCFR have hundreds of years of combined experience dealing with forestry regulation, complaints, negotiations, government officials, Registered Professional Foresters, and harvest licence holders.

Join us

Individuals and organizations that are aligned with the BCCFR mission are encourage to join the coalition.  Click on the link below to submit your application.

Application Form

Contact us

We will use our experience to help you get your voice heard!

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The BCCFR is cooperative group of individuals, community organizations, and non-profits. We are not currently incorporated as a separate non-profit organization.  However, we do incur expenses, and very much appreciate your financial support.


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