The draft SHS leads to old and very old forest levels dropping below the predicted natural range of variability (NRV) on the managed landbase. It is important that the details of this analysis are made available to the public for comment. The information package lacks the necessary information (e.g., how far below NRV, and for how long?) to make informed comment on this outcome. 

Interior old forest is a metric used to assess the amount of intact old forest, which is a key metric for biodiversity. Based on the information provided, we are unclear on the scientific justification for the targets provided. The VOIT describes the means to identify the target as “based on sound science, ecological considerations, wildlife zones, and disturbance regimes.” What is the methodology that is utilizing these aspects and how has it been used to identify the targets?  

Structure retention is a metric used to decide how much of a forest to leave behind within a clearcut logged area. This is a key metric for biodiversity and ecosystem function. The target of approximately 5% structure retention is too low. 10% retention should be a minimum to maintain biodiversity and ecosystem function. This assertion is supported by the EMEND project, which provided robust Alberta-based analysis demonstrating the importance of a minimum 10% retention level for enhancing biodiversity outcomes. We also recommend that a commitment be made to explore the use of less damaging partial harvest systems with higher retention levels, where appropriate.  

For bull trout and westslope cutthroat trout, both of which are threatened species under the Species at Risk Act (SARA), there are additional regulations for watercourse crossings to avoid destruction of critical habitat. However, this VOIT makes no mention of SARA, the recovery strategies for these species, or Fisheries and Oceans Canada (DFO) requirements in this regard. To ensure this VOIT is effective, SARA requirements must be included. 

In early drafts of the VOITs, there was no VOIT included that specifically addressed protection of threatened native trout species. With C5 containing 29% of remaining Westslope Cutthroat Trout critical habitat, as well as vitally important Bull Trout populations, the importance of this region for these threatened species cannot be overstated. The survival and recovery of these species, will, in large part, be driven by how forestry proceeds in this landscape. 

West-Fraser Cochrane have now added a VOIT for these species, for which we applaud them. This is an important step forward toward protecting native trout habitat. We have a number of recommendations for strengthening this VOIT, particularly in regard to taking a precautionary approach where knowledge on forestry impacts is limiting. 

• Trout Watersheds: The term “trout watersheds” used in the VOIT wording should be clearly defined. We would identify this as referring to any FMP watershed that contains trout critical habitat as listed under the Species at Risk Act. 
• Strategic Mitigation: The target describes that “if ECA is > 30%, alter timber harvest scenario with strategic mitigations until ECA is <30%.” The term “strategic mitigations” should be clearly defined — i.e., does this refer to a reduction in harvest area?
• Equivalent Clearcut Area (ECA): ECA is a broad-scale indicator that can be helpful for assessing impacts to watersheds, when used in combination with other indicators. In the context of native trout populations, we are unaware of data that links specific ECA thresholds to outcomes for native trout. That is to say, the VOIT target of <30% may or may not be a useful target for protecting native trout populations, but we cannot say either way because of a lack of data. It is therefore vital that this VOIT contains a monitoring component and takes a precautionary approach. We recommend: 
  • A precautionary approach in which forest management planning watersheds have a maximum threshold of 15% Equivalent Clearcut Area (ECA). 
  • A monitoring program for native trout populations that provides sufficient detail on how these species’ recovery will be monitored and reported on over the lifespan of the plan. This is essential to make sure that further declines do not occur because of logging and to ensure that any mitigation measures that are implemented are effective. 
• Road Density and Crossings: While it is a positive step forward to report on all road densities and crossings, it is vital that this be a precursor to setting biologically defensible limits on road density and crossings. Collecting data by itself is insufficient and must be done in a such a way as to identify appropriate limits. This should form part of the monitoring program that is needed for this VOIT. In addition, as mentioned above in regard to VOIT 13, WFC must make clear their commitment to follow regulations under SARA for native trout species. 
• Habitat Conservation Strategy: The VOIT describes a Habitat Conservation Strategy and other items, but these are not included in the information package. Without further information it is not possible to provide informed feedback on this item. 

The C5 FMA encompasses a large area of the montane and foothills ecosystems that make up Alberta’s southern Eastern Slopes. These watersheds are vitally important from the perspective of headwaters protection. The South Saskatchewan Regional Plan (SSRP) states “Watershed management and headwaters protection is the priority. Forests will be managed with this as the highest priority (including water storage, recharge and release functions).” The Eastern Slopes Policy, as well as work by the Oldman Watershed Council and the Bow River Basin Council, under the Water for Life strategy, all identify the region’s highest priority as watershed management and headwaters protection.  

Given the importance of watersheds in this region, we recommend that the VOIT be significantly strengthened to embrace a precautionary principle to watershed disturbance. Recent research has shown that ECA values in the region of 20% cause significant increases in flood size. All forest management planning watersheds should have a maximum threshold of 15% Equivalent Clearcut Area (ECA), given the importance of the C5 watersheds for native trout species, for downstream drinking water, for flood mitigation, and the increased risks from steep and erodible slopes in the region.  

There is no VOIT included for the protection of wetlands. Wetlands provide important habitat for a wide variety of species, act as fire refugia, carbon sinks, and mitigate flood risk through retention, storage, and slower release of flood waters. Currently, harvesting plans are leaving no buffers on wetlands and minimal forest cover along wetland boundaries. We therefore recommend that an additional VOIT be added that addresses the maintenance of functioning wetlands. This should include minimum buffering distances on all wetlands.  

Based on the Wetland Best Management Practices guide for forest management (which, while focused on the boreal plains ecozone, is likely relevant to wetlands in C5), we also recommend consideration of low-impact forest harvest techniques in areas adjacent to wetland buffers, and a monitoring program to ensure that wetland function is not reduced after harvesting has occurred.