1
INFORMATION PROVIDED IN RESPONSE
TO SCC/SIRRA REQUEST OF AUGUST 10, 2016
Per SCC/SIRRA Request of August 10
should express to you our concerns about several issues that your project
community. We bring these forward now, believing that by addressing them more fully in the planning
phase, and before a public meeting, there will be more opportunity to resolve them in a neighbourly
manner. These include (in no par
Provided are:
· Extracts from the Introduction to the
· The Project Forest Management Plan Map
Fire Risk: We understand that debris management is part of every logging plan.
bounded by residential neighbourhoods as well as the National Park Reserve, protection of human life,
both firefighters and civilians, is our first priority.
were provided with the mitigation
logging plan that will be submitted to INAC.
Provided are mitigation and monitoring plans for
Road Safety: This is a subject of great concern to the community.
Description 9 truckloads per day were planned, over a 3 or 4 month period.
the narrow steep hill down to Lyall Valley (known on the Island as “t
residents to access the four ferries a day to and from East Point, and truck traffic around the school.
community will want to know the specifics of how you plan to manage and monitor the trucking with local
traffic and how you plan to address any damage to the roads that might be caused by over 800
truckloads. We look forward to working with your group regarding this issue.
Provided are
· Two Environmental Assessment
10, 2016: “At our recent Board meetings it was agreed that we
raises for the Island
particular order):
project Environmental Assessment
Map.
Re Item 1 Fire Risk
We think the community would be more at ease if we
and monitoring plans for debris management that form part of the
forest debris management for IR #7:
Re Item 2 Road Safety:
In the July 18 Summary Project
Of particular concern are
the missing link”), the need for
d extracts from Section 4.2 of the EA
Noting that IR7 is
he The
xtracts
2
(Potential Environmental Impacts Description & Analysis)
~ Logging Truck Traffic on Community Access Roads
~ Logging Truck Wear On Community Roads
Re Item 3 Reforestation
Reforestation: Long term forest management was featured in both the June 16 announcement and July
18 Summary Project Description. During our meeting on July 26 some doubt was expressed whether the
described reforestation could be achievable, given the dry conditions and the presence of both deer and
feral goats in the area. It would be helpful to see the silviculturist’s assessment, so that the community is
not left with unrealistic expectations.
Provided is a summary of the IR7 Preferred and Alternate Silviculture Plans
Re Item 4 Environmental Assessment and Species At Risk
We note with some concern the lack of reference about your environmental assessment plans and
specifically how you intend to identify species at risk (federally and provincially listed species). IR7 is
part of Coastal Dry Douglas Fir forest and the valley is known to be habitat for provincially listed and
likely federally listed species at risk. As a first step, it would be helpful to see the resource inventory that
we assume has been conducted, and to see what mitigation measures you have planned to protect listed
species, and the valley wetlands and ephemeral streams, where pools were still present in late July.
The following extracts from the project Environmental Assessment are provided in a
companion file:
· Section 3.5.4 of the EA (Biological Environment)
· Four Environmental Assessment extracts from Section 4.2 of the EA
(Potential Environmental Impacts Description & Analysis)
~ Encroachment on Sensitive Forest Ecosystems, On-site Resources, and Adjacent Land Use
~ Habitat Loss From Removal Of Vegetation/Forest Cover
~ Wildlife Disturbance From Operational Activity
~ Fish and Fish Habitat Disruption
· Seven Project Commitment extracts from Section 8 of the EA
(Summary of Project Commitments)
· EA APPENDIX B. Plant Species On IR7
· EA APPENDIX C. Species at Risk Analysis
*********************
3
SPECIFIC ITEMS RAISED
Overall
The Tsawout & Tseycum Nations plan to operate a tree farm on the 145ha Saturna Island Indian
Reserve # 7, which they hold jointly on Saturna Island, B.C.
The planning undertaken for this project involves the preparation of a Forest Management Plan and
an array of associated documentation, which includes, the conduct and of a project Environmental
Assessment. These are needed to provide a current, soundly planned and cost effective approach
the project’s operations and to account the potential effects of the project on the various elements
of the bio-physical and socio-community environment associated with the subject site and Saturna
Island in general.
The objectives of the Tsawout and Tseycum First Nations for this project are:
· Sound stewardship of their land and resources
· Optimization of economic opportunities afforded on these lands
· Implementation of Forest fuel management on aging and non-managed forest property
· Complementarily with nearby National Park and Regional Park orientations in future
uses of IRT#7
· Assurance of compatibility with Saturna Island orientations
· Maintenance of continued good relations with the BC Gulf Island Trust
Saturna IR#7 is 145 ha in area located near the east end of Saturna Island. Its main block has
1,733 meters of frontage on East Point Road (aka Tumbo Channel Road),and 1847 meters of
shoreline on Narvaez Bay, of which 364 meters fronts Fiddler’s Cove. A 9 hectare strip of this
property is situated on a north facing linear block between East Point Road and Tumbo
Channel.
The project at hand entails the selective logging of 50% of IR 7 in 3 blocks as shown below IR7
Project Forest Management Plan Map. These are.
BLOCK AREA % AREA of IR7 TIMBER VOLUME
Block A 45.1 ha 30.9% 27,000m3
Block B 11.6 ha 7.2 % 3.000m3
Block C 17.3 ha 11.8 % 5,000m3_
TOTALS 74.0 ha 50% 35,000m3
Harvested timber will be trucked via East Point Road to the existing Lyall Harbour log
dump to be watered and boomed for off-Island transport. It is estimated that 9 loads per
day will be hauled to tidewater on each of 90 days during the months of April to July
2017. Operational planning and site planning are oriented to conserving and managing
the various unique landscape features and environmental attributes of the property with
a view to long term future uses as a tree farm and for active public recreation in
conjunction with the adjacent Gulf Island National Park.
4
Saturna IR7 Forest Management Plan Map
Item 1 Fire Risk
Fire Risk: We understand that debris management is part of every logging plan. Noting that IR7 is bounded
by residential neighbourhoods as well as the National Park Reserve, protection of human life, both firefighters
and civilians, is our first priority. We think the community would be more at ease if we were provided with
the mitigation and monitoring plans for debris management that form part of the logging plan that will be
submitted to INAC.
The following is the mitigation and monitoring plans for debris management for IR #7:
Forest Fuel Fire Risk Control The current advanced second growth stand on IR7 has
considerable fuel loading on the duff layer and coarse woody debris from aging trees that
have fallen over. Logging the designated area will allow for the forest fuel-fire risk to be
reduced and managed for. This is due to the removal of a portion of the advanced second
growth stand on IR7. Partial harvest of IR7 will create a good fire break between the areas
inhabited on East point and the Federal Park.
POST HARVEST OPERATIONS
All cut blocks will be planted and tended to ensure we meet free to grow criteria. Larger
woody debris that is suitable for firewood will be put aside from slash piles for further use by
the Tsawout Nations for Firewood. Slash piles shall be burnt in winter months to open
plantable spots.
5
The attached Fire Hazard Assessment (Appendix E) will be filled out, assessed and acted
upon as warranted once logging has been completed.
8. SUMMARY OF PROJECT COMMITMENTS
Pertinent commitments to the subject topic are presented below
ENVIRONMENTAL
RESOURCE/
FEATURE
ITEM CONTEXT
C.1 On-Site Activities
Fire Risk Slash and candidate understory will be moved into
piles at internal roadside locations
Large pieces will be separated and set aside for a
possible future firewood preparation and marketing
program There is also an opportunity for the
remainder to be chipped and mulched for sale and
use, both on and off Saturna Island,
Slash
Management
&
Forest Fuel
Reduction
****************
Site Preparation:
No Site preparation other than slash piling will be
required or the re-distribution of slash to allow for
plantable areas.
Assess the slash post-harvest. Provided it is not a
fire hazard, the preferred option is to redistribute
the roadside slash if target stocking can still be
met.
Site Preparation:
The Planters may be required to move slash to find
plantable spots.
An alternate fire hazard abatement method is to
pile and burn when the risk of escape of
broadcasting is low. Other fire hazard abatement
options include removal or chipping.
6
Item 2 Road Safety:
Road Safety: This is a subject of great concern to the community. In the July 18 Summary Project
Description 9 truckloads per day were planned, over a 3 or 4 month period. Of particular concern are the
narrow steep hill down to Lyall Valley (known on the Island as “the missing link”), the need for residents to
access the four ferries a day to and from East Point, and truck traffic around the school. The community will
want to know the specifics of how you plan to manage and monitor the trucking with local traffic and how you
plan to address any damage to the roads that might be caused by over 800 truckloads. We look forward to
working with your group regarding this issue.
B.2 Off-Site Activities
Transportation Via Public Roads To Tidewater
At Lyall Harbour Log Dump
1. Logging Truck Traffic on Community Access Roads
Possible Impacting Activities/Actions: Numbers and frequencies of haul traffic
Potentially Affected Environmental Elements: Local traffic patterns, traffic timing and durations,
risk to pedestrians. Haul route adjacent to elementary school
Impact Analysis: The haul distance from the point of planned site-road access to the Lyall
Harbour log dump is approximately11 km. Of this, 10km will be on East Point Road, and 1
km will be via either Sunset Road or Money Road along the established access routes to the
Lyell Harbour Log Dump. East Point Road is the sole east-west artery on the northern
portion of the Island. As such, it is routinely used by local residential and recreationists
accessing the nearby cliffside subdivisions and the East Point Lighthouse Park.
The main access from East Point Road to the Lyall Harbor log dump, involves a right turn
form East Point Road onto Sunset Boulevard, and passage in front of the Saturna
Elementary School before turning left onto Waverly Road and then proceeding on Money
Road to the Log Dump.
The alternative route would be to stay on East Point Road, turning right onto Money Road
which continues behind the school and directly to the log dump. This alternate route goes
beside the back of the school grounds (east side) rather than down Sunset Blvd.
which is close to the front of the school (west side) and to a greater number of
houses.
Impact Significance: Ephemerally high
Environmental Management Prescription:
• The access to East Point Road from the subject property will be sited at a point of
maximum site lines in both directions
• Truck log hauls are foreseen as 3 hauls by 3 trucks daily, amounting to a total of 18
movements on this road each day for a period of 90 days.
7
• These will occur over a 4 month period during the months of April to July 2017
• Log hauls will be scheduled to minimize interference with normal vehicular traffic on East
Point Road
• Signpost road to caution residents and off-island recreationists regarding log hauling
operations.
• Speed limits for logging trucks along the Sunset Road and/or Money Road will be
confined to 25kph.
• Use of Sunset Blvd. by logging trucks on school days during lunch hours and for a 45
minute period when school is starting or getting out, logging trucks will not use Sunset
Boulevard to access or egress the log dump .
• Flaggers will be used on initial construction of the junction to the IR 7. No flaggers are
required for operational activities on the road as highway trucks have proper turn signals.
• All trucks will be in radio contact; constant communication by truck drivers will be needed
to reduce meeting at poor locations.
• Drivers will be aware of other traffic on the road at all times ’
2. Logging Truck Wear On Community Roads
Possible Impacting Activities/Actions: Frequency and extent of road use by haul trucks
Potentially Affected Environmental Elements: Wear and tear to community roads
Impact Analysis The haul distance from the point of planned site-road access to the Lyall
Harbour log dump is approximately 11 km. Of this, 10km will be on East Point Road, and 1
km will be via Sunset Road or Money Road along the established harbour access routes to
the Log Dump East Point Road is the sole east-west artery on the northern portion of the
Island. As such, it is routinely used by local residential and recreationists accessing the
nearby cliffside subdivisions and the East Point Lighthouse Park
Impact Significance: Limited
Environmental Management Prescription The haul route in general will be inspected for quality
and integrity prior to commencement of hauling activities, Logging trucks to be utilized on
this project will be suited to highway standards and will not unduly create any excess burden
on the road than what already exists from present traffic. Ongoing residential and
recreational use as well as past logging activity occurring over the past century throughout
the island compacted the soils on the roads, in particular before it was paved. Highway
trucks used for log hauling and equipment transportation will adhere to load regulations
posted by Ministry of Highways. All log trucks will be equipped with radios to ensure
communication with each other with respect to road traffic.
8
8. SUMMARY OF PROJECT COMMITMENTS
Pertinent commitments to the subject topic are presented below
ENVIRONMENTAL
RESOURCE/
FEATURE
ITEM CONTEXT
C.2 Off-Site Activities
Traffic Safety · The access to East Point Road from the
subject property will be sited at a point of
maximum site lines in both directions
· Truck log hauls are foreseen as 3 hauls by
3 trucks daily, amounting to a total of 18
movements on this road each day for a
period of 90 days.
· These will occur over a 4 month period
during the months of April to July 2017
· Log hauls will be scheduled to minimize
interference with normal vehicular traffic on
East Point Road
· The road will be signposted to caution
residents and off-island recreationists
regarding log hauling operations.
· Speed limits for logging trucks along the
Sunset Road and/or Money Road will be
confined to 25kph.
· Use of Sunset Blvd. by logging trucks to
access or egress the log dump on school
days during lunch hours and for a 45 minute
period when school is starting or getting out,
will not be permitted
· Flaggers will be used on initial construction
of the junction to the IR 7. No flaggers are
required for operational activities on the
road as highway trucks have proper turn
signals.
· All trucks will be in radio contact; as
constant communication by truck drivers will
be needed to reduce meeting at poor
locations.
· Drivers will be aware of other traffic on the
road at all times ’
Log Hauling
To Tidewater
Traffic Safety The haul route in general will be inspected for
quality and integrity prior to commencement of
hauling activities, Logging trucks to be utilized on
Log Hauling
To Tidewater
9
this project will be suited to highway standards and
will not unduly create any excess burden on the
road beyond what already exists from present
traffic. Highway trucks used for log hauling and
equipment transportation will adhere to load
regulations posted by Ministry of Highways. All log
trucks will be equipped with radios to ensure
communication with each other with respect to road
traffic
******************
10
Item 3 Reforestation:
Reforestation: Long term forest management was featured in both the June 16 announcement and July 18
Summary Project Description. During our meeting on July 26 some doubt was expressed whether the
described reforestation could be achievable, given the dry conditions and the presence of both deer and feral
goats in the area. It would be helpful to see the silviculturist’s assessment, so that the community is not left
with unrealistic expectations.
The following summarizes the Preferred and Alternate IR7 Silviculture Plans.
Preferred Alternate
Site Preparation:
No Site preparation other than slash piling will be
required or the re-distribution of slash to allow for
plantable areas.
Assess the slash post-harvest. Provided it is not a fire
hazard the preferred option is to redistribute the
roadside slash if target stocking can still be met.
Site Preparation:
The Planters may be required to move slash to find
plantable spots.
An alternate fire hazard abatement method is to
pile and burn when the risk of escape of
broadcasting is low. Other fire hazard abatement
options include removal or chipping.
Regeneration:
Plant TUs A, B, C with Fd 100% using 1+0 psb 412a
or b stock. Cw regeneration is expected from natural
ingress in the wetter sites near streams 1 and 1A. Cw
is not being planted because of the high browse
potential from deer and feral goats. Plant the first
spring post-harvest provided the stock is ready
otherwise do not plant later than 2 years post-harvest
to ensure early green-up.
Trees can be ordered from the following nurseries:
Arbutus Grove Nursery Ltd.
Website: http://www.arbutusgrove.com
Sylvan Vale Nursery Ltd.
Website: http://www.svnltd.com
Regeneration:
Changing the stock type to a larger type such as
415d to 615d for TUs A and C depending on
availability. No larger stock than 412a or b should
go in TU B because of the shallow soil each
species and for the stock type (for the 415 psb
stock an acceptable option is to use 512s or 515s)
can be used.
Survey within 2 growing seasons of planting. If the
survey results indicate then a fill-in planting may be
required.
Brushing:
Expect one manual brushing for both TUs A and C
with a possible second manual treatment for TUs A
and C. The brush hazard for TUs A, and C is low for
salal, moderate for salmonberry, moderate to high for
red alder (Dr).
The brush Hazard for TU B is moderate for salal and
low for all other brush competitors. Non-detrimental
yarding disturbance will reduce the salal competition.
No brushing other than a possible spot manual
treatment is anticipated. Survey TUs A and C for
brush year 3-6. Expect the first manual treatment
year 4-6 with a second possible spot treatment year
6-9.
Brushing:
A brush survey should be completed by year 9 to
ensure the late free growing period will be
achieved. Although chemical brushing would be
effective the preferred option is to manually brush
the competing vegetation. Therefore, no chemical
brushing is anticipated as manual brushing should
be effective.
11
Additional surveys:
A brush survey will be undertaken by year 9 to ensure that the late free growing period can be achieved.
Other:
It is acknowledged that feral goats are a consistent problem on Saturna Island and that steps
should be taken to eradicate them in order to retain and preserve the natural flora and fauna of
the island.
8. SUMMARY OF PROJECT COMMITMENTS
Pertinent commitments to the subject topic are presented below
ENVIRONMENTAL
RESOURCE/
FEATURE
ITEM CONTEXT
C. PROJECT OPERATOIONS AND MAINETNANCE
C.1 On-Site Activities
Forest Resources
Wildlife Habitats
Wildlife
The techniques and measures to be employed in
post–harvest planning and silviculture treatments
constitute widely accepted best environmental
management practices.
In addition, due to the selective nature of the timber
harvest and the extensive habitat edges created
among the remaining trees within the cutblocks, these
practices to be employed will further expand and
diversify the use of these areas by an array of wildlife.
Tree Farm
Planting
&
Silviculture
Treatments
******************