EAC Review of the Silvicultural Guide for the Ecological Matrix

Introduction

A key recommendation of An Independent Review of Forest Practices in Nova Scotia (The Lahey Review) was to revise Nova Scotia’s Forest Management Guide. The revised guide will describe appropriate silvicultural methods for the ecological matrix within the triad. The Lahey Review proposed that the guide be aligned to support the adoption of ecological forestry that must “give priority to protecting and enhancing ecosystems and biodiversity.”

The most recent draft Silvicultural Guide for the Ecological Matrix (SGEM) represents the third iteration of the Forest Management Guide. The changes contained within the current draft SGEM were the result of a previous consultation process that occurred in 2019-2020. EAC welcomes the opportunity to participate in the on-going review of the SGEM. The following submission is meant to reinforce the positive aspects of the most recent draft SGEM and offer recomendations to be included into the final version of the guide in order to align the SGEM with the Lahey Review’s vision for ecological forestry.

 

Positive Steps in Updated Draft SGEM

The updated draft SGEM contains several significant improvements over previous versions that will, if properly implemented, better align forest management on Crown lands with ecological forestry as envisioned by the Lahey Review, including;

1. Increased emphasis on managing for long-lived, shade tolerant species grown in structurally complex, multi-aged stands and more widespread application of multi-aged silviculture systems, specifically irregular shelterwood. The latest draft of the SGEM is better positioned than previous iterations for aligning silviculture with the natural disturbance regime of the Acadian Forest region.
2. Establishment of permanent reserve trees to serve a variety of important biological functions.
3. A reduction (but not elimination) in avenues to high removal harvests that resemble clearcutting. These “overstory removals” with minimal reserves carry significant ecological and economic costs and have no place in an ecological forestry paradigm for matrix lands that must prioritize ecological values to achieve the direction of the Lahey Review.
4. Removal of rare and ecologically sensitive sites from forest management within the matrix (cedar, karst, floodplain, open woodland, wet deciduous and wet coniferous forest groups). These sites play an important role in biodiversity conservation and removing them from harvesting is a positive step in line with prioritizing ecosystems and biodiversity.
5. Integration of soil nutrient sustainability as part of the harvest planning system. While some questions remain about the effectiveness of this element of the SGEM (see below), integrating this information into harvest decisions is critically important and will invariably reduce harvest removal rates as more trees are left behind to meet soil nutrient requirements. This is especially true in Western Nova Scotia, where already poor productivity soils have been severely degraded by clearcutting and acid rain. 

 

Continued Bias Towards Economic Outcomes 

Despite the improvements noted above, several concerning issues persist within the guides that collectively reduce ecological outcomes in favour of mitigating wood supply losses. Several changes to the draft SGEM are required to enable the Lahey Report’s vision for ecological forestry to become a reality on the matrix lands.

This bias is noted early in the document in the use of the selective quote from the Lahey Report that describes the matrix as the triad zone in which “conservation and production objectives are both applicable and combined.”

This limited and vague selection suggests a familiar attempt to “balance” competing objectives, where wood supply concerns are of equal or greater weight to ecological values.

The Lahey Review specifically rejected this notion of “balancing” economic and environmental considerations in the Matrix lands, instead concluding that “protecting ecosystems and biodiversity should not be balanced against other objectives and values as if they were of equal weight or important to those objectives of values. Instead, protecting and enhancing ecosystems should be the objective (the outcome) of how we balance environmental, social and economic objectives and values in practicing forestry in Nova Scotia.” (Lahey Report, executive Summary, p. iii)

In the draft SGEM, DLF recognizes that the Lahey Review defines ecological forestry at length and yet the document again uses selective language from an alternative source to reduce the importance of ecological values in defining ecological forestry as “based on maintaining, enhancing or restoring the ecological functions in an ecosystem in which biodiversity is one of the most important considerations.”

As stated above, the Lahey Review proposed that the SGEM be aligned to support the adoption of ecological forestry that must “give priority to protecting and enhancing ecosystems and biodiversity.” This needs to be reflected in the language and definitions throughout the final version of the SGEM.

One major economic bias from previous versions of the SGEM was the economic focus applied to the definition of “acceptable growing stock” (AGS) and the major influence that the presence or absence of sawlogs had on the silviculture system that was selected through application of the guides. The latest draft of the SGEM has reduced the influence of AGS, instead using forest structure as the primary guiding factor. This is a positive step.

However, the definition of AGS is still improperly influenced by economic factors. Consider the example from page 173 of the SGEM. A perfectly healthy hardwood tree is deemed to be “unacceptable growing stock” (UGS) due to a sweeping bole. Such an economic-based criteria has no place in a guide meant to prioritize biodiversity.

Many of the attributes of UGS as defined in the SGEM are required to support biodiversity features in our forests. Interior rot leads to cavity trees that are important for cavity nesting species such as chimney swift and flying squirrels. Forked or corked tops create ideal nesting sites for a variety of raptor species. Dead, standing trees serve many ecological roles and arguably support more life in the forest than live stems.

In order to address these issues, the following changes are required;

1. Rather than describing “minimum retention” rates or percentages, the language in the SGEM should be reversed to describe “maximum extraction rates” instead. This would provide a more proper framing of the ecosystem focused management regime intended for the matrix lands.
2. The definition of AGS should be amended to reflect an approach like the Ontario Tree Marking Guide.
3. Harvest damage cannot be considered a major defect as this will incentivize damaging trees as a means in increase removal rates in subsequent harvests.

 

Reduce Extraction Rates and Increase Permanent Retention Levels to Prioritize Biodiversity

Up to 80% of the forest on a given site can be removed under the draft SGEM and in some cases, this removal will happen in a single harvest. These alarmingly high extraction rates are far too high to achieve the goal of ecological forestry on matrix lands and are only driven be economic interests. This approach will have detrimental effects on wildlife, is out of synch with gap-based natural disturbance regimes, will lead to increased susceptibility to blowdown, reduce the production of high-quality forest products, contribute to soil carbon loss, and will perpetuate boreal species assemblages that are poorly adapted to a warming climate.

The designation of permanent reserve trees to serve as biological legacy is welcome and tremendously important but the amount of forest being left behind to serve ecological roles is too low.

The designation of permanent reserve trees to serve as biological legacy is welcome and tremendously important but the amount of forest being left behind to serve ecological roles is too low.

1. Maximum extraction rates in the matrix should be capped at 30% in a single entry, with cut cycles and stand rotations aligned with the “1% per year” rule that is widely accepted as the natural rate of canopy disturbance (see Seymour et al, 2002).
2. Permanent reserve tree levels should be drastically increased to a minimum of 50 trees/ha for all harvest sites.
3. Community-based licensees, such as the Medway Community Forest and the Mi’kmaq Forestry Initiatives should have the flexibility to cut less and leave more to meet their own social, ecological, and economic goals.

 

“Restoration” Key Leading to Clearcutting

The “Restoration” key is a shocking example of Orwellian language that misrepresents the outcome and as presented it is simply a re-worked version of the previously rejected “Salvage” key from the last draft SGEM. The proposed “Restoration” approach is a dressed-up version of clearcutting, with the SGEM prescribing the heaviest harvest removals and lowest retention levels for situations where LIT species abundance is lowest. This is counter-productive to the goal of restoring LIT species levels and creating or maintaining multi-age stands.

Indeed, many areas of the degraded matrix lands will require restoration of forest structure, composition, and soil productivity, but the current Restoration key does not come close to achieving these objectives. DLF’s approach to restoration reflects the utilitarian view that assumes that the forest exists first and foremost to be harvested. It is a relic of the outdated, discredited “start it over” mentality that runs counter to the natural succession patterns of the Acadian Forest. The reality that DLF seems to refuse to accept is that some wood volume must be left in the woods to achieve forest restoration goals.

The SGEM must prioritize ecosystem health and biodiversity to achieve the direction of the Lahey Review and restore public trust. The restoration keys acknowledge that gap-based shelterwood systems are better for biodiversity and yet these keys result in uniform/strip shelterwood systems and high removal rates. These systems lead to final overstory removal harvests with minimal retention that are biologically similar to clearcutting. In some cases, full overstory removals of up to 80% of the forest is taken in a single harvest.

Removing up to 80% of a forest site often dooms the remaining trees to blow down, negating much of the value of retaining trees on harvested sites. These extremely high removal rates will perpetuate boreal species, continue to degrade soil productivity, release stored soil carbon, and produce low value forest products at the expense of a sawlog economy. This is not Acadian Forest restoration. Not even close.

The issue of restoring LIT species and multi-aged stand structures on sites that would naturally support these species and structures is a major issue facing Nova Scotia’s degraded, impoverished forests. Instead of embracing this challenge, DLF has attempted to position an outdated approach to forest management as “restoration”. This will only further undermine public trust in DLF as a competent steward of our Crown forests and as an agency that is looking out for the broader public good rather than the economic bottom line of the mills that cut on Crown land. 

Significant work is needed in this area, as outlined below; 

1. The current “restoration” approach proposed in the SGEM requires a significant overhaul involving external experts and interested stakeholders. DLF, in cooperation with stakeholders and relevant experts, must convene an external working group to address the issue of developing a true forest “restoration” pathway for degraded sites in the matrix.
2. All matrix harvesting that focuses on regenerating stands must be based on high retention, gap-based irregular shelterwood systems that are acknowledged in the SGEM as the preferred approach for biodiversity considerations.
3. Red maple should be added to the list of LIT species for all forest groups, not just Tolerant Hardwoods. Recognizing the potential for red maple will significantly reduce the application of “restoration” keys as presented.
4. Extraction trails must be considered part of the harvest site when determining retention in any non-gap shelterwood variants. Trails can have a significant impact on overall block retention levels when only leave strips are considered.

 

Zonal/Azonal Ecosites

We note with some alarm the sudden appearance in the draft SGEM of an attempt to subdivide the Acadian forest into “zonal” and “azonal” sites for management purposes, with significantly increased removals allowed on “azonal” ecosites. This is counterintuitive to the principle of restoring degraded forests and soils that are often found on “azonal” sites. In many instances the appearance of borealized forests and low site productivity that leads to this new “azonal” classification is the result of past clearcutting. This is particularly true on transitional Ecosites (AC6, AC7 & AC9), where natural patterns of forest succession will often restore productivity and LIT species representation.

It is especially concerning that the increased removals on “azonal” sites is justified based on DLF’s own highly criticized work on natural disturbance regimes. This work has been recognized as overstating the role that large-scale disturbances play in the disturbance ecology of the Acadian Forest Region. It is unacceptable to move forward with this approach until more work is done to address the problems with DLF’s own natural disturbance regime science.

We are similarly concerned about further sub-categorization of “Maritime Boreal” sites and the development of a separate management guide for these areas. It is easy to accept that, for example, the Cape Breton Highlands have different characteristics than other areas of the province. But the concerns about the impacts of heavy removals on soil nutrients, carbon stores and wildlife are the same for these areas as they are for more typical Acadian Forest sites. This is especially true given the high degree of forest degradation and fragmentation that has resulted from decades of heavy cutting on the Highlands.

EAC rejects the new sub-categorization of the Acadian forest based on “zonal” and “azonal” ecosites for operational purposes.

EAC again states clearly that there should be no more than 30% removals in a single harvest entry, regardless of the so-called ecosite. 

Maximizing the Climate Changing Mitigation Capacity of Our Forests 

Although a section on climate change is a welcome addition to the most recent version of the SGEM, the document does not fully embrace the climate change mitigation potential of our forests. 

Our government has recognized that humanity is in a climate emergency. This needs to be acknowledged in the SGEM.

The selection of silviculture systems in the guide needs to consider the impacts on carbon stores, both within standing trees and soil horizons. The heavy removals (70-80% of the forest cover from a given site) that result from the current draft SGEM will reduce the standing stores of forest carbon in our forests and lead to soil carbon loss.

The next decade is a critical time for humanity in addressing the climate emergency. The carbon sequestration potential of our public forest must be maximized to help address the need for reducing atmospheric carbon dioxide levels in the short term.

Harvest rates that can be demonstrated to reduce short term carbon sequestration potential and soil carbon stores should not be allowed in the final SGEM.

 

Integration of Soil Nutrient Sustainability

The integration of soil nutrient sustainability into harvest decision making is welcome and long overdue. DLF has had this information for some time now and must take immediate action on this issue. The issue of soil nutrient sustainability is particularly concerning in the western region of the province, where soils are naturally thin, nutrient poor and heavily impacted from clearcutting and acid rain.

Rather than seeking to only maintain currently degraded rates of soil productivity, the goal of soil nutrient management within the SGEM should be to repair losses in soil productivity that have resulted from anthropogenic causes such as clearcutting and acid rain.

More information is needed to assess how soil nutrient sustainability will be integrated into harvest decisions making and how removal rates will be adjusted to ensure harvesting does not continue to rob our soils of their future productivity.

Additionally, the integration of nutrient budgets into the SGEM should undergo a separate external review with stakeholders as this is a key component of advancing forestry on Crown lands and aligning it with an approach that prioritizes protecting ecosystems and biodiversity.

 

Additional Considerations for Prioritizing Biodiversity

We also strongly recommend, either in the final SGEM or through policy and regulation, the mandating of a “silent spring” period during bird nesting season when harvesting in the Matrix lands would not occur. This is in keeping with the focus on biodiversity in the Matrix lands and the Migratory Bird Act as well as the Lahey Report’s Recommendation #16: “DNR, with Crown licensees, must take immediate and sustained action – including by conducting or commissioning appropriate scientific research, engaging interested parties in collaborative problem‐solving forums, and adopting precautionary measures – to be responsive to concerns about the potential adverse impact of forestry on Crown lands on the following interests: a. Sensitive soils, particularly on Crown lands in the western region b. Bird populations c. Tourism operations and developmental plans d. Outdoor recreation activities, including established trails e. Protected Areas” 

Similarly, we recommend the expansion of riparian zones within the Matrix zone from 20 to 100 meters to increase protection of waterways and for greater wildlife connectivity and biodiversity conservation. 

 

Conclusion 

While the most recent draft SGEM contains some significant improvements over previous versions of the guide, much work remains to achieve the goal of “prioritizing ecosystems and biodiversity.”

Additional external review by outside experts (eg. Bob Seymour or Laura Kenefic) is required for the overall SGEM, and particularly for the soil nutrient sustainability and restoration sections of the guide. While this will take time and effort, external review is required to give credibility to the final product after such slow progress and significant deficiencies that have plagued the development of the SGEM thus far.

In the meantime, EAC strongly recommends immediate implementation of updated Interim Retention Guidelines mandating a maximum of 30% basal area removal harvests as described above.

Additionally, any harvesting plans that were previously approved under earlier versions of the FMG or current Interim Retention Guidelines should be subject to the new SGEM.