Submission by Anthony Britneff to the BC Government's TFL-Expansion Plans
Anthony Britneff, May 22, 2014
The forests minister promised public consultation. What he has provided instead is stakeholder engagement by invitation.
Democracy is about public debate and choice. This process offers neither to British Columbia’s residents, the owners of the forest resource. It is about changing the mix of tenure within the existing system of governance without choices.
The declared purpose of the process is to obtain input on the criteria to be considered in evaluating proposals for converting some or a portion of some volume-based forest licences to new or expanded area-based tree farm licences. Conversion to TFLs is a foregone conclusion.
The question of whether or not the public wants more TFLs does not fall within the terms of reference. Nor does consideration of other models of governance such as local forest trusts that would devolve jurisdiction over local forests to forest-dependant communities and to First Nations.
Under the terms of reference, who gets to convert forest licences to TFLs is also a foregone conclusion. With the initial focus being on those areas worst affected by the mountain pine beetle epidemic we know that:
• Allowable Annual Cuts (AAC) are unsustainably high and will decrease radically
• An AAC determined by the Chief Forester bears little relation to the economic AAC because a significant volume of timber is impracticable to log.
• Non-replaceable forest licences and licences-to-cut largely held by First Nations will not be renewed because the timber volume does not exist.
• Replaceable forest licences take precedence over other forms of licence.
• A handful of companies possess the lion’s share of replaceable forest licences.
Therefore, the only beneficiaries of TFL rollover will be an oligopoly of companies, who through licence trading are already trying to strengthen regional monopolies over timber supply.
This process is mock consultation at its worst. The government objective – revealed in a leaked Cabinet document last April 2013 — to further enclose the commons by granting more private rights to a few companies through more private tenure over public lands is disguised as a process to seek public guidance on forest governance under the rubric of area-based management.
Registered Professional Forester (retired)
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