Forest Management Certification Assessment Report for - Rainforest ...

FSC PrincipleP6: EnvironmentalImpactComments from InterestedParties• AAC calculations are completed onthe whole Cranbrook and KootenayLake TSAs (including Tembec andother tenure holders), not the areadefined as the management unit forthe purposes of certification. Theassumptions used in that calculationdo not necessarily reflect Tembec’spractices, and even if they did,Tembec’s portion of the AAC for theTSA is based on a percentage of thetotal, including whatever practicesthat may be occurring in otherlicensees’ operating areas (i.e. chartareas).• The assumptions used in theCranbrook and Kootenay Lake TSAsdo not adequately reflect thereliability and uncertainty associatedwith the data and assumptions (theSIBEC growth rates are the antithesisof a margin of safety).• There is no adequate managementplan for non-timber forest products.Improper harvesting may bedamaging mushroom mycelial mats.• A RONV description is in place butthere is not an environmentalbenchmark.• Habitat and access-sensitive speciesseem to be compromised in somecases to meet timber objectives (e.g.OG retention, mature/old on winterranges, riparian reserves, access), butTembec does not seem to be usingAssessment Team Response• The team agrees with this point. CAR12/06 addresses the need for a separateanalysis of timber supply informationand management assumptions forTembec’s operating area. This needs toreflect land base reductions andmanagement strategies and practices setout in Tembec’s SFMP.• The team found that the AACdeterminations do address uncertaintyand risk in the assumptions.• The BC Standard places responsibilityfor non-timber products on Tembeconly if Tembec “harvests or controls theharvest” of NTFPs. Tembec does notharvest or control the harvest, so thisconcern is not within the scope of theassessment and there is no nonconformance.• As part of the SFMP and C&Iframework, Tembec has prepared awritten description of the range ofnatural variability (RONV) associatedwith the natural disturbance regimes inthe BEC subzones found within all ofTembec’s operating areas in BC. Thisdescription includes references toecosystem conditions and ecosystemfunctioning consistent with the FSC-BCGuidance Material on RONV. The teamaccepted this as a benchmark.• Wildlife habitat assessments haveincluded consultations regardingaccess-sensitive species such as grizzlybears. Tembec’s consultations withgrizzly bear researchers have aidedmanagement planning.Page 26 of 89