by David Patriquin
Page Posted Dec 4, 2024
NAVIGATION
www.nsforestmatters.ca
_ _ _ Bioeconomy
_ _ _ _ _ _ NS Forest Biomass RRA 2024
_ _ _ _ _ _ _ _ _ Notes & Comments (THIS PAGE) <—-
_ _ _ _ _ _ _ _ _ Some Background
_ _ _ _ _ _ _ _ _ Some Stats from FPI 2021 Doc
_ _ _ _ _ _ _ _ _ Forest Biomass issues in Nova Scotia
_ _ _ _ _ _ _ _ _ Diverging Forest Bioenergy Perspectives in 2010
_ _ _ _ _ _ _ _ _Forest Biomass Supply/Demand estimates for NS
1. THE DOCUMENT TO BE REVIEWED
1a. Link to submit comments
1b. Related Post on nsforestmatters.ca Nov 7, 20242. NOTES from & COMMENTS on the DRAFT RRA
2a. About the process
2b. About Section 4 Regional Background
2c. The Crux of the Process: Annex 1: Detailed Findings for Indicators
2d. List of Indicators & Ratings
2e. Comments Submitted/Reservations about Select Indicators
2f. Just the Comments
Also view
SOME BACKGROUND TO THE RRA
1. What are Regional Risk Assessments (RRA)
2. Stakeholder groups to be consulted in the RRA process
3. SBP risk reporting template: Indicators
1. THE DOCUMENT TO BE REVIEWED
—>Draft Regional Risk Assessment for the province of Nova Scotia, Canada
Version draft for Stakeholder Consultation, September 4, 2024. The Wood Pellet Association of Canada (WPAC). 254 pages with 19 Figures, 8 Tables and 6 Annex sections.
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1a. Link to submit comments (due by Dec 6, 2024)
View this page on the Sustainable Biomass Program Website :
SBP Launches Public Consultations on Seven Regional Risk Assessments
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1b. Related Post on nsforestmatters.ca Nov 7, 2024:
Sustainable Biomass Program launches public consultations on “Regional Risk Assessments” including one for Nova Scotia
“As a compendium of ‘what’s broadly understood about NS forests & wood supply’ (my paraphrasing), this RRA warrants careful scrutiny by Nova Scotians – especially given that the “biomass issue” was not addressed by Lahey in the 2018 Forest Practices Review and given the several plus mega-projects that involve use of wood, wood processing byproducts or clearing of forested lands that have been proposed, discussed, and some approved recently coupled with our commitment to 20% Protection by 2030.
“This initiative for Nova Scotia was announced back in mid-June with the public consultation process then expected to begin in mid-Aug (NSFM Post, June 16, 2024).
“The release of a Draft RRA for public review was finally announced yesterday, not only for Nova Scotia but for 6 other regions as well (Provinces of Alberta, British Columbia, New Brunswick, Quebec; plus Denmark – Trees Outside Forests, & US – Primary Sourcing Regions).”
2. NOTES from & COMMENTS on the DRAFT RRA
The “Notes” are in the form of (i) quotes from the document, indicated by quotation marks or placement in blockquotes (indented paragraph) format; (ii) screen captures from the document, (iii) simple text by the authors (no quotations).
“Comments” are highlighted as brown text.
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2a About the Process
“The purpose of an SBP-endorsed RRA is to evaluate an entire geographic region and determine the risks associated with sourcing feedstock for biomass pellet or wood chip production from that region.”
“The Wood Pellet Association of Canada (WPAC) initiated the RRA for the province of Nova Scotia (NS) in 2021 to verify the legality and sustainability of feedstock.”
“In 2023, the SBP engaged Hopkin Forest Management Consulting Ltd. and a team of independent natural resource and certification professionals to form the Working Body and complete the RRA”.
“…Information was obtained from provincial authorities, such as the NS Department of Natural Resources and Renewables (DNRR) and Department of Environment and Climate Change (DECC), and federal authorities, such as the Canadian Forest Service (CFS) of Natural Resources Canada (NRCAN) and Environment and Climate Change Canada (ECCC)… Many stakeholders were consulted in the process and information was obtained verbally and from written public and private sources”
“Once the RRA-NS is endorsed by SBP, each Biomass Producer must use the results of the RRA-NS to complete a Supply Base Evaluation. The Supply Base Evaluation is to demonstrate the Biomass Producer’s compliance with its findings and implement mitigation measures to manage any specified risks so the risks can be reduced to low. It is the role of an independent, accredited third-party Certification Body, to verify that the Supply Base Evaluation has been correctly undertaken and that any mitigation measures are being effectively implemented.”
REF: Risk Evaluation Framework
“The following key definitions are paramount in the REF:
• Threat: Anything that can exploit a vulnerability, intentionally or accidentally, and obtain, damage, or destroy an asset (in this case Indicator value). A threat is what needs to be managed to protect the value.
• Risk: Potential for loss, damage, or destruction of an Indicator value because of a threat exploiting a vulnerability.
• Risk assessment: Defines the level of risk by considering the probability/likelihood against the consequence/severity.”
“The REF provides a hierarchical set of questions to evaluate risk. The Working Body interprets the probability/likelihood as the management system.”
“Assessing the probability/likelihood was verified through the evaluation criteria” (given Table 2, page 14)
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2b About Section 4 Regional Background (pages 18-40 in RRA-NS doc). The sections:
4.1 Overview Description
“Nova Scotia’s (NS’s) land base is 5.5 million ha. Over 81% (4.5 million ha) are dominated by trees., p18”
COMMENT This (“Over 81%”) is a very out of date figure. The 2016 State of the Forest Report gives forest cover as 75%; that is the more usually cited figure for NS, but even that figure needs to critically reviewed/possibly revised.
4.2 Ecological Overview
4.2.1 Ecological Classification
4.2.2 Protected Areas and Parks
As of December 2023, 739,000 ha (13.5%) of NS land area is protected in parks and other types of protected areas. COMMENT No Mention of 20% protection by 2030
4.3 Indigenous Peoples
4.4 Land Use
4.5 Land Ownership
4.6 Forest Sector by Land Ownership
4.7 Forest Certification
4.8 Overview of the Biomass Sector
COMMENT: This section (4.8) describes only the Pellet Industry in NS
Table 6 lists two pellet mills; Shaw producing 50,000 tonne/yr and Great Northern Timber Inc. producing 100,000 tonnes per year.
There is no documentation/description of other forms, uses of biomass, chips, bark etc. for bioenergy and other, non-timber bioeconomic uses e.g., as given in the FPI 2021 Document.(https://novascotiainnovationhub.com/wp-content/uploads/2021/11/Nova-Scotia-Feedstock-Supply-2021_FINAL-August-2021.pdf)
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2c. The Crux of the process: Detailed Findings for Indicators (Annex 1)
COMMENT These pages on the 42 Indicators and their evaluation are mostly in Table format, take up most of the Draft RRA document (pages 41 to 228 out of 254 pages in total in the RRA-NS doc) , and are the crux of the whole process.
Below I attempt to summarize/highlight the items particularly relevant to the ecological and social values of NS forests.
The List below is extracted from Table 7, pp 41-46
– Table lists Indicators
– Ratings are given for each of these four land groups
Provincial
Crown
Industrial Private
Private Woods
A dash (-) means risk not specified Or that it is encompassed by Province-level Risk – as I understand it.)
L means LOW RISK
S means SPECIFIED RISK.
e.g. 1.1.1 Comply with laws L—
(L— means Low for Provincial, not specified for other Land Groups or they come under the Provincial designation)
e.g. 2.2.2 Health, vitality & other services – LSS
(- LSS means no designation at Provincial level, Low Risk for Crown lands, Soecified Risk for Industrial Private ad Private Woodlot lands)
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| 2d. List of Indicators and Ratings from Table 7, pp 41-46 in the RRA-NS doc.
***Flagged RRA by process ##### NS Forest Matters has some reservations about the ratings 1.1.1 Comply with laws L— |
COMMENT A significant proportion of the indicators (14 out of 42) were flagged by the RRA process (***) as involving more than Low Risk (i.e. were designated Specified Risk) for at least one Land Group; Industrial Private lands were identified as Specific Risk in 13 of the 14 cases, Private Woodlot lands in 14/14 cases, and Crown Land in only 3/14 cases.
Fifteen (15) of the Indicators addressing ecological/social aspects were flagged as having “NS Forest Matters’ Reservations” (#####); of those ten, 6 were not otherwise flagged (***) by the RRA process as involving more than Low Risk for at least one Land Group. Nine (9) of the 14 Indicators flagged by the RRA process as involving more than Low Risk (***) were also flagged by NS Forest Matters’ (#####); five were not.
So overall, in the Draft RRA, most of the Specified Risk was assigned to the Industrial Provate and Private Woodland groups. A commonly cited Rationale re: Specified Risk is “lack of regulatory framework; publicly available evidence to support implementation mechanism, monitoring”. This is not surprising given a tacit taboo to imposing more regulations on private lands from 2010 onwards (see Comments under 4.2.1 – Negative Social & Community Impact ID & Avoided in section 2e below).
The 15 Indicators described in Section 2e (NS Forest Matters’ Reservations about Select Indicators) applied mostly to Crown land forest management, i.e. NS Forest Matters identified many more issues of concern with Crown land management than had been identified in the Draft RRA.
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2e. Comments Submitted/Reservations about Select Indicators
For each of the indicators about which I had reservations, I have copied some of the text from the RRA-NS document that describes each indicator, reasons for decisions etc., i.e. text which is most pertinent to my reservations about the Indicator or about the Risks identified in the draft document. My comments are highlighted by brown colored text; these comments were submitted to the RRA-NS process on Tues. Dec 3, 2024 (The deadline for recipt of comments is Fri. Dec 6, 2024).
2.1.1 –Key Eco/HCV ID ( L—) #####
“Key species, habitats, ecosystems, and areas of high conservation value (HCV) pertaining to biodiversity in the supply base shall be identified…Landscape-level Biodiversity Values (Coarse scale)/…Stand-level Biodiversity Values (Medium/Fine Scale)
Potential Threats / Impacts: Resource-based activities can have a negative impact on functioning ecosystems, species and genetic diversity, and habitat protection. Harvesting disturbance, the direct and indirect effects associated with access, and the loss, fragmentation or degradation of ecosystems and/or habitats can influence the abundance and distribution of biodiversity values.
Regulatory Framework:
• Species at Risk Act (SARA)
• Migratory Birds Convention Act (MCBA)
• Fisheries Act
• Canada National Parks Act
Provincial
• Endangered Species Act
• Wilderness Areas Protection Act
• Special Places Protection Act
• Forests Act
• Biodiversity Act
• Provincial Parks Act
Stand-level Biodiversity Values (Medium/Fine Scale)
Federal
• Species at Risk Act)
• Migratory Birds Convention Act
• Fisheries Act
Provincial
• Endangered Species Act
• Wilderness Areas Protection Act
• Special Places Protection Act
• Forests Act
• Wildlife Habitat and Watercourses Protection Regulations
• Biodiversity Act
• Provincial Parks Act”
COMMENT: In regard to “areas of high conservation value (HCV) pertaining to biodiversity in the supply base shall be identified” – there is widespread dissatisfaction with the way the NS Gov. is proceeding to assign Crown lands to each of the 3 zones of the Forest TRIAD. In particular there is concern that harvesting is ongoing on some lands currently assigned to the Ecological Matrix when a larger area has been advanced by a citizen group as a candidate for Protection, based on fairly rigorous citizen science (not simply wishful thinking, NIMBY etc); and there is frustration that the government is proceeding very slowly to identify new Crown lands for protection via a vis its now legislated commitment to “20% protection by 2030″* but at the same time has proceeded much more quickly to identify candidate ares for the HPF (High Production Forestry) zone. As well, overall, there, is a severe lack of any published landscape level planning for biodiversity conservation in NS, e.g. equivalent to the Halifax Green Network Plan.
*Environmental Goals and Climate Change Reduction Act
CHAPTER 20 OF THE ACTS OF 2021:
“Land protection goals
10 The Government’s goals with respect to the protection of land are
(a) to conserve at least 20% of the total land and water mass of the Province by 2030 as protected areas and other effective area-based conservation measures, including Indigenous Protected and Conserved Areas, in a manner consistent with national reporting criteria;”
Also view these posts on nsforestmatters.ca
– Plans for harvesting within the proposed Ingram River Wilderness Area (IRWA) continue 23Sep2024
– Open letter to Nova Scotia Premier Houston requesting cessation of logging in areas that are prime candidates for protection 17Oct2024
– Harvesting in citizen-proposed Nova Scotia Protected Area continued…4Nov2024
– CBC InfoAM interviews on Logging in Citizen-Proposed Protected Areas #1: the “Activists” 20Nov2024
The NS Gov has a Collaborative Protected Areas Strategy, but has not acted on it, see:
Collaborative Protected Areas Strategy. An Action Plan for Achieving 20 Per cent ISBN 978-1-77448-553-8 December 2023. Commented Ecology Action Centre’s Raymond Plourde: “There is no collaboration with citizens groups or industry or civil society at large, the public, about moving that forward [on this strategy] in any kind of concrete way.”
2.1.2 – Key Eco/HCV Threats ID & Evaluated (L—) #####
“Threats to and impacts on the identified key species, habitats, ecosystems, and areas of high conservation value (HCV) pertaining to biodiversity in the supply base shall be identified and evaluated.
“Rationale for [LOW] Risk Designation There is a comprehensive federal and provincial regulatory framework with appropriate protocols and experts to identify and evaluate threats to and impacts on landscape-level and stand-level biodiversity values. Government agencies, both at the federal and provincial level, are responsible for the process of threats/impact evaluation and subsequent reporting for identified biodiversity values. Government agencies provide oversight for the threats/impact evaluation process, as well as appropriate monitoring and/or adaptive management to adjust threats/impact evaluations or resulting mitigation measures. Government websites and resources include listing, reports, analysis, recovery plans and spatial information (subject to confidentiality) demonstrating that landscape-level and stand-level biodiversity values such as key species, habitats, ecosystems, and areas of high conservation value have been evaluated or are in the process of being evaluated for threats to and impacts on identified biodiversity values. Based on evidence reviewed, this Indicator is designated as low risk at the provincial level in Nova Scotia.”
COMMENT: See concerns expressed above re: 2.1.1 –Key Eco/HCV ID
***2.1.3 – Key Eco/HCV Maintained (-SSS) #####
“Key species, habitats, ecosystems, and areas of high conservation value (HCV) pertaining to biodiversity in the supply base shall be maintained or enhanced.”
Rationale for [-SSS] Risk Designation “Crown Licence: The Crown licensees’ FMP, and subsequent operational plans are the primary implementation mechanism of legislation related the management and maintenance of biodiversity values.
“Government programs provide oversight and monitor regulatory planning and practices for biodiversity values. There is no indication of widespread or systemic legal non-compliance. However, government oversight is focused on legal compliance with legislation for biodiversity values but not on sufficiency relative to the maintenance and enhancement of biodiversity values. This reinforces uncertainty with respect to sufficiency/uniformity of implementation across diverse Crown licences….
“This risk assessment does identify areas of uncertainty. In the evaluation of Crown land, the most evident areas of uncertainty for the maintenance of biodiversity values are related the following:
- SAR recovery plans and critical habitat for identified species-at-risk are at various stages of completion; and
- RTE ecosystems are not recognized at the stand level.”
COMMENT: See concerns expressed above re: 2.1.1 –Key Eco/HCV ID
***2.2.1 – Conversion – a, b, c, d. (- SSS) ##### Page 88ff
“Feedstock shall not be sourced from land that had one of the following statuses in January 2008 and no longer has that status due to land conversion:
a. Forests;
b. Wetlands;
c. Peatlands;
d. Highly biodiverse grasslands.”
“Context
…In Canada, the industrial groups contributing to deforestation include agriculture,
built-up, forestry roads, hydro & hydro lines, mines, oil & gas, and transportation.”
“Potential Threats / Impacts
“Negative impacts of conversion include deforestation, fragmentation, altered or degraded habitat and ecosystems, reduced productive forest areas, and increased carbon emissions.”
Oversight Framework:
“Crown Licence
As of March 2024, there is no publicly available information describing an oversight framework that prevents the conversion of forests on Crown land utilised by non-forest management industry sectors.
Industrial Private Land and Private Woodlots
As of March 2024, there is no publicly available information describing an
oversight or monitoring framework that prevents the conversion of forests on
industrial private land and private woodlots. Owners are responsible for the
oversight of operations.”
“Rationale for Risk Designation
On Crown land for the industry sectors that do not have forest management type tenures, legislation does not restrict land conversion. Due to a lack of evidence to support implementation mechanisms, a monitoring framework, and/or results of current condition of deforestation, a precautionary approach is applied. As such, this Indicator is designated as specified risk for Crown land in Nova Scotia.
Industrial Private Land and Private Woodlots
Due to a lack of a regulatory framework, evidence to support implementation mechanisms, a monitoring framework, and results of current condition of deforestation, a precautionary approach is applied. As such, this Indicator is designated as specified risk on industrial private land and private woodlots in Nova Scotia.”
COMMENT: The Draft RRA correctly identifies factors that result in poor tracking of net deforestation in NS. Note the Comment above under 4.1 Overview Description above:
“Nova Scotia’s (NS’s) land base is 5.5 million ha. Over 81% (4.5 million ha) are dominated by trees., p18″ ****….This is a very out-of-date figure, The 2016 State of the Forest Report gave forest cover as 75%, the more usually cited figure for NS”. The fact that several plus government foresters/researchers provided input and presumably reviewed earlier drafts of the RRA and did not correct this error illustrates, unfortunately, lack of government concern about this issue. Currently, with ongoing mine development and windmill and solar farm construction for biofuel production for export, as well as windmill construction for regional use, there are large areas of NS being deforested for industrial use, but as the RRA notes, a formal monitoring framework is lacking. In the case of one biofuel mega-project, the promoters expressed pride that they were able to keep the whole project secret for several years prior to announcing it essentially as a fait accompli. (See Guysborough Journal, Sep 18, 2024). There is also sloppy accounting by the NS Gov. of the land deforested for forestry roads on Crown lands in NS., some of which involve excessively wide clearcuts (e.g., 30 m width); further, wood removed in constructing the roads is not counted as wood harvested – See Shady Accounting and Vanishing Forests on Nova Scotia’s Crown Lands , post by Nina Newington on nsforestmatters.ca on July 14, 2024.
***2.2.2 – Health, Vitality & Other Services (-LSS) #####
“Ecosystems, their health, vitality, functions and services in the supply base shall be maintained or enhanced.
Context
“The assessment of this Indicator focuses on the maintenance of healthy and vital ecosystem functions and services. To maintain health and vital, ecosystems must maintain functions and services. Functions and services have been evaluated more specifically in other Criterion 2.2 Indicators, including:
• Maintaining productivity:
• Indicator 2.2.4 – Residue Removal Minimises Neg Impact to
Ecosystem #####
• Indicator 2.2.9 – Long-term Production Capacity #####
• Indicator 2.2.10 – Regen After Harvest #####
• Maintaining soil productivity:
• Indicator 2.2.3 – Soil Quality Maintained or Enhanced #####
• Maintaining water quality and quantity:
• Indicator 2.2.5 – Water Quality/Quantity Maintained or Enhanced #####
• Managing natural disturbances:
• Indicator 2.2.11 – Natural Processes are Managed” #####
COMMENT: See concerns related to 2.2 series indicators as identified above (#####).
***2.2.3 – Soil Quality Maintained or Enhanced (-LSS) #####
“Soil quality in the supply base shall be maintained or enhanced.
…The Nova Scotia Silviculture Guide for Ecological Matrix (SGEM) describes soil damage hazards such as rutting and compaction and impacts of forest management on soil productivity and soil health. SGEM uses an ecological classification scheme based on soil nutrient and moisture regimes with silvicultural prescriptions for ecosites related to soil productivity, hazards, and protection…On private woodlots, there are no regulatory requirements to manage or maintain soil quality…The Nova Scotia Woodlot Owners and Operators Association (NSWOOA) provides guides related to soil compaction and soil conservation from other jurisdictions, as well as links to ecosite soil descriptions, soil type, and ecological landscape analyses which have regional landscape descriptions of soils and ecosites. It is encouraged, but not mandatory, to utilise the SGEM and NSWOOA guidelines. As of March 2024, there is no publicly available information describing implementation mechanisms to manage or maintain soil quality on private woodlots.”
Rationale for Risk Designation
Crown Licence
“There is a comprehensive regulatory framework governing the management and maintenance of soil quality for Crown licence. Operational guidelines and the FOMP monitor forest management practices on Crown licence. FOMP inspection results verified Crown licensees comply with practice requirements related to soils. As a result, this Indicator is designated as low risk for Crown licence in Nova Scotia.
Industrial Private Land
Due to a lack of a regulatory framework, evidence to support implementation mechanisms, a monitoring framework and/or results of current condition of soil quality, a precautionary approach is applied. As such, this Indicator is designated as specified risk for industrial private land in Nova Scotia.
Private Woodlots
Due to a lack of a regulatory framework, evidence to support implementation mechanisms, a monitoring framework and/or results of current condition of soil quality, a precautionary approach is applied. As such, this Indicator is designated as specified risk for private woodlots in Nova Scotia.”
COMMENT: The Draft RRA correctly identifies factors that result in poor monitoring of soil quality on Industrial Private Lands and Private Woodlots. However, the assumption that all is OK on Crown lands because they are monitored etc. can be questioned in two regards:
(i) Under FULA Agreements and “Outcomes Based Management” etc. we (the public) don’t (re: the current FULA with Port Hawkesbury Paper) or won’t (re: presumably soon to be announced FULA with the WestFor group) see any results of any monitoring until some years, perhaps many, after it is conducted. Even currently the reporting on PTAs etc that once occurred in response to requests submitted via the Harvest Plan Map Viewer for WestFor lands seem to be greatly reduced and they do NOT include info. on nutrient budgeting, nor is the public being informed of such or of any followup monitoring of nutrient status of harvested sites. The major venue recommend by Lahey (2018) for public review of longer term harvesting plans for FULA agreements was to be a Forest Environmental Assessment/Forest Stewardship Guide, but while that project was developed to a certain point, it seems to now have been tacitly dropped which undermines public confidence in these agreements.
An inconvenient truth: sketch shows prominence of highly acidic, calcium-deficient/high aluminum forest soils in Nova Scotia. Sketch after Keys et al. (2016), Fig 3.
(ii) The extensive degree of acidification/base depletion of forest soils in NS over more than 50% of landscape was well documented by Kevin Keys & Co. in 2016. They came up with a scheme to adjust harvest levels in the Ecological Matrix Lands that would theoretically* avoid further base depletion and allow some recovery; and for fertilization of more intensively harvested lands assigned to the HPF (High Production Forestry) zones. We (the public) have not been informed of any follow-up monitoring of harvested sites to confirm (or not) the theoretical expectations.
* See A Nutrient-Sustainable Harvest Assessment Tool for Nova Scotia Acadian Forests
Kevin Keys & Jana Bockstette. NS Natural Resources and Renewables Biodiversity Conservation and Forestry Technical Report Series. Forestry Tech Report 2023-04 | October 2023 “Nova Scotia forest soils have been severely impacted by acidic deposition and base cation depletion to the point where mean percent base saturation levels for many dominant soil series are below 10%. Given these conditions, it is critical that nutrient budget assessments be integrated into timber harvest planning to ensure site-specific harvest removals are nutrient sustainable. … Given that forest ecosystems tend to naturally acidify over time, and that Ca2+ concentrations in base-poor soils in Nova Scotia were probably already decreasing before the accelerated losses from acidic deposition (as suggested by Leys et al., 2016), Nova Scotia forest soils will likely never return to “pre-acid rain” base cation levels without the use of remedial amendments (e.g., dolomitic lime). In addition, any natural recovery will be slow as discussed by Lawrence et al. (2015) and supported by a 20-year soil reassessment study in Kejimkujik National Park (Keys, 2018). It is therefore critical that timber harvest operations do not exacerbate the lingering impacts of acid deposition on soil base cation levels. To this end, the default %BS value for all NBM-NS calculations was set to 30%. This approach allows for some level of timber harvesting while theoretically [italics & underlining inserted] allowing soil base cation levels to gradually rebuild to more healthy levels over time.”
In fact, there is good reason to suspect that on the more acidified sites, liming would be required to “kick start” a recovery process**, i.e. that the theoretical rebuilding of soil base cations is not occurring withiytliming (selectively harvested or not), at least not on the more acidified soils.
**See Helicopter Liming to Help Restore Acidified Forest Soil Productivity
McCavour, Caitlin ; Sterling, Shannon ; Keys, Kevin ; Halfyard, Edmund
Publication date 2021/4; Journal EGU General Assembly Conference Abstracts Pages EGU21-13660
Decades of acid deposition across northeastern North America has caused excess leaching of soil base cations (Ca2+, Mg2+, K+) and increases in bioavailable aluminum (Al3+) that, in combination, have resulted in widespread decreases in potential forest productivity. Despite major reductions in SO2 and NOx emissions since the 1990s, forest soils across the region have shown few signs of recovery from acid deposition impacts and it could take decades or centuries for natural recovery to occur. As a result, affected forests are stressed, less productive, and more prone to climate change-induced damage. Helicopter liming of upland forests may be an effective way to jump-start the soil recovery process. Here we report on early results (one-year) from a helicopter liming trial in Nova Scotia, Canada where 10 tonnes/ha of dolomitic limestone was applied to approximately 8 ha of mature red spruce (Picea rubens …
If that is the case, i.e. liming is required to “kick start” a recovery process on many perhaps most of these highly acidified sites, then the current system for management of these sites within the Ecological Matrix Zone is resulting in further soil degradation.
Currently NS NRR has delineated potential HPF sites, but few if any finalized HPF sites. On at least some of these potential sites – located currently in lands identified as Ecological Matrix – harvesting is occurring now,* without fertilization (apparently, or it’s not being declared). So what is happening in such cases in regard to the subsequent use of the land (Ecological Matrix Or HPF Or Conservation) and in regard to the nutrient status of the soils? We don’t know. *
*See, for example Harvesting in citizen-proposed Nova Scotia Protected Area continued…4Nov2024
For the HPF areas, we still don’t know what sort of fertilization schemes will be applied, and their risks. There has been testing of sewage processing products as fertilizers – will such materials actually be used? We don’t know.
There are recurrent informal reports of poor forest recovery on some forest lands in NS, at least some of those in areas of severely acidified soils.
In the absence of more reporting and transparency on such matters by NS NRR, it should NOT be assumed, we suggest, that there is a LOW RISK to this indicator (“Soil quality in the supply base shall be maintained or enhanced”) on Crown lands and most specifically to those lands shown to have significant base cation deficiencies.
2.2.4 – Residue Removal Minimises Neg Impact to Ecosystem (-LLL) #####
“The removal of harvest residues and stumps shall not lead to irreversible negative impacts to the ecosystem.
Rationale for Risk Designation: There is a comprehensive regulatory framework that prohibits full-tree and whole- tree harvesting on Crown licences…Industrial Private Land, and Private Woodlots
“There is no regulatory requirements regarding the removal of harvest residues on industrial private land and private woodlots. Requirements for not negatively impacting the ecosystem are addressed in Criterion 2.1 and Criterion 2.2. Trees are delimbed and processed in-block, harvest residues are left in the forests. As such, there is no removal of harvest residues to negatively affect the ecosystem. There is no indication of systemic concerns relating to removal of harvesting residues. As such, this Indicator is designated at low risk for industrial private land and private woodlots in Nova Scotia.”
COMMENT: The contention that on industrial private land and private woodlots “harvest residues are left in the forests. As such, there is no removal of harvest residues to negatively affect the ecosystem” may not be true universally for all private lands in Nova Scotia; the common understanding is that the prohibition on whole tree removal (including stumps) is limited to Crown lands. A ban on whole tree removal on private lands was anticipated in 2013 when “Whole-tree operations in Nova Scotia harvest[ed] less than 100,000 green metric tonnes. That represents less than four per cent of the total annual provincial tree harvest”, and the bans were to be made as amendments to the the Wildlife Habitat and Watercourses Protection Regulations, but it appears that never happened.
***2.2.5 – Water Quality/Quantity Maintained or Enhanced (-LRR) #####
“Quality and quantity of ground water, surface water and water downstream shall be maintained or enhanced.
“Context: The intent of this Indicator is to maintain or enhance water quality and quantity by managing ecosystem functions and services. Maintenance of drinking water is addressed in Indicator 4.2.3 Basic Needs of Community Maintained or Enhanced. Spills and waste requirements are addressed in Indicator 2.2.8
“Potential Threats / Impacts: Forest management activities may negatively affect water resources directly and indirectly by changing ecosystem functions and services. Impacts include sedimentation, disturbance of site’s hydrology above and underground, modification of the site’s capacity to control seasonal precipitation fluctuances (i.e., flooding), spawning habitat, hinder fish’s capability to move up or downstream, water temperature, water quality (i.e., turbidity) and/or quantity, and loss of riparian habitat and function.
“Rationale for Risk Designation On Crown licence, the federal and provincial legislation related to the maintenance of water quality and quantity is comprehensive. There are operational guidelines and government programs monitor forest management practices. FOMP inspection results verified Crown licensees comply with practice requirements related to water quality/quantity. Based on the evidence reviewed, this Indicator is designated as low risk for Crown licence in Nova Scotia.
On industrial private land and private woodlots, the federal and provincial legislation related to the maintenance of water quality and quantity is comprehensive. There is no publicly available results to verify compliance with WHWPR, or the Environment Act and Activities Designation Regulations. There is insufficient evidence of guidance or monitoring results to verify current condition of water quality or quantity, a precautionary approach is applied. As such, this Indicator is designated as specified risk for industrial private land and private woodlots in Nova Scotia.”
COMMENT: Related to the soil acidification/base depletion discussed under Comments for 2.2.3 Soil Quality Maintained or Enhanced above, it’s pertinent to point out that potability of well waters is significantly adversely affected by this condition (due to high aluminum) also, the suitability of fresh waters for salmonids is severely affected. View scientific literature by Shannon Sterling & Colleagues at http://nsforestnotes.ca/current-issues/calcium-depletion/history/#sterling
In addition, many studies are emerging showing that declines in calcium under forests are having diverse adverse effects either through calcium deficiency directly or indirectly through reduced pH, aluminum mobilization and enhanced mercury toxicity e.g., on cold tolerance of red spruce, , sugar maple decline, forest salamanders and snails, loon reproduction, zooplankton, forest herbs, invertebrates and song birds. View scientific papers listed at http://nsforestnotes.ca/current-issues/calcium-depletion/history/#diverse
Thus to the extent the highly acidified/low base saturation,high aluminum soil condition is worsened by harvesting without concurrent liming of the soils over the large areas of Nova Scotia with severely acidified/base depleted soils, these areas should be regarded as at elevated risk even under Crown land management.
There are also concerns about the impacts of extensive clearcutting in NS on flooding downstream, especially given the oft-increased intensity of storms in NS in recent years and associated extreme flooding/ View Is extensive clearcutting in Nova Scotia causing excessive flooding 16Mar2022? (Post on nsforestnores.ca Mar 16, 2022). Very Pertinent: Modeling Reforestation’s Role in Climate-Proofing Watersheds from Flooding and Soil Erosion by Robert L. France et al., 2019 in American Journal of Climate Change ABSTRACT The mitigation potential of reforestation for offsetting the deleterious effects of increased flooding and soil erosion projected to occur in Atlantic Canada through future climate change was investigated. Modelling determined a strong but non-linear relationship between extent of vegetative cover and runoff volume and discharge rate for a Nova Scotian watershed, suggesting that reforestation will reduce, but not completely prevent, flooding. Predicted erosion rates were found to be progressively reduced in relation to the extent of upland reforestation. Of three scenarios examined in which 60%, 65%, and 85% of the entire watershed are randomly reforested, only the latter would reduce the elevated erosion expected to occur through climate change back to present-day existing levels. Additional modelling revealed that comparable mitigation of soil erosion can ensue through implementation of 70 m streamside buffer strips, which would only take up 19% of the total surface area. Prioritizing riparian zones for reforestation will therefore subsume less of the overall productive land area and therefore enact a less severe socio-economic impact on agriculture and forestry.
What would it take to adopt a minimum of 70 m streamside buffer strips in Nova Scotia? Amongst the recommendations of Prof Lahey (2018) that L&F/NRR have evidently not even begun to address was this:
25. The efficacy and adequacy of a 20 metre riparian zone that is only varied on the basis of slope conditions, currently required by the Wildlife Habitat and Watercourse Protection Regulations, should be independently studied with a view to determining (a) if it should be changed and (b) how it should be changed to better address the ecological rationale for riparian buffer zones.
See also conclusions 67, 68 & pp30 to 31 in the Forest Practices Review of Lahey 2018.
***2.2.7 – Pesticides & Pest Management Comply with Laws (-LRR) #####
“Potential Threats / Impacts The primary threat from the use of chemicals in forest management is the possible adverse effects on the health of humans, wildlife, and fisheries. If misused or inadequately monitored, chemical use can also lead to loss of insect and plant biodiversity.
“Results…Only chemicals registered by the federal government
may be used in NS. Crown Licence As published in the High Production Forestry in Nova Scotia Phase 2 Guidance
for Implementation, pesticide use as a forest management tool on Crown licence has not been used since 2010.
Industrial Private Land and Private Woodlots Annual approvals of pesticide application for industrial private land and private woodlots are available on the DECC website. However, as of March 2024, there is no publicly available reporting on pesticide application, monitoring, enforcement or results of current condition of pesticide use for industrial private
land and private woodlots.
“Rationale for Risk Designation Crown Licence: Pesticide use has not been used as a forest management tool on Crown licence in NS since 2010. As a result, this Indicator is designated as low risk for Crown licence in Nova Scotia.
Industrial Private Land and Private Woodlots:There is publicly available information regarding all approved pesticide applications on the DECC website, but there is no publicly available reporting on monitoring or enforcement of pesticide use. As a result, a precautionary approach is applied and this Indicator is designated as specified risk for industrial private land and private woodlots in Nova Scotia.”
COMMENT: Factual Update re: use of herbicides on Crown lands. Herbicide use will be permitted and may even be encouraged/required in the HPF zones of the Triad on Crown lands, hence the risk should be a Specified Risk as it is for private lands.
Herbicide use in forestry in NS is especially controversial because most of our managed forests are in moderately settled watershed (unlike in most other provinces where much of the Crown land is in very remote areas). There have been repeated complaints about poor notification of herbicide spraying, particularly in relation to berry picking, most of which occurs in the same fall period in which most herbicide spraying is conducted.
To date, but possibly not ongoing, herbicides are NOT used on Port Hawkesbury Paper managed Crown lands under their FULA as they hold FSC certification for these lands, re the FSC pesticides policy:
In the short-term, FSC aims to:
- Eliminate the use of the most hazardous chemical pesticides;
- Promote best practices to minimize associated risks to human health and the environment when using chemical pesticides; and
- Reduce the overall volume and number of chemical pesticides in use.
In the long-term, FSC aims to eliminate the use of chemical pesticides in FSC-certified forests.
The fact that forestry operations on such a large area of Crown lands in NS are managed without herbicides, apparently successfully, supports arguments for simply banning use of herbicides in forestry operation in NS. Rightly or wrongly there is concern that NS NRR may in future require PHP to use herbicides on their HPF sites – NRR needs to clarify their position in this regard.
2.2.9 Long-Term Production Capacity, page 124 ff (-LLL) #####
“Context: The assessment of this Indicator considers whether long-term sustainable harvest levels have been determined using appropriate information and assumptions and whether actual harvests are below these levels.
Potential Threats / Impacts: Timber harvesting that exceeds the long-term sustainable harvest level of the forest is unsustainable and will erode the productivity of the forest, ecosystem services and the timber supply it produces.”
“Results: Provincial: The most recent publicly available NS sustainable wood supply estimate was provided in the 2016 State of the Forest Report, which reported a potential short- term harvest level for 2016 to 2018 based on the Crown Lands Forest Model.
The 2016 State of the Forest Report estimated the potential annual provincial softwood supply was 4.15 million m3, of which 1.3 million m3 was from Crown land and 2.85 million m3 was from the combination of industrial private land and private woodlots. The potential annual provincial hardwood supply was 1.59 million m3, with 410,000 m3 from Crown land and 1.18 million m3 from industrial private land and private woodlots combined.”
[State of the Forest 2016 (https://novascotia.ca/natr/forestry/reports/state_of_the_forest_2016.pdf)] See page 81 for stats above.]
….Crown Licence
“On Crown licence, the Registry of Buyers of Primary Forest Products, 2022 Calendar Year Report shows the actual annual Crown harvest volume has remained relatively steady between 2005 and 2022, fluctuating from 500,000 to 750,000 m3. In 2022, the softwood harvest was 529,000 m3, representing 40% of the sustainable Crown softwood supply. The 2022 actual Crown hardwood harvest was 79,000 m3, representing 19% of the sustainable Crown hardwood supply.”
“….Rationale for Risk Designation: The provincial harvest levels in NS have declined during the past 20 years and are well below the potential supply. The total actual harvest levels from Crown land, industrial private and private woodlots were well below the sustainable wood supply volumes available on each ownership. Based on the evidence reviewed, this Indicator is designated as low risk for Crown licence, industrial private land, and private woodlots.”
COMMENT In contrast to the rankings assigned, we suggest there is abundant reason to assign Specified Risk to all 3 land groups. The major issues: the figures for potential annual softwood and hardwood supply were produced in 2016,
– before the Forest Practices Review (2018),
– before exotic pests began to ravage Eastern Hemlock, American Ash and American Beech,
– before the onset of extreme climate changes which have caused record-breaking fires and floods and blowdown,
– before broad recognition globally and locally of the need to manage our forests better to sequester carbon and reverse biodiversity loss,
– and perhaps most notably, before the government made a legal commitment to “20% Protection by 2030” (re: Environmental Goals and Climate Change Reduction Act, 2021)
In regard to the last mentioned, as of Dec 2023, 13.45% of the area of land+water in Nova Scotia was protected/conserved, leaving 6.55% to be added, a major portion of which will of necessity have to come from Crown lands. Some rough calculations on how much that could affect the area of working forest on Crown lands:
The total Land+Inland Water Area of NS is 5,525,o14 ha. 6.55% (20%-13.45%) of that area is 361,888 ha. If 80% were to come from Crown lands (& 20% by purchase of &/or Conservation Easements on, Private lands) that would be 289,510 ha.
It’s concerning that the host of reviewers of the RRA to this point did not, apparently, raise any of these concerns.
The new NS Government of 2021 moved quickly to ‘implement Lahey’ on Crown lands in the form of the TRIAD, which is laudable except that:
(i) NS is the largest experiment in TRIAD forestry yet, i.e. we are on the leading edge, not applying a tested, tried and true system of forest management; and
(ii) the NS Government – or more specifically the NS DNRR (Nova Scotia Department of Natural resources and Renewables) – has moved quickly to implement aspects that cater to ‘Big Forestry’ interests (re assignment of potential HPF areas, new roads, harvesting in the Ecological Matrix) but much more slowly on the aspects – most notably identification of lands for protection to meet 20% by 2030) – that cater to a large constituency that sought a better balance between Big Forestry interests and the many non-fibre values of NS forests. That is in direct conflict with adage of Lahey:
“In other words, I have concluded that protecting ecosystems and biodiversity should not be balanced against other objectives and values as if they were of equal weight or importance to those other objectives or values. Instead, protecting and enhancing ecosystems should be the objective (the outcome) of how we balance environmental, social, and economic objectives and values in practising forestry in Nova Scotia.” – William Lahey, Aug 2018
The result has been an undermining of the trust and good will that was created initially by the Lahey report, and seemingly a rush to assign as much of the forested land as possible to Industrial Forestry and other industrial interests (mining, biofuel for export etc) before such actions could be reversed (e.g. view
Dreams of producing biofuel from Nova Scotia forests just got very big 14Sep2024, post on nsforestmatters.ca).
2.2.10 – Regen After Harvest page 128 ff (-LLL) #####
“Context : To ensure future forests, regeneration with natural or planted seedlings following harvest must be prompt and adequate. Sufficiency is a measure of species selection, seedling distribution, and time of establishment. Species selection needs to be consistent with site ecology (i.e., original stand composition, ecosite, and natural disturbance) and considerate of future climate change risks. Distribution must be sufficient to allow future crop trees to occupy the site in a free-growing state, and timing needs to be prompt enough to allow early establishment unhindered from competing vegetation….
“Evidence Reviewed
-
-
- Association for Sustainable Forestry
- Crown Lands Act
- DNRR FOMP Inspection Data 2017-2023
- DNRR The Registry of Buyers
- Ecological Landscape Analysis by Ecodistrict – 2023
- Forest Sustainability Regulation
- Forests Act
- Nova Scotia Silvicultural Guide for the Ecological Matrix
- Nova Scotia Woodlot Owners & Operators Association
- Nova Scotia’s Code of Forest Practice: A Framework for theImplementation of Sustainable Forest Management (2012)
- Registry of Buyers of Primary Forest Products Report – 2023
- Registry of Buyers of Primary Forest Products Report – 2022
- Registry of Buyers of Primary Forest Products Report – 2021″
-
COMMENT: Conifers remain the focus of replanting & plantation forestry even though there is abundant evidence that some species, e.g. balsam fir, can be expected to be strongly adversely affected by warming and that may even be occurring now.* We should be looking seriously at Assisted Migration to diversify our forests and “pre-adapt” to climate warming. Some species that might be appropriate, e.g.Bur Oak, have already been introduced horticulturally. *See Investigating climate anomalies associated with the sudden mortality of balsam fir trees in eastern Canada, by Broom et al., 20234 in Frontiers in Forests and Global Climate Change. “Our study highlights this vulnerability of balsam fir with both drought and warm spring conditions predicted to increase under future warming scenarios (Albert et al., 2023). Forest stakeholders should use this information to support the diversification away from balsam fir (as part of climate-focused forest management).”
2.2.11 – Natural Processes are Managed (-LLL) #####
“The impacts of natural processes such as fires, pests and diseases shall be managed.
Context:Wildfires, pests, diseases, and windthrow are natural disturbance events that shape the ecological attributes of all forests. These events can be small events such as single tree deaths, but most often are stand modifying or replacing events and work to create a persistent landscape pattern related to the dominant disturbance type.
Disturbance is essential to forest health and regeneration, although it can pose challenges to tenure holders and communities. Insect damage and windthrow are the primary sources of natural disturbance and cause more temporary forest loss than timber harvesting. Aspects of healthy and vital ecosystem services are addressed in Indicator 2.2.2 Health, Vitality & Other Services.
Localised timber diseases are left untreated as they tend to be small, are difficult to control, and generate a variety of key ecological attributes for sustaining biodiversity. Similarly, for wildfires, not all fires need to or should be suppressed. Extensive fire suppression can lead to the build-up of fine fuels, increasing the risk of large-scale fires
“Potential Threats / Impacts: Inappropriate management of impact from natural disturbances can lead to:
• Loss or long-term alteration of forest ecosystems;…
“Oversight Framework:Pests and Diseases
For Crown licence, private land, and private woodlots, DNRR also provides regular provincial aerial and ground plot monitoring and assessment of eight major forest pests on all tenures….On all tenures, DNRR provides forest fire weather forecasts and real time conditions of fire weather index…Windthrow On Crown licence, industrial private land, and private woodlots, windthrow is monitored annually with aerial surveys and satellite imagery following major wind events or hurricane tracks. The SGEM provides windthrow hazard rating for wind prone sites and windthrow conditions. SGEM provides harvest recommendations for salvage only after major wind events…
Results The most current regular monitoring on the eight major forest pests was for 2016. In that year, only two of eight pests showed an increase over the previous year, most prominent being eastern spruce budworm up 68% from 2015. No major forest diseases requiring treatment were reported.
Rationale for Risk Designation: There is a comprehensive regulatory framework to assess, respond, and manage natural disturbances such as pests, disease, wildfire, and windthrow…”
COMMENT: Some of the info cited is well out of date, e.g. “No major forest diseases requiring treatment were reported” is based on formal reporting in 2016. Since then we have had major outbreak of Hemlock Wooly Adelgid; hemlock is a keystone species in many of our forests; also Beech leaf-mining weevil (on American Beech) and Emerald Ash Borer (on Ash trees). The province has been slow to restrict firewood movement between areas heavily impacted by HWA and those not, and new outbreaks have occurred in campgrounds. We have had major blowdowns from hurricanes; the government and forest industry have been quick to conduct salvage harvesting when a more cautionary and more site-specific approach would be more appropriate because of the negative impacts of salvage harvesting, especially on the more nutrient depleted soils. In the spring of 2023 we had the largest fires on record, both set, but also occurring in areas where there was predominance of conifers reflecting past forestry practices, a factor that appears not to have been acknowledged or otherwise objectively investigated. There is pressure from Forest NS to allow thinning in Protected Areas on the assumption it would reduce fire hazard, but even if true (benefits of thinning for fire hazard reduction vary with forest types, stand age etc) at the same time it would increase flooding hazard, possibly a more serious threat in NS (related to our warming sea waters). The government needs to look at these issues openly and objectively both for public confidence and to ensure we manage our forests for the greatest possible benefits to all of us.
3.1.1 – LULUCF – A, B, or C (L—) #####
“LULUCF emissions shall be accounted for through one of the following routes:
Feedstocks may be sourced from a country of origin which is party to the Paris Agreement,…
Feedstocks may be sourced from a country of origin which is party to the Paris Agreement and has national or sub-national laws in place…
Feedstocks may be sourced from a supply base where an assessment demonstrates that both the carbon stocks is stable, and the forests’ capacity to act as a carbon sink is stable or increasing over the long term
Scale of Assessment: Provincial
Results: This Indicator provides three routes for compliance. Route A is applicable to Canada and, by extension, to Nova Scotia. Canada is a signatory to the Paris Agreement and provided its NDC in July 2021.
Rationale for Risk Designation: LULUCF emissions are accounted for through Route A and have been met at the national level by Canada. Based on evidence reviewed, this Indicator is designated as low risk for Nova Scotia.
Means of Verification: Paris Agreement signatory
• Nationally Determined Contributions for reduced GHG emissions targets
and progress reports”
COMMENT: Whether or not Canada is properly accounting for its forestry-related carbon emissions is hotly debated. It’s pretty clear that the emissions associated with forestry per se are masked to large extent by including a lot of non-harvested forest areas, e.g. protected areas, in the bucket of “managed forests”. Both our federal and governments need to look at these issues openly and objectively both for public confidence and to ensure we manage our forests for the greatest possible benefits to all of us.
3.2.1 – Forest Carbon Stocks Stable or Increasing (L—) #####
“All feedstock sourcing shall be consistent with either of these two options:
Option A. Feedstock may be sourced from supply bases where an assessment of the supply base shows that the forest carbon stocks are stable or increasing, or
Option B. Feedstock may be sourced, if the assessment shows that the forest carbon stocks are declining in the supply base, provided that the decline is due to natural processes (fire, pests, etc.) and sourcing of feedstock has the aim to recover feedstock otherwise lost or assist regeneration.
“Scale of Assessment: Provincial
Potential Threats / Impacts: Forests experiencing declining forest carbon stocks are net emitters of greenhouse gases (GHG) and are contributing to climate change.
Regulatory Framework In Nova Scotia (NS), there are no specific regulatory requirements that forests must be managed to maintain or increase carbon stocks.
Oversight Framework NRCan, in partnership with DNRR, provides oversight and monitors forest carbon stocks, GHG emissions, and other fluxes.
Results Specific to NS, the Net Ecosystem Productivity metric in the Carbon Budget Model is the sum of all carbon increments in a year less losses due to litterfall, biomass turnover, disturbances, harvesting, and decomposition. Between 2017 and 2021, the annual values of Net Ecosystem Productivity were positive indicating the forest accumulated carbon. DNRR’s network of permanent sample plots results show a 10% increase in forest carbon between 2012 and 2016, and 2017 and 2021….Both carbon analyses show the forest carbon stock has been stable to increasing from 2012 to 2021.”
COMMENT: Re: “Both the NRCAN and DNRR data showed the combined impacts of timber harvesting and disturbances have been equal to or below the level of growth, resulting in stable to increasing forest carbon stocks.” We need to be careful about concluding from such results that all is OK carbon-wise in our forests. Look at the chart below from the State of the Forest Report for 2016 – a lot of the increase in recent years is likely associated with ongoing soil recovery from excessive harvesting in earlier years; this has implications for the “sustainable harvest carbon-wise” -i t’s likely well below the 5.7 million cubic meters per annum commonly cited as the Sustainable Harvest Level for Nova Scotia.
From the 2016 NS State of the Forest Report
Also pertinent: M.G. Betts et al., 2024. “Congruent Long-Term Declines in Carbon and Biodiversity Are a Signature of Forest Degradation”Global Change Biology Oct 30, 2024. https://doi.org/10.1111/gcb.17541 “According to our forest-inventory plot-derived model, above-ground biomass in NB forests has declined by a total 246 Tg CO2e, which is 141 Tg CO2e (4.02 Tg year−1) [over a 35 year period, 1985 to 2020] after accounting for lifecycle carbon. This is equivalent to 32% of the province’s total annual emissions (12.4 Tg in 2020), and greater than all annual oil and gas emissions combined (3.3 Tg year−1) (Government of Canada 2023)…Although our results might have been predictable given the relatively high harvest rates and short harvest rotations in NB forests (typically about 50 years) they stand in contrast to most predictions in the literature about the carbon storage role of managed forests” It seems pretty likely that the more intensively harvested lands in NS are likewise losing carbon.
To its credit, NS NRR now has a PhD level ‘Carbon modeller’ (James Steenberg) on staff, he has has been very active and recently produced a “Nova Scotia Forest Carbon Calculator” (NSFCC). Say Steenberg and O’Keefe, authors of Nova Scotia Forest CarbonCalculator (NSFCC): Overview,Methodology, and Application, (NS NRR, March 2024): “It is hoped that the different NSFCC features make it useful to a variety of forest managers and stakeholders with differing needs. A particular need has been identified among woodland owners to better understand and manage their forest carbon and ideally access carbon markets, with which NSFCC might bring some utility. A necessary starting point for mitigation action in forestry is building carbon literacy and quantitative tools like NSFCC to enable a variety of forest stakeholders to estimate and model their forest carbon.” For that sort of thing happen, the department/NS government need to give their scientists much more of a free hand to interact with academics and the public more broadly than they do currently.
***3.2.2 – No Primary Feedstock from Low Site Productivity/Difficult Regen (-LRR) #####
“Primary feedstock shall not be sourced from forest areas where site productivity is low and according to local definitions or norms, the areas are classified as low-productive or difficult to regenerate.
Context: Primary feedstock is fibre delivered directly from the forest to a wood pellet facility. Typically, this includes low-grade roundwood, logging slash, and ground or chipped material…The Indicator is intended to ensure primary feedstock is not sourced from the least productive forest sites, which usually support slow-growing forests.
In Nova Scotia (NS), such sites could include rocky maritime coasts, forests with thin, wet or poor soils or with other limiting site characteristics that inhibit tree growth. Many such forests would be considered inoperable and would not be part of the forest that contributes to the long-term sustainable harvest levels. See Indicator 2.2.9 – Long-Term Production Capacity, for more details on long-term production capacity.
Potential Threats / Impacts: Harvesting from slow-growing forests result in an extended time before the renewed stand accumulates sufficient carbon stocks to replace those removed. Similarly, harvesting from forests that are difficult to regenerate results in uncertain renewal prospects and therefore uncertain future carbon stocks.
“Regulatory Framework
Crown Licence
– Crown Lands Act (CLA)
– Forests Act
Industrial Private Land & Private Woodlots
There is no regulatory framework to prevent harvesting sites with low productivity or difficult to regenerate on industrial private land.
Implementation Mechanisms
Crown Licence
The Nova Scotia (NS) Department of Natural Resources and Renewables (DNRR) has authority to administer the Crown Lands Act (CLA) and the Forests Act. The CLA provides the regulatory framework for long-term sustainable harvest levels, which includes identification of low productive sites and requirements for post-harvest regeneration on Crown Licence.
The Nova Scotia Silvicultural Guide to the Ecological Matrix (SGEM), prepared by DNRR, provides direction on acceptable management prescriptions for each forest type on Crown land. Crown licensees’ management prescriptions, including those with a Forest Management Plan (FMP) (i.e., Forest Utilization Licence Agreement areas) must conform to the SGEM.
DNRR’s allowable prescriptions are set based on the ecosite type. Several ecosites of low productivity/difficult to renew are not allowed to be harvested, as enforced by DNRR. Sites of low productivity are correlated with sites that have renewal challenges. Nova Scotia’s Code of Forest Practice and SGEM provide guidelines for reforestation planning and implementation.
Licensees prepare FMPs and site plans accounting for sites of low productivity and difficult to regenerate.
‘Rationale for Risk Designation:
Crown Licence
There is a comprehensive regulatory framework governing the determination of long-term sustainable harvest levels. Government legislation and guidance demonstrates long-term sustainable harvest levels are calculated based on applicable inventory and growth data, excluding low-productivity sites. Low- productivity sites are removed from by DNRR at the approval stage. DNRR inspection of renewal verify compliance. Based on evidence reviewed, this Indicator is designated as low risk for Crown land in Nova Scotia.
Industrial Private Land and Private Woodlots
Due to a lack of a regulatory framework, evidence to support implementation mechanisms…a precautionary approach is applied. As such, this Indicator is designated as specified risk for private woodlots in Nova Scotia.
Evidence Reviewed: Provincial Nova Scotia Silvicultural Guide for the Ecological Matrix”
COMMENT: Concerns expressed in relation to 2.2.3 – Soil Quality Maintained or Enhanced (above) apply to this indicator as well.
****3.2.3 – No Primary Feedstock from HCS/HCV (-RRR) #####
“Primary feedstock shall not be sourced from forest areas in the supply base which according to local definitions or norms, are classified as having combined attributes of high carbon stocks and high conservation value (HCV).
Context: SBP’s Standard 1 Guidance document indicates “high carbon stock forests as forests that have significant amounts of carbon stored in their above-ground biomass, belowground biomass, and soil. The exact threshold for what constitutes a high carbon stock forest will vary depending on the context. Forests that stand at the top 10% of the volume per ha in the region, with adjustment to reflect normal range for species or mix, would normally be considered ‘high carbon’ and warrant further examination and justification.”
Potential Threats / Impacts
Sourcing primary feedstock from forests with the combined attributes of high carbon stocks and high conservation values (as defined above) will reduce the carbon stocks and conservation values present. As well, the forest that regrows is unlikely to reach the same levels of carbon stocks, leading to a net emission of carbon into the atmosphere when these stands are harvested.”…
“As there is no regulatory framework, provincial policy or planning direction specific to high carbon stock forests, there is no publicly available information describing the implementation mechanisms for the management of high carbon stocks on Crown licence, industrial private land and private woodlots.
…As of March 2024, there is no publicly available results to verify that harvesting of primary feedstock is not sourced from forests that have combined attributes of high levels of carbon stocks and high conservation values on Crown licence, industrial private land and private woodlots.
‘Rationale for Risk Designation
Crown Licence, Industrial Private Land & Private Woodlots
The federal and provincial regulatory framework governing the management and maintenance of biodiversity values is extensive (Details provided in Indicator 2.1.3 Key Eco/HCV Maintained or Enhanced). There is no regulatory framework specific to the management of high carbon stocks.
A specified risk designation was applied to Indicator 2.1.3 Key Eco/HCV Maintained or Enhanced for Crown licence, industrial private land and private woodlots. Additionally, there is a lack of evidence to support implementation. mechanisms, an oversight/monitoring framework, and/or results to verify the identification and the subsequent avoidance of harvesting of primary feedstock from forests that have combined attributes of high carbon stocks and high conservation values on Crown licence, industrial private land and private woodlots. Given the lack of evidence, a precautionary approach is applied. As such, this Indicator is designated as specified risk for Crown licence, industrial private land and private woodlots in Nova Scotia.”
COMMENT: We are pleased to see that the reservations cited above apply to Crown as well as to private lands, re: “As there is no regulatory framework, provincial policy or planning direction specific to high carbon stock forests, there is no publicly available information describing the implementation mechanisms for the management of high carbon stocks on Crown licence, industrial private land and private woodlots.” There is additional reason to be concerned that even on Crown lands, harvests are being taken from areas “having combined attributes of high carbon stocks and high conservation value”, via “Highgrading at the Landscape Level” on lands in the Ecological Matrix*, facilitated at this point by slow movement of the NS Government to identify forested areas on Crown lands that will ultimately be protected.**
*See “Forest degradation in Nova Scotia: Highgrading at the Landscape Level” at http://nsforestnotes.ca/consultations/comment/on-reversing-forest-degradation-in-nova-scotia/#highgrade
**See Open letter to Nova Scotia Premier Houston requesting cessation of logging in areas that are prime candidates for protection 17Oct2024 at https://nsforestmatters.ca/open-letter-to-nova-scotia-premier-houston-requesting-cessation-of-logging-in-areas-that-are-prime-candidates-for-protection-17oct2024.
3.3.1 – Principles of Cascading Use (L—) #####
“Feedstock sourcing shall be in compliance with the principles of cascading use, high quality stem wood shall not be used as feedstock if it’s in substantial demand for long lived products in the supply base.
Context: Under the European Union Renewable Energy Directive 2018/2001 (REDII), considers long-term to be at least 30 years (Navigant Netherlands et al 2021). The Intergovernmental Panel on Climate Change (IPCC) Good Practice Guidance for Land Use Land Use Change and Forests (2003) provides default half-lives for forest products: sawnwood (i.e., lumber) is 35 years, and for veneer, plywood and structural panels it is 30 years. Non-structural panels have a half- life of 20 years.
Using these data as a basis for describing how to assess this Indicator suggests that long-lived forest products include veneer, lumber, plywood, and other structural panels. Long-lived forest products store carbon and can keep it out of the atmosphere for extended periods of time. In this context, high-quality stem wood includes sawlogs, veneer bolts, and logs that are suitable for oriented strand board production.
When processing natural resources, the highest quality raw material is typically used to produce the highest quality products, which are usually a higher value. High-quality raw material could also be used to produce lower-valued products whereas a low-valued raw material cannot produce a high-valued product.
“Potential Threats / ImpactsIf feedstock procurement is diverting high-quality stem wood away from the production of long-lived forest products, it will be contributing to GHG emissions. It may also negatively affect the viability of the mills that produce long-lived forest products.
Regulatory FrameworkIn Nova Scotia, there are no specific regulatory requirements that stem wood, or timber in general, must go to its highest and best end-use, or preferentially towards the production of long-lived forest products.*****
Implementation Mechanisms
Nova Scotia’s forest products industry is highly integrated. Under all licence types, the licence holders have rights to harvest timber. Primary licensee will typically use part of the timber allocation for its mills and then sell or trade the remaining components of the harvest to other forest products companies…Integrated forest products companies are highly incentivised by the profit motive to use sawlogs (i.e., high-quality stem wood) for lumber/stud production. Similarly, harvest contractors have incentive to maximise the revenue received for the timber harvested and are highly motivated to ensure that sawlogs go to sawmills, which pay the highest price for wood and have quality specifications that preclude the use of pulpwood and other low-grade stem wood.
Oversight Framework: There is no oversight framework in place specific to the principles of cascading as there are no relevant requirements or policies.
…
“Rationale for Risk Designation
Stumpage price data indicate high-value stem wood is worth much more than low-value stem wood, and this price differential drives forest product cascading. The evidence indicates that market drivers are in place to induce high-quality stem wood to be sent to its highest valued use, which is associated with long- lived forest products.
The pellet facilities in Nova Scotia are largely dependent on residues produced by sawmills. This sourcing pattern, as well as the harvest data presented above, is consistent with the principles of product cascading. Based on the evidence reviewed, this Indicator is designated as low risk at the provincial level for Nova Scotia.”
COMMENTs:
Comment: 1. There was a case in 2018 when high quality Old Growth hardwoods managed by Port Hawkesbury Paper under a FULA were going to a biomass boiler, confirmed by subsequent gov. investigations. The alarm was raised by a forester. He commented in an interview when asked ” If this forest was managed the way you would want to manage it, how would it be different, what would you do?”, he replied “It would be based upon achieving the highest end value of the product coming out and the harvest would be minimal. It would be cut at about 10-12 trees per acre. The trees that come out would be cut for high end products such as veneer logs saw logs and the balance for fuel wood. There would be a very low impact with about 80% of the canopy left, some light would come in which would encourage regeneration of the tolerant species. View Danny George rings the alarm bell (again) on Loon Lake Nova Scotia clearcuts of Old Growth at http://nsforestnotes.ca/2018/02/23/danny-george-rings-the-alarm-bell-again-on-loon-lake-nova-scotia-clearcuts-of-old-growth/ These cuts occurred even though PHP operated under a Crown licence and was FSC certified. While steps were taken subsequently to better monitor such situations, it’s not clear that there are enough people on the ground to avoid them ” GF: I worked for lands and forest from 1977 to 1988. We had 14 technicians in the area . Now I think there are 3 to cover the same ground . What needs to be done is the premier needs to cancel the grants and put people back on the ground.” – Forester’s comment, see DNR confirms Loon Lake area cuts included Old Growth at http://nsforestnotes.ca/2018/05/17/dnr-confirms-loon-lake-area-cuts-included-old-growth/
2. There is ongoing controversy, somewhat ‘below the radar’, over harvesting of older Sugar Maple trees or stands on some Crown lands in NS when the same trees are sought by maple syrup producers, a use that would likely be more valuable over the long term AND retain the old forest qualities of these stands that are important for biodiversity conservation and carbon sequestration. (A contact person in the maple syrup business can be provided if requested.)
3. In Nova Scotia we have something less than 0.5% Old Growth, and overall our forest biodiversity has declined significantly because of loss of “Old Forest” including Old Growth*, thus conservation of Old Forest (80 yrs +) in NS is seen by many in the conservation community as critical to reverse losses in biodiversity and likely also to increase carbon sequestration. In this regard, the use of smaller diameter trees (8-12″ dbh) in sawmills combined with mass timber techniques to simulate or even improve upon the structural qualities of larger, older trees should or could allow us to conserve Old Forest trees with little impact on wood supply for sawmills.
* Forest degradation drives widespread avian habitat and population declines
by Matthew G. Betts et all, 2022 in Nature Ecology & Evolution.https://www.nature.com/articles/s41559-022-01737-8
***4.2.1 – Negative Social & Community Impact ID & Avoided (-LRR) #####
“Negative social and community impacts shall be identified and avoided.
Context: The intent of this Indicator is to promote sustainable and responsible practices that benefit individuals and communities.
Sustainable forestry practices must take into account the needs and rights of local communities, protect ecosystems and biodiversity, and support local livelihoods and economies. Elements of this Indicator are discussed and assessed in the following Indicators:
• Biodiversity, ecosystem productivity and function are described across Criterion 2.1 and 2.2;
…
• Contributions to the local economy are described in Indicator 4.2.2 Positive Contribution to Local Community;
“..The focus of this Indicator is to ensure that the identification and avoidance of negative social and community impacts are incorporated into forest management planning through a consultation process with stakeholders who may be impacted.
Potential Threats / Impacts
Negative impacts to communities may occur if sustainable and responsible forestry management are not conducted, including loss of tenure and use rights, loss of access to areas with cultural, social, heritage, and economic values used by communities, loss of employment and economic opportunities, health and welfare impacts on communities, and loss of adequate access for recreation.
Regulatory Framework
Crown Licence
• Crown Lands Act
• Forests Act
Industrial Private Land and Private Woodlots
On industrial private forest land and private woodlots, there is no regulatory framework that requires the identification and avoidance of negative social and community impacts.
Oversight Framework
Crown Licence
DNRR is responsible for reviewing and approving FMPs, Annual Operating Plans (AOPs), and harvest plans. Public comments from the Harvest Plan Map Viewer are provided to the Crown licensee and DNRR.”
COMMENT: Re: “…The focus of this Indicator is to ensure that the identification and avoidance of negative social and community impacts are incorporated into forest management planning through a consultation process with stakeholders who may be impacted.” In Nova Scotia, since 2008 we have been through two major reviews of forests and forestry that involved a lot of public consultation: the Natural Resources Strategy (NRS) of 2008-2011; and the the Forest Practices Review, aka the “Lahey Report” of 2017-2018. Significant recommendations that were made by the Steering Panel in the NRS process, notably to (i) Require management plans prior to cutting on all public and private lands and (ii) Allow clear-cutting by permit only were vigorously opposed by the forest industry, the government finally did not go forward with them, and thereafter more regulation on private lands in NS essentially became a taboo*
*Illustrated further by successful forest industry opposition in 2019 to components of a new Biodiversity Act that would apply to private as well as Crown lands. See Big Forestry versus the Nova Scotia Biodiversity Act, round II, post on nsforestnotes.ca Mar 16, 2021
Public concerns about forest harvesting including for biomass as well as concerns of some woodlot operators over the assignment of Crown land harvests to larger entities led to the second review in 2017-2018. Central to the Lahey recommendations was one to adopt a Forest Triad model for Crown lands; it would entail assigning forested Crown lands to 3 zones: 1 Conservation (Protected Areas), 2 High Production Forestry (HPF) on no more than 10% of the Crown lands, and most to 3 Ecological Matrix in which Ecological Forestry would be practiced.* A basic tenet of this system is that by intensifying forest production in the HPF zone, less forested land needs to be harvested to meet production levels previously achieved, and they might even be increased. The TRIAD was touted and, finally, widely accepted as a compromise between the interests of the Forest Industry writ large and the interests of the more ecologically oriented woodlot owners and the public at large. A controversial issue from the get-go was whether sustainable harvest levels would dip for a period while new ecological methodologies were developed, and as the results of more intensive production in the HPF zone could be realized. The review panel, which included the two authors/founders of Triad Forestry (Robert Seymour and Malcolm Hunter) predicted there would be a transition period in which there would be a reduction of Crown land wood supply of 10 to 20 per cent**, however Iain Rankin (Minister of the Department of Lands & Forestry) disagreed, insisting that “We believe that we can sustainably grow this industry”.*** The evidence for that assertion, if it exists, has never been shared with the public.
*See Perspectives: Thirty years of triad forestry, a critical clarification of theory and recommendations for implementation and testing
Austin Himes et al., 2022 in Forest Ecology and Management at https://www.sciencedirect.com/science/article/pii/S0378112722000974#b0360 Section 4.4 4.4. Nova Scotia case study
**Lahey Report, 2018, item 64 page 29, item 85 page 36.https://novascotia.ca/natr/forestry/Forest_Review/Lahey_FP_Review_Report_ExecSummary.pdf
***Comments by Iain Rankin quoted on CBC News dec 3, 2018 Nova Scotia vows to reduce clear cutting, move toward ‘ecological forestry’ by Michael Gorman at https://www.cbc.ca/news/canada/nova-scotia/lands-and-forestry-clear-cutting-lahey-iain-rankin-1.4929953
The Liberal government of the day moved slowly to implement the Lahey Recommendations. In 2021, a new government was elected and took office under Premier Tim Houston (a PC). In its widely lauded Environmental Goals and Climate Change Reduction Act passed early on the new gov. made these major commitments related to forests and forestry:
From the text of the Environmental Goals and
Climate Change Reduction Act (2021)
At the end of 2024, there has been limited progress in regard to (a), and essentially no collaboration with the public in regard to (b). In regard to (c), the government announced in early 2023 that “The Province has dedicated a high production forest zone, completing its triad model of ecological forestry”, however they have yet to implement and appear to have tacitly dropped, a key component of public participation, the Forest Environmental Assessment; also the related Forest Stewardship Guide which would guide long term planning has not yet emerged. In regard to (d), the government/DNRR have identified all of the potential sites for HPF, but have done so while they have not yet identified which forested lands now in the Ecological Matrix will be the added to the Conservation Zone and are already proceeding with harvests in areas of citizen-proposed Protected Areas. The general lack of public consultation, lack of response to expressed concerns and lack of transparency in decision-making that has characterized the NS Department of Natural Resources and Renewables in the last 2 years has created a lot of public mistrust in Crown land forest management, and a loss of much of the good will garnered initially by the Lahey Report. There is a perception that the forest industry but not the public at large has the ear of this government on forestry matters, not helped by the Premier Tim Houston’s appointment on Aug 9, 2024 of Stephen Moore as Communications Director for the Premier’s Office – Moore who had no background in forestry had previously been Executive Director of Forest Nova Scotia where he advanced poorly documented claims about the benefits of forestry practices criticized by “Environmental Activists”.
4.2.2 – Positive Contribution to Local Economy (L—) #####
“Feedstock sourcing shall positively contribute to the local economy, including employment.
Results: The Forestry Economic Task Force, commissioned Gardner Pinfold to conduct a study Economic Impacts of the Forestry Sector in Nova Scotia. The report was published in 2023 with data from 2022.
In 2022, there were approximately 6,414 full-time equivalent jobs across NS (2,694 direct, 2,672 indirect, 1,048 induced). In 2022, 880 jobs were in the forestry and logging and support subsectors (0 direct, 736 indirect, 144 induced). 3,874 full-time equivalent jobs were in the wood product manufacturing subsector, which includes wood pellet mills (1,886 direct, 1,355 indirect, 633 induced). 1,660 jobs were in the paper manufacturing subsector (808 direct, 581 indirect, 271 induced)….
Rationale for Risk Designation
There is a highly integrated forest products industry in Nova Scotia. Biomass- related activities contribute to the local economies for outputs, GDP, employment, and capital investment. Based on evidence reviewed, this Indicator is designated as low risk at the provincial level in Nova Scotia.
Evidence Reviewed
Other
● Economic Impacts of the Forest Sector in Nova Scotia, Gardner Pinfold, 2023
● Wood Pellet Location Map, Wood Pellet Association of Canada”
COMMENT: A major issue, a problem with the indicator, and with the evidence provided – mainly the Gardner Pinfold study on the Economic Impacts of the Forestry Sector in Nova Scotia – is that neither take into consideration (a) the many direct non-fibre economic benefits of forests such as fishing, hunting, tourism, food gathering etc., and (b) the “Ecological Services” of intact forests that are “free” until we have to pay replace them; and the impacts of the forest harvest level on those economic benefits and services. Looked at alone, there are definitely economic benefits from “Feedstock sourcing”, but this question needs to be addressed: Is or could the level of feedstock supply become high enough to have significant negative economic impacts in other regards? There is increasing concern amongst Nova Scotians at large that current or anticipated levels of forest harvesting are or will have such impacts. There is good evidence, although it needs to be updated, to support that concern: The Nova Scotia GPI Forest Accounts study of 2001 assigned “explicit value to natural capital assets, including the full range of forest functions and vital ecosystem services that provide multiple benefits to human society”. From that study:
Extrapolating from one global study, Nova Scotia forests are estimated to provide a minimum of $1.68 billion (1997$) worth of services annually in climate regulation, soil formation, waste treatment, biological control, food production, recreation, and cultural benefits (Costanza et. al. 1997). This estimate does not include other vital forest ecosystem services such as soil erosion control, water supply and watershed protection, nutrient cycling, gas regulation, pollination, habitat, disturbance regulation, and genetic resources. Increased clearcutting and the loss of natural forest diversity are rapidly diminishing the value of these forest ecosystem services in the province.
Nova Scotia’s forests store about 107 million tonnes of carbon, thereby avoiding an estimated $2.2 billion in climate change damage costs. However, the accelerated rate of cutting, and the loss of old growth and mature forests in Nova Scotia since 1958, have drastically reduced the province’s carbon storage capacity by 38%, costing an estimated $1.3 billion in lost value. In other words, based on the 1958 forest inventory, the carbon stored would be worth $3.5 billion. Carbon loss in Nova Scotia’s forests is now contributing to global climate change.
Direct non-timber contributions to the Nova Scotia economy include a four-fold increase in maple sugar production over the past three decades. However, valuable forest-dependent medicinal plants that are dependent on mature forests, are becoming increasingly rare in the province as forest ecosystems with old-growth characteristics disappear.
Nova Scotians spend $250 million a year on nature and wildlife-related pursuits, a lot of it in forests, of which 70% is non-consumptive (e.g. hiking, bird-watching, canoeing) and 27% is consumptive (mostly hunting and fishing). In addition, total tourism revenues rose to a record $1.26 billion in 1999, contributed $430 million to the provincial GDP, and generated $200 million in tax revenues (current dollars), with nature tourism the fastest growing sector of the industry. The tourism industry directly employs more than 12,000 Nova Scotians, with direct and indirect tourism jobs increasing by 13.3% between 1997 and 1999. A Nova Scotia government report on the nature tourism market noted that natural settings, protected areas, parks, and opportunities for hiking and wildlife viewing were critical to the development of ecotourism market potential.
Total forestry industry shipments in 1999 were $1.4 billion, and contributed $431 million to GDP, remarkably similar in size to the tourism industry contribution.
From the perspective of sustainability, however, this forestry industry contribution must be assessed in relation to the health of the natural capital stocks on which it depends.
SOURCE: The Nova Scotia GPI Forest Accounts Volume 1: Indicators of Ecological, Economic & Social Values of Forests in Nova Scotia by Sara Wilson et al., 2001 ISBN 0-9689923-1-5 (v. 1) Executive Summary 16 pages 192K PDF Full Report 212 pages 1.6MB PDF
Also view
– The Nova Scotia GPI Forest Accounts Volume 2: A Way Forward: Case Studies in Sustainable Forestry by Linda Pannozzo & Minga O’Brien, 2001. ISBN 0-9689923-2-3 (v. 2) Full Report 255 pages 3.4MB PDF
– GPI Forest Headline Indicators for Nova Scotia by Linda Pannozzo and Ronald Colman. May 2008. PDF 3 MB
– Provisioning food and medicine from public forests in the United States by James Chamberlain et al., 2024 in Trees, Forests and People at https://www.sciencedirect.com/science/article/pii/S2666719324002449 “The evidence strongly supports the assertion that large volumes of forest-dependent fauna and flora contribute to the health and well-being of a substantial portion of the country’s population.”
***4.2.3 – Basic Needs of Communities Maintained or Enhanced (-LSS) #####
“Food, water supply or high conservation values (HCV) that are essential for the fulfilment of basic needs of communities shall be maintained or enhanced.
Context: This Indicator assesses the impacts on the ability of rural communities, both Indigenous and non-Indigenous, to meet basic needs.
Sustainable Biomass Program’s (SBP) glossary defines basic necessities as “Sites and resources fundamental for satisfying the basic necessities of local communities or indigenous peoples (for livelihoods, health, nutrition, water, etc.), identified through engagement with these communities or indigenous peoples. A site or resource is fundamental for satisfying basic necessities if the services it provides are irreplaceable (i.e., if alternatives are not readily accessible or affordable), and if its loss or damage would cause serious suffering or prejudice to affected stakeholders. Basic necessities in the context of HCV 5 may cover any or all of the provisioning services of the environment including tangible materials that can be consumed, exchanged or used directly in manufacture, and which form the basis of daily life.”
Forests, on a daily basis provide both food and drinking water. Food from forests typically falls into two categories: hunting/fishing (ungulates, freshwater, and anadromous fish) and foraging (mushroom, berry, and herbaceous plant collection). Drinking water supply is from surface water (lakes and rivers), as well as sub-surface ground water.
Impacts on the rights of Indigenous communities, including hunting, fishing, and gathering are considered in Indicator 4.2.4 Legal, Customary, and Traditional Tenure & Use Rights and Indicator 4.2.6 Consultation/Accommodation. Negative impacts on non-Indigenous communities are considered under Indicator 4.2.1 Negative Social & Community Impacts ID & Avoided. Maintaining ecosystem functions and services of water resources is considered under Indicator 2.2.5 Water Quality/Quantity Maintained or Enhanced.
The protection of drinking water via protected water areas is the focus of this Indicator.
“Potential Threats / Impacts Forestry operations and related activities can potentially have a negative impact on the quality or quantity of the local or community water supply, negatively affecting the health and quality of life of water users.
Regulatory Framework
Provincial
• Environment Act
• Forests Act
• Wildlife Habitat and Watercourses Protection Regulations
“Rationale for Risk Designation
Crown Licence
There is a regulatory framework and implementation mechanisms for the protection of drinking water on Crown licences. Harvest prescriptions for Crown licences are closely reviewed by DNRR through the Integrated Resource Management process and the reviews include an assessment of whether aquatic buffer requirements have been met. Based on evidence reviewed, this Indicator is designated as low risk for Crown licences in Nova Scotia.
Industrial Private Land and Private Woodlots
There are provincial legislative requirements on industrial private land and private woodlots for the protection of human drinking water. There is no publicly available information on management guidance or monitoring to determine if forest operations negatively impact Protected Water Areas or designated watersheds. There is no publicly available information to indicate compliance with WHWPR, or the Environment Act. Based on the lack of information, a precautionary approach is applied, and this Indicator is designated specified risk for industrial private land and private woodlots in Nova Scotia.
“Means of Verification
• Regulatory framework
• Regulatory agency websites
• Forest management plans
• Best management practices and/or operational procedures, including
assessment of impacts and implementation of mitigation measures
• Consultation/engagement process
• Grievance/dispute resolution mechanisms
• Regulatory compliance and enforcement data/reports
• Oversight agency database records and/or reports
• Consultation/engagement notices, opportunities, meeting minutes,
records, and applicable outcomes
• Site plans and/or post-activity inspections demonstrate negative impacts
mitigated
• Supplier verification program
• Interviews with regulatory/oversight agency
• Interview with local government, community members, special interest
groups/organisation
• Interview with experts”
COMMENT: Related to the soil acidification/base depletion discussed under Comments for 2.2.3 Soil Quality Maintained or Enhanced above, it’s pertinent to point out that potability of well waters is significantly adversely affected by this condition (due to high aluminum) / View scientific literature by Shannon Sterling & Colleagues at http://nsforestnotes.ca/current-issues/calcium-depletion/history/#sterling As noted under 2.2.3, the extensive degree of acidification/base depletion of forest soils in NS over more than 50% of landscape was well documented by Kevin Keys & Co. in 2016. They came up with a scheme to adjust harvest levels in the Ecological Matrix Lands that would theoretically* avoid further base depletion and allow some recovery; and for fertilization of more intensively harvested lands assigned to the HPF (High Production Forestry) zones. We (the public) have not been informed of any follow-up monitoring of harvested sites to confirm (or not) the theoretical expectations, and…In fact, there is good reason to suspect that on the more acidified sites, liming would be required to “kick start” a recovery process, i.e. that the theoretical rebuilding of soil base cations is not occurring at least on the more acidified soils.d
2f. Just the Comments
A PDF with just the name of the Indicator, and my comments (on behalf of NS Forest Matters)
View PatriquinNSFMCommentsRRA-NS6Dec2024.pdf