Comment deadline for Goldsmith Lake Wilderness Area harvest plan

A harvest planned for Block AP022053, located within the citizen-proposed Goldsmith Lake Wilderness Area, was announced on Oct 31st, 2024. The deadline for comments is December 13th.

See New Crown Land Harvest Plans” notice for Oct 31, 2024

To comment on the Plan, there are two options:

(i) Go to the Harvest Plan Map Viewer and submit
comments via a form – View images illustrating the process below.

(ii) Send an email to ecologicalforestry@novascotia.ca
Be sure to reference AP022053.

SOOF would appreciate a copy of your comments: Please  send to soof@saveouroldforests.ca.


Some points of concern to SOOF:
General:
– There should be a hold on all logging and road-building in the proposed Goldsmith Lake Wilderness Area until it has been formally assessed for protection.
– Two separate proposals to protect the area were submitted to Environment and Climate Change (ECC) in 2022, one by a well-respected Land Conservation Manager, the other by the Citizen Scientists of Southwest Nova Scotia.
– Citizen scientists have thoroughly documented the high conservation value of the area. As of September 30th, 2024 they had identified and reported 77 occurrences of Species at Risk and 18 stands of old growth forest within the proposed Wilderness Area.
– The proposed Goldsmith Lake Wilderness Area meets the criteria for areas that should be protected as laid out in the Collaborative Protected Areas Strategy (December, 2023).
– According to the government’s own Collaborative Protected Areas Strategy, NRR should be working with ECC and the public to meet the legislated target of protecting 20% of Nova Scotia’s lands and waters by 2030. Instead they are putting forward new plans to log within the area. Why?

More specifically:
– However ‘ecological’ the harvest prescription, it is never ecological to cut in a forest that should be protected.
– Ample evidence has been collected since the harvest plan was made public on November 4th to indicate that the part of the proposed Wilderness Area where this new cutblock is located is even richer in biodiversity than other areas surrounding Goldsmith Lake.
– While the 36 ha stand identified for logging is managed softwood, predominantly red spruce,, citizen scientists have already identified 13 Species at Risk whose protective buffers overlap with the proposed cutblock.
– Three endangered Black Ash have been identified next to the southwest tip of the cutblock. A possible 4th was found just east of the cutblock. Has anyone from NRR checked the area for this or any other endangered species?
– The adjoining stand to the southeast appears to be old growth with very large hemlocks and numerous coral lichen, a lichen species specifically identified in the province’s Old Growth Forest Policy as an old growth indicator.
– Forest stands immediately around the proposed cutblock support the richest diversity and highest concentration of rare lichens found to date in the whole 3900 ha proposed Wilderness Area. This includes the first occurrence of Anzia colpodes or Black Foam Lichen.
– Logging in the cutblock, and clearcutting a passage for a new stretch of road to access the block, will compromise the conditions of shelter and high humidity that these rare species require.
– This additional evidence of the high conservation value of the whole area should be sufficient to prompt the withdrawal of this harvest plan. Will it be? Will the public be informed of whatever decision is made?


Comment submitted by Donna Crossland*
Dec 8, 2024:
If harvesting proceeds on block AP022053, it represents a significant departure from the previously agreed-upon Triad approach to managing public forest lands. This shift in focus—targeting areas under consideration for conservation—is deeply concerning and is becoming an issue of growing concern among Nova Scotians. As a former member of the Minister’s Advisory Committee tasked with implementing the Lahey recommendations from the Independent Forestry Review (2018), I must highlight that this harvest proposal, along with others targeting proposed wilderness areas, directly conflicts with the established government process under the Triad model.

This apparent prioritization of “getting the wood out while you can” appears to be sanctioned by government foresters—professionals entrusted to manage public forests with a commitment to ecological integrity and the broader public interest, not singularly industry demands.

While the proposed ‘high retention gap irregular shelterwood’ harvest may remove ~ 33 % of the forest, the additional 30 m wide logging road likely brings the total forest removal to closer to 40 % and represents a permanent removal of carbon-capturing forest cover on the landscape in an area proposed for conservation. This stand and neighbouring stands will be exposed to increased wind damage and drying effects. This level of disturbance could jeopardize recently identified rare lichen populations nearby, alter the water table, and negatively impact the black ash occurrences in the area.  Has DNRR sent government biologists to the site to thoroughly inspect for SAR?  We’ve learned that much was over-looked in other proposed harvest sites in the Goldsmith area.

It is both reasonable and prudent to request a pause on this harvest block, and indeed all harvesting activities in proposed wilderness areas, until the full evaluation of conservation sites is complete. Such a delay would be minimal and align with public expectations for responsible forest management. Should this area ultimately not be designated for the Conservation leg of the Triad, harvesting may be deemed reasonable. In the interim, I would entrust that forestry is conferring with land planners and biologists at ECC to ensure that this harvest plans as well as others are not in conflict with the Collaborative Protected Areas Strategy (2023).
*Donna Crossland is a NS Forest Matters writer.

Comment submitted by Nina Newington*
Dec9, 2024
NN comment on HPMV re AP022053 new cut GLWF 20241207
AP022053, the polygon proposed for harvesting, consists of managed softwood stands, primarily red spruce, bounded by much richer multi-aged, mixed species forest. While the managed stands are not of the highest value for biodiversity, they nonetheless contribute to the essential interior forest conditions of the surrounding stands. Any logging in this polygon – and the roadbuilding required to reach it – will adversely affect the high conservation value of the area as a whole. As such it must not be allowed to go forward.

While the specific prescription – High Retention Irregular Shelterwood – is one of a very few in the SGEM that retain adequate forest cover to qualify as genuinely ecological forestry (all the others allow for the removal of 50% or more of the cover during a single harvest), it is not appropriate for this site. It is undoubtedly appropriate for other areas of Crown Land forest on the South Mountain, but not for a site that should be left untouched from now on. 300,000 ha or so of Crown Land will need to be protected in the next 6 years to meet the legal target of protecting 20% of Nova Scotia’s lands and waters. The area surrounding Goldsmith Lake, including the area where AP022053 is located, were proposed for protection in 2022, first by a well-respected Land Conservation Manager in February, then by the Citizen Scientists of Southwest Nova Scotia in November. Both proponents requested that a moratorium should be placed on all harvesting, roadbuilding and industrial activities in the proposed Wilderness Area until it has been assessed for inclusion in the 20%. This new harvest plan flies in the face of that reasonable request.

The department’s rubric indicates that comments on the HPMV should focus only on the area within the specific polygon. This makes no sense from an ecological point of view. The importance of surveying the surrounding stands is amply borne out by recent discoveries. Since the publication of the harvest plan on November 4th, citizen scientists have identified occurrences of over 30 species of conservation concern in the surrounding forest as well as 13 occurrences of Species at Risk (SAR) where the required buffer zones impact the boundaries of the polygon proposed for logging. Of these thirteen, 3 are Black Ash, 2 Blue Felt lichen, 1 Black foam lichen, 7 Frosted Glass Whiskers. (Confirmation of these last by Frances Anderson has been delayed by the Canada Post strike. If they are not Sclerophora peronella they will be the even rarer S1/S2 Sclerophora amabilis.)

If any of these had been identified by NRR as part of its Integrated Resource Management process, the boundaries of the polygon would presumably have been modified to remove areas covered by the buffer zones before publication on the HPMV. Clearly that did not happen. This is far from the first time NRR has failed completely in its responsibility to identify and protect SAR. In 2022, in the cutblock at Beals Brook which the department claimed to have reviewed not once but twice, 17 SAR lichen occurrences were documented. At that point the Department had the good grace to admit that they lacked qualified people to identify SAR lichens and raised the idea of training citizens to help with the task. In the absence of department-sponsored training, citizen scientists organized their own training by expert lichenologists. We have been hard at work ever since.

It could be argued that the HPMV process is working: the public is alerting NRR to problems with the proposed cut. But, if the department is going to rely on citizen scientists to do their work for them to this extent, why are they refusing to respect the conclusions the citizen scientists have reached after many, many hours on the ground in the forests around Goldsmith Lake? The citizen scientists have identified this whole area as a biodiversity hotspot deserving permanent protection.

As it turns out, the forest stands immediately around AP022053 support the richest diversity and highest concentration of rare lichens found to date in the whole 3900 ha proposed Goldsmith Lake Wilderness Area (GLWA). This includes the first occurrence of Anzia colpodes or Black Foam Lichen in this area.

At least one of these adjoining stands, the one immediately to the southeast of AP022053, appears to be old growth with very large hemlocks and numerous coral lichen, a lichen species specifically identified in the province’s Old Growth Forest Policy as an old growth indicator. There is another probable old growth stand nearby, this time of yellow birch and sugar maple.

This is a pattern by now familiar to the citizen scientists who have been documenting biodiversity throughout the former Bowater lands that make up the GLWA: areas of old and old growth forest adjoin areas of managed forest. This is not surprising. Fragmentation of our forests is common throughout Nova Scotia. There are no vast tracts of pristine wilderness to protect. Areas that have already been granted protection include younger managed forest. That will inevitably be the case for the areas still to be designated for protection to meet the 20% target. The presence of managed forest is no argument for failing to protect this area.

What is surprising at Goldsmith is the sheer amount of old and old growth forest that Bowater left intact. This creates a wonderful opportunity to rebuild the stock of old growth forest. Old and old growth forest in the GLWA is largely composed of the long-lived species that were not commercially valuable to the pulp mill, notably yellow birch, sugar maple and hemlock. In order to restore the red spruce, another long-lived shade tolerant old growth species, to its rightful place in the Wabanaki forest, it is important to leave some mature stands (60 yrs +/-) like the one in AP022053 alone. As the province’s Old Growth Forest Policy makes clear, no silvicultural interventions can hasten the development of old growth forest. In fact any documented silviculture in the past 30 years disqualifies a stand from inclusion in the policy. What will allow those red spruce to develop old growth characteristics is time. Protection is necessary, the proximity of much older forest helpful.

Whether or not the old forest stands around AP022053 meet NRR’s criteria for inclusion in the Old Growth Forest Policy, we have provided ample evidence in a very short period of the biodiversity they support. Their conservation value is undeniable. Plans to fragment the area with new logging and some new roadbuilding before the area has been assessed for protection as part of the 20% make no sense.
**Nina Newington is a NS Forest Matters writer.


Submitting comments via the Harvest Plan Map Viewer:
Go to the Harvest Plan Map Viewer and you will see this map of NS with little brown “polygons”. Zoom in on the one indicated by the arrow below, then follow what you see in the next images below.