Council of Forest Industries 1501 700 West Pender Street Pender Place I Business Building Vancouver, British Columbia

a Canada V6C 1G8 Telephone: (604) 684-0211 Fax: (604) 687-4930 E-mail: info@cofi.org Website: www.cofi.org

Interior Lumber Manufacturers Association 440 Sealion Place Nanaimo, BC V9V 1B3 Telephone: (250) 756-3665 Fax: (250) 756-3621 E-mail: ilma@shaw.ca Website: www.ilma.com

March 18, 2014 Honourable Leona Aglukkaq Minister of Environment 10 Wellington St, 28th Floor Gatineau, Que. K1A 0H3 Dear Minister: RE: Recovery Strategy for the Woodland Caribou Southern Mountain (Rangifer tarandus caribou) in Canada

The Council of Forest Industries (COFI) and the Interior Lumber Manufacturers Association (ILMA) have collaborated to submit the following comments on the Recovery Strategy for Woodland Caribou, Southern Mountain Population (Rangifer tarandus caribou) in Canada (Recovery Strategy). COFI and the ILMA are forest industry associations that represent the British Columbia Interior Forest Industry. Comprised of both public and privately held firms, these two organizations represent 31 member companies who operate 75 production facilities across the interior of BC. These facilities, ranging from sawmills to pulpmills to oriented strand board plants to pellet plants, provide the economic backbone of the rural economies where they are located as well as for the province of BC. COFI and the ILMA are committed to a balanced land use policy that represents societys social, environmental and economic objectives. Member companies have long been committed to the management of Species at Risk and specifically, the survival of Mountain Caribou. This commitment has been demonstrated through ongoing investments in research, inventories, habitat conservation, management tools, planning activities, land use plans and staff participation on recovery teams. These findings have been incorporated into management and operational plans designed to minimize potential impacts on Caribou. Although both organizations have many concerns with the Recovery Strategy, we have limited our comments to three key issues; Critical Habitat, Predators and Climate Change. Critical Habitat - The lack of maps, incomplete information, and confusing definitions and text has made the evaluation of proposed protection measures very difficult. The lack of thresholds for high elevation 1

habitat, the adoption of a 65% undisturbed threshold for low elevation winter habitat, and the lack of clarity defining matrix habitat is very concerning. The 65% undisturbed threshold appears to have been borrowed from the federal boreal strategy despite the lack of any analyses or data to support its use or effectiveness in the mountainous terrain of BC. The matrix habitat definition is also very confusing as it includes areas both within and outside caribou range, which may or may not be used by the species. The inclusion of a 500 m buffer on any human caused disturbance or burnt area represents a further concern. We do not believe this is feasible or realistic in southern BC because almost all of the low elevation area that is not forested, is dominated by agriculture and/or urban areas. Predators The Recovery Strategy is very weak on predator control. It does not stress the importance or need for both intensive and extensive control programs. Instead, it focuses on habitat alteration and the need for habitat restoration. The predator control measures are focused almost entirely on wolves. It does not adequately address cougars, grizzly bears or wolverines which are having significant impacts on caribou recovery efforts. Climate Change The Recovery Strategy fails to mention or incorporate the potential impacts of climate change. Not only is climate change predicted to alter existing ecosystems, it may also affect the animals health and reproductive capability. If current climate change predictions are correct, much of the area currently identified as potential caribou habitat may not be caribou habitat when the altered stands reach maturity. Policy Impacts The forest industry is very concerned about the additional impacts to timber supply, regional income and employment that would result, should the Recovery Strategy and resultant action plans be implemented. Although the impacts are not possible to estimate at this time, we do know that further habitat preservation beyond the 2.2 million ha set aside under the provincial Mountain Caribou Recovery Implementation Plan (MCRIP) would have devastating impacts on the interior forest industry of BC and associate resource dependent communities. We are not convinced that further habitat preservation is required as evidenced by the declining caribou population trends in pristine areas such as Jasper and Banff National Parks and Wells Gray Provincial Park. As previously identified, other actions must be implemented concurrent with the habitat preservation that has already occurred. Background work completed for the MCRIP estimated that every 4 hectares of timber harvested generated between 0.61 and 1.14 person years of direct employment in the timber harvesting and processing sectors1. Results varied depending on the region, but they are significant multipliers and provide good reason for our concern. We understand that a socio-economic evaluation is not required within the caribou Recovery Strategy but it is required as part of an action plan. We urge the government to complete one since it will enable a comprehensive review of critical economic factors that will undoubtedly be affected by the Recovery Strategy. Accomplishments to date The MCRIP for the southern mountain herds enacted in 2007, is a good plan, supported by both COFI and the ILMA. We acknowledge that it has not achieved the desired
1

Central Kootenay Region Timber Harvesting & Processing Employment Survey, Final Report, December 15, 2008. Prince George Region Timber Harvesting & Processing Employment Survey, Final Report, December 15, 2008 and Central Cariboo Region Timber Harvesting & Processing Employment Survey, Final Report, May 25, 2009. Pierce Lefebvre Consulting, Vancouver, BC.

results, but must point out that it has not been implemented as recommended. Of the six key elements in the Plan, only habitat preservation has been fully implemented. The remaining five elements have only been partially implemented. In particular, the commitments to implement predator control programs and to augment herds with low populations have been far from adequate. Regardless, industry continues to support the provincial plan through to its full implementation. Summary The proposed Recovery Strategy does not recognize management practices that have either succeeded or failed in the past. Rather, it applies simple threshold objectives to complex varied ecosystems, despite limited and contradictory evidence and no supporting analysis. This Strategy does not provide the foundation for an evidence-based, feasible approach to improving chances for caribou recovery. Both COFI and the ILMA request further consultation on the Recovery Strategy, as required by s. 39(3) of SARA and urge the federal government to re-consider its plan in favour of the current provincial Mountain Caribou Recovery Implementation Plan.

Yours truly,

James Gorman, President and CEO Council of Forest Industries

James S. Hackett, RPF, President Interior Lumber Manufacturers Association

Cc: Honourable Joe Oliver, Minister Natural Resources Canada Bob Zimmer, MP Prince Peace River, BC/Yukon Caucus Chair Honourable Mary Polak, Minister of Environment, Province of BC Honourable Steve Thomson Minister Forest Land and Natural Resource Operations, Province of Stephen Hureau, Head, Species at Risk Recovery Unit, Environment Canada Darcy Peel, Recovery Planning, Environment Canada