Policy -
Forest Biomass Harvesting
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| May
18, 2007
David Ferguson Re: Policy - Forest Biomass Harvesting Dear Mr. Ferguson: CCNB raised its concerns regarding the impacts of forest biomass harvesting on ecosystem health, biodiversity and wildlife habitat with you in our meetings of last year. These have not been addressed in the policy, despite the fact that the |Policy Statement 1.1 says," Forest biomass is an important component of a forest ecosystem, vital to nutrient cycling, wildlife habitat, biodiversity and overall forest health." The policy is singularly focussed on minimizing site nutrient loss. In particular, removing the residual tree tops, branches, foliage, non-merchantable woody stems and pre-existing woody material eliminates the biological legacy that remains following clearcutting operations. The draft Forest Biomass Harvesting policy fails to assess the impact of removing much of the biological legacy of the former forest community on biodiversity, wildlife, hydrology, or on the trajectory of recovery from the clearcut. As a result there are no guidelines to help conserve biodiversity, habitat, or hydrologoical functions. This is unacceptable. Anything handed down from a forest community before it is clearcut, including green trees, surviving propagules and organisms, dead wood, and certain aspects of soil chemistry and structure such as soil organic matter, large soil aggregates, pH and nutrient balances can be considered biological legacies of the former forest community. Most if not all legacies probably influence the trajectory of recovery from a clearcut to one degree or another. The residual tree tops, branches, foliage, non-merchantable woody stems and pre-existing woody material defined as forest biomass in the policy constitute the biological and structural legacies of a clearcut. This decaying wood is the centre of biological activity in the clearcut. Not only are decay organisms active, but invertebrates and small mammals use this legacy for habitat. It acts to create micro-climate which influence the natural regeneration on the site of trees, shrubs, and vascular plants, and therefore the composition of the forest community that comes to occupy the clearcut. Recent work by researchers at the University of Saint John has demonstrated that existing riparian buffers are woefully inadequate to conserve amphibian populations by themselves. It is likely that forest biomass remaining after a clearcut supplements this riparian habitat to some degree. Forest biomass plays a role in mitigating the flow of water during rainfall and during snow melt. This policy ignores that role. A final point. The policy fails to specify appropriate forest biomass removal practices. The biomass removal operations I have witnessed on Crown bocks to-date disturb and remove the organic layer in the soil profile and also tend to remove some topsoil. Where topsoil is thin, sub-soil can be exposed. And it's not just soil that is disturbed but buried seeds, seeds in cones, surviving roots, basal buds, mycorrhizal fungi and soil microbes may also be disturbed, negatively influencing the recovery of the forest community. This shortcoming must be redressed in the final policy. In summary: The forest biomass harvesting policy fails to address the impacts of removing forest biomass on forest ecosystems, wildlife habitat, biodiversity, hydrology and the overall health of the forest and therefore is ill-suited to support sustainable forest management in New Brunswick. CCNB respectfully requests that you delay any request for expressions of interest in biomass harvesting until these significant gaps in the policy have been addressed. Sincerely, David Coon |