Letter to the Editor

Forest Management Branch’s Environmental Assessment Process: An Internal Shenanigan?

The Yukon Territorial Government’s Forest Management Branch (Branch) has performed two of its own Environmental Assessments (EAs) since devolution in April, 2003. Both EAs indicate that the Branch is unable to adequately consider the full range of environmental and societal concerns. Until the Branch reforms itself, Yukoners can have little confidence that the Branch is capable of performing an impartial EA of forestry projects.

Forest Management on the Beaver River, SE Yukon Photo by Juri Peepre

Environmental assessments examine the actual and potential adverse environmental effects of proposed projects or activities. Factors to be considered in an EA include cumulative effects of a project in combination with other projects, the significance of such effects, and comments from the public. An EA is supposed to provide a balance between the applicant’s interest in development and the public’s interest in environmental protection.

In the Yukon, prior to devolution, forestry related EAs were performed by the Forest Resources branch or the Environment Department of the Federal Government’s Department of Indian Affairs and Northern Development (DIAND).

The Branch’s first stab at performing its own EA, since devolution, was in the fall of 2003 in response to a Dimok Timber Ltd. application near Haines Junction. Dimok requested approval to log 11,800 m 3 of white spruce to protect the nearby MacIntosh subdivision from fire. This application elicited some serious public concerns.

The requested volume of 11,800 m 3 was approximately twice the amount of wood that was originally stated in a higher level (Development) plan that incorporated considerable public input. This volume was approved in the EA, demonstrating how the Branch can exceed higher level plans whenever they feel it is appropriate, despite public concern.

The public interest is best served when EAs are impartially conducted by skilled resource managers and are based on thorough research of the best available science. Rather than using sound science and simple logic, the Branch reasoned in its EA that the logging by Dimok would not exceed the area’s thresholds for cumulative environmental effects because “there have been extreme natural disturbances in the area, including volcanic activity, glacial flooding and surges…”

Volcanic eruptions and glaciation are catastrophic disturbances that operate on vastly different scales of time and space than contemporary logging in the Yukon. Comparison of the effects of such geologic phenomena with those of logging is simply ridiculous. Logging also has environmental effects (some of which can be long lasting and detrimental), which should be evaluated with respect to natural disturbance regimes, historic ranges of variability, and realistic, well-defined ecological thresholds. The relevant comparisons to logging in the boreal forest are with natural disturbances such as fire, insect outbreaks, windthrow, stream flooding, and landslides. Such comparisons should be used to guide forest management, not to justify giant clear-cuts.

Besides bizarre logic, inadequate public consultation was an issue in this EA. The MacIntosh Community Association was not provided with the project description or the application for review. The Branch claimed that various stakeholders were provided with the necessary information to comment on the application; however, this was not the case for the very community that is most affected by the project.

The Branch’s recent EA of the south-east Yukon Interim Wood Supply Plan, further illustrates a disregard for normal EA standards. It fails to adequately address detailed comments provided by public interest groups and follows a minimum standard rather than precautionary approach. In this case, the Branch performed an EA of a plan, for 5 proposed cut-blocks, that they wrote in the first place. The Branch is both the applicant AND the party evaluating the application! Can the Branch perform an objective EA of this Interim Wood Supply Plan when they are committed to seeing it happen?

Once again, adequate consideration was not given to the well-founded concerns and mitigations put forward by the public. Responses to public input were circular arguments that skated around comments that the Branch received. For example, it was pointed out by more than one interest group that thresholds for ecosystem function and species of concern (such as marten) were not identified. The EA responded that “Thresholds for wildlife have not yet been set in the Yukon.” Even after acknowledging insufficient information for determining thresholds, the EA does not state that further mitigation and a precautionary approach are necessary. If more information is required, the EA process should call for it as a mitigation, or at least suggest further mitigations to avoid undue impacts in the absence of information.

Does this illustrate the Branch’s level of consideration for the values of the citizens directly affected by this plan?

It appears that both EAs were produced to meet the applicant’s needs rather than to ensure that the proposed project will have no significant detrimental environmental effects.

It is timely to ask whether the public can rely on the Branch to objectively perform adequate Environmental Assessments. Based on the Branch’s performance to date, we are not convinced that the Branch is currently capable of considering and meaningfully assessing the potential environmental impacts of proposed forestry projects.

We, as Yukoners respect and admire this land that we call home. The state of our forests is at risk and it’s about time that the Forest Management Branch started taking this seriously.