In this issue:
Over its 20 years, the Forest Practices Board has published some 500 audits, investigations and special reports; a few of which, for one reason or another, have ended up being controversial.
This past summer, the Forest Stewardship Plans Need Improvement special investigation (FSP) was one of those few reports. It garnered accolades from some for “saying it like it is,” and criticism from others for the tone taken in the Board’s commentary and executive summary and for not reporting the “on-the-ground results.” Initially, in many instances, forest industry representatives, professionals, government staff, and others did not read beyond page one of the report.
The Board’s intent in all cases is to “say it like it is,” to not mince words and to not water down findings in the quest for consensus. Saying it like it is has different meanings to different parties. In the end, the Board must report the facts and, given the importance, opportunity for improvement, progress to date, and opportunity to effect change, the Board crafts comments it believes are appropriate for the subject.
This is the second report the Board has issued on the poor quality of FSPs, thus the frustration that came through in the commentary. Over 75 percent of the FSPs in the province are due for renewal in the next 18 months. If government and industry don’t take advantage of this opportunity, it will be another 5 to 7 years before there can be any substantive improvements. The FSP is the only plan the public has the legislated right to review and comment upon. When these plans are extended, the public has no opportunity for review and comment and improvements to the existing plan are not possible. So much for continuous improvement.
A results-based framework does not focus upon how we get to the result we want to achieve. Ironically, the initial reaction to this report hung up on how the Board tried to get attention for this important issue, rather than the recommendations in its report and what needs to be done. This has been a reminder to the Board that it needs to choose its words carefully.
Despite the initial reactions of some, the Board is very encouraged that the government has placed a high-priority upon achieving improvements to FSPs and has engaged with the Board. We are also pleased to see the Association of BC Forest Professionals react positively to the report, and we appreciate that several forest companies have met with Board staff to better understand the analysis and findings so they can make improvements to their own FSPs. There is a year and half window to improve existing FSPs. The Board looks forward to seeing its recommendations acted upon and hopes to be able to report next time that the improvements have been made.
During the fall I was able to get out and tag along on a range audit in the Merritt area, go for a bush tour with a major licensee in the north Okanagan, and spend a field day with staff on the sleep slope road construction special investigation. I plan to touch bases with other licensees and interested parties over the coming months as well as follow-up on conversations I had with local government representatives at the UBCM convention in September.
As always, remember our door, phone and email are open. We look forward to your comments, concerns and suggestions. And finally, I would like to take this opportunity to wish you all the best in 2016.
Investigation to Publication - The Making of a Board Report
At the end of the field work, Board staff pack up their gear, assemble all their documents and notes and head to the airport for their flight back home. With just a couple of phone calls left to make to clarify a few details, it would appear that a Board report on the results of the investigation is not far off. Back at the office, news reporters phone, asking when they can expect to see the report now that the field work is done. In an ideal world, the report would just be a month or so away from completion. But in fact, this is the end of the easy part for most investigators and the real work of preparing a report is only just beginning.
Forest Practices Board reports are widely read, and always reviewed word-by-word with a critical eye by anyone involved in the case or affected by the conclusions and recommendations that come out of it. In order to ensure a thorough, accurate and credible product, the Board has developed a detailed and intensive writing and review process that the investigators must navigate before a report ever sees the light of day. The following is a brief overview of the process involved.
Analysis – after the field work is complete and the data and information has all been collected, a thorough analysis and review of the information takes place. The lead investigator consults with other professionals on staff and with hired experts when necessary. Draft findings are developed, often reviewed with the participants in the investigation, and any other relevant information or data is sought. The investigator may have to go back and collect more data and evidence.
Draft Report – the investigator begins with an outline of the proposed report and findings, laying out the investigation questions, the key evidence and the potential findings and conclusions. Once the outline receives internal approval, the writing process begins. Working with other team members and the program director, a first draft is prepared.
Peer Reviews – the initial draft report goes through one or more internal peer reviews, where it is critiqued, revised, reorganized and rewritten to ensure it is clear, all the evidence is there to support the findings and the conclusions are sound. It undergoes a review by legal counsel to ensure the interpretations of legislation and regulations are correct. It goes to the communications department for a plain English edit and a check to ensure logic, flow, clarity and conciseness. The draft may be revised and rewritten several times during this process.
Panel Review – the Board Chair determines whether a report or investigation is reviewed by a panel of Board members. The investigators must brief the Board members on the investigation, the analysis and the findings. The Board may provide direction on how to deal with any strategic or policy issues that arise from the investigation, suggest recommendations and draft their own commentary on the investigation findings and why they matter to the public.
Representations – at this point, any party that may be potentially adversely affected by the report has a legal right to make representations to the Board on the draft report. The Board Chair determines if any party is potentially affected and the report is provided to them for review. They are given several weeks to consider the draft and then make their representations to the Board. They may provide additional evidence that was not provided to the investigators earlier, they may request changes to the wording in the report, or they may argue their interpretation or point of view. The investigator, program director and the Board panel consider the representations and make further changes to the report as deemed appropriate. If there are substantive changes to the report, it goes back through the internal review processes with peers, legal counsel and communications staff reviewing the revisions.
Quality Control Review – Once the final draft is near completion, and all the comments and input have been incorporated, the report goes to an internal quality control review, where the investigator is grilled, line by line questions are asked, and affected parties’ potential reactions to the report are considered. Some Board staff have likened this review to a thesis defense. The intent of this review is to ensure every angle and interpretation has been thoroughly considered and that the final report is as clear and concise as possible, and is supported by evidence and legal interpretation.
Approval for Publication – Once the report passes the quality control step, it goes to the Chair of the Board for approval to publish. Final edits and proofing take place and a communication plan is developed, including a press release in appropriate cases. Stakeholders are notified that the report is coming, and given briefings on the main findings if appropriate. A week or two after final approval, the report is released to the public and all parties at the same time.
The process outlined here varies in length depending on the complexities of the issue investigated and the findings – anywhere from 3 to 18 months. But the ultimate goal is to ensure thorough, defensible and credible reports to the public and recommendations to government and industry that promote continuous improvement of forest and range practices in BC. So those investigators may have finished their field work, but they are nowhere near finished preparing a Forest Practices Board report.
Audit Season Update
Audit season wrapped up in October with the audit of Lowell Johnson Consultants Ltd near Smithers, BC. A small audit, the results have already been reported, along with audits of Teal Jones near Chilliwack, BC Timber Sales in the Boundary TSA, and Pacific Bioenergy and RPP Holdings near Quesnel. Five more audits are presently being written up and should be published in the first quarter of 2016. Those are an audit of oil and gas operations in the Peace Region, BC Timber Sales in Kamloops, range practices in the Cascades district, two community forests and a tree farm licence near Fort St. James, four woodlots in the Selkirk District and a Western Forest Products forest licence on Vancouver Island.
Staff and Board members are often invited to speak to groups and organizations about our reports and recommendations. This year, we spoke at more than 25 meetings, conferences and events. A couple of significant ones are highlighted here.
Forest Road Bridges
In November, Board staff participated in a two and a half-day workshop at the University of Northern British Columbia on bridge inspections. This workshop focused on routine and detailed bridge/culvert/retaining wall inspection processes as well as management issues surrounding structures and how they affect lifespan and maintenance. Board staff were there to discuss forest road bridges, auditing processes and how to ensure bridges can pass inspection. Workshop participants included forest professionals and industry staff, forestry consultants and government staff from across BC. The Board’s report on Bridge Design and Construction was required reading for the workshop.
Given that we continue to find issues with bridges in our audits, we are very pleased to see the attention to proper bridge design, construction and maintenance that has come out of that investigation and we applaud UNBC for offering this training to help improve performance on the ground.
Forest Stewardship Planning Report
Our report on forest stewardship plans was met with a great deal of interest from stakeholders. As a result, staff and the Board Chair have had a number of meetings to explain the basis for the findings in that report and to ensure people clearly understand the issues we found with forest stewardship plan content and how to address them. Since September, Board staff have met with:
- FLNR district managers
- FLNR district staff in Okanagan Shuswap and Kamloops
- ForestEthics and Sierra Club of BC
- Council of Forest Industries forestry committee
- Planning staff from Tolko
- Planning staff from Canfor, Apollo, L&M Lumber, and Louisiana Pacific in Prince George
- Ministers Practices Advisory Committee
Staff will also be presenting the report findings at the upcoming SISCO winter workshop in Kamloops, February 22-24, 2016.
Forest stewardship plans are the public’s only legal opportunity to provide input into forest practices and they are the document that holds licensees legally accountable for their forest practices. Given the short window of time we have to fix the current crop of FSPs, this interest in the Board’s findings is very encouraging. Anyone interested in meeting to discuss the report findings is encouraged to contact our office in Victoria.
What We Are Working On
An Evaluation of the Forest and Range Evaluation Program
Interviews with 100 individuals from industry and government have been completed and the results are now being analyzed. A draft report is in development and we intend to publish the report in Spring 2016.
Road Construction in Steep Terrain
Most field work has been completed with inspections of steep road construction carried out in four districts in both the interior and on the coast. One more week of field work remains to be completed on the coast when weather conditions permit. Analysis of the findings is underway and we hope to have the report completed by May 2016.
Investigation of Visual Quality Impacts in Alberni Inlet
This investigation was started after Board staff attended a visual quality training session in April of this year. Harvesting that did not appear to comply with visual quality objectives was observed during the session and the Board decided to investigate to find out what had happened and why. The investigation is in the final stages and the results should be released early in 2016.
Bulletin on Stewardship
This bulletin provides the Board’s perspective on stewardship and what it means for forest and range practices in British Columbia. It will outline the principles of stewardship that the Board considers when looking at the findings of our audits and investigations. The bulletin is in the final writing stages and should be released early in the New Year.
Young Stand Harvesting
The Board is aware that some stands in coastal TSAs are being harvested below the minimum harvest ages assumed in timber supply reviews, but is not certain of the extent of the practice or why it is occurring. Extensive harvesting of these young stands could have a negative impact on FRPA timber objective to maintain or enhance an economically valuable timber supply. Strong concerns have been expressed to the Board that this practice may threaten sustainability and stewardship. The purpose of the investigation is to explore the extent of young stand harvesting in five coastal timber supply areas and comment on issues related to harvesting at young stand ages if we find this practice is extensive.
Appropriateness of Government Enforcement Audit
This project will look at government’s new approach to enforcement of FRPA and the Wildfire Act, among all the other natural resource statutes Compliance and Enforcement Branch is responsible for.
Management of Fish Habitat under FRPA
This topic was identified as a priority to examine in the Board’s 2014 strategic planning meeting, but work is just getting underway now. The project has been scoped out and a terms of reference will be released in January.
In addition to the above work, and the regular audits and complaint investigations, Board staff are developing several new special projects. Over the last three months, the Board has been considering its priorities for the coming year and has decided to do work looking at three topics: management of wildlife under FRPA; whether reforestation is meeting expectations; and management of recreation under FRPA.
These topics were chosen because they are consistent with the Board’s strategic priorities (promote stewardship, demonstrate value, expand expertise), they are topics the Board has not looked at in recent years, and they were all raised by our stakeholders as issues we should examine when we did our stakeholder survey in early 2015. Staff expertise, availability and interests and capacity were other criteria considered by the Board in identifying these topics. Scoping of the new projects will begin in 2016.