The Regional Risk Assessment (RRA) Process
Regional Risk Assessments (RRA) are a part of SBP’s approach for identifying and mitigating risks associated with sustainably sourcing feedstock for biomass pellet and wood chip production. The process that must be followed is set out in SBP’s RRA Procedure Version 1.1. The scope of the BC RRA includes all uncertified forests on Crown and private lands in the province.
The intent of the information presented here is to encourage information sharing to ensure that all stakeholders have the opportunity to review and provide comments on the draft BC RRA. Click here for the SBP Endorsed RRA for the Province of British Columbia.
Sustainable Biomass Program
The Sustainable Biomass Program (SBP) is a non-profit international standards organization that has developed a certification system for woody biomass, which is mostly used in the form of wood pellets and woodchips, as fuel for industrial, large-scale energy production. The certification system is intended to provide assurance that woody biomass is made from legal and sustainable sources.
Biomass must be compliant with the SBP Standard to enter certain markets - many European utilities only take SBP biomass. Feedstock certified at the forest level through standards such as those promulgated by the Forest Stewardship Council (FSC) or by the Program for the Endorsement of Forest Certification (PEFC) (standards by organizations such as Sustainable Forest Initiative (SFI) and the Canadian Standards Association (CSA)) is considered SBP-compliant; this represents a significant portion of the public and private forest land in British Columbia.
The Working Body (WB) utilizes experience gained from years of stakeholder engagement on various certification projects, advisory groups, certification audits, as well as evaluating the processes and outcomes from provincial-lead consultation. From the start, the WB reaches out to individuals and organizations to identify sources of information, highlight facts and experiences to write well-documented and logical findings to determine the risk level associated with the standard's indicators. The WB chose to a -2- phased approach to consultation.
Phase 1 - Stakeholder Outreach
Prior to the required 30-day stakeholder consultation, as part of the Sustainable Biomass Program (SBP) RRA process, the WB reached out to numerous individuals and groups through out the Province, some linked to the Biomass Industry as well as others. These groups included:
Local Government Elected Officials
Members of the Legislative Assembly (MLA’s)
Members of Parliament (MP’s)
First Nation Organizations
Chamber of Commerce
The goal of this outreach was to gauge the level of impact the biomass industry has on local communities and to supplement the required 30-day required stakeholder consultation.
Phase 2 - 30-Day Stakeholder Consultation
As part of the Regional Risk Assessment (RRA) process, a draft report was made available to the public, including all stakeholders, for review and comments. The draft was prepared by a team of consultants (RRA Working Body) based on a review of literature and on-line information, interviews with experts, and the personal knowledge and experience of the consulting team. The evidence gathered forms the basis of the assessment of each indicator.
The RRA team Working Body thanks you for the many comments received to improve the draft report.
British Columbia is 95 million hectares in size (about double the size of California). BC’s2010 State of the Forest Report indicated that forests cover almost 58% of the province – about 55 million hectares. The province owns approximately 52 million ha of forest land, which is known as Crown land or Crown forest. Only 42% (22 million ha) of BC’s Crown forest area is available for logging. Privately-owned forest land is roughly 3 million ha and approximately 2 million ha is suitable for harvesting. Less than 1% of the available forest area is harvested annually. The proportion of provincial land in each major ownership class is shown in the figure below.
Approximately 14.1 million ha (14.8%) of BC is protected in parks and other types of protected areas; in addition, another 14% of the landbase has been placed into special management zones. Ninety-five percent of the province’s forests are composed of softwood species, consisting of the following commercial species: lodgepole pine, subalpine fir, white and Engelmann spruce, subalpine, grand and pacific silver fir, Sitka spruce, western red cedar, Douglas fir and western hemlock. Hardwoods primarily consist of aspen and birch with maple, alder and oak present in coastal areas.
British Columbia has an exceptionally wide range of geophysical and ecological conditions. As a consequence, BC has the most biodiversity rich forests in Canada. Of the 15 ecozones in Canada, 5 exist in BC (BC Ecozone Map). These are further sub-divided into 14 biogeoclimatic zones. More than 50,000 species (not including single-celled organisms) exist in BC, but only about 3,800 of these have been assessed for their conservation status. Of the Canadian provinces and territories, BC is home to the richest diversity of vascular plants, mosses, mammals, butterflies and birds, and the largest number of species of reptiles, tiger beetles and amphibians found only in one province or territory.
BC is known to have a majority of the global range for 99 species. In fact, the Vancouver Island Marmot is found nowhere else in the world. BC has the largest population of grizzly bears of any province or state apart from Alaska. There are at least eight insect species that are found only in the South Okanagan. Almost the entire world population of the Western Sandpiper and North Pacific population of the Humpback Whale migrate along the British Columbia coast.
Of the 3,808-native species in BC for which conservation status has been assessed, 233 species (6%) are of global conservation concern and 1,640 species (43%) are of provincial conservation concern. The Provincial Government, through the BC Conservation Data Centre, identifies species of provincial concern as red-listed, which are either extirpated, endangered, or threatened and are considered to be the most at risk, or blue-listed, which are considered to be vulnerable to human activities and natural disturbance.
The species at risk lists identify species that need protection. BC is developing recovery plans for Federal and BC listed species on an ongoing basis, and the province has expanded its inventory of sensitive ecosystems, developed regional conservation strategies and provided local governments and private landowners with workshops and conservation strategies. The Federal Species at Risk Act only applies to federal lands within the province. British Columbia has taken steps to develop and pass its own Endangered Species law, however it has not yet been enacted.
Public forests are managed by the BC Ministry of Forest, Lands, Natural Resource Operations and Rural Development (FLNRORD) and the Ministry of Environment and Climate Change Strategy (MoECCS).
FLNRORD, under the Forest Act, is the authority that allocates forest tenure and issues forestry licences and oversees forest management. Tree Farm Licences and Forest Licences are the two long-term licences that are generally issued to forestry companies. There is a wide range of other licence types that are issued for other types of licensees and conditions. The Forests and Range Practices Act sets out operational planning and practices requirements for Crown land.
FLNRORD also regulates the harvesting, transporting, and scaling of all timber harvested from both Crown and private land through the Forests Act and its associated regulations. Tracking all harvested timber is essential to ensure that there is no illegal harvesting and that royalties owing to government for harvested Crown timber (stumpage) are completely and accurately invoiced. This data is tracked through the provincial government Harvest Billing System.
MoECCS is responsible for the effective protection, management and conservation of B.C.’s water, land, air and living resources. It oversees the province’s protected areas network, as authorized under several pieces of legislation. The Parks Act provides for the establishment, classification and management of parks, conservancies and recreation areas. The Park, Conservancy and Recreation Area Regulation provides regulations around the requirement for permits; public conduct and enforcement; the use of motor vehicles, vessels and aircraft; the use of firearms for hunting and fishing; waste management; camping and picnicking; fees; and the authority of park rangers.
The Ecological Reserve Act provides for the establishment and administration of ecological reserves. Finally, the Protected Areas Act of British Columbia consolidates most of the Class A parks, conservancies and ecological reserves and ensures that the boundaries of these areas cannot be modified to remove lands except by an Act of the Legislature.
The Forest and Range Practices Act (FRPA) was enacted in 2004 to replace the 1995 Forest Practices Code Act of British Columbia, moving to a “results-based” approach, where the results of management actions were specified in forest plans and it was up to the forest managers to figure out how to achieve them. FRPA, together with the Forest Planning and Practices Regulation (FPPR), regulates forest and range operational planning and practices on Crown land, while ensuring the protection of plants, animals and ecosystems.
FRPA requires licensees to prepare a forest stewardship plan (FSP) that must receive provincial government approval prior to cutting permits and road permits being issued. FRPA sets out the content of FSPs, sets the term to five years, and specifies what tests must be met in order for the FSP to be approved by FLNRORD. FRPA also requires that more detailed individual site plans be prepare for each harvest block before harvesting can commence. Requirements related to practices, forest health, and silviculture are also found in FRPA.
The FPPR sets out additional FSP content requirements, and significantly, it identifies the management objectives set by government to ensure the protection of eleven resource values which include: biodiversity, cultural heritage, fish/ riparian, forage & associated plant communities, recreation, resource features, soils, timber, visual quality, water quality, and wildlife. FPPR also sets out the basic test that is required to assess whether the FSP strategies and/or results are consistent with the government objectives.
Biodiversity in Forest Management
BC’s rich biological diversity is important at all scales, ranging from the local to the international. In addition to parks and other protected areas, there are numerous measures in place to conserve biodiversity on the working forest. There is considerable debate as to how effective these measures have been, and whether they are sufficient – for example, the province has mandated a two-person panel to conduct public hearings on old growth forests and their management.
The Forest Stewardship Plans are one of the key mechanisms that ensure practices as well as the organization of how the forest is managed maintains biodiversity. The FPPR sets out eleven objectives set by government that must be included in FSPs and these include four that are directly related to biodiversity, and others that are indirectly related (e.g. fish habitat in fisheries sensitive watersheds). FREP and the Forest Practices Board are the key oversight programs /organizations.
Under FRPA, the government also has the capability to issue Government Action Regulations (GARs) to protect species at risk, regionally important wildlife and ungulates. GARs are spatially defined, and there are a number of them scattered across the province. Many of the GAR orders have been issued for mountain caribou habitat, and other winter range areas for ungulate species in general. Old growth may also be subject to provincial orders, and managers in many Crown forests are required to identify and map old growth management areas (OGMAs), which function as protected areas while some parts of the forest are subject to non-spatial OGMAs.
Species at risk are considered in forestry and the emphasis is on the conservation of habitat and implementation of recovery plans. The populations of some species at risk have stabilized whereas other species have continued to decline.
Private landowners are modestly constrained on how the forested land is managed. The federal Fisheries Act applies on private land. Key provincial regulations that apply to all private owners of forest land include the Water Sustainability Act, the Water Protection Act, the Drinking Water Protection Act, the Forest Act, the Wildlife Act and the Heritage Conservation Act. The various water protection acts ensure that activities undertaken on private land do not disrupt or contaminate surface water and groundwater, and the Heritage Conservation Act specifies that items or sites with archeological significance, or suspected of being significant, are brought to the attention of government and are not damaged or destroyed.
Private landowners may also be subject to municipal regulations limiting the harvest of trees, usually referred to as tree-cutting by-laws. These are normally passed by the councils of large and medium-sized communities, as well as some small communities.
Private landowners may choose to register their forested land in the Private Managed Forest Land (PMFL) Program. Private managed forest land is an assessment category – in exchange for favourable property tax treatment, the property must be managed sustainably. The Private Managed Forest Land Act and its regulations authorize this program and also establish the oversight of the Managed Forest Council. As of March 31, 2018, there were approximately 818,000 ha of private managed forest land in the province, with 284 owners. In 2018, PMFL yielded annual harvests of 5.2 million m3, equivalent to 8% of that year’s provincial harvest.
The goal of the PMFL is to encourage owners to manage their forests so that the forests continue to provide ecological, social and economic benefits. While PMFL owners are not required to prepare a forest management plan, they must report annually on the forestry activities that they undertake, including harvesting. The Managed Forest Council receives the annual reports and conducts regular audits and assessments to ensure that the requirements of the Act are being followed. The Managed Forest Council web site reported that there have been 623 inspections completed since 2007, and the compliance rate has been 99%.
Monitoring Forest Practices
Monitoring is the act of making assessments of activities and/or their outcomes, usually to assess either compliance, effectiveness, or how the actual outcomes compare with the anticipated outcomes. While licensees undertake their own inspections of operations to ensure they are compliant with requirements and the effectiveness of renewal and tending operations is also assessed regularly, there are three principle government programs in place to provide additional oversight:
the activities of the Compliance and Enforcement Branch (CEB),
the Forest & Range Evaluation Program (FREP) and
the activities of the Forest Practices Board (FPB).
The provincial Compliance and Enforcement Branch assesses compliance with a wide range of regulations affecting the use of Crown land, including those pertaining to timber harvesting. The C+E Branch investigates contraventions to a variety of laws and regulations, including those designed to protect the environment, prevent illegal logging and land use, and monitor road and trail use.
FREP evaluates the effectiveness of forest and range practices in achieving the forest management objectives set out in FRPA, and more generally the overall sustainability of resource management. In other words, it is FREP that is designed to ensure that the expected results of forest management are occurring. FREP monitoring is not directly assessing whether forest and range practices are achieving the government's objectives in FRPA. Instead, FREP evaluates at the site level whether forest practices are resulting in conditions that are “sustainable”. FREP uses “impact ratings” as a measure of sustainability; if the practices are deemed sustainable, FREP assumes that the value is being conserved as intended by FRPA.
The Forest Practices Board, which is an arms-length board appointed by government, operates at a higher level. FPB’s mission statement is that it “serves the public interest as the independent watchdog for sound forest and range practices in British Columbia.” It evaluates the effectiveness of forest management, planning, and associated regulations, as well as forest practices. For example, the FPB recently assessed the effectiveness of Forest Stewardship Plans in meeting the government’s forest objectives and provided comments on proposed amendments to FRPA. However, the majority of the FPB’s resources are used to conduct audits and investigations on various forest licence areas and to investigate complaints.
Indigenous Involvement in Forestry
Statistics Canada reported that in 2016, there were 270,585 Indigenous people in British Columbia, making up 5.9% of the population. Of the Aboriginal population in British Columbia, 63.8% (172,520) were First Nations people, 33.0% (89,405) were Métis, and 0.6% (1,615) were Inuit. There are almost 200 distinct First Nations communities in B.C., each with their own unique traditions and history. More than 30 different First Nation languages and close to 60 dialects are spoken in the province.
In BC, traditional rights as they apply to Indigenous Peoples – are complex, particularly on Provincial Crown land. While this overview cannot do justice to the context of the environment within which Indigenous Peoples exist in BC, several key factors are:
Very few treaties have been signed between Indigenous Peoples, BC and Canada, with provincial, federal and First Nations governments all asserting ownership;
The 1982 federal Constitution Act affirmed Indigenous People’s rights and the courts have further affirmed rights for some First Nations including Title to the Tsilhqot’in in BC; and
Existing legal and policy frameworks are in place that are intended to protect Aboriginal Rights. However, there are specific instances in BC where it has been proven that Aboriginal Rights have not been sufficiently protected.
Consultation with Indigenous Peoples is a necessary component of forest management. In addition to the overarching provincial policies, there is also key forestry legislation for consultation. These include the Forest and Range Practices Act (FRPA) and the Forest Planning and Practices Regulation (FPPR) provides direction regarding consultation, as does FLNRORD’s Updated Procedures for Meeting Legal Obligations When Consulting First Nations (2010). Requirements are changing fairly rapidly, as court cases and the drive for reconciliation take hold. Additionally, BC is the only province that has passed legislation committing the government to bring its laws and regulations into conformance with the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP).
For many years, consideration of Indigenous peoples in forest management was limited to the conservation of cultural heritage features. These aspects continue to have a place. For example, Forest Tenure Agreements have an obligation to participate in the FRPA information sharing process with Indigenous Peoples during the development of the FSP. FSPs must identify results or strategies that address protecting cultural heritage resources.
More recently, tenure has increasingly been granted to Indigenous communities, companies, and partnerships. The Forest Act was amended to create a new class of tenure – the First Nations Woodland Licence. However, only two have been issued as of 2018, but there have been many more agreements and timber sales awarded to First Nations so that as of 2017, 11.6% of the provincial AAC had been allocated to Indigenous entities.
Another relatively recent innovation is that the BC government has agreed to share revenue from certain carbon offset projects with First Nations. The province has entered into Atmospheric Benefit Sharing Agreements (ABSA) which enable First Nations to sell carbon credits. Specifically, these agreements clarify First Nations ownership and the right to sell tonnes of carbon in local or international carbon markets. Many of the offset projects that have been developed to support ABSA’s have involved increasing the carbon balance in forests and /or reducing net emissions from forests, and the First Nations’ share of the benefits has steadily risen from approximately 50% to a level that is now close to 100%.
Where is the biomass sourced from?
Biomass Producers (BPs) can source fibre to be feedstock supply for pellet production from primary, secondary and tertiary sources.
Primary feedstock is fibre sourced directly from the forest, which includes chipping whole trees and grinding of piles of logging slash left alongside forest roads and at landings.
Secondary feedstock is wood fibre generated as a by-product from mills manufacturing logs, most notably it consists of sawdust, bark and excess wood that cannot be converted into lumber.
Tertiary feedstock is derived from pre- and post-consumer fibre, such as trimming of cardboard and paper from a remanufacturing facility.
The Wood Pellet Association of Canada (WPAC) says that the “vast majority” of fibre use to make pellets comes from mill residuals – this is estimated to be 80-90% of the source fibre for pellet manufacturers in BC. The remainder is primary fibre mostly obtained by grinding roadside slash, with a very minor of amount of whole tree chipping.
During the past decade, the BC forest industry has concentrated on salvaging timber from trees killed by the mountain pine beetle, and to a lesser extent from extensive wildfires. Much of this timber was sawn and what could not be used by sawmills was chipped for biomass. Now that the salvage effort is coming to an end, the mix of fibre sources used by BPs is changing with a higher proportion of their furnish coming from primary sources, focusing on low-quality timber stands and ‘bush grind’ of roadside slash-piles.
The Province has done biomass inventories and delivered cost estimates throughout the Crown land TSAs. This has identified a significant biomass fiber business opportunity.
The provincial government has been supportive of the biomass industry, encouraging business-to-business relationships between primary harvesters and secondary producers (e.g. contractors who grind roadside slash). This effort is aimed at improving the use of lower-quality timber in areas of the province where there is a demand for the residual fibre from secondary users (pulp mills, pellet plants, bioenergy facilities, and other users of low-quality logs). These relationships are intended to lead to cost-effective removal of residual fibre through integrated methods, or “one pass” harvesting. Primary harvesters and secondary users are encouraged to share information on harvesting opportunities to start the fibre recovery process. Where business to business agreements cannot be established, there are legislative tools available for the District Manager to encourage better fibre recovery, such as creating fibre recovery zones or issuing secondary recovery tenures. More information on this Program can be found at Ministry of FLNRORD Residual Fibre Recovery.
Documents, Forms & Maps
Maps (PDF Download)