Spray Lake Sawmills

Mixed Use Forest Management Workshop (Follow-up)

Forest Harvest Plan – West Bragg Creek

July 10, 2013


SLS has made the promise that it will carefully consider public comment and follow-up with stakeholders with a response. SLS will also follow-up with stakeholders with any changes made to a plan or operation as a result of public input. As stated at the workshop we want to continue to try new approaches working with the public to create plans that satisfy a diverse mix of uses on the landscape.


Below, we have listed the comments received from stakeholders at the June 11th workshop and we have given them careful consideration. We have also provided a response to explain how we have addressed the comments.


After carefully considering workshop comments, we believe stakeholders want more opportunities to be involved earlier in the planning process.  To accomplish this, SLS is proposing to pilot a 3 step, stakeholder collaborative harvest planning approach on the FMA as follows:


Step 1: SLS facilitates interested parties to develop preliminary harvest designs on a forest compartment basis using GIS, the Detailed Forest Management Plan and the General Development Plan. This will give stakeholders the opportunity to collaborate with SLS, prior to any field work or harvest plan submission to the government.


Step 2: If specific concerns are raised during step one, SLS will arrange a field tour with stakeholders to address specific concerns on the ground and make any needed mitigations etc. prior to any field work or harvest plan submission.


Step 3: SLS will follow-up with participants showing how the collaborative planning work was used to develop draft final harvest plans. Stakeholders will have the opportunity to comment on the draft plans prior to harvest plan submission. SLS will then follow up with stakeholders and write the final harvest plan and submit it to the government.


If a collaborative planning approach like this, is of interest to you, and you would like to participate on the pilot and or provide comment, your input is appreciated by October 1, 2013.



Breakout Group #1 (Jason)

Comment                                                                      Response

Why not use selective   logging or smaller cutblocks like they do in BC? The forests   found in Western Alberta are generally dry and cold and naturally prone to   large stand replacing wildfires. SLS’s, FMA is a fire dominated ecosystem and   lodgepole pine and white spruce are the dominate conifer tree species. In   general, these species do not persist for long periods of time on the   landscape and are not fire resistant. The establishment of young forest   habitat, by way of timber harvests, having large openings with variable edges   and variable retention levels are consistent with the FMA’s forest ecology and   landscape patterns. The dominant species, lodgepole pine also requires full   sunlight for growth and survival, which limits partial cutting options. From   an aesthetic standpoint, in block tree retention strategies, may be used for   softening visual impacts in visually sensitive areas. SLS has successfully used   recreation trail buffer retention for this purpose in West Bragg Creek.
Better   buffers are needed on ephemeral draws and intermittent streams. SLS has   recently updated its harvest policies related to ephemeral draw and wetland   buffers. SLS will be discussing possible ground rule updates with the   government. In reference to other forest management practices (including in   BC), SLS has some of the largest stream buffer requirements in North America.
Does SLS   review water management plans prepared for watershed protection? Although   there are no completed water management plans, SLS has historically worked   with the Bow River Basin Council and other water quality groups concerning   watershed management issues. SLS has recently volunteered to participate on   the Bow River Basin Council Board and is very concerned with watershed   management.
Should there   be a process in place to consider the recommendations of these plans in the Operating   Ground Rules (OGR’s)? How do we improve ground rules? Is there a process to   review these rules with the provincial government? There is a   process for OGR updates and SLS is actively working with the government to   keep OGR’S effective and up to date. When compared to other industries including   municipal development, SLS has the highest stream protection regulations in   the watershed. SLS is looking to continually improve its practices and individuals   or organizations concerned with ground rule effectiveness may contact SLS   anytime to share their specific concerns.
What about   water quality monitoring?

What about   cumulative effects? A cumulative impact assessment approach is needed to   consider past logging activities and other land uses.


In 2006, SLS   organized a cumulative effects group to discuss options for developing a   collaborative water quality monitoring program. The group included ENGO’s,   oil and gas, and government interests. Unfortunately, an agreement was not   reached on how to proceed with a joint program. SLS continues to be   interested in a joint, cumulative impact water quality monitoring program. SLS   has completed extensive water quality monitoring and watershed analysis (6   streams measured for 9 years).  The sub   watersheds studied had varying levels of use, ranging from virtually no   activity (the control) to high use, including forestry, riparian grazing and heavy   ATV, recreational use. This information is being summarized and will be   incorporated into the second version of the stewardship report to be posted   on our company website in August 2013.
Would like to   see historic blocks on maps.


SLS is   currently creating a new map template to improve communicating the locations   of our activities to stakeholders. This map will be posted on the SLS website   soon.
Grazing was   not mentioned at all during the presentation. Forestry takes away grass.

Fences need   to be built and we have to build them. If forestry is done they should burn   all the debris, clean everything up and don’t leave a mess. Grass seed all   the roads.

There’s a   huge impact on grazing. It’s disgusting. Prefers no logging, it’s ugly.

SLS needs a   landscape planner.



It’s SLS’s   goal to have constructive and positive working relationships with all forest   users including grazing permit holders. Forest operations have to be balanced   to meet a variety of objectives in addition to maintaining healthy range   sites for cattle grazing. SLS processes trees at the stump to evenly   distribute tops across the block. Approximately 90% of the nutrients in a   tree (like nitrogen and phosphorous) are located in the needles and branches   and are important for soil nutrition and forest health. The coarse woody   debris is also important for protecting seedlings from winter’s desiccating   Chinook winds and provides critical shade on dry summer day’s greatly   increasing seedling survival. SLS fully reclaims its roads with the intention   they will be reforested. The top soil is saved alongside road construction   areas. This soil contains viable seed and roots that are returned during the   reclamation process. After reclamation the exposed soil surface also creates   a seedbed for natural regeneration. In some cases SLS plants reclaimed roads   with seedlings. SLS strives to develop collaborative grazing timber   agreements for all of our harvest planning.
Two people   didn’t get the email invite to the meeting.


SLS is   continuing to try new approaches to provide meaningful opportunities for the   public to participate in FMA planning and operations. SLS advertises in local   newspapers, updates its website and sends out emails to the stakeholders   listed in our records. SLS encourages stakeholders to complete the email   subscription on the SLS Blog to ensure notification of upcoming news and events.  If there’s concern you’re not on our list,   please send us an email. We will respond back with an email to ensure the emails   are not accidently going into junk boxes. It’s also okay to phone us to   double check your on our stakeholder list.
Have third party decision maker   (arms-length) make decisions (Finland example). SLS developed   its Detailed Forest Management Plan in collaboration with the Alberta government   and stakeholder consultation. Provincial legislation and policy including the   Alberta Forest Management Planning Standard (A methodology approved by the   Canadian Council of Forest Ministers which satisfies the Canadian Standard   Association forest certification program for sustainable forestry.) SLS must   also obtain annual written approvals, from the Alberta government, prior to   any timber harvesting or road building on the FMA.



Breakout Group #2 (Rob):

Comment                                                                      Response

All uses on   same piece of land at the same time cannot work, Need zoning and priority   setting. SLS believes recreation   and forestry are compatible. This is based on feedback from satisfied users   and as evidenced by the recreational parking lots that are consistently full   of families, mountain bikers, hikers and horse riders enjoying the public   forests in West Bragg Creek.
Logging our   forests for local use is okay however, having products leave the local area   is unacceptable. Local means Alberta.


The wood   products industry is the third largest industry in the province. The industry   is sustainable and renewable and is vitally important for sustaining Alberta   families and communities. SLS products are made by Albertans and are sold within   Western Canada.
Forest   management = Forest Renewal

Must elevate   the uses of the land over a longer timeframe not just “point in time”. Mixed   use can work over a longer period of time.


Agreed. The   Detailed Forest Management Plan is a 20 year plan, renewed every 10 years with   the Alberta government. Forest management is modelled over a 200 year period.   All harvest areas are reforested to meet provincial standards.
Getting not   only stakeholder groups meeting and consulting but also senior government   officials and government agencies consulting.


See the   response on the bottom of page 3 related to the Detailed Forest Management   Plan and government approvals.
Mixed use   management means that more than just industry wins.


Agreed. SLS   believes communities benefit, due to job creation (manufacturing jobs are   scarce in Canada), company and employee related spending (helping diversify   and sustain the economy at large) and tax base contributions. Society as a   whole also benefits in terms of maintaining forest health and biodiversity, reducing   the risk of catastrophic wildfires that can negatively impact municipal   drinking water, air quality and important wildlife habitat.
Required to   test that the ground rules are meeting the objectives for the entire East   Slopes and that practices are meeting environmental and social outcomes.


The operating   ground rules are reviewed annually to ensure they are current and meet   environmental standards and social expectations. SLS is monitoring ongoing   operations and ESRD has a monitoring/enforcement program that tracks OGR   compliance.





Breakout Group # 3 (Jordan)

Comment                                                                      Response

A special   designation for areas with high density of trails – require special   consideration.


SLS is   looking to improve consultation approaches and use a collaborative public   consultation approach to meet diverse mixed use objectives.
Consider   planned logging roads to be turned into trails.


SLS is   committed to reclaiming all of its block roads to manage road densities below   thresholds identified in the Alberta Grizzly Recovery Plan. If new road   locations can mitigate water quality impacts, SLS will work with trail users   and the government to minimize linear disturbances on the FMA. Contact SLS   for specific areas in mind.
Consider   aesthetics from the point of view of the trail users (hikers). Wanting to   have opportunities to enjoy viewscapes from trails (less trail buffers). Contact SLS   for specific areas in mind.
Consider   Allotment Boundaries


See grazing   permit responses on the bottom of page 3.
Consider   Cumulative Effects (Oil & Gas / Forestry)


See cumulative   effects responses on page 3.
More   transparent forest modelling.


SLS has its Detailed   Forest Management Plan posted on its website. Please contact us for specific   concerns regarding forest modelling that cannot be found on our website.



Breakout Group # 4 (Bryan):


Comment                                                                      Response

Look back at   past experiences (Twenty-five years ago Bragg Creek had a collaborative   approach that was effective from start to finish)


Let us know   what you liked better about the process 25 years ago.
Recreation   and logging are the big issues, squeezing others out. Keep the focus on all   values and uses.


See responses   regarding grazing on the bottom of page 3.
Evolve as   things change.


How many   passes for each area? (2,3?)


Areas located   within Fire Smart Zones generally have increased harvest compared to non-fire   Smart Zones and were identified by the government as high priority for   harvest. Long term forest management planning is based on a forest   compartment basis. A spatial harvest sequence is established for a 20 year   period. This approach maintains forested areas adjacent to harvested blocks   on the landscape overtime.
Forestry   should recognize other values and how much use like recreation management   around these values.


Government   management on public lands. More government involvement in public   consultation.


SLS’s FMA is   administered by the government

SLS is   responsible for completing the public consultation. See responses regarding decisions   on page 4.

More   communication between users.


SLS is   striving to continually improve communication with stakeholders and   encourages them to contact us with their concerns.
Provide draft   maps for review through the process.


SLS is   currently creating a new map template to improve communicating the locations   of our activities to stakeholders and has some new approaches to offer
Look at other   areas that have similar situations, where collaboration is working better.


Our   suggestion is to not give up on this process. However, we are interested in   learning about any successful process.
Results: ask,   don’t tell.


SLS wants to   work constructively with stakeholders and develop balanced plans that   integrate all of the users on the landscape. We hope workshops like this will   lead to improved plans and improved consultation opportunities for   stakeholders.