AAC Determinations – Wrong All This Time?

An Editorial Opinion – Right From The Stump, December 2, 2025

By David Elstone, RPF, GDBA - Spar Tree Group/View From The Stump & Jim Girvan, RPF, MBA - Associate, Indstrial Forestry Service Ltd.

A recent article in the Business In Vancouver (BIV) makes serious allegations into the process used by the province’s Provincial Chief Forester to determine the allowable annual cut (AAC), claiming the “BC timber harvest is vastly overestimated.” The BIV article, written by journalist Stefan Labbé is based on a “leaked” consultants’ report prepared for a group of First Nations whose traditional territory overlaps with the Mackenzie Timber Supply Area (TSA). The consultants that wrote the report are Dave Radies, an ecologist and Martin Watts, a registered professional forester.

The quotes and comments made in the BIV article challenges the (Provincial) Chief Forester’s role in protecting the public interest with respect to sustainable forest management, reading more as an “I gotcha moment” which questions the Timber Supply Review (TSR) process that underpins the setting of AACs across the province.

According to the BIV article,

“’there’s a strong likelihood that throughout the province we’re cutting almost at twice the rate of what is considered sustainable,’ said report co-author Dave Radies ‘We’re running out of wood.’” 

The BIV article reads,

“the unreleased report charges that the methods the province uses to calculate… how much can be logged...is fundamentally flawed and based on ‘wildly extreme assumptions’ that hurt the long-term health of BC’s forests.”

Quite the inflammatory commentary about a customary process for examining sustainable timber supply.

The BIV article also cites comments from a UBC forestry lecturer, Peter Wood regarding the AAC determination process:

“Without oversight, what comes out of the Ministry of Forest’s ‘black box of calculations’ has been difficult to prove or disprove”. The lecturer professor also is quoted to say that “this is how ghost towns are made.”

The BIV article states,

“According to Wood, the flawed assumptions and glaring omissions raised in the report show how BC’s complex forestry policy hides the truth from the public.”

The BIV article concludes that the cause of the long list of mill closures across the province is associated with the way AACs are determined with comment from an anonymous expert within the Ministry of Forests who,

“said the way timber supply reviews are conducted in BC amounts to ‘voodoo science’ and gross overestimates of harvestable wood.” 

And that,

“it’s a dirty secret. But if you lower that number, its seen as some kind of loss.”

The BIV article said the consultants noted the Ministry of Forests’ chief statistician,

“acknowledged that the ministry’s own calculation was not appropriate and supported the statistical approached taken by Watts.”

The BIV article, with its explicitly descriptive language, offers a damning impression of the AAC determination process, to the point of suggesting that allowable harvest levels are double what they should be.

For the general public reading the BIV article, they have no way to confirm or dispute the conclusions made, and the article’s messaging is now being proliferated by the environmental community as a fundamental reason to reduce AACs (which are often mistaken or equated with actual harvest levels).

With the blanket assertion that every TSR process conducted across the province is overestimating the AAC, the natural question arises:  Have the professional foresters working in the forest sector managed by the provincial government been “living a lie” of sustainability?

I am sure no one would say the TSR process is perfect. In fact, there are already efforts in place to change it via the Forest landscape Planning (FLP) process. That said, here are some thoughts to ponder which address some of the sensational statements made in the BIV article:

We focus our perspectives on the BIV article using our knowledge of the AAC determination process. For reference, you can check out this link to a TSR Backgrounder.

• It is important to clarify that the consultants’ report, as stated in the BIV article, is challenging the estimation of AAC for the Mackenzie TSA which “could have province-wide implications.”  Radies is quoted in the article to say  “there’s a strong likelihood that throughout the province we’re cutting almost at twice the rate of what is considered sustainable”

Rarely has the actual harvest been high enough to equal the AAC, and in fact, the harvest over the last couple of years has been close to half the AAC. One reason for the difference is that the AAC is a set maximum level that is allowed to be harvested, a level that is adjusted on a periodic basis (up to 10 years) through the TSR.

The actual harvest in any given year can fluctuate by immediate influences such as market conditions or ability to obtain cutting permits. The focus of the consultants’ report is about estimating the AAC. The actual harvest is a separate conversation, but to suggest that the AAC is estimated to be twice of what it maybe should be, does not mean we are actually cutting timber at twice the rate of what is considered sustainable.

• As far as we are aware, there is no position in the Ministry of Forests with the title of “Chief Statistician” which may explain why said individual is curiously not named in this article.

• The AAC determination process is not a “black box” but rather, follows a well-documented process where a large number of technical factors and assumptions are considered and assessed with full transparency in the TSR documentation and final AAC determination decision. The range of factors considered is legislated through the Forest and Range Practices Act and the Forest Act.

• As per the BIV article,

“Radies said the core problem is that the Minister of Forests can legally direct the chief forester to manipulate up to 49 inputs used to model how much timber is actually on the land base. That allows the minister to warp data and prioritize economic interests over what’s truly sustainable”.

“’The fact is, the minister puts restrictions on the inputs to the model to serve an economic interest. That’s what creates a lack of transparency,’ Radies said.”

This is an important comment to address as it suggests legalized political interference.

Nowhere within legislation, including the Forest Act and the Forest and Range Practices Act is the minister given power to direct the Chief Forester on inputs used to model how much is timber is actually on the land base.

A minister’s letter to the Chief Forester (which is public and included in the AAC determination) does give guidance on social and economic objectives of the government. The letter does ask the Chief Forester to consider these objectives when setting the AAC, but it does NOT specify to manipulate the inputs to the timber supply model.

Furthermore, the Forest Act, s8 (8) does list items that must be considered in determining the AAC, but again there is NO provision for the minister to direct manipulation of model inputs. The Chief Forester as a registered and regulated professional, makes an independent professional judgement focused on sustainability when setting allowable harvest levels. 

With no statute to support the claim of manipulation, it puts into doubt many of the other claims made by Radies and others in the BIV article.

• The Chief Forester is responsible for setting AACs that reflect current forest management approaches as dictated by existing regulations and policy established by all branches of government, not just that of the Ministry of Forests.

Direction on how forests are to be managed comes from other parts of government (e.g. wildlife specialists create objectives for wildlife management) – leaving the Chief Forester with the task of setting an AAC that aligns with forest management following these prescribed practices. There is little to no opportunity for the Chief Forester to influence how forest management is practiced on the ground through the TSR process (exception being First Nations rights and title issues).

• The Chief Forester does not speculate on land use decisions that have yet to be made by government and instead, follows the objectives already set by government. The same goes for negotiations and pending treaty settlements with First Nations. These parameters are clearly stated in the Mackenzie TSA Rationale for AAC Determination.

• The Chief Forester uses long-term planning horizons, up to 300 years, to capture the influence of future growth of harvested, beetle killed or burned areas. Reforested areas may fail, but they remain the legal responsibility of the licensee that harvested the area until regenerated. By law, they will eventually be reforested and therefore assumed to contribute to the future growth and yield of the area (an average regeneration delay is considered).

Because long term predictions of sustainability have a degree of uncertainty and new information becomes available, AACs determinations are reassessed at least every 10 years (by law).

• The timber supply review (TSR) process is well understood and takes into consideration a large set of values, data and commentary – it is an explicitly open and largely public process that takes several years to complete. Documents prepared for public review and engagement with First Nations include:

1)    An extensive data package of all data used in the modeling process to reflect assumption on current forest management;

2)    A Public Discussion Paper outlining the results of various analyses, and eventually;

3)    A concluding Rationale for AAC determination.

• The workings of the TSR and AAC determination are not a “dirty secret” or a “black box” process, but rather, one that is routinely replicated by knowledgeable and qualified professionals. Using the inputs that are largely cited and noted, the modelled timber supply projections can be easily reproduced. Several natural resource professionals including foresters and biologists all contribute to generating data used in timber supply reviews. It is inappropriate to label such standard modelling practices as “voodoo science.”

Mackenzie TSA AAC Determination

There may, however, be disagreement with the inputs and assumptions that come from the stakeholders to a timber supply review process. Looking at the Mackenzie TSR process in all three of its public reports, it would appear to be a well-documented, lengthy process that took into consideration input from many stakeholders including the collaborative technical working group formed between local First Nations and the BC government.

The resultant AAC determination appears to be an informed judgment made by the Chief Forester that draws a balance between the social, environmental and economic objectives of the Crown.

For those curious, the current Mackenzie TSA AAC, that has been disputed by Radies and Watts, has been reduced to below levels prior to the temporary increase in AAC due to the mountain pine beetle epidemic. 

The BIV article points to serious allegations that should be clarified.

If there is indeed validity to these allegations, that the Chief Forester supposedly used “wildly extreme assumptions” and as suggested by Radies who believes, “we’re running out of wood”, then there are at least two options to address their concerns which have been proven avenues for change.

First, they would need to raise their concerns about the Chief Forester with the Forest Professionals of British Columbia (FPBC) through a formal complaint. The FPBC is the regulator overseeing the practice of professional foresters in BC and has a duty to investigate allegations of improper practices by forest professionals.

Surely, an overestimate of twice the sustainable level of harvest is implying there must be improper practices, particularly if their report was cause for a former parliamentary secretary to the Minister of Forests (Mike Morris) to comment publicly (via the BIV article) on the credibility of the Chief Forester.

Second, any member of the public can file a complaint with the Forest Practices Board (FPB) for again suggesting that the Chief Forester and the TSR process has “grossly” overestimated the sustainable harvest across the province which if grounded in fact as taken verbatim by the BIV article would easily qualify as a legitimate concern to be investigated.

It would appear that the level of future sustainable AAC resulting from the Chief Forester’s AAC determination was arrived at after balancing input assumptions. The consultants believe the full adoption of their assumptions, having a more conservative approach to manage for uncertainties should have been used. Given the commentary of the BIV article which is now being widely cited, the public’s confidence is clearly at stake in the claims of sustainability of our province’s forests.

Where to go from here?

We would suggest BIV’s editor look to produce more balanced editorial because it is difficult to take the BIV seriously considering the one-sided language used to make the case that there is something not right in BC forestry. In doing so, it undermines the work of the consultants’ report, which could be an educational tool to advance forestry in this province but is now clouded in skepticism.

Also we suggest either Radies and Watts, the First Nations that supported and endorsed the consultant’s evaluation or anybody else in British Columbia, including the individual that “leaked” the consultants’ report, should contact the Forest Professionals BC (the regulatory body) or the Forest Practices Board (the agency responsible for investigating forest practices) with a formal complaint given their comments and finding amount to a shocking undermining of the public’s confidence in the management of BC’s forests.

FPBC registrants (professional foresters) ensure the multiple values society has assigned to the BC’s forests are balanced and considered. As the BIV article implies, Radies and Watts do not believe the Chief Forester achieved this balance.

It’s one thing to inspire a sensational article to propagate doubt, but if there are such strong convictions, for which there must be to write a 572-page report that was released to the BIV and therefore available in the public realm, then push forward and raise those convictions through formal channels, especially if there are greater implications to the province’s forest sector than just the Mackenzie TSA.

Of course, this is a two-way street. The consultants’ report has now made its way into discussions in the provincial legislature. Green MLA, Rob Botterell argued to the Minister according to legislature transcripts for November 25^th,

“British Columbians deserve the truth about what’s happening in our forests…A leaked technical review makes it clear the province is massively overestimating how much timber can be sustainably harvested, rely on wildly extreme assumptions, and that’s a quote, and may be cutting almost twice what is sustainable.”

The Minister has said that First Nations participating at the forest landscape planning table [presumably the Mackenzie TSA FLP project] “vehemently oppose the points of view that have been brought forward at that table [presumably from the consultants’ report].”

If the Minister and or the Chief Forester believe the BIV article’s commentary as well as the actions of Radies and Watts to be incorrect they too should be responding to these claims in a direct and very public manner (again looking to the FPBC or FPB) given the public interest.

Aside from the sensationalism of the BIV article, whichever side you believe, there is a need to investigate these claims given the risk to erosion of the public’s confidence in the province’s sustainable management of its forests.

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Written By David Elstone, RPF

Publisher, View From The Stump newsletter

Managing Director, Spar Tree Group Inc.

david@spartreegroup.com