Forest Practices Code Discussion Paper: Industry's Key Messages
(Initial evaluation only: May 2002)

General Messages:

• It is important that British Columbians, dependent on a healthy forest sector, take time to participate in the provincial government's Forest Practices Code discussion paper review process.
  
  
• This review process provides British Columbians from all walks of life the opportunity to work together in support of an industry that provides great benefits to all British Columbians and is sustainable for future generations.
  
  
• British Columbians and their government want to ensure their forest industry is efficient, sustainable and competitive. To that end, we need a Forest Practices Code that is based more on managing the forests than processing paper; a Code that meets the public's environmental performance objectives while allowing companies to be ever more innovative.

Government's Overall Strategic Direction is Sound:

• The provincial government's strategic direction and its prescription for economic renewal are sound. When implemented they should serve to revitalize the forest industry and the provincial economy.

Ministries' Proposed Code Won't Achieve Government's Objectives:

• Unfortunately, the proposals by the Ministries of Forests and Water, Land and Air Protection for changing the Forest Practices Code will not fulfill the government's prescription for economic renewal. In fact, these changes could make things worse for the industry, not better.

An Alternative is Needed:

• An alternative to the Ministries' proposals, that will better satisfy the government's objectives, must be adopted.

Fundamental problems with the Ministries' proposed Code:

1. Unworkable regulatory regime: Rather than streamline the regulatory burden, the new plan creates an unworkable regulatory regime. For example:
   
   
   • Inadequate Socio-Economics: Although the Ministries' Paper suggests that the Code must recognize socio-economics, these considerations appear to be largely excluded from decisions under the Ministries' proposed Code;
     
     
   • Inconsistent Results: Although the Paper calls for workable results, it proposes results that are inconsistent, with limited opportunity to reconcile the inconsistencies;
     
     
   • All Penalties: Although the Paper emphasizes the importance of compliance, it focuses on penalties and ignores the value of incentives and certification;
     
     
   • Multiple Ministries, Little Integration: Although the Paper calls for single decision makers in government, it indicates that three Ministries will have decision making authority related to their proposed Code.
     
     
2. Worse than current Code: Rather than improve on policies developed in the 1990s, the new model could, in key respects, be worse.

The implications of these problems:

1. Added costs, not more competitiveness: Rather than restore industry competitiveness, the Ministries' proposed new Code is likely to increase industry costs.
   
   
2. Reduced timber supply, not enhanced ability to expand: Rather than create opportunities for increasing the sustainable timber supply, the Ministries' new Code assumes ongoing reductions and the related adverse consequences for the province.

An Alternative: Principles for a Workable Code:

1. Balances values: Both economic and environmental considerations should factor into decisions under the Code.
   
   
2. Requirements should be achievable and adaptable to circumstances: The Code should establish achievable results through a flexible process based on the application of judgment to the varying values, forest conditions and innovations around the province.
   
   
3. Promotes good performance: The Code should provide incentives and recognize certification. It should contain an efficient and just compliance and enforcement system that clearly distinguishes between good and poor performers so that government resources can be focused on the latter.
   
   
4. Integrated with Other Government Ministries & Initiatives: The new Code and other important government initiatives, such as strategic planning and the working forest, should be fully integrated to deliver the government's objectives.