BC Timber Sales - May 1, 2020-April 30, 2021 SFI Surveillance Audit
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BC Timber Sales – May 1, 2020-April 30, 2021 SFI Surveillance Audit Between May 1, 2020 and April 30, 2021 an audit team from KPMG Performance Registrar Inc. (KPMG PRI) carried out a multi-site surveillance audit of BC Timber Sales’ operations against the requirements of the Sustainable Forestry Initiative ® (SFI) 2015-2019 Forest Management Standard. This Certification Summary Report provides an overview of the process and KPMG’s findings. Description of the BC Timber Sales Organization BC Timber Sales is an autonomous organization within the Ministry of Forests, Lands, Natural Resource Operations and Rural Development (MFLNRORD), with financial and operational independence from Regional and District operations. The organization is comprised of 12 Business Areas with an operational presence in 33 locations across the province, and supports the Ministry's goal of providing British Columbians with sustainable benefits from the commercial use of public forests. BC Timber Sales provides these benefits by planning, developing and selling through auction a substantial and representative portion of the province's annual available timber volume. The bid prices received from auctioned timber drive the Market Pricing System for setting stumpage in coastal and interior operating areas of the province. The organization manages approximately 20% of the provincial allowable annual cut (AAC). BC Timber Sales does not operate any forest products manufacturing facilities, nor does it have a fibre sourcing program. BC Timber Sales Certifications BC Timber Sales holds a multi-site SFI 2015-2019 forest management certificate covering all of its 12 Business Areas (BAs) that is valid until September 9, 2022. Scope of the BC Timber Sales SFI Certification The BC Timber Sales multi-site SFI certificate applies to sustainable forest management planning and practices (roads, harvesting and silviculture) conducted by BC Timber Sales Corporate staff, Business Area staff, licensees/permittees and contractors (LPCs) in all of the following Business Areas: ▪ Babine Business Area (TBA) ▪ Cariboo-Chilcotin Business Area (TCC) ▪ Chinook Business Area (TCH) ▪ Kamloops Business Area (TKA) ▪ Kootenay Business Area (TKO) ▪ Okanagan-Columbia Business Area (TOC) ▪ Peace-Liard Business Area (TPL) ▪ Prince George Business Area (TPG) ▪ Seaward-tlasta Business Area (TST) #0746 ▪ Skeena Business Area (TSK) ▪ Strait of Georgia Business Area (TSG) ▪ Stuart-Nechako Business Area (TSN) A detailed listing of applicable forest management units is included as Appendix B of the BC Timber Sales Provincial Sustainable Forest Management (SFM) plan at: bcts_provincial_sustainable_forest_management_plan.pdf (gov.bc.ca) At the time of the 2020/21 surveillance audit BC Timber Sales had a combined AAC apportionment of 13,475,471 m3 per year within the forest management units covered under its multi-site SFI forest management certificate. This equates to a prorated area under management of 15,000,936 hectares. The 2020/21 audit confirmed that BC Timber Sales had not exceeded its combined AAC apportionment for the 2020/21 BCTS fiscal year. The total volume sold for the year across all Business Areas was 10,048,136 m3.
Findings – BC Timber Sales – May 1, 2020-April 30, 2021 SFI Surveillance Audit Page 2
All 12 of the BC Timber Sales Business Areas are covered by a multi-site SFM plan that
addresses the Objectives of the SFI forest management standard and includes a variety
of targets in relation to them. In addition, government-approved Forest Stewardship BC Timber Sales
Plans (FSPs) that address both timber and non-timber values are also in place. Various 2020/21 SFI Surveillance Audit
higher level plans developed by government (e.g., Land and Resource Management Findings
Plans (LRMPs), etc.) also provide direction to forest management within the areas
managed by the organization.
The areas covered by BC Timber Sales SFI certification fall within the following World Open non-conformities from
0
Wildlife Fund (WWF) ecoregions: (1) Alberta-British Columbia Foothills Forests, (2) previous audits
North Alberta Mountain Forests, (3) British Columbia Mainland Coastal Forests, (4)
Cascade Mountains Leeward Forests, (5) Central British Columbia Mountain Forests,
(6) Central Pacific Coastal Forests, (7) Fraser Plateau and Basin Complex, (8) Muskwa-
Slave Lake Forests, (9) North Central Rockies Forests, (10) Northern Cordillera Forests, New major non-conformities 0
(11) Northern Pacific Coastal Forests, (12) Northern Transitional Alpine Forests, (13)
Okanagan Dry Forests, (14) Pacific Coastal Mountains Icefields and Tundra, (15) Puget
Lowlands Forests, and (16) Queen Charlotte Islands.
New minor non-conformities 3
The forests managed by the BC Timber Sales are predominantly coniferous with the
main commercial tree species being Douglas-fir, hemlock (western and mountain),
western red cedar, yellow cedar, lodgepole pine, spruce (sitka, white, black, englemann
and hybrids), grand fir, subalpine fir, balsam fir, western larch and trembling aspen. New systemic opportunities
1
for improvement
The forest management approach employed by BC Timber Sales is based primarily
on even-aged management, ground and overhead cable-based harvesting systems,
clearcut harvesting with the retention of reserves of standing trees (either within or
adjacent to harvest areas), replanting of harvest areas within a few years with a mix of
ecologically suited tree species and control of competing vegetation through the use of Types of audit findings
government approved chemical herbicides or non-chemical means. Controls are in
Major non-conformities:
place to help reduce reliance on chemical brush control where feasible.
Are pervasive or critical to the
Audit Scope achievement of the SFM Objectives.
The audit was conducted against the requirements of the SFI 2015-2019 forest Minor non-conformities:
management standard, and incorporated an assessment against the SFI program Are isolated incidents that are non-critical
objectives for: to the achievement of SFM Objectives.
▪ Protection and maintenance of water resources;
All non-conformities require the
▪ Conservation of biological diversity; development of a corrective action plan
▪ Protection of special sites; within 30 days of the audit.
▪ Recognize and respect Indigenous Peoples’ rights;
Corrective action plans to address major
▪ Legal and regulatory compliance; non-conformities must be fully
▪ Training and education, and; implemented by the operation within 3
months (or up to 6 months at the
▪ Management review and continual improvement. discretion of the KPMG PRI Business
Leader) or certification cannot be
achieved / maintained.
Corrective action plans to address minor
non-conformities must be fully
implemented within 12 months.
Opportunities for Improvement:
Are not non-conformities but are
comments on specific areas of the SFM
System where improvements can be
made.
Findings – BC Timber Sales – May 1, 2020-April 30, 2021 SFI Surveillance Audit Page 3
The Audit
▪ Audit Team – The audit was conducted by Dave Bebb, RPF, EP(EMSLA), Orrin
Quinn, RPF (MBA), Yurgen Menninga, RPF, EP(EMSLA) and Craig Roessler,
RPF, EP(EMSLA). All of the members of the audit team have conducted numer-
ous SFM audits under a variety of standards including SFI, ISO 14001, CSA Z809
and FSC.
▪ Significant Issues Impacting the Audit – The 2020/21 BC Timber Sales SFI forest
management audit was conducted during the COVID-19 pandemic. In order to
help manage the health risks associated with travel and interpersonal interactions,
the audit was based on a hybrid model that included an enhanced off-site docu-
ment review/telephone interview component combined with a focused field visit to
each site by a single auditor. BCTS staff and licensee interviews were conducted
either over the phone or in the field with appropriate PPE and social distancing.
▪ 2020/21 SFI Surveillance Audit – The audit included an assessment of the
BC Timber Sales’ SFI program and the environmental management system (EMS)
procedures that pertain to it. Site visits were made to 6 out of the 12 Business
Areas (TSN, TSG, TCC, TBA, TOC and TST). In addition, the audit included an
assessment of the BC Timber Sales Corporate Office’s implementation of the SFI
program requirements that are applicable at the corporate level. This level of sam- BC Timber Sales is an autonomous organi-
pling meets the IAF (International Accreditation Forum) requirements regarding zation within the Ministry of Forests, Lands,
audit sampling for multi-site certifications with 12 sites. The audit involved a review Natural Resource Operations and Rural
of selected forest management plans and records, interviews with a sample of Development (MFLNRORD), with financial
staff, licensees and local stakeholders, and visits to several field sites (59 roads, and operational independence from
54 cutblocks and 14 silviculture sites) to assess conformance with the require- Regional and District operations. The
ments of the SFI 2015-2019 Forest Management Standard. The SFI audit took
organization is comprised of 12 Business
approximately 54.5 days to complete, 22 of which were spent on-site. The balance
of audit time was spent preparing the audit plan, completing off-site document re- Areas with an operational presence in 33
views of records supporting SFI conformance, conducting telephone interviews locations across the province, and supports
with selected BCTS staff, completing audit checklists, and preparing the main and the Ministry's goal of providing British
public summary audit reports. Columbians with sustainable benefits from
the commercial use of public forests. BC
▪ BC Timber Sales’ SFI Program Representative – Laura Chessor, RPF, Certifica-
tion Officer served as the organization’s corporate level SFI program representa- Timber Sales provides these benefits by
tive for the audit. In addition, the various Certification Standards Officers (CSOs) planning, developing and selling through
located at each of the local Business Area offices included in the audit sample auction a substantial and representative
acted as the SFI program representatives at the Business Area level. portion of the province's annual available
timber volume. The bid prices received from
Audit Objectives auctioned timber drive the Market Pricing
System for setting stumpage in coastal and
The objectives of the audit were to evaluate the sustainable forest management system
at BC Timber Sales to: interior operating areas of the province. The
organization manages approximately 20%
▪ Determine its conformance with the requirements of the SFI 2015-2019 Forest (14.2 million m3/year) of the provincial
Management Standard; allowable annual cut (AAC).
▪ Evaluate the ability of the system to ensure that BC Timber Sales operations meet
applicable regulatory requirements;
▪ Evaluate the effectiveness of the system in ensuring that BC Timber Sales meets
its specified SFM objectives;
▪ Identify opportunities for improvement, where applicable.
Use of Substitute SFI Indicators
None of the SFI indicators included within the scope of the assessment were modified
or substituted for the purpose of this audit.
Findings – BC Timber Sales – May 1, 2020-April 30, 2021 SFI Surveillance Audit Page 4
Audit Conclusions
The audit found that the BC Timber Sales sustainable forest management system:
▪ Was in full conformance with the requirements of the requirements of the SFI 2015
-2019 forest management standard included within the scope of the audit, including
the requirement to complete internal audits and management reviews at planned
intervals, except where noted otherwise in this report;
▪ Continues to be effectively implemented, and;
▪ Is sufficient to systematically meet applicable requirements and expected out-
comes, provided that the system continues to be implemented and maintained as
required.
As a result, the KPMG Lead Auditor has recommended that BC Timber Sales continue
to be certified to the SFI forest management standard.
Evidence of Conformity with the SFI 2015-2019 Forest
Management Standard
Primary sources of evidence assessed to determine conformity with the SFI 2015-2019
Forest Management Standard are presented in Table 1 below.
The audit included a review of selected
forest management plans and records,
SFI Objective # Key Evidence of Conformity interviews with a sample of sBCTS taff,
licensees and local stakeholders, and
1. Forest Management Planning Not in scope for the May 1, 2020-April 30,
visits to several field sites (59 roads, 54
2021 audit.
cutblocks and 14 silviculture sites) to
2. Forest Health and Productivity Not in scope for the May 1, 2020-April 30, assess conformance with the
2021 audit. requirements of the SFI 2015-2019
Forest Management Standard.
3. Protection and Maintenance of SFM plan, FSPs, EMS operational controls,
Water Resources conformance with the results of watershed
assessments, review of site plans and
harvest plans, inspection of a sample of
field sites with riparian features.
4. Conservation of Biological Diversity SFM plan, FSPs, interviews with planning
staff, EMS operational controls, review of
wildlife and biodiversity information and
strategies contained in BA GIS, site plans,
inspection of a sample of field sites with
wildlife habitat features.
5. Management of Visual Quality and Not in scope for the May 1, 2020-April 30,
Recreational Benefits 2021 audit.
6. Protection of Special Sites SFM plan, FSPs, review of site plans and
associated AIA (archaeological impact
assessment) results, review of selected
stakeholder and First Nations consultation
records, inspection of field sites.
7. Efficient Use of Fibre Resources Not in scope for the May 1, 2020-April 30,
2021 audit.
8. Recognize and Respect Indigenous BCTS policy on Indigenous Peoples’ rights,
Peoples’ Rights records of consultation with local
Indigenous Peoples, interviews with BCTS
staff and representatives of local
Indigenous Peoples.
Findings – BC Timber Sales – May 1, 2020-April 30, 2021 SFI Surveillance Audit Page 5
SFI Objective # Key Evidence of Conformity
9. Legal and Regulatory SFM plan, BC Timber Sales environmental,
Compliance social and health & safety policies, BA and
Provincial level EMS and SFI management
review records, BC MFLNRORD C&E
(Compliance & Enforcement Branch) reports,
BA non-compliance records, field inspections.
10. Forestry Research, Science & Not in scope for the May 1, 2020-April 30,
Technology 2021 audit.
11. Training and Education SFM plan, EMS and SFI awareness training
materials and records, interviews with a
sample of staff and LPC employees.
12. Community Involvement and Not in scope for the May 1, 2020-April 30,
Landowner Outreach 2021 audit.
13. Public Land Management Not in scope for the May 1, 2020-April 30,
Responsibilities 2021 audit.
14. Communication and Public Not in scope for the May 1, 2020-April 30,
Reporting 2021 audit.
15. Management Review and SFM plan, BA and Provincial level EMS and
Continual Improvement SFI management review records, internal In the picture shown above, the audit
audit reports and associated action plans, BA found that a temporary crossing on an
and Provincial level Environmental in-block S4 (small, fish-bearing) stream
Management Programs (EMPs), interviews had been removed by the TSL holder
with a sample of corporate and BA staff. following harvesting with little or no
impact to the stream channel.
Follow-up on Findings from Previous Audits
At the beginning of the May 1, 2020-April 30, 2021 audit year there was 1 open major
non-conformity and 6 open minor non-conformities from previous external SFI forest
management audits. The audit team reviewed the implementation of the action plans
developed by BC Timber Sales to address these findings and found that: (1) all of the
required corrective/preventive actions had been implemented, and (2) the actions taken
by BCTS were effective in preventing the recurrence of the issues that gave rise to
these findings. As a result, all of the open non-conformities identified during previous
external SFI forest management audits have been closed.
Good Practices
A number of good practices were identified during the course of the 2020/21 BC Timber
Sales SFI surveillance audit, including:
▪ SFI Objective 3 (Protection and Maintenance of Water Resources): An aerial in-
spection of a concrete bridge associated with a recent TSL found that the bridge
was well designed and constructed with respect to the approaching road grades,
concrete abutments, and riprap armoring the steep banks to protect the stream
crossing. (TSN)
▪ SFI Objective 3 (Protection and Maintenance of Water Resources): TBA’s FSPs
include riparian management requirements that often exceed the default require-
ments of the FPPR (Forest Planning and Practices Regulation). For example, the
Nadina FSP requires a 10m RRZ (riparian reserve zone) on S6 streams, a 25m
RRZ on S3 streams and a 35m RRZ on S2 streams. (TBA)
Findings – BC Timber Sales – May 1, 2020-April 30, 2021 SFI Surveillance Audit Page 6
▪ SFI Objective 3 (Protection and Maintenance of Water Resources): TBA has been
conducting its own effectiveness monitoring program based on Forest & Range
Evaluation Program methodology. The BA is currently assessing the effectiveness
of the larger RRZs required on S4 and S6 streams under the Bulkley and Nadina
FSPs, the ecological value of wildlife tree retention areas that are retained on har-
vest blocks, post-harvest coarse woody debris levels and the effectiveness of efforts
to retain visual screening on harvest blocks for moose and grizzly bear (for which
there is an objective in the Bulkley FSP). (TBA)
▪ SFI Objective 4 (Conservation of Biological Diversity): Joint annual monitoring
(which is completed by Forsite for BCTS, Tolko and West Fraser) of seral stage
distribution, patch size and ECA (equivalent clearcut area) within key watersheds
(Cariboo River, Cottonwood River and Horsefly River) is conducted as a means to
enable cooperative landscape level planning and help ensure that key landscape
level biodiversity and riparian management objectives are met. (TBA) Where identified during harvest block
layout, bear dens (such as that shown
▪ SFI Objective 5 (Management of Visual Quality and Recreational Benefits): TSG above) are excluded from the harvest
has had a significant level of engagement with the Snowden Demonstration Forest area by either relocating the harvest block
Advisory Group as a means to incorporate stakeholder concerns, including updating boundary or incorporating them within
the Snowden Guiding Principles to include a high recreation sensitivity map identify- internal retention patches. The BCTS
ing management standards in higher recreation use areas. This work also included EMS also includes requirements for
assisting the group with a 20-year plan to provide some certainty with the future workers to stop work and report to their
condition of the trail network. (TSG) supervisor in situations where previously
▪ SFI Objective 6 (Protection of Special Sites): The audit found that TSG had collabo- unidentified resource values are
rated with contractors, caving clubs, forest licensees, district staff, inventory staff encountered on active field sites.
and First Nations with respect to protection of Karst features. This included provid-
ing in-house expertise for the building of a Karst database to inventory operationally
important information. This has resulted in several benefits related to the safety of
workers, determining the significance of karsts features, increased accuracy of data,
identification of new surface features, and protection to important karst habitat and
critical bat habitat. (TSG)
▪ SFI Objective 8 (Recognize and Respect Indigenous People’s Rights): TCC has
created an Aboriginal Liaison group within the BA to help manage the Aboriginal
information sharing and relationship building process and address UNDRIP (United
Nations Declaration on the Rights of Indigenous Peoples) requirements. (TCC)
▪ SFI Objective 9 (Legal and Regulatory Compliance): TCC utilizes a number of plan-
ning tools (e.g., Universal Overlap Tool and the Landscape Level Checklist) to help
ensure that planned TSLs conform with FSP results and strategies and demonstrate
due diligence on the part of TCC planning staff and multi-phase contractors. (TCC)
▪ SFI Objective 9 (Legal and Regulatory Compliance): Based on staff interviews, the
audit noted that the Columbia field team staff walk all planned blocks and write the
site plans rather than contracting this work out. This increases the oversight over
layout contractors, reducing the risk that non-timber values and features might be
missed or not managed appropriately. (TOC)
▪ SFI Objective 9 (Legal and Regulatory Compliance): The TST audit noted that for
the sample of harvest inspections reviewed detailed notes were documented, re-
cording items such as the current status of activities, what was seen, discussions
with TSL holders, etc. This level of detail in inspection records helps demonstrate
due diligence and provides assurance with respect to the level of oversight by BCTS
staff. (TST)
NB: The above list of good practices is not intended to be a comprehensive list of all the
noteworthy or innovative forest practices that are taking place at the operations. Rather,
they are observations made by the audit team as a means to highlight some of the posi-
tive aspects of the organization’s forest management practices.
Findings – BC Timber Sales – May 1, 2020-April 30, 2021 SFI Surveillance Audit Page 7
New Areas of Nonconformity
The 2020/21 BC Timber Sales SFI surveillance audit identified a total of 3 new minor
non-conformities, as follows:
▪ SFI Forest Management Performance Measure 2.3 requires Program Participants
to: (1) ensure long-term soil conservation with the use of erosion control
measures to minimize the loss of soil and site productivity, and (2) construct roads
in a way that minimizes impacts to soil productivity and water quality. Further-
more, SFI Forest Management Performance Measure 3.2 requires Program Par-
ticipants to address the management and protection of all water courses during all
phases of management. These requirements are addressed through various
BCTS operational controls including the TSL document, EFP 01 and EFP 04 and
site plans.
The July 2019 TSN site visit identified a potential BA level finding related to inade-
quate deactivation (failure to remove log bundle cross-drains on a number of win-
ter harvest blocks prior to spring freshet), some instances of which were not iden-
tified in BCTS inspections. This issue was the subject of a follow-up special pur-
pose visit in July 2020 to assess TSN’s progress towards addressing it.
The 2020 special purpose visit found that TSN had completed all of its proposed
action plans to address this finding. However, the field assessment noted that log
corduroy and/or log bundles in stream/NCD (non-classified drainage) crossings
had not been removed prior to spring freshet in 6 out of 22 sites visited. Review of
the applicable inspection reports noted that TSN had improved in its timing and
accuracy of reporting and did identify most of the same concerns prior to the The audit found that TSG had
spring freshet. Further, TSN had instructed TSL holders to deactivate these collaborated with contractors, caving
stream crossings. Review of post-freshet inspections for these sites found that the clubs, forest licensees, district staff,
logs were not removed and TSL holders were then issued corrective action re- inventory staff and First Nations with
quests by BCTS to remove the logs. However, two of the 6 inspection reports did respect to protection Karst features. The
not note a final completion date for the corrective actions. Additionally, recent above picture shows a karst cave that
erosion was observed across a section of road with no waterbar resulting in sedi- was protected during harvesting through
mentation running into an NCD on a recently harvested TSL. (TSN)
the retention of a buffer of standing trees.
▪ SFI Forest Management Performance Measure 9.1 requires that Program Partici-
pants develop and implement a system to comply with applicable laws and regula-
tions, including those that relate to the transportation of dangerous goods. These
requirements are addressed through various BC Timber Sales EMS procedures
including EFP-06. The audit found that the requirements of EFP-06 had been met
in the majority of instances. However, inspection of an active TSL found a 700
litre specification slip tank in the back of a pick-up that was not adequately se-
cured to the vehicle to prevent its loss in the event of a rollover (i.e., it was only
tied down with a tension strap that was affixed to the tie-down hooks in the bed of
the pick-up). In addition, the inspection plate on the tank indicated that it had last
been inspected in August 2014 and as such the tank had not been inspected with-
in the 5 year period required under the TDG regulations. (TBA)
▪ SFI Forest Management Performance Measure 9.1 requires that Program Partici-
pants develop and implement a system to comply with applicable laws and regula-
tions. These requirements are addressed through various BCTS EMS proce-
dures, including the Incident Tracking System (ITS), which is now part of the LRM
(Land Resource Manager) system. However, the audit identified the following
weaknesses in the implementation of BCTS’ ITS procedures:
− The audit found that TSN had identified a number of non-conformities related
to TSL holders not removing logs in road crossings prior to spring freshet as
required by FPPR Section 39. However, these had not been identified as
incidents or tracked in ITS. (TSN)
− Review of TSG’s use of the BCTS Incident Tracking System noted several
recorded incidents. However, there were four regulatory non-compliances
identified by C&E that had not been entered into ITS. Note: TSG staff stated
Findings – BC Timber Sales – May 1, 2020-April 30, 2021 SFI Surveillance Audit Page 8
during the audit that they have to specifically request non-compliance infor-
mation from C&E and that BCTS HQ is currently in the process of developing
a MOU with C&E with respect to communication of non-compliance infor-
mation. (TSG)
− The audit noted a lack of detail in ITS regarding root cause analysis, the pro-
posed action plan or due date for one incident in ITS (lack of erosion control
measures on a road) although the status of this incident in ITS is closed.
Note: Evidence was later provided by TCC to support the conclusion that the
proposed action plan had been implemented as required. (TCC)
− TST experienced significant landslide activity in 2020-21, including at least 5
that were deemed to be anthropogenic in origin and according to EOP-04 are
classified as incidents. The audit noted that significant effort had gone into
investigating the causes and risks associated with these slides (including
bringing in a Geotech and Biologist where necessary to conduct assessments
and make recommendations along with other efforts). However, while the
EOP-04 EMS Incident Reporting and Investigation Flowsheet (and CHK-009
EMS Incident Report Form) had been completed in all cases: (1) none of
these incidents were entered within the required 30 day window and three
were not entered at all, and (2) the CHK-009s were found to be incomplete in
many cases, particularly with respect to incident investigation details. (TST)
New Opportunities for Improvement The above picture was taken during the
Several opportunities for improvement, many of which were restricted to a single Busi- audit on a recent TST harvest block. It
ness Area, were also identified during the 2020/21 BC Timber Sales SFI surveillance shows the retention of a large red cedar
audit. These have already been reported to BCTS through the Business Area level legacy tree as well a wind-firming
audit reports that were provided to the organization either on-site or soon after the (topping) treatment along the harvest
applicable Business Area site visits took place. In the interest of brevity, this corporate block boundary.
level Certification Summary Report only includes systemic (i.e., corporate level and/or
multi-Business Area) opportunities for improvement. However, Business Area level
opportunities for improvement are still followed up on by KPMG auditors during subse-
quent audit visits to these sites.
The 2020/21 BC Timber Sales SFI surveillance audit identified 1 new systemic oppor-
tunity for improvement related to the requirements of the SFI 2015-2019 Forest Man-
agement Standard, as follows:
▪ SFI Forest Management Performance Measure 3.2 requires Program Participants
to address the management and protection of all water courses during all phases
of management. These requirements are addressed through various BCTS opera-
tional controls including the TSL document, EFP 01 and EFP 04 and site plans.
The 2020/21 BC Timber Sales SFI forest management audit found that these
requirements had been met in the majority of instances. However, the following
isolated weaknesses were noted:
− The Client Self Inspection Report (BCTS CHK-011) includes general consid-
erations related to water and soil productivity. However, it lacks the specificity
of the additional guidance already developed by TSG. (TSG/Corporate)
− Inspection of a slide that occurred in 2017 found that road deactivation had
occurred to remediate the slide and the block had been planted after the slide
occurred. However, there were no trees planted on the slide itself. Reforesta-
tion (and revegetation) of the actual slide could have assisted with bank stabi-
lization and mitigate future risk of siltation. (TSG)
− The TCC audit found that the mapping of riparian features and associated
prescriptions met the requirements of the SFI forest management standard in
the majority of instances. However, one isolated weakness was noted on
A80516-1 where there were 2 versions of the harvest plan map present on
Findings – BC Timber Sales – May 1, 2020-April 30, 2021 SFI Surveillance Audit Page 9
the block that included different text regarding the proposed crossing of an on
-block S4 (small fish-bearing) stream, both versions of which were dated
05/17/2019. On one version the map correctly indicated that the proposed
crossing was on an S4 stream, while on the other it indicated that the stream
was an S6 (small non-fish bearing) stream. Note that other than the confu-
sion that this caused amongst the licensee’s site foreman and equipment
operators the impact of this discrepancy was minimal as the licensee had
elected to avoid constructing the crossing and relocated the road to access
the block at a different point. (TCC)
− A partially built road on an active TSL was visited during the field audit. The
road is in a community watershed and is planned for long term access to fu-
ture timber sales. A Terrain Stability Assessment (TSA) was completed on
August 15 2018, which had specific recommendations for the end-haul of soil
excavated road construction and a 1400mm culvert placement at an S3 The audit included the inspection of a
(medium sized fish-bearing) stream crossing, providing key protection number of post-harvest road/bridge deac-
measures for water quality in the community watershed. However, while the tivation projects, including a temporary
excavator operator interviewed during the audit was found to be aware of the bridge that had been removed from the
TSA prescriptions, road construction information critical to environmental S2 (larger fish-bearing) stream crossing
management was missing on several of the key documents that had been depicted above.
provided to the operator. (TOC)
Corrective Action Plans
Corrective action plans designed to address the root cause(s) of the findings identified
during the 2020/21 BC Timber Sales SFI surveillance audit have been developed by
BC Timber Sales and reviewed and approved by KPMG PRI. The 2021/22 audit will
include a follow-up assessment to assess whether the corrective action plans were:
(1) implemented as required, and (2) effective in addressing the root cause(s) of the
findings identified in this audit report.
Focus Areas for the Next Audit Visit
The following topics have been identified as focus areas for the next audit visit:
▪ Implementation of action plans developed by BC Timber Sales to address all open
non-conformities identified during external audits. (BCTS Corporate and all Busi-
ness Areas)
▪ A new SFI forest management standard was recently published by SFI Inc. Future
external audits will evaluate BCTS’ efforts to address the incremental require-
ments of this standard (e.g., revision of the BCTS SFM plan, responsibility matrix,
various EMS documents such as EOPs and EFPs, staff and LPC training materi-
als, etc.). (BCTS Corporate and all Business Areas)
▪ The extent to which FPOC (Forest Professional Oversight and Certification) is
incorporated into TSL requirements for higher risk timber sales (rather than simply
remaining a pilot project for a limited number of sales). (BCTS Corporate)
▪ Follow-up on the Business Area-specific SFM system issues/potential concerns
noted in the applicable May 1, 2020-April 30, 2021 Business Area audit summary
reports. (Applicable Business Areas)
▪ The level of merchantable waste levels left on site on cruise-based versus scale-
based timber sales. (TSN)
▪ Assessment of whether changes are required to the plan for the Schmidt Creek
Watershed in light of the results of the old growth review strategic review, and
continuing public and First Nation consultation findings. (TSG)
Findings – May 1, 2020-April 30, 2021 SFI Surveillance Audit Page 10
▪ Implementation of the BCTS TSG Terrain Risk Management SOP (standard oper-
ating procedure) to mitigate the risk of future landslides. (TSG)
▪ The action plan to address a 2019 internal audit finding regarding the Williams
Lake road inspection program was still in progress at the time of the 2020 audit
and had yet to be fully implemented. No inspections were completed in 2018/19
due to a staffing issue and there is now a significant backlog. TCC was in the
process of signing contracts with various local First Nations to do this work in
2020. However, the backlog of inspections had yet to be addressed at time of the
September 2020 external audit. (TCC)
▪ TBA progress towards filling the CSO position (the position had been vacant for
several months at the time of the September 2020 site visit, which had resulted in
some EMS requirements assigned to this position not being addressed in a timely
manner). (TBA) Inspection of a sample of reforestation
▪ Efforts by BA staff to ensure that road RoW (right-of way) logs that are cut during blocks during the 2020/21 BCTS SFI sur-
road construction (which may or may not be done by the holder of the TSL that veillance audit found that BCTS had met
the road accesses) are recovered in a timely manner to prevent degrade. (All the reforestation requirements specified
Business Areas) in the applicable FSP.
▪ BCTS’ responses to new and ongoing concerns raised by stakeholders and the
results of ongoing Forest Practices Board investigations.
Contacts:
Chris Ridley-Thomas, RPBio, EP(EMSLA) (604) 691-3088 This report is the property of KPMG and may only be reproduced by the intended
Dave Bebb, RPF, EP(EMSLA) (604) 691-3451 client, BC Timber Sales, with the express consent of KPMG. Information in this issue
is of a general nature with respect to audit findings and is not intended to be acted
upon without appropriate professional advice. © 2021 KPMG. All rights reserved.
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