Course:CONS370/Projects/The Stuwix Resources Joint Venture Case Study: Understanding Decision-Making, Relationship and Forest Management Planning for Forest Tenures Managed by Indigenous Peoples in the Merritt Timber Supply Area, British Columbia, Canada
For this case study, we will study the unique structure of the Stuwix Resources Joint Venture (SRJV); a First Nations forestry company comprised of eight bands in the Nlaka’pamux and Syilx territories (Cooks Ferry, Coldwater, Nooaitch, Shackan, Siska, Upper Similkameen, Lower Nicola, and Upper Nicola). This case study strives to explore how these nations work together to manage tenure and administrative agreements, make collective decisions that benefit all stakeholders, respect each other’s contextual knowledge and values, and how they manage relations with other interested parties. In addition, this case study discusses the importance to Stuwix Resources Joint Venture of managing forest lands for seven generations into the future by incorporating local culture and belief systems.
As two non-Indigenous students, we felt it was our duty to consult with an Indigenous representative of Stuwix Resources Joint Venture. Our primary contact for this project was Lennard (Lenny) Joe of the Shackan band, Nlaka’pamux First Nations. We are very grateful to Lenny who was kind enough to take the time to provide further insight on this case study, assist with the credibility of the content and share some of his values. He is the General Manager of Stuwix Resources Joint Venture, one of the first people in all of British Columbia to become a Registered Professional Forester and is also an Administrative Advisor to the Shackan Indian band. This case study will be shared with Lenny to ensure accuracy of the information.
- 1 Context and the Merritt Timber Supply Area
- 2 Tenure arrangements
- 3 Administrative arrangements
- 4 Managing relations within Stuwix Resources Joint Venture across the eight bands
- 5 Managing relations between Stuwix Resources Joint Venture and other interested parties
- 6 Discussion on how Stuwix RJV manage forest lands for seven generations and traditional values while also managing for timber production
- 7 Differences from non-Indigenous forestry practices
- 8 Conclusion and Recommendation
- 9 References
Context and the Merritt Timber Supply Area
Stuwix Resources Joint Venture operates within the limits of the Merritt TSA which is located in south-central British Columbia (BC). As described by the Ministry of Forests, Lands and Natural Resources of British Columbia:
"To the north of the Merritt TSA is the Kamloops TSA, to the west are the Lillooet and Fraser TSAs, and to the east is the Okanagan TSA. Manning Park, Cathedral Park and the Canada-United States border lie to the south. The total TSA, which occupies a total area of about 1.13 million hectares, is located within the Thompson Okanagan Region and is administered by the Cascades Natural Resource District in Merritt. The Merritt TSA includes the mountainous terrain and steep river valleys of the Cascade Mountains in the west and the relatively dry, flat Thompson Plateau in the east. The TSA encompasses two major river systems: the Similkameen and the Nicola."
First Nations play a significant role in the economy of the Merritt area. "First Nations play an active role in the management of forest resources having forest companies, resource based businesses and forestry consultation businesses." 
Stuwix Resources Joint Venture
Stuwix Resources Joint Venture is an Aboriginal forestry company operating in the Merritt TSA. Stuwix was named in honor of their ancestors – the Stuwix people who lived in this region hundreds of years ago. The establishment of Stuwix Resources has made room for First Nation cultural and traditional use practices to be incorporated in the initial stages of resource planning and management. This cooperation allows for First Nation culture to be "recognized, and encouraged as legitimate uses of the land."  Stuwix Resources Joint Venture is a forest company in the Merritt area that is jointly owned and operated by eight First Nation Bands in the Nlaka’pamux and Syilx territories (Cooks Ferry, Coldwater, Nooaitch, Shackan, Siska, Upper Similkameen, Lower Nicola, and Upper Nicola) .
Through relationship building the eight-band partnership developed from the Forestry Department of the Nicola Tribal Association. As a result of this relationship, in 2001 SRJV became the first owned and operated First Nation company to acquire a renewable forest license in BC with an allowable annual cut of 950 cubic metres. This license was transferred from Ardew Wood products.  The Indigenous Board and Investment Council describe how, "Ardew had a good relationship with the Bands and recognized their value as a partner, having worked together on cultural archeology issues and other projects. Once Stuwix Resources had its forest license, it received an Innovative Forestry Practices Agreement shortly after from the Province, making it the sixth licensee in the Nicola-Similkameen Innovative Forestry Society (NSIFS)."
As previously stated, Stuwix practices in the Merritt Timber Supply Area. A Timber Supply Area is established by the British Columbia government and is a designated area to practice forestry and improve on principles for allowable annual cut. Since, it is established and designated by the Ministry it is considered public land.  The Merritt TSA is a 1.1-million hectare area with 594,000 hectares of land available for timber harvesting (nearly 1.5 million acres).
From the outset, Stuwix resources had non-replaceable forest licenses (NRFLs). In 1996, Innovative Forestry Practices Agreements were introduced by the BC government and five licensees were awarded IFPAs in the Merritt Timber Supply Area. Section 59.1 of the Forest Act is an example of why these licensees are highly cherished; “Section 59.1 of the Forest Act enables the regional manager to increase the current allowable annual cut associated with the licence of an innovative forestry practices agreement holder.” At the time, there were no First Nations who were awarded with IFPAs.
Stuwix had to prove that they had more harvestable area through advanced technologies such as predictive ecosystem mapping and silviculture regimes. The Nicola-Similkameen Innovative Forestry Society website states, “Stuwix is the only First Nations company in the B.C. Interior to hold a replaceable forest license.” Stuwix Resources Ltd. is the company under which the replaceable forest license is held but the business is actively known as the Stuwix Resources Joint Venture. This replaceable forest license which was transferred in 2001 along with their NRFLs, time, support from the bands and experience they acquired one of the IFPAs. The IFPA was transferred from Ardew Wood Products with a start up allowable annual cut of 950 cubic meters. Allowable Annual Cuts are usually updated every ten years and around the time that Stuwix acquired their IFPA the AAC under their IFPA went up a million cubic meters. This increase was validated due to the rising mountain pine beetle epidemic and forest fires in the TSA.
All of this did not occur without conflict. There was tension in the TSA over harvesting on traditional land without any recognition or collaboration with the First Nations in the area. First Nations, such as Lenny himself set up blockades in the late 1990s in order to protest and claim their territory as their own. As a solution to the blockades, Lenny amongst others realized they must support the IFPA process but would only do so with a seat at the table. The large forestry corporations, after not being able to access their logging roads, had a sit down meeting where the arrangement was made for Stuwix Resources Ltd. to attain the IFPA. 
While Stuwix did have a non-renewable forest license and then succeeded in becoming the first First Nation to achieve an Innovative Forestry Practices Agreement, the attainment of a license was not the asset to Stuwix Resources Joint Venture, but rather it was the mechanism by which they could have some level of control over decision-making related to social and environmental goals and also build capacity within their bands to be successful in the forest sector. 
In 1996, the BC Government introduced Innovative Forestry Practices Agreements (IFPAs). The goal was “to increase the sustainability and productivity of forests in order to provide licensees with environmentally sustainable increases to their Annual Allowable Cut”.
To manage the five IFPAs as a cohesive unit and to ensure efficient use across the Merritt TSA, the Province created the Nicola-Similkameen Innovative Forestry Society (NSIFS) in 1998. The Society included the Ministry of Forests and the five licensees with IFPAs. Five licensees were awarded in the Merritt TSA as a result; including Stuwix Resource Joint Venture It is worth noting that the Province (BC government) recognized that each of the eight Bands involved in Stuwix Resources Joint Venture “represented a separate First Nations government." The Nicola Tribal Association Bands and the Upper Similkameen Indian Band did not have forest licenses which therefore prohibited their eligibility to obtain IFPA’s just yet and so they were “invited to be part of the Society because industry and government recognized that First Nations needed and deserved to play a bigger role in the local forest industry."
Today, the Board members include: Harvey McLeod (Upper Nicola Band), Harry Spahan (Coldwater Band), Bonnie Jacobsen (Upper Similkameen Band), Fred Sampslon (Siska Band), Aaron Sumexheltza (Lower Nicola Band), David Walkem (Cooks Ferry Band), Sharon Stone (Shackan Band) and Marcel Shackelly (Nooaitch Band). This relationship is visually represented in the Stuwix resources logo; which depicts 8 people surrounding one tree.
Although a unified First Nation’s company contributes to efforts of Indigenous governance and establishing responsibility for the lands they operate on and care for, the size of this company presents its own challenges. The eight bands “ranges from the 129 to 1,400 members, profits are shared equally by each of the eight shareholders. Where negotiations can be more challenging is in the division and assignment of millions of dollars worth of fee-for-service contracts to carry out work such as logging, hualing and silviculture."
Managing relationships and decision making across eight bands can be a challenge due to the diversity of hierarchies, knowledge holders and cultural practices. As members of the NSIFS, Stuwix Resources Joint Venture is incorporated into the NSIFS governance model. The NSIFS 2010-2011 action plan states that “all resolutions are based on a full Board of Directors’ quorum that supports the strategic objectives of the NSIFS. Two directors represent the First Nations and participate fully on the board. The NSIFS conducts a number of board meetings during the fiscal year to provide direction on activities, budgets, funding mechanisms, staff appointments and Timber Supply Analysis scenarios."
Communal and External Influence: Structure and Employment
Stuwix Resources operates on the communal land of the Nlaka’pamux and Sylix territories within the Merritt Timber Supply Area. They have a collaborative management agreement shared by eight first nation bands. Lennard Joe, the current General Manager of Stuwix Resources Joint Ventures (SRJV) said, “There was no partner that came to us and said we want access to those resources. It was an internal group of community members that said we want access to these resources.”
As a fibre management and marketing company, “SRJV has just seven employees and relies on contractors to carry out most of its work. While outside contractors were used at first to provide forest management, financial and sales expertise, Stuwix focused on developing internal capacity and quickly acquired the skills and expertise to carry out that work themselves."
Managing relations within Stuwix Resources Joint Venture across the eight bands
Stuwix Resources Joint Venture is responsible for the overall management of the licence, including planning, developing, marketing, timber-harvesting, road building and silviculture.To manage its new license, Stuwix Resources Ltd. created Stuwix Resources Joint Ventures (SRJV) in 2004. The company’s Board of Directors is “made up of one appointee from each Band." Just as Stuwix Resources’ Board of Directors is made up of one appointee from each of the eight Bands, so is the management committee of Stuwix Resources which makes operational decisions.
Interestingly enough, it was easier for Stuwix Resources Joint Venture to decide on profit sharing which they share equally regardless of the size of the band than it was easier for them to decide on which bands take on which management responsibilities for management of the forest resource including planning, harvesting, replanting and so forth.
"While the size of the eight Bands ranges from the 129 to 1,400 members, profits are shared equally by each of the eight shareholders. Where negotiations can be more challenging is in the division and assignment of millions of dollars worth of fee-for-service contracts to carry out work such as logging, hualing and silviculture. At Stuwix Resources, decisions about which Bands get which contracts are typically based on the size of the Band, its location and its capacity to carry out the required work."
They also decided early on that they needed to improve communications pathways and build capacity if they were to succeed. It became clear that they needed to spend time, effort and dollars on their people so they could develop the skills to manage the operations.
“Effective communication was a challenge at first,” said Lennard Joe. “As a result, investment in people was key and we spent more money on people building than anything else in the beginning. We brought in consultants for staff training and to work with the Board and the Bands to have effective communication. They gave us the tools to increase the likelihood of messages getting across. You’ve got to build on the people and build on the grass roots.”
Stuwix Resources Joint Venture also developed a Forest Stewardship Plan. This plan, as described by the Indigenous Business and Investment Council, "goes beyond the expectations with respect to First Nations consultation and protective measures by also considering and dealing with water management, protection of wildlife habitat and biological diversity, soil conservation & protection of ecological, geographical, historical and culturally special sites". 
Managing relations between Stuwix Resources Joint Venture and other interested parties
The eight bands that comprise Stuwix Resources Joint Venture are not the only bands on the TSA.
“The Merritt TSA includes the overlapping territories of the following First Nations: Adams Lake Indian Band, Ashcroft Indian Band, Stuctwewsemc (Bonaparte Indian Band), Boothroyd Band, Boston Bar First Nation, Chawathil First Nation, Seabird Island First Nation, Spuzzum FirstNation, Stó:lō Nation, Yale First Nation, Coldwater Indian Band, Cook’s Ferry Indian Band,Kanaka Bar First Nation, Lower Nicola Indian Band, Lytton First Nation, Nooaitch Indian Band, Shackan Indian Band, Siska Indian Band , Stk'emlupsemc te Secwepemc Nation, Tk'emlups, Skeetchestn, Upper Nicola Band, Upper Similkameen Indian Band, Oregon Jack Creek Indian Band, Lower Similkameen Indian Band, Neskonlith, Nicomen Indian Band, Okanagan Indian Band, Penticton Indian Band, the Nlaka’pamux Nation and the Westbank First Nation.
Communities located in the Merritt TSA include: Merritt, Princeton, Tulameen, Brookmere, Missezula Lake, East Gate, Douglas Lake, Spences Bridge and Allison Lake. First Nations communities located within the TSA include: Coldwater, Cooks Ferry, Nooaitch, Shackan, Upper Nicola, Lower Nicola and Upper Similkameen.” 
Due to the immense overlapping of territories and communities it was not always easy. While the eight bands had to work hard to achieve an IFPA, that was only the beginning of a journey to self-determination and to achieving social, economic and environmental goals for the eight bands. Stuwix Resources didn’t just have to learn how to operate as a Joint Venture between eight bands, they also had to learn how to interact with provincial government authorities, and other First Nations and forest product companies in the Merritt TSA.
It was important to Stuwix Resources to hold themselves and their contractors to high standards as their business would also affect those around them. Stuwix Resources reflected on a variety of certifications and determined they would achieve SAFE Certification.
"We wanted to build a really strong relationship with industry and with government,” says Joe. “So, we developed a SAFE Certification program under WorkSafe BC, and forced other companies to be SAFE certified under the BC Forest Safety Council. Many didn’t know how to do that, so we helped companies develop checklists and developed a safety manual.”
At a side event at the United Nations COFFI event at the Vancouver Convention Centre, Lennard Joe explained how Stuwix Resources Joint Venture also considered all three forest certification standards available in Canada: the Canadian Standards Association’s Sustainable Forest Management Standard, The Forest Stewardship Council’s BC Standard, and the Sustainable Forestry Initiative’s Forest Management Standard.  After hearing from representatives from each of these organizations, reflecting on the respective standards and the needs and values of the eight bands, Stuwix Resources Joint Venture felt the Sustainable Forestry Initiative’s Standard’s aligned tightly with their needs which included respect for the rights of Indigenous Peoples, respect for traditional knowledge and cultural values, and many other requirements for special sites, and biological diversity. In addition, the Sustainable Forestry Initiative offered things that the Forest Stewardship Council did not. SFI had local SFI Implementation Committees that enabled Stuwix to work directly with other forest companies, community interests and government representatives. The Sustainable Forestry Initiative also had requirements for training that was essential as Stuwix Resources was building capacity. In addition, the Sustainable Forestry Initiative had many other programs beyond the Standard including conservation collaboration opportunities, as well as opportunities facilitated by SFI to connect with other First Nations and Tribes whose traditional territory was comprised of forested land. All of these factors set Stuwix up for success in working with others on the land base and to build their capacity.
While Lenny Joe nor any of the eight bands were affiliated with SFI in any way, when the eight bands made a decision to certify to the SFI Standard as a mechanism to support training, planning, Indigenous values, and connecting with other interests on their landbase, it is encouraging to see that Chief David Walkem was on the SFI Board, and now Lennard Joe has a seat at the SFI Board. This First Nation representation on the SFI Board enables Stuwix Resources and the Nicola Tribal Association through Lennard Joe’s representation to have a voice and input on decision-making of SFI including but not limited to their governance, standard revision processes, their annual work plans, and their strategic direction.
“As Stuwix has progressed, the company has played an important role in establishing forestry best practices with organizations such as the Aboriginal Forest Industries Council, National Aboriginal Forestry Association, BC First Nations Forestry Council, Southern Interior Beetle Action Coalition and Omineca Beetle Action Coalition.”
Discussion on how Stuwix RJV manage forest lands for seven generations and traditional values while also managing for timber production
We asked Lenny Joe to clarify Stuwix Resources Joint Venture's goal to manage forests for the present but also to the benefit of seven generations into the future. To contextualize this goal, Senator Murray Sinclair of the Truth and Reconciliation Commission reminds the public that “residential schools were with us for 130 years, until 1996. Seven generations of children went to residential schools. It’s going to take generations to fix things.” The resulting fragmentation of Indigenous families resulted in fragmented language, traditions, self governance and even relations to their land--stolen lands in the hands of White colonialists. The effects are continuously felt; today and intergenerationally.
According to Lenny Joe, Stuwix Resources Joint Venture focuses on two main areas while managing forests for seven generations - food security and cultural survival. He describes cultural survival as “what we need to be who we are." This is connected to food security as Indigenous culture (language, laws, traditional ecological knowledge) are what drive relations to land and dictate the ethical practices for harvesting food. These goals strive for the overarching one which is to “rekindle all that was lost in the past." This does not imply that the past is the only source of information that will inform future action. This is because sustaining resource and culture requires adapting to changing environments in the present (natural, social, political, economic). Lenny Joe shares that “the responsibility to the land exists with or without tenures." It always existed but the efforts were fragmented as a result of colonial acts and imposition. The time to incorporate traditional values in order to sustain them for the future is now and involves a resurgence of language, practices and the creation of ethical protocols for working with Indigenous foresters. Stuwix Resources Joint Venture strives to revive and sustain rekindled knowledge and practices.
One example of how this is being achieved is using Indigenous ways of knowing to inform Stuwix forestry practices. According to Lenny Joe, the members of Stuwix Resources joint Venture develop their own management plans and principles based on the Sylix Nation’s Principles of the Land; which were applied to an action plan in 2010. These principles are known as the Suxwtxtem which consider the protection of water, travel corridors, migration patterns and food.These principles always gave insight in what needed to be maintained, where, and the how was learned from elders. The incorporation of the Suxwtxtem into measurables for an action plan are useful for helping other interested parties understand how these beliefs and values inform Stuwix Resources Joint Venture management plans. We asked Lenny to provide an example of how the Suxtxtem are put into practice:
“The principles of Suxwtxtem were brought forward from the Syilx tribe, the Upper Nicola Indian Band is one of our partners in our venture, and we were given the values to protect the land when the mountain pine beetle was at its peak. The values were designed to maintain riparian areas and to utilize natural breaks in the land. We had larger riparian management areas to protect the streams from sedimentation, as well as to provide shade and therefore help maintain temperatures. We would put our boundary at the stream band break, many times leaving behind valuable spruce. Pine stands are clearcut harvested but whenever possible, if understory stems that were not lodgepole pine were present, we would work to avoid knocking them over so as to have some standing timber on the block after harvest. We also thought that connectivity and travel corridors were important so we would design them in our cutblocks. Trails were most common along large streams and therefore we would have a larger buffer between the block and the larger streams so as not to interfere with the trails."
Stuwix Resources Joint Venture also strives to support other First Nations communities when working with other interested parties. In March 2018, the BC Ministry of Forests, Lands, Natural Resource Operations and Rural Development stated in the 1st Quarter report that, "In February, the Lower Nicola Indian Band Development Corporation, Stuwix Resources Ltd, and Aspen Planers (Aspen) signed a long-term Memorandum of Understanding (MOU) to set out a framework for negotiating agreements to contribute to Aspen’s timber supply and support First Nation community with forestry jobs. The Lower Nicola Indian Band has a long-term timber licence in the amount of 50,000 cubic metres per year. These logs will be supplied to Aspen’s Merritt mills.”
Currently, Stuwix is involved in a few projects. Lenny shares that:
“The first [project] is working directly with each of our bands referral agencies and communities to develop the Cultural Survival Area Management Strategy. It is a funded project where we are developing management strategies for many of our cultural values, for example, sasquatch and little people. The management strategies have spatial, temporal and protocol strategies attached to them so for example we look at block shapes, sizes, roads, for spatial, time of year, and how many years we can work in an area for temporal and whether ceremonies are required for protocols. Stuwix is also working on incorporation of cultural burning into our forest management plans. We think that fire needs to be reintroduced on the land and will be a good strategy for reducing fuel loading and therefore reduce fire hazard risks throughout our territory. We just completed a burn on the Shackan Indian Reserve last week and are planning for another burn in the fall.”
Differences from non-Indigenous forestry practices
Some of the differences between non-Indigenous and Indigenous practices, as evidenced by SRJV, include a Seven Generation perspective, planning for little people and Sasquatch, as well as logging road construction.
When Stuwix Resources Joint Venture makes a decision they think about what situation their people will be in seven generations from now and try to manage for what is to come. As mentioned above, they have developed a Cultural Survival Area Management Strategy to protect various cultural values such as little people and Sasquatch. Lenny said something along the lines of, "Sometimes you need to leave money on the table to protect other values." Nonetheless, Stuwix has provided a measurable for ecosystem mapping, spatial, temporal and protocol strategies for these cultural management strategies that they have received money from the province to support them.
While Lenny Joe already spoke about some of the differences in management such as planning for seven generations, the sasquatch and little people, what is interesting is that even the government of Canada is noticing their different techniques when it comes to forestry. Chief Forester for British Columbia, Diane Nicholls, noted this difference between Stuwix Resources and other practices regarding road construction in the Merritt TSA to help maximize and not waste timber harvesting land base area. Stuwix's method of constructing roads to be narrower than the 10 meter standard buffer allows them to fully rehabilitate once they are no longer needed and allows for the loss of productive forest land to be reduced. Diane Nicholls said in her 2016 annual allowable cut rationale, "I agree with Stuwix Resources that road rehabilitation and construction of narrower roads can reduce the loss of productive forest commonly associated with roads and other access structures, and I commend them on their efforts in this regard. I encourage all licensees to consider incorporating similar practices in order to mitigate the loss of productive forest, while maintaining road safety requirements."
Lastly, Lenny concluded that, “Stuwix prides itself as a company that works on behalf of its people to protect our interests to the land and resources while promoting our cultural practices on the land. Over time we have built a capacity that has been able to work with industry and government and develop a relationship that moves toward reconciliation."
Conclusion and Recommendation
This is a story on how the bands of Stuwix started out without a base of legal operating tenure. Now they are a functional, economical profitable company that manage forest tenures to respect Indigenous rights while running a profitable business that sustains the livelihoods of several First Nation communities. It demonstrates that they are not just a stakeholder, but much more. Collaboration is the future, not confrontation. Lenny mentioned how one of his goals is that with First Nations being more involved in the industry, their values will be incorporated locally, nationally and on the global market. When someone sees a piece of wood from Canada, he hopes that they will recognize that it is not only a piece of wood, but a piece of wood taken off of a First Nation traditional land that was sustainably harvested.
We learned a lot through this case study and found it brought a lot of the concepts learned in the Aboriginal Forestry (CONS370) course to life. Our recommendation would be to consider having Lennard Joe in as a guest speaker in the future as he embodies what we learn at UBC and so he can bring practical examples into the classroom.
- "Merritt Timber Supply Area: Timber Supply Analysis Discussion Paper" (PDF). Ministry of Forests, Lands and Natural Resource Operations: 3–5. July 2015.
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- "Stuwix Resources Joint Venture". Indigenous Business and Investment Council. Retrieved March 26, 2019.
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- "FADM - Timber Supply Area (TSA)". British Columbia Government. Retrieved March 25, 2019.
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- Joe, L. Personal Communication, April 1, 2019.
- Joe, L. Personal Communication, March 19, 2019.
- Thiem, Glenn (April 2011). "2010-2011 Annual Report For the Merritt IFPAs" (PDF). Nicola-Similkameen Innovative Forestry Society. Retrieved March 26, 2019.
- Nicholls, Diane (March 30, 2016). "Merritt Timber Supply Area: Rationale for Allowable Annual Cut (AAC) Determination" (PDF). British Columbia Ministry of Forests, Lands and Natural Resource Operations: 1.
- Joe, L. United Nations Committee on Forests and the Forest Industry event. "Forests are the Answer." November 8, 2019.
- "SFI 2015-2019 Standards and Rules" (PDF). Sustainable Forestry Initiative. January 2015.
- "Diverse Independent Board". Sustainable Forestry Initiative. Retrieved March 26, 2019.
- Rubinstein, Dan (October 5, 2016). "Truth and Reconciliation: Murray Sinclair at Carleton". Carleton Newsroom. Retrieved March 26, 2019.
- "Quarterly Mill Status Report -Q1 2018" (PDF). Ministry of Forests, Lands, Natural Resource Operations and Rural Development. May 15, 2018. Retrieved March 26, 2019.
- Nicholls, Diane (March 2016). "Merritt Timber Supply Area: Rationale for allowable annual cut (AAC) determination" (PDF). British Columbia; Ministry of forests, lands and natural resource operations: 11–12.
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