B. C. TAP WATER ALLIANCE
Caring for, Monitoring, and Protecting
British Columbia's Community Water
Supply Sources
P.O. Box #39154, 3695 West 10th Ave.,
Vancouver, British Columbia, Canada. V6R-1G0

May 24, 2009

Hon. Pat Bell,
B.C. Minister of Forests & Range

We would like to thank the Honourable Minister for the brief return email of
February 9, 2009, and Southern Interior Forest Regional Executive Director,
Larry Peitzsche's return letter of April 22, 2009. Both responses were to our initial letter of November 11, 2008 concerning the Creston Valley Forest Corporation Community Forest Licence to log in four community drinking
watersheds, three of which are designated Watershed Reserves (Arrow, Sullivan, and Lister Creeks) and one of which was a Watershed Reserve until being cancelled with no notice (Camp Run).

We would also like to thank the Minister for appointing one of his staff to contact us directly to discuss our concerns on January 28, 2009. For your information, we have included, as an attachment to this letter, a transcript of much of that conversation. As you will see, the substance of the Ministry's
subsequent official response dated April 22, 2009 has no bearing, whatsoever, on the discussion between your representative and me that occurred on January 28, 2009. This was in spite of the fact that, according
to your staff-person, a report would be prepared for you detailing the conversation. As a result, our concerns, about the government's handling of the Arrow Creek Watershed Reserve, as re-stated in the conversation of January 28, 2009, remain unanswered.

We note your comments, specifically about your, and your Ministry's, "confidence" in awarding a licence to log in community drinking watersheds, which, according to you, are to be "managed in accordance with legislation and to high environmental standards". Nevertheless, in the third paragraph of your email you also acknowledge our concern, with your Ministry's approval of a licence to build roads and log in Arrow Creek, given its legislative status as a "Watershed Reserve". Your email, however, failed to comment about the nature of the Reserves, vis-à-vis their function to
withhold Crown Forest land from dispositions of any kind. Neither did it acknowledge that these two issues - Crown forest dispositions (in this case, for Community Forest) and Watershed Reserves - are mutually exclusive
directives.

We also note the statement that logging in the four community watersheds by the licensee has "very strong support from the Creston community". However, correspondence files from the North Canyon Improvement District to the Ministry of Forests & Range, to the Ministry of Health, and to the Creston
Valley Forest Corporation over a four month period in 2008 makes it evident that the opposite is, in fact, true:

This document is a statement, prepared by the North Canyon Improvement District (NCID), detailing numerous serious Creston Valley Forest Corporation (CVFC) violations of their 2007 Forest Stewardship Plan (FSP) as
it pertains to their proposed logging in the NCID's drinking watershed of Camp Run Creek. This statement is centered on the CVFC's blatant disregard for the public participation process in their proposed logging of a drinking watershed...

. The NCID is, and has been, a licenced consumptive water-use group with a
water licence on Camp Run Creek since 1908. The NCID has relied upon the watershed in question as a primary barrier in their source water protection for a century. The pristine, undisturbed nature of the Camp Run Creek
watershed ecosystem has consistently
provided the drinking water quantity,
quality, and timing of flow necessary for the citizens of North Canyon.
There are very grave concerns and outrage within the community that the NCID
is being purposely denied an opportunity to defend the watershed for their
vital drinking water purposes. The NCID is appealing to the Ministry of
Forests and Range, Kootenay Lake Forest District, to order an immediate halt
to the CVFC's ruinous logging proposal for the Camp Run Creek watershed..

Copies of the North Canyon Improvement District's nine-page letter to Kootenay Lake Forest District Manager Garry Beaudry, dated February 15, 2008, were sent to the Minister of Forests & Range, to the Ministry of Forests & Range Deputy Minister, the Ministry of Forests & Range Executive Director, to the Forest Stewardship KLFD (Dale Anderson), to the Minister of Environment, to the Kootenay's Section Head of Water Stewardship, to MLA Bill Bennett, and to the BC Community Forest Association.

The Improvement District remains steadfastly opposed to any and all road
building and logging of the District's pristine Camp Run Creek drinking watershed (a former Watershed Reserve that was mysteriously cancelled on the whim of R.H. Roberts, a former Ministry of Lands, Parks and Housing Regional Director, who also inexplicably failed to notify the Reserve holder). This is entirely at odds with your Ministry's assurances of strong community
support.

And, to provide clarity, is your Ministry suggesting that, conversely, if a community does not support the community forest operating in its drinking water sources the areas would not be included in the community forest licence? The following indicates otherwise:

1. We know, for example, from the Sechelt Community Forest licensee (Sechelt
Community Projects, Inc.) that its Directors did not have, and still do not have, community support to log in the Sunshine Coast Regional District's Watershed Reserves. This was plain to all, especially your Ministry. Yet, from 2003 to early 2008 your Ministry studiously ignored the community's and
the Regional District's well-known concerns. This is where the matter rested until the Sechelt Nation finally intervened in early 2008 and the community watersheds became subject to Interim Measures.

2. Secondly, in a telephone conversation with BC Timber Sales top administrator, I was told that the Ministry of Forests and Range intends to log in every community watershed, no matter their given status as Watershed
Reserves. In this respect, we are also deeply disturbed by your administration's policy that sanctions logging in community watersheds under the "not unduly" clause of the Forest Act. Your administration stands alone in the history of British Columbia's Legislature having apparently decided that our most valuable collective asset - drinking water supply - is secondary in importance to timber supply.
In Chapter 8 of our book, From Wisdom to Tyranny, of which a copy was supplied to your office in June 2006, as well as the Ministers' of Environment and Agriculture and Lands offices, we explain how
government, apparently and purposely, withheld relevant information about the Watershed Reserves from Regional and sub-Regional land use planning processes, and, by
so doing, contravened legislation that necessitated the input of all Land Status information. This fact should in and of itself make the Kootenay Land Use Plan "illegal", or at least automatically subject to review, with
respect to decisions affecting Watershed Reserve lands.

Based on the foregoing, we question your Ministry's award of a Community Forest licence to the Creston Valley Forest Corporation to log in the Arrow, Sullivan, Camp Run and Lister Creek community watersheds. Please initiate the steps necessary to rectify this matter in favour of public health and community sustainability, as the community Watershed Reserve designations
intend.

We look forward to your response.

Sincerely,

Will Koop, Coordinator.

CC. Barry Penner, B.C. Minister of Environment
B.C. Minister of Health
B.C. Minister of Agriculture and Lands
Bob Simpson, New Democratic Party, Forests and Range Critic
Shane Simpson, New Democratic Party, Environment Critic
B.C. Green Party
Larry Peitzsche, Southern Interior Forest Region Executive Director
Garry Beaudry, Kootenay Lake Forest District Manager
Dr. Perry Kendall, B.C. Provincial Health Officer
B.C. Ombudsman
B.C. Forest Practices Board
Regional District of Central Kootenay
The Sunshine Coast Regional District
Union of B.C. Municipalities
The City of Rossland
North Canyon Improvement District
The City of Creston
Slocan Valley Watershed Alliance
Valhalla Wilderness Society
Perry Ridge Water Users
Western Canada Wilderness Committee
David Suzuki Foundation
Council of Canadians
Sierra Club of B.C.
Sunshine Coast Conservation Association
Sunshine Coast Concerned Citizens
British Columbia Environmental Network
Vancouver Island Water Watch
West Coast Environmental Law Association
The Creston Valley Forest Corporation
The B.C. Community Forest Association
Creston Valley Advance
Nelson Daily News
Globe and Mail
Vancouver Sun
Victoria Times Colonist
The Georgia Straight
The Tyee