21st February 2008
EDITOR
continuation;
Section 4.6.2, subsection (iii) and (iv) of the CVFCʼs FSP is a very critical area that the
CVFC has omitted in their planned attack on the Camp Run Creek watershed. This has
left the community of North Canyon in a dangerously precarious position in this assault
on their drinking watershed. The CVFC has not identified the type and class of the
Camp Run Creek watershed, nor has it initiated the required public input pertaining tothis designation. This has had the effect of maliciously denying the community itʼs right
to engage the CVFC in a battle over the use of forest resources contained on Crown
lands. By undercutting the entire intent and purpose of the public participatory provision
written in to their own FSP, the CVFC has committed a serious contravention of their
duties and responsibilities as a logging company with access to the publicʼs cherished
forest resources. Where is the notion of ʻcommunityʼ in this community forest company if the very tenets of their own corporate objectives have been so blatantly ignored?
The citizens of North Canyon, when informed of this charade, will vehemently oppose any
logging activity in the Camp Run Creek watershed in order to protect their source water quality, quantity, and timing of the flow. The present debacle has resulted from the
abdication of any accountability on the part of the CVFC to the legitimate, overriding
rights of the NCID regarding the sanctity of their drinking watershed. The NCIDʼs right to
the protected waters of the Camp Run Creek watershed was enshrined long before the
CVFC was created to denude the timber resource, a resource the NCID requires to
remain intact for the continued production of high-quality drinking water.
Under Section 4.6 (Water) of CVFCʼs FSP, in compliance with Section 8.2 of the FPPR,
the CVFC has committed to undertaking hydrology assessments. These assessments
are to include input from “water licensees and any organized water groups”. The MoFR
specifically asked the CVFC to amend their FSP to include an “opportunity for public
working groups to have input on the assessment prior to implementation.”
The Ministry wanted “to see some form of public consultation that includes folks who may not be part of the CVFC Board.” It would seem that the CVFCʼs draft copies of their FSP did not include the very provision - encouraging public involvement and informing the public -they proclaim as one of their goals and objectives as a corporation in stewarding a community forest. The MoFR noticed this also, and instructed the CVFC to change their FSP to reflect this serious transgression of policy. The smoke-screen strategy was once again revealed.
Hydrology assessments commissioned by the CVFC are inherently biased and do not
provide for the protection of water-usersʼ sources as this conflicts with the profit motives
of the logging company. The CVFC has attempted to placate the NCID by suggesting
that the hydrologist to be hired by the CVFC will act in an independent and
professionally responsible manner in assessing the Camp Run Creek watershedʼs
vulnerability to logging and its effects on water produced by the catchment area. This is
another example of overt advocacy designed to ensure the continuation of the travesty
that is the logging of the publicʼs drinking watersheds. Any hydrologist understands all
too well the the intricate ecological interrelationships in a watershed that lead to the provision of high-quality drinking water. To suggest otherwise would be pure folly. The
logging industry in general would not continue to hire the services of any hydrologist if he or she were to deny them access to the very timber they are so anxious to attain.
The creation of the area of study known as ʻforest hydrologyʼ was instituted by the
forestry industry itself to legitimize and justify the logging of sensitive watersheds. It is
the NCIDʼs contention that (i) any input as a licensed water provider and an organized
water group should occur before the hydrologist does the study (ii) the protection and continued provision of the water supply should be allocated the sole top priority in this
investigation (iii) the allowance for any hydrological assessment must include the
stipulation of ʻground-truthingʼ of results as map-based assessments are inaccurate and
subject to incorrect interpretations, and (iv) the NCID must designate the hydrologist to
conduct the study to ensure that their concerns are paramount.
The CVFC is aware that the NCID has no information on the hydrological functioning of
the Camp Run Creek watershed in its present undisturbed state. The water supplier nor
the logging company has any baseline data to describe the water quality, quantity, and
flow regime that the watershed currently provides. The NCID has no information on the
catchment area or the recharge area of the watershed or the aquifer. The NCID has no
information on the nature of the aquifer in which our wells are located; the sources and
origins of the water that comprises the groundwater that forms the aquifer are not
understood. There is no evidence to determine if the NCID aquifer is under the direct
influence of surface waters from Camp Run Creek. There have been no hydrologic or
geotechnical studies to assess the geology of the aquifer recharge zone, which is instrumental in determining the rate of surface water infiltration into the NCIDʼs aquifer.
The interaction of Camp Run Creekʼs surface waters and the watershedʼs groundwater
involves many physical, chemical, and biological processes that influence the pathways for contamination of the aquifer.
There is no data to show these complex
interrelationships already in place and functioning for time immemorial in this very
special watershed. The NCID has been advocating that the precautionary principle be
applied in this matter concerning the Camp Run Creek watershed: ʻif we donʼt know,
then we donʼt goʼ succinctly describes this principle. The CVFC has stated that a short
hydrological study, conducted mostly from the cozy confines of an office somewhere,
will suffice to describe the possible implications of logging on the water supply in the
NCIDʼs drinking watershed. This assertion is utter lunacy and nonsense. The NCIDʼs
water users are not willing to be the unwitting guinea pigs in this dangerous game of
watershed roulette.
The FPPR grants forest licensees like the CVFC a wide degree of latitude in their
approach to watershed logging. This free rein is granted at the expense and liability of
water-user groups like the NCID. For instance: (i) Section 8 of the FPPR states that the
CVFC only has to conserve drinking water quality in the watershed if it does not unduly
reduce the supply of timber they are able to extract from the forests growing there, and
(ii) Section 8.2 of the FPPR states that when CVFC logging activities adversely impact
drinking water quality resulting in a threat to human health, the NCID as a licensed
water-user group would be responsible for installing the necessary water treatment
facilities to render the water safe for human consumption. The FPPR does nothing to
instill public confidence or to create assurances in the logging proposed by the CVFC. It is too late to try and remediate a watershed once the damage has been done through logging practices.
One has only to view the devastation that exists in the Sullivan Creek watershed, directly adjacent to the north of the Camp Run Creek watershed, for confirmation of this brutal fact; the quality, quantity, and timing of the flow of water from this basin is still terribly compromised, making it unfit and unreliable for human consumption some forty years after the logging occurred there. The small, highelevation Camp Run Creek watershed is much too valuable and sensitive as a source of drinking water to be compromised by logging in any form; resource exploitation, road building, and human trespass by the CVFC will destroy the water production of this vital watershed. This is the message the community of North Canyon would be giving to the CVFC if the logging company was following the format laid out in their FSP, and actually seeking the input of the public.