Mr. David Butt
Drinking Water Officer
Ministry of Health
Interior Health Authority
Creston, BC
February 23, 2008

Dear Mr. Butt,
This statement is being submitted by the North Canyon Improvement District (NCID)
Board of Trustees in response to a letter from the Ministry of Health (MoH) dated
December 18, 2007. The NCID is appealing the decision of the MoH, represented by
the Interior Health Authority (IHA) and the office of the Drinking Water Officer (DWO),
not to conduct an investigation - under Section 29 of the Drinking Water Protection Act
(DWPA) - requested by the NCID on November 1, 2007. The NCIDʼs Section 29
investigation request was in reference to a logging proposal, being prepared by the
Creston Valley Forest Corporation (CVFC), for the Camp Run Creek drinking
watershed.
The NCID contends that this logging proposal represents a significant risk of an
imminent drinking water health hazard to the community water system of the NCID and
its water users. The Camp Run Creek watershed is the sole source of drinking water for the community of North Canyon; the water purveyor has relied upon the undisturbed nature of the watershed as the primary source water protection barrier for one hundred years. In this statement the NCID Board of Trustees are petitioning the IHA, not only for an investigation under Section 29 of the Act, but more importantly for a complete halt to the logging proposal for their drinking watershed as per the DWPA Section 25, entitled
“Hazard abatement and prevention orders.” The NCID is requisitioning these actions by
the DWO based on the directives received by the water supplier in the December 18,
2007 IHA letter to the NCID. In that letter, the DWO refused to comply with the NCIDʼs
pleas for protection of their water source (under the legislation of the DWPA) unless the
CVFC chose not to “address the concerns of contamination of the [water supply source
of the] NCID,” or the “CVFC refuses to engage with the NCID on this issue.” This statement by the NCID will provide evidence that the logging company has violated both of these mandates, as the CVFC has refused to engage with the NCID on the issue of source water protection, and has not addressed concerns of contamination of the NCIDʼs drinking watershed. There is no indication that source water protection issues of vital importance to the NCID have been considered by the logging company, and because of this there is a serious threat that a significant drinking water health hazard will occur because of their proposed activities.
These drastic transgressions of the
logging companyʼs responsibilities dictate that the DWO conduct a prompt investigation
followed by the immediate issuance of an abatement order - under Sections 29 and 25
of the DWPA, respectively - regarding any proposed logging and road building activity in
the NCIDʼs drinking watershed, Camp Run Creek.

The following remarks are taken from an article entitled “Doctoring Our Water: From a
Policy of Protection to a Policy of Submission,” written by Will Koop for the British
Columbia Tap Water Alliance in 2002.
The Ministry of Health has historically been a government agency that supported water-user groups in their activities to protect drinking water sources. The Ministry's historic
mandate has been to act as guardians of the public's health;
utilizing a very strong vision and legislative framework, the Ministry of Health advocated for and protected drinking water sources. Since the late 1800s, this has been due, in large part, to the remarkable efforts of public health inspectors and public health engineers within the Ministry of Health, whose
avocation has been the protection of drinking water sources in order to protect human health.
The erosion of the Ministry of Health's authority and administrative powers over the last twenty years has resulted in a position of subservience within a highly political
and sensitive arena dominated by a special interest group, the logging industry. That is because the Ministry of Health has been assimilated into the pervasive provincial agenda that now permits the resource exploitation of drinking watersheds. The British Columbia provincial government has
practiced ʻsympathetic administrationʼ by catering to these special interests, resulting in the degradation of hundreds of drinking water sources. Under this new directive,
summarized generally as ʻmultiple useʼ or ʻintegrated resource management,ʼ the Ministry of Healthʼs historic role
and policy has been interfered with and then actively neglected by senior government administrators and politicians. This has eventuated in the removal of the powers
of the Ministry of Health officers to protect the collective drinking water sources in British Columbia.
Since the 1960s, despite the concerns of the public and the Ministry of Health, drinking water sources have been subjected to other resource agendas, both by government
and the logging industry. The protective legislation and policy which formerly emanated from the ardent and commonsense
views of the public and government leaders and administrators, has vanished. Despite widespread public disapproval and resistance, the provincial government has chosen to make devastating changes to its policies and
legislation protecting drinking watersheds. The present provincial government is a strong advocate for resource exploitation, a proponent for the systematic removal of
environmental regulations, and untiring advocate for industry self-regulation of its own “performance-based” activities on
Crown land.
Professional medical and health representatives have an
ethical responsibility for human life which should be reflected in their activities. It is this important responsibility which must be re-administered in the conduct of government duties, as it previously was, free from the influences of a ʻsympathetic administrationʼ that benefits special interests only. Provincial
health authorities are failing to live up to the public's expectations of them as guardians and protectors of drinking water sources in British Columbia. The senior administrators
within the Ministry of Health subscribe to the risky assumption that technology obviates the need for protection of water processes. The Ministryʼs historic mandate has been replaced with the authority to order municipal
governments to construct expensive treatment works in order to ʻprotectʼ the public from the degraded water being
produced from ʻunprotectedʼ watersheds. In order to accommodate business opportunities in community watersheds at the publicʼs expense, conscientious medical health officers have become ʻflies in the ointmentʼ of
provincial government policy and direction. This is a direct result of the government's interests in prohibiting criticism of
its mandates which are responsible for the degradation of these community water sources.

The above selection is a poignant synopsis, tinged with trepidation, of what has
transpired historically in relation to drinking watershed protection and the role of the
MoH in British Columbia. Therefore, it was with great optimism and gratitude that the
NCID was introduced to the following document at an IHA-sponsored workshop in Cranbrook in September 2007. In the May 2006 IHA publication entitled “Drinking Water Quality Improvement Program Guidelines for Operating Permit Conditions” (DWQIP), the MoH expresses their desire to “help water suppliers to reduce risks to public health by using a multi-barrier, source to tap approach to protect, monitor, and improve drinking water quality.” The MoH wishes to help drinking-water purveyors “to respond quickly to changes in water quality that may cause an increased risk to the health of their consumers.” The DWQIP is presented as “a way for Interior Health and water
suppliers to work together to improve drinking water quality through better protection
and monitoring. . . . ”