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30th May 2018
Editors Note: The following letter was sent to government as a follow-up to our April 10th meeting with the Island MLAs/Ministers.


Greetings to each of you,

Vancouver Island Water Watch Coalition met with a number of you on April 10th, 2018.
At this meeting we requested that your government do the following:

1. Establish the legislative and regulatory framework to empower local governance of community drinking watersheds through the full implementation of the Water Sustainability Act (WSA) and its Regulations.

2. Amend the necessary forestry acts (The Forest Act, The Forest Planning and Practices Regulation, Forest and Range Practices Act, and the Private Managed Forest Land Act) to improve standards of practice and oversight. Forest harvesting and management standards in watersheds that supply community drinking water must be raised to ensure quality and quantity (supply) for future use, within the context of climate change.

3. Establish a Community Drinking Watershed Investment Fund for the purchase of Private Managed Forest Land Act (PFL), in community drinking watersheds on Vancouver Island. In addition, preserve and protect Crown Land within existing Vancouver Island TFL’s.

4. Amend the Mines Act to restrict mining activity in community drinking watersheds to ensure protection of source drinking water and the environment as the highest purpose.

In relation to #1 above we specifically requested;

• We call on the Minister of Forests, Lands, Natural Resource Operations and Rural Development to designate the development of Water Sustainability Plans for key watersheds on Vancouver Island

• We call on the Minister of Environment and Climate Change Strategy to set clear triggers for Critical Environmental Flow Orders and Fish Population Protection Orders at the regional level, Including requirement for a provincial environmental flows presumptive standard (which involves maintaining flow within a certain percentage of the natural flow regime) while more time- and cost-intensive region and site-specific flow thresholds are established.

• We call on the government to develop an overarching provincial strategy for water monitoring and data to fulfilling these commitments. The Province must build capacity to collect, store, analyze and report on data describing water quantity and quality (including a strategy to leverage community-based monitoring and incorporate Indigenous knowledge) in order to: better understand water and aquatic resources; identify high risk areas; and provide the necessary information to inform decision-making.

• We call on the Minister of Indigenous Relations and Reconciliation to provide funding directly to First Nations to ensure capacity to participate in and lead local watershed governance initiatives that address identified problems and co-develop a consultation framework for Water Sustainability Act phase 2 regulations with First Nations leadership.

In relation to #2 above we specifically requested;

• Amend section 8.2 of the Forest Planning and Practices Regulation to give priority to statutory water quality objectives over other land uses. Such a change is necessary to give Community Watershed designations the power to restrict logging. This would also mean the removal of point 3.

• Insert a provision within the Forest and Range Practices Act framework that would enable compliance and enforcement of water quality objectives established by the Ministry of Environment for Community Watersheds. This would give already existing water quality objectives on Vancouver Island the integrity and strength needed to ensure water quality.

• Amend section 4 of the Land Act to provide stand alone powers in sections 15 and 16 of the Land Act for the Lieutenant Governor in Council to establish watershed reserves of Crown land that are not affected by interests in land granted under the administrative authority of different Ministers. Doing so will give rise to the possibility of reserving watersheds from logging activities.

The Private Managed Forest Land Act and Regulations are sadly lacking in any kind of watershed protection. Section 13 – Water Quality, needs to be amended to include water quantity as well. We are wondering why this section does not cover off riparian areas around streams, lakes and rivers? This part of the Act should also include (d) and (e) from section 14. Section 21 should be repealed.

Concerning items #3 and #4 above, we left you with information that could be utilized alongside the development of any policies.

We are wondering when you may take action on any or all of the items we have raised?
Many of the Community groups that belong to VIWWC will be scheduling community town halls over the next two months to appraise the citizens in each community of what we have done to date as well as what we need the government to undertake on all of our behaves. Can you please provide us with some kind of timelines for address so we can in turn apprise the citizens in each of the communities?

With thanks.

June Ross
Chair – VIWWC
On behalf of all of the member groups that belong to VIWWC

Bcc – VIWWC Core Group