PART 2 – continuation of February 15th letter

The CVFC was initially formed to log the publicʼs sensitive Crown lands,
somewhat dubiously labelled the ʻcommunity forests,ʼ in the Creston Valley. The welldocumented
efforts of licensed, organized water-user groups to protect their drinking
watersheds in the Creston Valley has long been a thorn in the side of both government
and the forest industry. The people in the Creston Valley, including North Canyon, have
been adamant in their voice concerning this issue; there was to be no logging
whatsoever in drinking watersheds like the Camp Run Creek. Owing to this history of
vigorous public opposition to logging in the areaʼs watersheds dating back to the early
1940s, the provincial government undertook a number of devious strategies to subvert
the publicʼs wishes and to facilitate logging in these highly sensitive, publicly-defended
watersheds. The latest strategy by the government was to dish out community forest
license tenures to groups – like the CVFC in the Creston Valley – in order to distance
themselves from the historical controversy surrounding logging in the publicʼs drinking
watersheds. The provincial government quietly allocated the CVFC several contentious
and highly-valuable drinking watersheds for their logging activities, including the Camp
Run Creek watershed. The ʻresultsʼ and ʻstrategiesʼ approach legislated within the
Forest and Range Protection Act (FRPA) and the Forest Protection and Planning
Regulation (FPPR) – which leave the publicʼs water supplies vulnerable to the profitmaking
discretion of logging companies – together with CVFCʼs hollow rhetoric about
eco-forestry practices, has given them permission in their own minds to ignore public
dissent and to launch this assault on the NCIDʼs drinking watershed. Even CVFC
procedures contained within their own 2007 FSP indicate that they are to conduct their
activities for much more than mere corporate profits; theirs was to be a far grander
vision encompassing both meaningful community involvement coupled with ?an
ecologically responsible philosophy of forest stewardship that respects all forest values
and functions.? This has proven to be nothing more than a smoke-screen strategy
designed to cloak the main purpose, which was to enable the CVFC to log highlysensitive
Crown lands in the Camp Run Creek watershed previously protected for the
sole purpose of providing the NCIDʼs drinking water.
The following evidence will document the CVFCʼs very serious violations of their 2007
FSP with regard to public participation in the logging of Crown lands encompassing the
NCIDʼs drinking watershed. The CVFC boldly states in their own corporate literature that
one of their primary goals and objectives as a corporation is ?to encourage involvement
and to inform the public in management of forest resources.? Another of their selfproclaimed
goals is ?to provide the maintenance of water quality, quantity, and flow
regime of all streams and lakes within the operating area of FL A54214.? Towards these
ends, the CVFC is required to provide a written notice of referral – under Section 21 of
the FPPR – to licensed consumptive water-user groups once their FSP has been
formulated. This referral letter is to ?specify the dates, location and time that the public
viewing will take place,? as they must ?provide the opportunity for agencies or the public
to meet with them to review the plan.? In addition, the CVFC is required to meet Section
20 of the FPPR by printing a notice of the public viewing opportunities in a minimum of
one local newspaper. There is a strong suggestion by the Ministry of Forests and Range
(MoFR) that ?broader advertising is encouraged as it will likely encourage more public
participation.? The CVFC is to send out the referral letter at the same time as they
advertise the FSP in the local newspaper(s). The CVFC is then to allow sixty days from
the date of the letter for the public to provide their comments.
The CVFC is not in compliance with Section 21 of the FPPR, as the NCID has never
been provided with a written notice of referral as a licensed consumptive water-user
group in the Camp Run Creek watershed. Because of this, the NCID has had no
opportunity to engage the CVFC in the early stages of their logging plans and to
express their strong opposition to this scheme. Indeed, except for the Board of Trustees
of the NCID, the rest of the community of North Canyon is not aware of the CVFCʼs plan
to log in their drinking watershed. Not only does this violate Section 21, but it is in direct
contravention of their own goals and objectives as a corporation, stated in their 2007
FSP, to ?encourage involvement and to inform the public in management of forest
resources.? The CVFC is quick to point out that they did comply with Section 20 of the
FPPR, however, they did not adhere to the strong MoFR suggestion that ?broader
advertising is encouraged as it will likely encourage more public participation.? The
CVFC has purposefully denied public notification of the NCID, as well as broader public
participation in general, in order to avoid the very serious concerns the NCID and others
would have expressed about the second CVFC corporate goal mentioned earlier; that
is, ?the maintenance of water quality, quantity, and flow regime? within the Camp Run
Creek watershed. The notion of a community forest is meaningless unless and until the
community has a chance to exercise their right to the protection of their drinking water, a
forest resource of the highest order for any community. The CVFC has made it very
clear in their literature that they feel the ?important local stakeholders have been
notified? of their FSP through ?participation on the CVFC Board of Directors.? The CVFC
Board knew about the FSP and the subsequent plans to log Camp Run Creek, but the
North Canyon community knew nothing of it because they were deemed to be
unimportant local stakeholders by the CVFC. The NCID begs to differ with this
derogatory designation, and demands the right to have their watershed protected for the
sole purpose of the providing a reliable supply of high-quality drinking water.
Under Section 4.6.2 (Consumptive Use) of the CVFCʼs FSP, in compliance with
Sections 59-61 of the FPPR and Objective 6 of the Kootenay-Boundary Higher Level
Plan Order, the CVFC committed to stringent forest stewardship strategies. Their plan
indicated they would (i) obtain the latest data on water licensees within a watershed
from the Water Stewardship Branch of the Ministry of Environment (ii) field locate licensed water userʼs points of diversion (iii) identify and define the type and class of
watershed, and (iv) provide for local water usersʼ input. The CVFC has committed to a
very precise format for achieving all of these objectives. According to CVFC statements
in their 2007 FSP, drinking water resources are the most important value in community
forests. Drinking water is given a higher priority as an important watershed forest
resource than any other component of the ecosystem therein. Consultation with
licensed water users is purported to be critical for the CVFC. The following is taken directly from their 2007 FSP.