...the argument for an Eco-system based Community Forest
“When one tugs at a single thing in nature, he finds it attached to the rest of the world.” John Muir
“Of all the outputs of forests, water may be the most important.”
US National Research Council
We are stewards and stakeholders of the Glade Creek Watershed and members of the public. By way of this letter and attachments, the Community of Glade is submitting an application for a Community Forest Agreement (CFA).
On January 11, 2018 our committee met with our MLA, Minister Katrine Conroy. We spoke to her about the serious water issues facing Glade and asked her to support the Glade Community in this application. Minister Conroy agreed to assist us in obtaining a meeting with you, Minister Donaldson, and hopefully Minister Heyman, regarding this application.
For the past 3 years we have been trying to protect our water at a level that we feel is acceptable to the community, not only for the present, but also for the future. In the APEX hydrogeomorphic report, Dr. Green [the hydrologist hired by Atco Wood Products (Atco) and Kalesnikoff Lumber Company (KLC)] documented the past watershed degradation from logging and wildfire. Our watershed is in need of restoration, not further exploitation.
However, the current situation with Atco and KLC does not address either protection or restoration of the watershed. Management by Atco and KLC gives priority to short-term timber extraction at the long term expense to water. A CFA held by the GWPS would correct this problem.
The value that the forest adds to the health and welfare of all life is paramount and how we care for the elements of nature that provide us with these benefits needs to be foremost in our actions. These purposes would be the priority for management of the CFA.
We believe that a CFA based on principles of ecological restoration is a better system than currently is in place under Atco and KLC. Our watershed is small and it could be considered two even smaller Category 1 watersheds, the most ecologically sensitive watershed classification, due to its very different sub basins. Glade Creek Watershed has suffered from numerous past issues, and continues to suffer from recent landslides and high turbidity that compromise our water quality.
There are many advantages to having a CFA for Glade: climate change impacts will be addressed; fire risk in the WUI will be reduced; the current licensees will avoid a lot of ill will, bad publicity and ongoing strife under the current situation; Atco and KLC will be given first option to purchase any timber that the Glade CFA tenure extracts at a fair market value; and a Community Forest based on restoration can be an educational model for development of other sensitive watersheds .
There are a number of points that support designating the Glade Creek watershed as a Eco-system Based Community Forest Agreement under the control of the community to protect water and other ecological services vital to our community: 1. Glade watershed is in recovery 2. GWPS is supported by the Glade Irrigation District 3. Cumulative hydrological effects are not being considered 4. Predicted climate disruption concern 5. Management should be under one entity 7. Existing supportive political climate 6. Funding availability and local Community Forest knowledge
1. Our Community watershed is in recovery: It has suffered fire (1930), horse logging in the 1920’s, historic flooding, landslides which are still occurring today, high turbidity in our water, and conventional logging in late 1990- early 2000.
Atco has proposed plans to log the few older stands at the top of the watershed. These remnant old forests are the most valuable to the health and resilience of our watershed. Given its history and designation as a community water supply, the Glade Creek watershed is not suited to conventional logging. It needs restoration, both in the forests throughout the watershed and in the North and South fork channels to ensure a safe and potable water source for this community for many years to come.
KLC has plans to log young forests in the mid and lower elevations of our watershed. These forests are recovering from past logging and fire, and are just beginning to function well for conserving our water. From both the standpoints of water protection and mitigation of climate change, these young forests need to be protected from commercial timber cutting.
Our watershed is categorized as a sensitive Category 2 watershed, and it is small (2977Ha). One could argue that because the two sub basins of Glade Creek watershed behave so differently, as explained by Dr. Green’s APEX hydrological report that the Glade Creek watershed is actually comprised of two Category 1 watersheds. Category 1 watersheds are judged to be the most vulnerable to impacts. In the Community Watershed Guidebook it states: In general, the smaller the watershed the more sensitive it is to damage from forest land use. Application of community watershed guidelines will strongly and measurably benefit small watersheds.  Glade Creek Hydrogeomorphic Assessment. Apex Geoscience Consultants.Ltd. Apex File HA-15-KL-02, released Feb 2016  https://www.for.gov.bc.ca/tasb/legsregs/fpc/fpcguide/watrshed/water1.htm#2.1 Community watershed guidebook Oct 1996
2. The Glade Watershed Protection Society is supported by the Glade Irrigation District in this endeavor of ecological based forestry and restoration. The GID Board and trustees oversee the water distribution for 90% of the community, and have been in place since Glade received its second water Licence in 1973. The first was in 1908.
3. Cumulative Hydrological Effects are not being considered: The Glade Creek watershed is classified as a Community Watershed under the Forest & Range Practices Act (FRPA) The objective set by government in FRPA for the quality of water in Community watersheds is described in B.C. Reg. 14/2004 O.C. 17/2004 8.2 (2). It states that the objective “…for water being diverted for human consumption through a licensed waterworks in a community watershed is to prevent … the cumulative hydrological effects of primary forest activities…”
Cumulative effects are not being considered in the management of our watershed even though the Auditor General’s Office states that it is in “the interest of British Columbians to address cumulative effects management (in natural resources) without delay.” Firstly, the Ministry of Forests, Lands and Natural Resources has no policies in place to address cumulative impacts. In May 2015 the Auditor General’s Report Managing the Cumulative Effects of Natural Resource Development in B.C stated: “…neither legislation nor other government directives explicitly requires this ministry (FLNRO)… to manage cumulative effects when authorizing the use of natural resources” and that an “assessment framework is slated for full implementation by 2021. In the meantime, decisions regarding natural resource development continue to be made” - as is currently happening in the Glade watershed.
Secondly, the Glade watershed has been divided in half, with the top half of the watershed allocated to Atco and the bottom half allocated to Kalesnikoff. There is no watershed plan in place that coordinates the activities of the two companies in ways that protect water or other important ecological services, like carbon sequestration and storage, and biological diversity.
Thirdly, both lumber companies have stated that these cut blocks are the first and there will be others to come, but without a long-term plan the blocks are being considered piecemeal - without consideration of the impacts of their combined activities. We are very concerned that there will be cumulative negative hydrological effects on our forest, our water system and on Glade Creek. Under a CFA planned and managed by the residents of Glade, we would have the best interests of our water at heart and would work to eliminate negative hydrological effects on our water source.
4. Predicted Climate Disruptions are a Concern: Much Kootenay based scientific research has been done on the current effects of climate change occurring in our region. The Ministry of Forest, Lands, and Natural Resource Operations states “significant ecological change has already been observed”. Unfortunately, in the same article we read the challenges are: “Existing management objectives may be inappropriate because they were developed without considering climate change and do not generally include objectives for mitigation or adaptation, existing management strategies are unlikely to achieve existing objectives under a changing climate…In addition, slow regulatory or administrative change may pose a challenge to implementing timely management responses to changing conditions.”
The Forest Stewardship Council (Nov2016) in Managing for Climate Change states “climate change effects are shaping the character, renewal, and disturbance patterns of Canadian forests” (p3).
An Association of Professional Geoscientists and Engineers of BC 2012 document states that “for smaller watersheds, rain-dominated floods are expected with potentially higher peak flows due to increased storm precipitation intensity”. Dr. Kim Green, the author of the Glade Creek Hydrogeomorphic Assessment speaks of ‘ice jam floods’ (p31) in the Glade Creek watershed.
Dr. Martin Carver speaks specifically to the Glade Creek watershed in his expert opinion letter Is there a Threat to Glade Creek Drinking Water? Dr. Carver states: “…there is a high likelihood that the risks to the biological, chemical and physical water quality of the Glade community’s drinking water source will rise due to piecemeal resource development that is not aligned with the (climate) changes that are already underway and are expected to accelerate in the coming years and decades. … To maintain forest cover in a changing climate, any forest harvesting must shift focus from maximizing the timber resource, to maximizing ecosystem resilience.”
Our watershed is one of the few in the Kootenays that does not have extensive roads and/or logging in it. In the face of climate change, the relatively low levels of disturbance under CFA management by the Glade community are the best insurance for a continued safe source of water. Through an ecosystem based community forest, we will restore the natural forest composition and structure to build climate change adaptation in our watershed. This approach is not being undertaken nor seriously considered by Atco or Kalesnikoff for their logging in the Glade Creek watershed.
Resilience and Climate Change: Adaptation Potential for Ecological Systems and Forest Management in the West Kootenays: A detailed analysis of the potential impacts of climate change for forest management in the West Kootenays. http://www.westkootenayresilience.org/index.html Conservation Planning in the Face of Climate Change: A Case Study in Southeastern British Columbia. Project Overview: G. Utzig, P.Ag. http://www.westkootenayresilience.org/Conservation-Project.html. Vulnerability/ Resilience Project Documents (http://www.westkootenayresilience.org/page04.html) including: Climate Change Projections for the West Kootenays (G. Utzig, P.Ag); Ecosystem and Tree Species Bioclimate Envelope Modeling for the West Kootenays (G. Utzig, P.Ag.); Climate Change and Forest Health: Impacts to West Kootenay Ecosystems (H. Pinnell, R.P.F.); An Ecosystem Vulnerability and Resilience Assessment for West Kootenay Ecosystems (G. Utzig, P.Ag. and R.F.Holt, R.P.Bio.); Achieving Climate Change Adaptation in West Kootenay Forest Management – Barriers and Opportunities (C. Pearce, R.P.F); Water Monitoring and Climate Change in the Upper Columbia Basin https://ourtrust.org/wp.../2017-02_Trust_WaterMonitoring-ClimateChange_Web.pdf This 68 page report was prepared by Martin Carver based on a wide range of existing information and emerging science.  Adapting Natural Resource Management to Climate Change in the Kootenay Boundary Region, Considerations for practitioners and Government Staff (Feb 2016 FLNRO) p13 Ibid. p15 (Schnorbus et al., 2010) Aqua Environmental Associates, Professional Opinion Letter: ‘Is there a Threat to Glade Drinking Water Supply?’ January 2017 p6. http://www.protectgladewatershed.com/glade-water-section-29--impact-of-proposed-logging.html
5. There would be one entity managing the Watershed: The watersheds serving the Glade community will benefit from one entity managing the watershed—a Glade Community CFA. The fact that the Glade Creek watershed has been essentially cut in half with a straight line has little to do with any ecology and much more to do with the location of lumber mills and the objectives of timber companies facing timber supply shortages. To us, this situation symbolizes graphically that the current provincial priority for the Glade Creek watershed is to be a provider of timber, with little concern given to the value of water. The Glade community is much better positioned to protect water than timber companies.
6. Funding and local community forest knowledge and support would be available to the Glade community. Besides local experts like Herb Hammond, there are good examples of successful community forests in this area: the Harrop-Proctor Community Forest, the Slocan Integral Forestry Cooperative (SIFCo), and further afield in the province, the Xaxli’p First Nation’s CFA carries out eco-cultural restoration.
Glade Community Forest would have access to funding. From Silva Ecosystem Consultants Ltd., Herb Hammond states in his 34 page Initial Report: Proposed Logging in Glade Creek Watershed (June 2017): “Through the years, the provincial government has provided programs to fund various kinds of forest restoration. Currently the Forest Enhancement Society of BC provides significant funds for forest restoration. One of their priorities is to provide monies for forest restoration to holders of Community Forest Agreements. Given the need to mitigate climate change, which grows each year that we wait to take appropriate action, social subsidies for restoration are likely to continue. Thus, restoration forestry activities, which would be the primary focus of a Glade Creek CFA, would be likely to qualify for funding.” In conclusion, the Glade Watershed Protection Society and the Glade Irrigation District support the following statements by Herb Hammond, Forest Ecologist and RPF (Silva Ecosystem Consultants Ltd: Glade Creek Watershed, Initial Report):
Remnant old-growth forests need to be protected for both water production and mitigating climate change.
Forests occupying the remaining portions of the watershed are young, and need to be protected so that they may develop into old/old-growth forests capable of high quality water production and climate change mitigation.
Part of the protection of young forests would be to carry out restoration activities that would assist natural processes to heal the damage from past logging and other human activities, reduce fire risk, and improve water production and climate change mitigation. A byproduct of forest restoration would likely be small volumes of timber, which could be used to offset a portion of restoration costs.
7. Supportive Political Climate: The members of the Glade community are not a lone voice. Many citizens of BC, provincial and regional government bodies, academics and professionals in the field are speaking out about inequities in the system, the lack of oversight, the dangers of overharvesting, the need to protect our water sources, and the changing landscape in the face of climate change.
From MLA Heyman (March email 2017) “…it is clear that it is more important than ever that we stand up for water, and watershed protection and rehabilitation. A B.C. New Democrat government is committed to recognizing and protecting the right to clean, safe drinking water for all British Columbians.”
Minister George Heyman (Oct 2017): “Reviewing the professional reliance model is a top priority for this government because the public must be assured that we have a strong transparent process in place that upholds the highest environmental standards.”
Forest Practices Board, Dec 2017. Special Report: Opportunities to Improve the Forest and Range Practices Act: “There are many recommendations where government promised to look into issues and carry out follow-up work, but there is little evidence that has actually happened. This is particularly true of actions to review and strengthen FRPA legislation through a process of continuous improvement.“
Environmental Law Centre, University Of Victoria, (Jan2011): “This report explored the efficacy of public participation in environmental decision making and considered the various barriers… issues we identified…inconsistent and unduly narrow “standing” rules; diminished rights for citizens to pursue environmental appeals; the rapidly escalating costs incurred by citizens associated with participating in appeal processes including legal and expert witness fees.”
In a 2015 report Professional Reliance and Environmental Regulation in British Columbia the University of Victoria Environmental Law Centre concluded “that much of B.C.’s deregulation goes too far in handing over what are essentially matters of public interest to those employed by industry. Proponents should not be decision makers for matters involving the weighing and balancing of multiple, often competing, environmental and societal values.”
BC Office of the Ombudsperson: (Mar2014) Report #50 Striking a Balance: The Challenges of Using a Professional Reliance Model in Environmental Protection, British Columbia’s Riparian Areas Regulation (RAR): “We found that environmental protection programs such as the RAR must strike an appropriate balance between professional reliance and effective governmental oversight to work effectively.”
Simon Fraser University, Summary Report (Jan2009) Climate Change Adaptation and Biodiversity Transitioning to an Ecosystem Based Economy in British Columbia: “To sum up, there is no ability under provincial legislation to assess the cumulative effects of multiple decisions on the land base and watersheds. As a result, biodiversity is threatened and natural capital is being drawn down. This loss of biodiversity will have other significant economic impacts on communities, such as increased risk of flooding as wetlands are impacted, extended droughts in summer as the natural water storage capacity of ecosystems is reduced, and increased sedimentation of drinking water supplies, requiring either boil water advisories or additional, expensive water filtration and treatment.
UBCM Pre-conference Session (Sept2016) Forest Policy Decision-Making: The Case for Greater Community Consultation and Engagement: “Survey respondents noted that a lack of community engagement and consultation on forestry decisions leads to varied but significant consequences, and negative community impacts.”
Please seriously consider this application for Community Forest Agreement tenure to be managed and developed by Glade residents. Even maintaining best practices within the constraints of FRPA, neither ATCO nor Kalesnikoff are able to consider water protection as the priority. Therefore, we think that both licensees are not able to meet the public interest.
The BC Community Forest Association reports in Community Forest Indicators 2015: Measuring the Benefits of Community Forestry (Feb2016) that community forests (CF) have a range of priorities and motivations, but collectively their efforts support the provincial government’s goals. The report investigated eighteen indicators to measure progress towards the following four key objectives:
CF provide economic benefits to their communities and to British Columbia.
CF provide social benefits to their communities and to the province; they promote community involvement and participation, and forest worker safety.
CF promote communication and strengthen relationships between Aboriginal and non-Aboriginal communities and persons.
CF management is consistent with sound principles of environmental stewardship that reflect a broad spectrum of values.
Glade residents, the people who live in this community, are the best people to protect water through an ecosystem-based community forest. From the first settlers who came here in 1908, Glade has a long history of ‘Toil and Peaceful Life’. This community is well suited to the work at hand.  http://bccfa.ca/community-forests-community-benefits-the-economic-contributions-of-community-forests-to-rural-communities/
The value that the forest adds to the health and welfare of all life is paramount and how we care for the elements of nature that provide us with these benefits should be foremost in our actions. This value is as important as or, or even more important than, economic gain, for without the forest ecosystems we cannot flourish. Water is the priority – our forests that produce that water is our priority. Water is life and without clean water, nothing can live. Glade Watershed Protection Society, Glade, Castlegar, West Kootenays, British Columbia, Canada