Don Kayne, CANFOR president and CEO
100-1700 W 75th Avenue
Vancouver, British Columbia
B.C. V6P 6G2
8 February 2017
Re: Moratorium on logging in Upper Clearwater near Wells Gray Park
Dear Mr. Kayne:
This letter is written on behalf of the Upper Clearwater Referral Group1 out of deepening concern that SARA-designated Critical Habitat for Caribou near Wells Gray Provincial Park is being destroyed by on-going logging by CANFOR – and that this logging has for some time threatened the future of these herds.
We note that in a statement by you to the Special Committee on Timber Supply on 9 July 2012, you succinctly laid out the terms of CANFOR’s commitment to its social license with the people of British Columbia. Included in the statement are the following two commitments:
CANFOR will not support actions that overturn landscape objectives set through public planning processes unless there is full public consultation and support.
We will not support actions that impact parks or critical habitat for species at risk.
Unfortunately, as we show below, neither of these commitments is commensurate with actions now being taken on behalf of CANFOR near Wells Gray Park.
I. Disregard for Public Process
In 1996 the B.C. Ministry of Forests (MoF) entered into a mediated, consensus-driven public process with the residents of Upper Clearwater, about two hours north of Kamloops. The end product of this 18-month process was a formal land-use agreement, Guiding Principles for the Management of Land Resources in the Upper Clearwater Valley (the Guiding Principles).
The intent of the Guiding Principles was to serve as a Local Use Plan under the Kamloops LRMP. In exchange for community endorsement of private woodlots on 1350 ha of public lands, valley residents were accorded a meaningful say in future forest harvesting decisions according to the terms set out in the Guiding Principles.
The Guiding Principles document was signed into effect by MoF in May 1999. While MoF has subsequently walked away from the agreement, CANFOR has nonetheless on several occasions publically committed to abide by the terms set forth within it.
In light of this, the Referral Group recently engaged with CANFOR and MoF in an eight-month Information Exchange Process intended to resolve numerous concerns raised by valley residents over CANFOR’s proposed logging here. However, of 15 concerns raised and discussed, CANFOR was able to address only three. The accompanying document summarizes the current status of the remaining concerns – including three in direct violation of the Guiding Principles and two in direct violation of CANFOR’s social license.
Notwithstanding local opposition to CANFOR’s cutting plans (which are unanimously seen as inconsistent with the Guiding Principles agreement), CANFOR has lately signalled its intention to go ahead with them.
This situation, in the view of the Referral Group, makes a mockery of your 2012 assertion that CANFOR “will not support actions that overturn landscape objectives set through public planning processes unless there is full public consultation and support.”
II. Disregard for Species at Risk
You will be aware that British Columbia’s Southern Mountain Caribou are now designated as endangered under the federal Species at Risk Act (SARA) and that B.C. has provincial, national and international responsibility for their recovery.
Perhaps you are also aware that Wells Gray Park currently sustains the world’s second largest southern Mountain Caribou population which, nonetheless, has been in precipitous decline since about 2000. The ultimate cause of this decline is widely attributed to excessive industrial-scale logging – much of it by CANFOR (John Surgeonor, pers. comm. 2012).
In October 2016, the Minister of Environment and Climate Change, Catherine McKenna, and British Columbia’s Minister of Environment, Mary Polak, announced a joint study to review regulations in place for the protection of Southern Mountain Caribou and their habitat – and “to inform a critical habitat protection assessment under the Species at Risk Act (SARA) to determine what additional steps may need to be taken by federal or provincial governments.”
In connection with this, we note that portions of the Clearwater Valley immediately south of Wells Gray are now designated under SARA as Critical Habitat for Caribou, as indicated on page 87 of the 2014 SARA Recovery Strategy for the Woodland Caribou, Southern Mountain population.
At the same time we also note that CANFOR is preparing to conduct industrial-scale logging here in the very near future, as outlined in the accompanying map. Indeed, CANFOR’s general manager for forest planning, Peter Baird, recently announced that the “logging blocks under discussion … would yield about 200,000 cubic metres of wood – equivalent to between 20 and 25 per cent of CANFOR’s Vavenby division’s annual allowable cut.” Much of this has already been cut, and indeed all of it is located within SARA-designated Critical Habitat for Caribou.
These observations are, we submit, irreconcilable with your 2012 assertion that CANFOR “will not support actions that impact parks or critical habitat for species at risk.”
Please be aware that the Upper Clearwater Referral Group has recently called upon Premier Christy Clark to establish a moratorium on industrial-scale logging in SARA-designated Critical Habitat for Caribou near Wells Gray Park – a moratorium that would remain in place until such time as Wells Gray’s Mountain Caribou show definite signs of recovery.
In light of CANFOR’s avowed commitments to its social contract as referenced above, we encourage your company to stand down from further logging here for the duration of the moratorium; and further to join us in pressuring the B.C. Liberals to establish it.
Trevor Goward (spokesperson, Upper Clearwater Referral Group)
1 The Upper Clearwater Referral Group is a citizen committee established on 22 November 2000 by the B.C. Ministry of Forests (MoF) to ensure adherence to a formal, government-sponsored Local Use agreement called the Guiding Principles for the Management of Land and Resources in the Upper Clearwater Valley. For its part, the Guiding Principles agreement had been signed into effect by MoF on 19 May 1999, but later quietly dropped by the B.C. Liberal government during transition to the Forest and Range Practices Act [The Referral Group].
One test of CANFOR’s respect for the Guiding Principles would have been how different its harvesting plans in Upper Clearwater look different from harvesting plans anywhere else. To us they look pretty much like business as usual.
15 CONCERNS FORMALLY RAISED WITH CANFOR ON BEHALF OF UPPER CLEARWATER RESIDENTS BY THE REFERRAL GROUP BETWEEN NOVEMBER 2015 AND JUNE 2016
Note: While items 3, 4 and 9 have formally been addressed by CANFOR, the remaining 12 items remain unaddressed. Refusal to seriously address items 1, 8 and 11 places CANFOR in clear violation of the Upper Clearwater Guiding Principles, while failure to address items 12 and 13 places CANFOR in direct contravention of its own social license as articulated by CANFOR president and CEO Don Kayne.
- 1. The stipulation under the Guiding Principles that water quality, quantity and timing of flow of six streams that cross private property should be maintained “within their natural range of variability.”
- 2. The importance of recognizing that Clearwater’s $20 million tourism industry is grounded in wilderness values, which place a premium on unaltered landscapes readily disrupted by industrial logging.
- 3. The requirement under the Guiding Principles to avoid creating visually disruptive clearcuts in sensitive areas visible from Spahats Picnic Areas and the Green Mountain Lookout tower.
- 4. The importance of placing logging activities out of sight of trail access to prominent existing and proposed tourist features.
- 5. The importance of ensuring that logging does not detract from key features of government-supported initiatives, i.e., (a) the Buck Hill Regional Park Proposal (proposed by the Thompson-Nicola Regional District); (b) the UNESCO GeoPark (supported by BC government, now spearheaded by the TNRD); and (c) and World Heritage Proposals (now spearheaded by the Wells Gray Wilderness Society).
- 6. The importance of recognizing the negative impact that on-going industrial-scale logging near Wells Gray Park has had – and continues to have – on the park’s declining, formally endangered Mountain Caribou.
- 7. The importance of maintaining forest structure conducive to heavy hair lichen production – again for Mountain Caribou.
- 8. The requirement under the Guiding Principles to maintain wildlife travel corridors, including the creation of leave strips sufficiently broad to protect against windthrow clearcut margins.
- 9. The importance of properly regenerating sites prone of Alder while at the same time avoiding herbicide use.
- 10. The need to ensure stability of soil and, in the case of volcanic hyaloclastite deposits, to avoid creating conditions conducive to landslides.
- 11. The requirement under the Guiding Principles to refrain from logging oldgrowth forests.
CANFOR’s Social License
- 12. CANFOR’s obligation under its social license to “refrain from overturning landscape objectives set through public planning processes without full public consultation and support.”
- 13. CANFOR’s obligation under its social license to refrain from impacting parks or other areas that provide critical habitat for species at risk.
- 14. CANFOR’s questionable use of professional reliance, e.g., hiring an owl expert to advise on caribou management, engaging a hydrologist unwilling to acknowledge the implications of climate change on his prescriptions, and refusing to allow peer review of its terrain report by specialists in volcanic geomorphology.
- 15. Concerns over the feasibility of legal recourse in the event of downstream damage to private property traceable to logging by CANFOR.
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