From: Reid Robinson
To: Health, HLTH HLTH:EX
Cc: lynne.magee@viha.ca ; Fraser, Scott
Sent: Tuesday, January 06, 2009 8:59 PM
Subject: Re: Ministry of Healthy Living and Sport Response - 757635

Dear Tim Lambert,

During the passed 8 years, I have been directly involved in discussion with various timber companies, private property owners, including local government in the Port Alberni area, regarding protection of karst resources.

As a result, I have discovered that pubic awareness of Karst and associated drinking water vulnerability is poorly understood and not appropriately considered by utilities, timber companies or private property owners prior to conducting ground-breaking activities.  I can only conclude that fault lies with the lack of public knowledge, largely because of the absence of acknowledgement and vague generalizations in Section 23 of the Drinking Water Protection Act (DWPA) and associated Ministry guidebook(s).

Many in the scientific community consider karst terrain a type of wet-lands with special landforms and drainage characteristics due to greater solubility of carbonate rocks such as limestone. The Forest Practices Code, Biodiversity Guidebook Sept. 1995, for example infers that areas of exposed karstified bedrock are unique and require special management.

As you are most likely aware, the Ministry of Forests produced the 2003 Karst Management Handbook for BC, which was provided primarily as a guide for timber companies when conducting operations on crown land.  Never the less, most timber companies continue to believe that Karst is a recreational issue only.

During 2004, the BC provincial government established the Government Actions Regulation (GAR) providing the Minister of Forest and Range with an opportunity to protect elements of a karst system within provincial forests.  However, none of the 3 existing district GAR karst orders identify water as an important or significant element of a karst system.

In contrast, the DWPA provides no specify wording with respect to Karst, nor is the term or directive contained in related handbook guidance.  Current DWPA handbook definition for �Stream� for example, includes surface landforms such as swamp, ravine, gulch, etc, yet does not include exposed calcareous bedrock or associated features, such as swallets, sinking streams, sinkholes, vertical shafts, caves, epikarst or dry valleys.

Prior to December 2007, the term �groundwater� was also included in the Ministry�s guidebook definition for �Stream� (Working in and around drinking water?).  Upon learning of this, Ministry staff removed the term �groundwater� from the definition in less than one working day.

I do not believe it unreasonable to request revising Section 23 of the DWPA and related handbook guidance with the intent to clarify protection for karst, associated features and  drainage systems utilized for commercial and domestic water supply.

In light of your response and current expectation, Regional Drinking Water Coordinator Lynne Magee will be contacted and offered a field tour to better understood the high probability of future impact to karstic drinking water supplies.  Perhaps you would like to attend.

Thank you for sharing your perspective and recommendation.

Best Regards,

Reid Robinson