The comments below provide insight into the proposed development of an Order to protect more than recreational Karst values in our forest district. 

Letter October 13th 2008

Subject: Development of a Draft South Island Forest District GAR Karst Order

Hi Paul and All,

There are a number of ecological and management issues I would like to rise with regard to protection for karst ecosystems and related resources. Some of these issues include well-defined definition for problematic terminology, monitoring and enforcement.

Various Ministry staff (other than SIFD) has stated that definition for Karst Cave for example, is not advised because they are always changing. They assert, definition for Karst Cave may be challenged in court therefore, its best to allow a judge to decide resource feature criteria by simply referring to a dictionary. These types of comment infer reactionary strategy as opposed to meaningful legal directive to avoid impact to karst systems and related forest resource values.

An element of a karst system for example often includes non-karst caves, hydrologic and biologically connected to surface karst openings. The absence of definition for terms such as, Karst Cave threatens the opportunity to practice ecosystem-based management, and reasonable protection for key public environmental resource values.

In my view, well-defined criteria-based definition is necessary to meet the public expectation for potable water supply, government objectives for ecosystem-based management of forest resources, and provide clarity for forest workers, land managers and timber companies.

The BC Ministry of Forests, Recreation Manual, under Chapter 13, Cave/Karst Management, outlines Ministry responsibilities, provides longstanding inventory and assessment methology, definition and guidance.

As the new SIFD Manager Paul, could you provide some sort of a time frame for development of a Draft Karst Order, and share prospective on stewardship and legal requirement necessary to protect the natural function of karst ecosystems (including any contributing non-karst recharge zone). (The Drinking Water Protection Act for BC provides specific wording to protect a wells recharge area, but does not provide specific terms to protect the recharge area for karstic springs).

To assist in development of a karst order, I've attached a recent scientific paper which describes how the epikarst zone stores and releases groundwater through karst systems, sustaining perennial flow, resurfacing on slopes (epikarst springs). The paper also provides insight into the usefulness of ground penetrating radar as a management tool to prevent impact to near surface voids, streams and underground drainage pathways (conduits).

Epikarst_Williams.pdf  The role of the epikarst in karst and cave hydrogeology: a review. 

The photo shows a side view of local epikarst, courtesy of Craig Wagnell.

Best Regards,

Reid Robinson

MLA Scott Fraser's reply...

----- Original Message ----- From: "Fraser, Scott"
Sent: Tuesday, October 14, 2008 7:34 AM
Subject: Re: Development of a Draft South Island Forest District GAR Karst Order


Thanks Reid,

As usual, you are able to look below the surface on these issues.  Proactive definition is essential to ensuring adequate protection of caves, Karst and epikarst but also to ensure due diligence around public safety and water protection. That should not be the purview of a judge unless she/he is assessing damages where government policy (or lack therein like Walkerton) has already caused harm.
Judges, to my knowledge receive no specific training is karst/cave protection or their larger role in the environment.
In our earlier meeting with Minister Penner and senior staff, we made it clear that proper legislation was not just necessary for cave/karst/environmental protection, but for public safety (as in Walkerton). Accurately defining terms is an essential first step in appropriate legislation.

Thanks again Reid,

Scott