Below is my response to Tim Sheldan regarding
water protection for springs and their source.
----- Original Message -----
From: Reid Robinson
Executive Division Office, Forests FOR:EX
Sent: Friday, September 26, 2008 12:14 AM
Subject: Re: 114722 - Water quality
Congratulations as Assistant Deputy Minister Tim, you've come a
long way since we last meet. Thank-you for responding to my
letter of July 5, 2008 to the Honourable Pat Bell, Minister of
Forest and Range regarding drinking water and other related
karst resource issues in general.
In your response you state; 'All water sources used for public
consumption, regardless of being located on private land, are
regulated under the Drinking Water Protection Act (DWPA) which
is now administered by the Ministry of Healthy Living and Sports
and was put into place after the tragedies in Walkerton, Ontario
If the intent of the DWPA is to regulate all water sources, then
why did Water licensed Holders in 2002 and again in 2006
repeatedly defend their karst groundwater supply against
groundbreaking and other threatening activities?
In addition, during August 2007, BC Hydro entered onto Island
Timberlands property to replace power poles which required
groundbreaking activity including road repair. Some of the
pressure treated pole sites for example were drilled between
adjacent sinkholes and fine sand and gravel was placed on
previously washout roadbeds. As a direct result, the karst
groundwater supply experienced higher than normal sediment loads
a few months later, causing the Health authority to issue a Boil
Water Order. Also, water users are now concerned that the toxic
wood preservative used on the new power poles will soon leach
into their drinking water supply.
Karst terrain, related features and/or resources located on
private or Crown land need to be regulated and protected to
prevent utilities, such as those with property right-of-ways,
from negatively impacting public karst resource values out of
ignorance or lack of specific legislated directive.
In the Alberni/Clayoquot Regional District (A/CRD) numerous
domestic water supplies depend on groundwater from springs which
in most cases, if not all, have a hydrologic connection to
Karst, (the transitional zone from surface recharge to
groundwater storage and flow).
Under Part 4 Section 23.1(a) of the DWPA, the term 'a well
recharge zone' is quite specific and appears to be included as a
result of the tragedies in Walkerton, Ontario. In contrast, the
term 'a drinking water source' is quite broad and general.
Specific terms in the DWPA are required in support of MOFR's
legal responsibility to protect forest resources, forest
district Regulation orders, as well as address the public's
expectation for the protection of drinking groundwater sources
from karst systems (plus any contributing non-karst recharge
In particular, current DWPA prohibitions fail to specifically
identify Karst as the principle storage and recharge source for
springs, whereas the recharge zone for wells is protected by
regulation. It may be true that government need not create new
DWPA regulation but instead strengthen Section 23.1(a).
I trust the above rational will move government to update the
DWPA by introducing karst specific recharge zone protection for
associated springs utilized as a drinking water source.
In closing, I've decided to leave this matter in your hands and
await government's response on the issues raised regarding the
need to update the DWPA. As to your other points, I will
continue to work with SIFD staff and other Ministries to develop
an order under the Regulation to manage and protect Karst
resources within the SIFD.
- ----- Original Message -----
Executive Division Office, Forests FOR:EX
To: Reid Robinson
Sent: Tuesday, September 02, 2008 9:58 AM
Subject: RE: 114722 - Water quality
- Thank you for your letter of
July 5, 2008, to the
Honourable Pat Bell, Minister of Forests and Range, regarding
the quality of drinking water on private forest land. I have
been asked to respond.
In order to maintain the quality of drinking water, your
letter suggests there is a need to regulate and possibly
protect Karst features and resources occurring on private
land. In conclusion, you discuss the management of Karsts
features near Fossil Park and in the South Island Forest
District, in general.
- All water sources used for public consumption, regardless
of being located on private land, are regulated under the
Drinking Water Protection Act, which is now administered by
the Ministry of Healthy Living and Sports, and was put in
place after the tragedies in Walkerton, Ontario in 2000. The
Ministry of Forests and Range is not mandated to protect water
supplies on private land. Government believes that the
Drinking Water Protection Act meets the public expectation for
the protection of drinking water sources. Consequently, there
is no need to create a new regulation.
As you point out, the ministry has the responsibility to
manage and protect Karst resources in provincial forests and
the Government Action Regulation (the Regulation) provides for
a possible means for local district managers to address the
needs for Karst management. I should also mention, it is up
to the individual decision-makers, in this case the district
manager, to determine how the Regulation orders are worded and
- South Island Forest District staff have informed me that
they are working closely with the Central Island Caving Club,
the Ministry of Tourism, Culture and the Arts and the Ministry
of Environment to develop and propose an order under the
Regulation to manage and protect Karst resources in the South
Island Forest District, including the Karst features found in
the vicinity of Fossil Park.
If you have further concerns, or wish to provide input into
the ongoing process in the South Island Forest District, I
encourage you to contact Dan Biggs, Stewardship Officer at
- Thank you again for writing.
T. R. (Tim) Sheldan
Assistant Deputy Minister
- pc: The
Honourable Pat Bell, Minister of Forests and Range
Scott Fraser, MLA, Alberni-Qualicum
Paul Knowles, District Manager, South Island
Dan Biggs, Stewardship Officer, South Island
- From: Reid Robinson
- Sent: Monday, July 7, 2008 12:54 AM
To: Forestry RoundTable FOR:EX; Minister, FOR FOR:EX
Cc: Knowles, Paul S FOR:EX; Heath, Dick ENV:EX; Penny Cote;
Subject: 114722 - Forestry Roundtable submission
- Please consider our July 5, 2008 letter to Hon. Pat Bell
as our submission on Karst to the Forestry Roundtable.
- Reid Robinson