forest harvesting and water quality: a case study of the china creek community watershed

I would especially like to thank Erik Piikkila, who put an extraordinary amount of time and effort into making this project a success. Finally, a special thank you to Dr. Jordi Honey-Rosés (Principal Investigator and Academic Supervisor) and Sarah Thomas (Academic Second Reader) for their hard work and support throughout this project. They provided excellent guidance, reviewed drafts, and connected me with many of the aforementioned individuals.

Annette ConstabelSenior Manager, Watershed Protection - Integrated Water Services, Capital Regional District

Bill SimsManager, Water Resources, City of Nanaimo

Chris ColeResource Specialist, Environment and Resource Integration, TimberWest

Dr. Dave SpittlehouseSenior Climatologist, B.C. Ministry of Forests, Lands and Natural Resource Operations

David MaloneyForest Water Management Officer (Kamloops), B.C. Ministry of Forests, Lands and Natural Resource Operations

Doug WahlManager, Audits and Investigations, Forest Practices Board

Edna CoxVolunteer, Save Our Valley Alliance

Erik PiikkilaForest, Landscape and Disturbance Ecologist, Ladysmith Watershed Coalition

Glen ZacharySenior Hydrology and Hydraulics Engineer, Urban Systems

Dr. Hans SchreierProfessor Emeritus, Land and Water Systems, University of British Columbia

Dr. Jordi Honey-RosésAssistant Professor, SCARP; Director, Water Planning Lab, University of British Columbia

June RossActing Chair, Vancouver Island Water Watch Coalition

Keith BellEditor-in-chief and Dad

Lori WilsonMapping and Computer Technician, Alberni-Clayoquot Regional District

Makenzie LeineManager of Community and Government Relations, Island Timberlands

Paul ManlyDocumentary Filmmaker, Manly Media

Dr. Rita WinklerResearch Hydrologist, B.C. Ministry of Forests, Lands and Natural Resource Operations

Sarah ThomasVolunteer, Watershed Forest Alliance; Planning Consultant, ECOllaborate Now

TJ WattConservation Photographer and Campaigner, Ancient Forest Alliance

Dr. Younes AlilaAssociate Professor, Faculty of Forestry, University of British Columbia

This report was made possible thanks to contributions from a number of academics, professionals, and Vancouver Island community members, all of whom share one common goal: to ensure that British Columbia’s natural resources are used responsibly and are treated with respect. Thank you to the following people for providing extremely valuable insights:

Acknowledgements

About the Author

Patrick (PJ) Bell is a Master’s student in the School of Community and Regional Planning at the University of British Columbia. He was born and raised in Regina, Saskatchewan, and received a Bachelor of Arts in Environmental Studies from the University of Regina. His professional interests include ecological and natural resource planning, active transportation, and sustainable urban environments.

At the University of Regina, PJ worked as a Research Assistant in the Department of Geography and Environmental Studies, assisting with a project that models climate impacts on Prairie environments in order to inform new sustainable management strategies. He then worked at Agriculture and Agri-Food Canada on the Drought Watch program, which monitors the agroclimate impacts of drought across Canada. During the 2015 summer, PJ worked for the City of Vancouver as a member of the Greenest City Scholars Program, a collaboration between the University of British Columbia’s Sustainability Initiative and the City of Vancouver. His research focused on improving the supply of “All Ages and Abilities (AAA)” bicycle parking for Vancouver residents.

This report serves as the capstone project for PJ’s Master’s degree. After graduating in August 2016, PJ plans to return home to Saskatchewan to begin his career in planning. However, British Columbia remains a potential future destination; one can only ignore the call of the ocean, forests, and mountains for so long.

[email protected] linkedin.com/in/pjonahbell issuu.com/pjonahbell

Figure i: Moss-covered trees in the China Creek Community Watershed

mailto:pjonahbell%40gmail.com?subject=

http://linkedin.com/in/pjonahbell

http://issuu.com/pjonahbell

4

FOREST HARVESTING AND WATER QUALITY: A CASE STUDY OF THE CHINA CREEK COMMUNITY WATERSHED

Acknowledgements ...................................................................................................................................................................................................2About the Author ......................................................................................................................................................................................................3

1.0 Executive Summary .........................................................................................................................................................................................8

2.0 Introduction ......................................................................................................................................................................................................12 2.1 Problem Overview .................................................................................................................................................................................13 2.2 Study Purpose and Methodology ..................................................................................................................................................14 2.3 Report Layout ...........................................................................................................................................................................................14

3.0 Context: Port Alberni’s Forestry History .......................................................................................................................................15

4.0 Issue Identification ........................................................................................................................................................................................17 4.1 Concerns from Various Stakeholders ..........................................................................................................................................18 4.2 Forestry Industry Perspective ...........................................................................................................................................................20 4.2.1 Island Timberlands .......................................................................................................................................................................20 4.2.2 TimberWest .....................................................................................................................................................................................21

5.0 Watershed Ecosystem Features and Services..............................................................................................................................22 5.1 Old Growth Forest ................................................................................................................................................................................23 5.2 Critical Wildlife Habitat ........................................................................................................................................................................24 5.3 High Value Fisheries ................................................................................................................................................................................25 5.4 Karst Formations ......................................................................................................................................................................................25 5.5 Water Quantity .........................................................................................................................................................................................25 5.6 Climate Change ........................................................................................................................................................................................26 5.7 Erosion and Landslides .........................................................................................................................................................................26 5.8 Cultural and Aesthetic Values ...........................................................................................................................................................27

6.0 Water Quality Parameters and Regulation ....................................................................................................................................28 6.1 Water Quality Overview ....................................................................................................................................................................29 6.2 Turbidity .........................................................................................................................................................................................................29 6.3 Water Quality Regulations .................................................................................................................................................................30 6.4 Filtration Deferral in Port Alberni ..................................................................................................................................................32

7.0 A Scientific Review of the Impact of Logging on Water Quality......................................................................................34 7.1 Overview of Natural Forest Hydrology .....................................................................................................................................35 7.2 Natural Causes of Water Quality Issues in Forests .............................................................................................................37 7.3 Effect of Logging on Water Quality ...............................................................................................................................................37 7.3.1 Roads ..................................................................................................................................................................................................37 7.3.2 Harvesting ........................................................................................................................................................................................39

8.0 China Creek Community Watershed Description...................................................................................................................42 8.1 Geographic and Biogeoclimatic Characteristics .....................................................................................................................43 8.2 Watershed Ownership .........................................................................................................................................................................44 8.3 Regulatory Framework ........................................................................................................................................................................47 8.3.1 Regulatory Overview ........................................................................................................................................................................47 8.3.2 Forestry Regulations on Crown Land ..............................................................................................................................48

Table of Contents

5

CONTENTS

8.3.3 Forestry Regulations on Private Managed Forest Land .........................................................................................49 8.3.4 Forest Certification Systems .................................................................................................................................................50 8.4 Land Uses ....................................................................................................................................................................................................51 8.4.1 Water Source .................................................................................................................................................................................51 8.4.2 Mining .................................................................................................................................................................................................52 8.4.3 Hydroelectric Power Generation .......................................................................................................................................52 8.4.4 Recreation ........................................................................................................................................................................................53 8.4.5 Logging History in the China Creek Community Watershed ...........................................................................53

9.0 Review of Existing Studies ........................................................................................................................................................................58 9.1 List of Studies .............................................................................................................................................................................................59 9.2 Coastal Watershed Assessment (CWAP) of China Creek Watershed (1998) ..................................................59 9.3 Alberni Valley Regional Water Study Update: Final Report (2010) ............................................................................61 9.4 China Creek Water Quality: A Comparison Before and After Timber Harvest and Independent Power Project Construction (2010) ...............................................................................................................61 9.5 Water Quality Assessment and Objectives for the China Creek Community Watershed (Overview and Technical Reports) (2011) ...............................................................................................................................62 9.6 Alberni Valley Drinking Water Reference Guide (Mapping Our Legacy project) (2011) ..............................64 9.7 Forest Practice Standards and Water Quality in Privately Managed Land in the China Creek and Honna River Watersheds (2014) ..........................................................................................................................................65

10.0 External Case Studies...............................................................................................................................................................................68 10.1 Unprotected Watersheds ................................................................................................................................................................69 10.1.1 Regional District of Nanaimo ............................................................................................................................................69 10.1.2 Comox Valley Regional District.........................................................................................................................................70 10.2 Protected Watersheds .......................................................................................................................................................................72 10.2.1 Capital Regional District ........................................................................................................................................................72 10.2.2 Metro Vancouver .......................................................................................................................................................................73 10.2.3 Notable International Examples .......................................................................................................................................74

11.0 Discussion ........................................................................................................................................................................................................75 11.1 Overview of Results ...........................................................................................................................................................................76 11.2 Questions of Interest ..........................................................................................................................................................................76 11.2.1 Are provincial institutions and legislation adequately managing source water and protecting community watershed ecosystems in British Columbia? ....................................................................................76 11.2.2 Are the laws governing forestry on private land sufficient to ensure the protection of drinking water sources? ..........................................................................................................................................................77 11.2.3 Who should have control over a community’s water supply? .........................................................................79 11.2.4 Should private managed forest landowners take on increased responsibility for legacy and non-forestry issues on their land? ...........................................................................................................................80

12.0 Conclusion ......................................................................................................................................................................................................82 12.1 Closing Thoughts ...................................................................................................................................................................................83 12.2 Recommendations ...............................................................................................................................................................................83

Works Cited ...............................................................................................................................................................................................................85Figure Credits .............................................................................................................................................................................................................93

6


List of Figures

Figure i: Moss-covered trees in the China Creek Community Watershed...................................................................Figure 1.1: McLaughlin Ridge in the China Creek Community Watershed, with cutblocks visible in the background......................................................................................................................................................................................Figure 1.2: Signs of logging within the China Creek Community Watershed.................................................................Figure 2.1: China Creek Community Watershed location.........................................................................................................Figure 3.1: Annual timber harvest in B.C.............................................................................................................................................Figure 3.2: B.C.’s vulnerability to downturns in forest economy.............................................................................................Figure 4.1: Elected officials and environmental activists speaking out about the China Creek Community Watershed..........................................................................................................................................................Figure 4.2: Citizen concerns regarding private forestry regulations.....................................................................................Figure 4.3: Logging road in the China Creek Community Watershed...............................................................................Figure 5.1: Old growth forest in the China Creek Community Watershed....................................................................Figure 5.2: Remaining productive old growth in B.C....................................................................................................................Figure 5.3: Queen Charlotte goshawk..................................................................................................................................................Figure 5.4: Marbled Murrelet......................................................................................................................................................................Figure 5.5: Vancouver Island marmot.....................................................................................................................................................Figure 5.6: Wild coho salmon.....................................................................................................................................................................Figure 5.7: Karst landscape digram...........................................................................................................................................................Figure 5.8: Logging along the steep slopes of McLaughlin Ridge in the China Creek Community Watershed....................................................................................................................................................................................Figure 5.9: Hiking in the China Creek Community Watershed..............................................................................................Figure 6.1: Turbidity Sample........................................................................................................................................................................Figure 6.2: Drinking Water Protection Act, Part 4, Section 23................................................................................................Figure 6.3: 4-3-2-1-0 Objective for drinking water in B.C.........................................................................................................Figure 6.4: Port Alberni’s new treatment facility..............................................................................................................................Figure 7.1: Water flowing downhill in the watershed..................................................................................................................Figure 7.2: Lichen intercepts water..........................................................................................................................................................Figure 7.3: Fungal growth on the side of a tree...............................................................................................................................Figure 7.4: Water flowing in the CCCW ...........................................................................................................................................Figure 7.5: Logging road on McLaughlin Ridge in the China Creek Community Watershed................................Figure 7.6 Sand and fine gravel on a bridge in the CCCW......................................................................................................Figure 7.7: Harvesting on McLauughlin Ridge in CCCW............................................................................................................Figure 7.8: Water flowing post harvest on McLaughlin Ridge.................................................................................................Figure 8.1: Snow in the upper reaches of the CCCW.................................................................................................................Figure 8.2: Stream order classification diagram................................................................................................................................Figure 8.3: Low flow (top) vs. high flow (bottom) at the CCCW intake dam..............................................................Figure 8. 4: Elevational profile of biogeoclimatic units for south central Vancouver Island.......................................Figure 8. 5: The CCCW is dominated by Douglas-fir....................................................................................................................Figure 8. 6: Comparison of forest ownership between the province of B.C. and the CCCW..............................Figure 8.7: Map of the E & N Land Grants of 1884-1925.........................................................................................................Figure 8.8: Overview of land ownership in the China Creek Community Watershed.............................................Figure 8.9: The three primary forest certification standards in B.C....................................................................................Figure 8.10: Upnit penstock road................................................................................................................................................................Figure 8.11: Logging by rail in B.C..............................................................................................................................................................Figure 8.12: Incline Railroad for logging in B.C....................................................................................................................................Figure 8.13: Donkey spar tree yarding system....................................................................................................................................Figure 8.14: Steel tower yarding system.................................................................................................................................................

3

911131616

18202123242424242525

26272931323335363637383939404343434445454647505353545454

7

CONTENTS

Figure 8.15: Grapple yarding system.........................................................................................................................................................Figure 8.16: China Creek Channel in 1952 and 1994, showing recovery of riparian vegetation..........................Figure 8.17: Forest cover in the China Creek Community Watershed (2000)...............................................................Figure 8.18: Forest cover loss and gain in the China Creek Community Watershed between 2000 and 2014........................................................................................................................................................................................Figure 8.19: Forest cover loss events by year in the China Creek Community Watershed between 2000 and 2014...........................................................................................................................................................................Figure 9.1: Much of the riparian area in the CCCW’s second-growth forest is dominated by alder, which provides insufficient large woody debris for the stream channel...................................................Figure 9.2: CCCW users are warned to respect the water ...................................................................................................Figure 9.3: Turbidity levels in China Creek between May 2003 and January 2005 as measured on 15-minute intervals by the automated water quality monitoring sation near the City of Port Albrni intake......................................................................................................................................................................Figure 9.4: Turbidity levels in China Creek between January 2004 and August 2014 recorded at the City of Port Albrni intake.....................................................................................................................................................Figure 9.5: China Creek Main road with riprap on the road side to stabilize the channel.....................................Figure 9.6: A breach in the grader berm along China Creek Main road allows sediment-laden water to flow into the creek.............................................................................................................................................................Figure 10.1: City of Nanaimo’s new $70 million filtration facility..............................................................................................Figure 10.2: Comox Lake is a popular destination for recreation............................................................................................Figure 103: The water intake on Sooke Lake is the only anthropogeic use allowed in the watershed ..........Figure 12.1: Sunset over the China Creek Community Watershed........................................................................................

Tables:

Table 6.1: Forest water quality parameters and example measures..................................................................................Table 7.1: Naturally occuring contaminant sources and the contaminants commonly associated with them.......................................................................................................................................................................................Table 7.2: Forestry-related contaminant sources and the contaminants commonly associated with them.......................................................................................................................................................................................Table 8.1: Breakdown of Biogeoclimatic Zones in the CCCW.............................................................................................Table 8.2: Summary of mining activities within the China Creek Community Watershed...................................Table 9.1: Existing studies on the China Creek Community Watershed.........................................................................Table 9.2: Summary of automated turbidity data measured at China Creek at City of Port Alberni intake station from May 2003 to Feb 2005...............................................................................................................Table 9.3: Summary of proposed Water Quality Objectives for the China Creek Community Watershed....................................................................................................................................................................................Table 10.1: Selected US cities that have avoided construction of filtration plants through watershed protection.............................................................................................................................................................

555556

57

57

5962

63

6566

6669717284

29

38

41445260

63

64

74

The China Creek Community Watershed (CCCW) provides drinking water to 20,000 residents in Port Alberni, Beaver Creek, and the Hupacasath Ahahswinis and Tseshaht Tsahaheh reserves. The primary water source is China Creek, with Bainbridge Lake serving as a backup source. There is concern amongst elected officials, city staff, environmental organizations, and local community members that logging and roads within the CCCW are negatively impacting water quality (Figure 1.1). Major forestry companies privately own ninety-three percent of the CCCW, with Island Timberlands controlling the majority of the watershed. While the private logging companies have been criticized for logging the watershed, they maintain that their forestry operations abide by all applicable regulations and they insist that source water protection is considered at all times. These companies have explained that there are misconceptions in the community relating to the impacts of logging on water quality.

In response to these concerns and misconceptions, the Watershed Forest Alliance (WFA), a Port Alberni-based NGO, identified the need for an independent third-party study. The WFA approached the University of British Columbia (UBC), and a graduate student from the School of Community and Regional Planning at UBC initiated and completed this study. The objective of this study is to synthesize research relating to the impact of logging on water quality in the context of Vancouver Island, with a particular focus on the CCCW. The aim was not to

provide an original ecological, hydrological or economic study, but rather to summarize existing data, literature, and scientific studies, followed by an analysis of important findings. This report is designed to be a resource for those interested in the issue.

A review of scientific literature and government publications revealed that logging does indeed present a number of risks to water quality—including erosion, soil compaction, and temperature changes—in addition to many other environmental and cultural elements. Road construction and use has been linked to the deposition of sediment into stream channels, which can increase turbidity. Turbidity serves as an indicator for the presence of pathogens and can interfere with disinfection processes, making it an important measure for examining water quality.

In addition to sedimentation from roads, the harvesting of trees may also increase turbidity, as soil can become unstable, resulting in erosion and landslides. The removal of trees can change the way that water moves across the landscape and is absorbed into the soil, often resulting in increased flows and erosion. An undisturbed forest may filter water, so the harvesting of trees has the potential to damage this useful ecosystem service. Not all ages or species of tree are equally adept at providing ecosystem services; for example, old growth Douglas-fir forests are particularly effective at regulating water flows, because these tall, mature trees present a large crown surface and

Figure 1.1: McLaughlin Ridge in the China Creek Community Watershed, with cutblocks visible in the background

9

CHAPTER 1: EXECUTIVE SUMMARY

occupy an extensive volume of space (Franklin, 1988).

It is important to note, however, that the impact of logging on water quality will vary greatly depending on a number of factors, the most important of which being the type of forestry practices that are followed. Modern harvesting and road building practices are significantly better at protecting water quality than those of the past. If managed properly, harvesting can result in relatively little sustained impact on the environment.

Additionally, forest ecosystems are extraordinarily complex, with climate, topography, and vegetation all representing compounding variables that dictate the impact of any disturbances. Under natural conditions, turbidity will fluctuate based on seasonality, extreme weather events, and natural erosive processes, and various pathogens can enter the water due to wildlife. Additionally, anthropogenic land uses other than logging can also influence turbidity levels, including mining, hydroelectric generation, and recreation. Therefore, determining the exact source of water quality problems can be very challenging.

An analysis of satellite imagery shows that between 2000 and 2014, approximately 18 percent of the CCCW was harvested. However, based on a review of existing studies that have been done on the CCCW, it cannot be said for certain that logging in the CCCW is currently impacting water quality. Various studies found evidence of sedimentation from roads and landslides, but it was difficult to identify the source of the turbidity. Legacy issues—logging operations that occurred prior to the current regulations and watershed ownership—and non-forestry land uses were identified by one study as being of greater concern than any current forestry operations. Additionally, at the time of writing, water quality in the CCCW was quite good, which has allowed the City of Port Alberni to seek a filtration deferral from the Vancouver Island Health Authority. This deferral is only an option due to built-in system redundancy and the recent construction of a UV disinfection plant, and the deferral remains contingent on the approval of a watershed management plan.

The regional districts of Nanaimo and Comox Valley also take their drinking water from watersheds that are privately owned and with forestry activity. In order to comply with new provincial water quality standards, these communities have installed or are planning to install expensive filtration plants. A brief examination of these cases did not show that logging was a factor in the purchase of these filtration

plants, despite concerns from citizens that this was the case. Instead, it appears that the increasingly strict water quality regulations necessitated the installation of filtration plants.

On the other hand, some regions of B.C., such as Metro Vancouver and the Capital Regional District, have fully protected watersheds. The Capital Regional District claims that this has significantly reduced their water treatment costs, as they were able to avoid the purchase of a costly filtration plant despite being under the same provincial regulations as the aforementioned regions. There are also international examples where municipalities have avoided the cost of installing filtration by protecting their watersheds. However, it was not determined in this study whether or not watershed protection would have led to filtration deferrals in Port Alberni, Comox, or Nanaimo. As mentioned earlier, a number of natural sources can cause increased turbidity, so a protected watershed does not automatically guarantee water quality.

While water quality does not currently appear to be an issue in the CCCW, the research process revealed a number of questions and concerns about the overall management and regulation of forestry operations in British Columbia. These issues could potentially affect the CCCW in the future. For one, the regulatory framework dealing with logging and water quality issues in British Columbia is complex, and there is a perception that the regulations governing privately managed forest land lack rigour and detail. While a series of professional standards and governing bodies provide regulatory oversight to private forestry operations, this oversight is less visible to the public than the oversight on Crown land, contributing to this negative perception. Furthermore, there are many overlapping regulations and institutions that are tasked with protecting water quality in watersheds, creating possible confusion as to the roles and responsibilities of various government departments and potentially resulting in inefficiencies. Finally, the lack of control over a private drinking watershed leaves communities vulnerable to changes in ownership and forestry techniques on private land.

Based on these concerns, it is suggested that the City of Port Alberni continue to push for more control over the CCCW, as they have already been doing. This control could take a number of forms: outright ownership, a change in legislation that allows increased government intervention in the watershed, or some sort of co-management scheme with the private landowners. Co-management is an appealing option, as it would allow professional industry

10


foresters that are removed from the election cycle to care for the watershed, while simultaneously creating enhanced oversight from elected officials who are directly accountable to the local community.

The regulatory framework should also be updated so that the “community watershed” designation applies across all land, instead of only on Crown land. Clarification of the roles and authority of the ministries involved in the protection of drinking water with respect to forestry operations is also necessary. Communication and data sharing across institutions needs to be improved, as does communication with the public. Clearing up some of the misconceptions related to logging impacts would go a long way towards reducing the conflicts between private industry, government, and citizens. Finally, forestry companies should consider seeking certification under the Forest Stewardship Council (FSC) program. FSC certification is internationally renowned for its strict regulations and environmentally friendly results, so certification would instantly provide added credibility for these companies.

Logging is paramount to the Port Alberni area’s heritage and economy. However, economic activity should internalize the costs of their operations; it should not come at the expense of a public good like drinking water. Additionally, when logging is negatively perceived in a “logging town” like Port Alberni, this issue can quickly become divisive in the community. The City of Port Alberni currently has a strong relationship with the private forestry companies, so these groups need to work together to ensure that proper communication between all stakeholders is achieved and that drinking water is protected for current and future generations.

Figure 1.2: Signs of logging within the China Creek Community Watershed

11

CHAPTER 1: EXECUTIVE SUMMARY

2.1 Problem Overview

Located on Vancouver Island at the head of Barkley Sound and surrounded by scenic forests, mountains, and lakes, Port Alberni, British Columbia has always had an intimate connection to the natural environment. From the Tseshaht and Hupacasath First Nations who have long inhabited the region right up to the area’s 20,000 current residents, people in the Port Alberni area have long relied on the abundant forest and water resources (Caulfield, 2015). Today, however, these two primary resources are seemingly in conflict with one another, as there is concern that the forest is being exploited at the expense of the area’s water supply.

The drinking water supply for the City of Port Alberni, the unincorporated community of Beaver Creek, and the Hupacasath Ahahswinis and Tseshaht Tsahaheh reserves comes from the China Creek Community Watershed (CCCW), which is located an hour’s drive southeast of the city (Figure 2.1) (Slepian, 2014, 2016). Since 1912, China Creek has served as Port Alberni’s primary water source

(B.C. Ministry of Forests, Lands and Natural Resource Operations, 1999). When water quality deteriorates in China Creek, the City switches to Bainbridge Lake, which is located just outside of CCCW in the McFarland Community Watershed (Koers and Associates Engineering Ltd., 2010). In emergency situations when both of these sources are unavailable, the City can draw water from the Somass River (Koers and Associates Engineering Ltd., 2010).

Local elected officials, city staff, non-governmental organizations (NGOs), First Nations, and other community members are concerned that logging within the CCCW is negatively impacting water quality. Logging has been occurring in the watershed for decades and it continues today. While several groups conduct forest operations in the CCCW, the most significant is Island Timberlands, a large forest company that owns the majority of the watershed (see ownership breakdown in Section 8.2). The rest of the watershed is split between TimberWest (another major forestry company) and Crown land.

Figure 2.1: China Creek Community Watershed location

13

CHAPTER 2: INTRODUCTION

Despite numerous scientific studies of the watershed, there remain a number of misconceptions and concerns regarding the effect of logging on water quality in the CCCW, and as a result, calls to halt logging have grown louder and louder through the years. The fact that most of the watershed is privately owned as opposed to Crown land, and therefore subject to different forestry regulations that govern harvesting practices, has been a point of particular contention.

2.2 Study Purpose and Methodology

In response to these concerns and misconceptions, the Watershed Forest Alliance (WFA), a Port Alberni-based NGO, identified the need for an independent third-party study. The WFA approached the University of British Columbia, and Patrick Bell (Master’s student), supervised by Dr. Jordi Honey-Rosés (Assistant Professor), initiated and completed this study. The objective of this study is to provide research relating to the impact of logging on water quality in the context of Vancouver Island, with a particular focus on the CCCW.

The aim of this study was not to provide an original ecological, hydrological, or economic study of the CCCW. Rather, this study is predominantly a synthesis of existing literature that is meant to serve as a resource for those interested in the issues surrounding logging and water quality in the CCCW. As such, a significant portion of the report is dedicated to providing background information on local context, forest hydrology, and logging regulations. Many scientific studies about the CCCW have already been completed, and these were reviewed as part of this study.

The researching and writing of this report were guided by the goal of remaining objective. The author relied heavily on scientific literature and government publications, but also included a balanced mixture of media stories as well as reports from industry, environmental NGOs, and community members. The research process also included interviewing numerous stakeholders from all sides of the issue, who in turn provided comments and suggestions for further research.

2.3 Report Layout

This report is divided into twelve chapters that can be loosely grouped into five main sections. The first section, Chapters 1 to 6, provides an introduction and context.

Chapter 3 provides a brief overview of Port Alberni’s forestry industry, while Chapter 4 identifies the origins of the concerns about logging and water quality. Chapter 4 also contains key quotes from various stakeholders and explains the forestry industry’s perspective. Next, Chapter 5 describes the ecosystem features and services other than water quality that are provided by watersheds such as the CCCW—water quality is the primary focus of this report, but it is necessary to acknowledge the many other factors in play within the watershed. Finally, Chapter 6 reviews water quality parameters and regulations in British Columbia and describes the impact of these regulations in Port Alberni.

The next section, Chapter 7, presents the results of a literature review on the impacts of logging on water quality in the Vancouver Island context. This section is not focused specifically on the CCCW; rather, it provides an overview of the potential impacts of logging within watersheds, without implying that these impacts are currently occurring within the CCCW. Again, the primary objective of this report is to examine the effect of logging on water quality, but other forestry impacts such as stream temperature and water quantity will be briefly described.

Section 3 (Chapters 8 and 9) returns the focus to the CCCW. Chapter 8 provides an overview of the watershed, describing its geography, geology, climate, land uses, ownership framework, and the regulatory framework that dictates forestry practices within the watershed. Chapter 9 is an overview of the numerous studies that have previously been conducted about the CCCW, identifying who commissioned and completed each study and reviewing their key findings.

The fourth section (Chapter 10) is a collection of brief case studies about watershed management in other municipalities. This section examines the difference between those areas with protected watersheds (i.e. the Capital Regional District and Metro Vancouver) and those areas with unprotected watersheds (i.e. Nanaimo and Comox Valley). Select international examples are also described.

The final section of this report attempts to bring all of these findings together and recommends further actions. Chapter 11 provides a discussion of important findings and identifies some unanswered questions that should be considered for further research. Chapter 12 provides concluding comments and a few recommendations for CCCW stakeholders.

14


There are 55 million hectares of forest in British Columbia, which amounts to nearly 60 percent of the province’s land area (Ministry of Forests, Mines and Lands, 2010). As such, forestry has been a major component of B.C.’s economy since the 1800s (Ministry of Forests, Mines and Lands, 2010). Similarly, Port Alberni has been a forestry town since its inception, with the lumber, pulp, and paper industries playing prominent roles in the Alberni Valley’s economy for over a century (Gordon, Halkett, Macauley, & Saunders, 2007; Ministry of Forests, Mines and Lands, 2010). Employment in the forestry sector tends to pay as much as twelve percent higher than other industrial jobs, and in the 1950s, ‘60s, and ‘70s, Port Alberni was bustling and prosperous—a booming city with one of the best-paid forestry labour forces in Canada (Gordon et al., 2007; Ministry of Forests, Mines and Lands, 2010).

The forestry boom in B.C. was the result of increasing demand for timber and technological innovations that allowed rapid and large scale harvesting (E. Piikkila, personal communication, May 5, 2016). The annual amount of timber harvested increased steadily from the early 1900s to the mid-1980s, at which point harvesting totals began to fluctuate, peaking in 1987 and again in 2005 (Figure 3.1) (Ministry of Forests, Mines and Lands, 2010). This fluctuation signified the beginning of a downward trend in many forestry-dependent communities, including Port Alberni. While the province’s economy has diversified over time, many smaller communities are still highly dependent on the forestry industry and have been heavily impacted by the decline over the past three decades (Figure 3.2) (Ministry of Forests, Mines and Lands, 2010).

In the Alberni Valley, the downturn is evidenced by changes in demographics and employment characteristics. The

population has been static and aging since the 1980s, while the resource industry has become less dominant. In 1996, 17.7 percent of the labour force was employed in agriculture, forestry, fishing, and hunting, but this dropped to 9.5 percent in 2006 (Alberni-Clayoquot Regional District, 2010). The forest sector is heavily reliant on export markets, so changes in international competition, trade restrictions, commodity prices, and major events such as the 2007 housing market collapse in the U.S. have had significant impacts on timber harvests in the province (Ministry of Forests, Mines and Lands, 2010).

Despite this downturn, the forestry industry—which in this area is now dominated by large private companies—remains the most prominent industry in the Alberni Valley (Gordon et al., 2007). The weight of the forestry industry is important context for this analysis and report. Forestry is critical to the culture, heritage, and economy of the Alberni Valley.

Total timber harvest

Not regulated by AACs

19100

102030405060708090

100

1920 1930 1940 1950Year

1960 1970 1980 1990 2000

Regulated by AACs

Tim

ber

volu

me

(mill

ions

m³)

Figure 3.1: Annual timber harvest in B.C.

Figure 3.2: B.C.’s vulnerability to downturns in forest economy

Data source: BC STATS (2009)

Least Vulnerable

Alberni-Clayoquot Regional District

Most VulnerableNot Reported

16


4.1 Concerns from Various Stakeholders

Concerns over logging in the CCCW have come from a number of sources, including regional and local elected officials, Port Alberni city staff, professional third-party engineering firms, NGOs, and community members. Many of these concerns have been voiced in local, regional, and national publications such as the Alberni Valley News, the Alberni Valley Times, the Vancouver Sun, and the Globe and Mail, along with several smaller papers and websites. Figure 4.1 provides a sample of some of the key quotes from a variety of different CCCW stakeholders.

Port Alberni mayor Mike Ruttan has emphasized the importance of protecting the region’s drinking water supply, explaining that ultimately, the City wants to control the CCCW (Slepian, 2015b). He has said that while the City regularly meets with Island Timberlands—the majority landowner in the watershed—these meetings “don’t address the real problem” of watershed control (Slepian, 2015b). Mr. Ruttan has noted that the City is working with surrounding communities to get the attention of the provincial government, whom they hope will be able to provide legislative and financial assistance towards Port Alberni’s goal of purchasing the CCCW (Slepian, 2015b). Port Alberni City Councillor Denis Sauvé has expressed frustration with the provincial government over this issue,

“Water defines our city. It’s our history and our future. It’s essential, it’s powerful, it’s precious and it’s something we can’t take for granted.” (Slepian 2016)— Mike Ruttan, Mayor of Port Alberni

“Logging on these steep old-growth slopes has a high potential to alter the quality and rate of water flow and the streams’ courses. [Cutblocks above China Creek] should never have been logged.” (Hume, 2015)— Scott Fraser, MLA for Alberni-Pacific Rim

“Water is a basic human right, and I am gravely concerned about the negative long-term impacts that logging in and above China Creek watershed will have on First Nations and all people with whom we share the Valley.” (Wilderness Committee, 2014)— Judith Sayers, Former Chief, Hupacasath First Nation

They have every right to log. All we’re asking is for the protection of the watershed.” (Slepian, 2015b)— Denis Sauvé, Port Alberni City Councillor

“Jurisdictions that protect their watersheds as healthy, intact systems will have more stability in a changing climate. In privately owned watersheds, we see industrial development that undermines water quality. In publicly owned watersheds, we don't. The provincial government simply has to address this. Port Alberni Mayor Mike Ruttan and many others have advocated for full municipal control of watersheds, and the provincial government can help make this happen. Surely the right to safe, clean water isn't only for those of us in municipalities with large enough tax bases to purchase our watersheds.” (Coste, 2015) — Torrance Coste, Campaigner and Spokesperson, Wilderness Committee

Regarding Nanaimo’s watershed: “If we don’t have control of our watershed, we don’t have control of our local economy. A clean, secure source of drinking water is crucial to the health of citizens and to the economy of a community.” (Manly, 2014)— Paul Manly, Documentary Filmmaker, Manly Media

Quotes from Influential Stakeholders

Figure 4.1: Elected officials and environmental activists speaking out about the China Creek Community Watershed

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indicating that while diplomatic relationships between the governments appear to be strong, there is no concrete action on the ground (Slepian, 2015b).

One way that Port Alberni is lobbying to the provincial government is through the Union of B.C. Municipalities (UBCM), an organization that provides a “common voice for local government” by bringing resolutions from municipalities to the province for discussion (Union of BC Municipalities, 2016b). Throughout the years, a number of official UBCM resolutions have addressed the matter of logging and water quality in community watersheds such as the CCCW (see UBCM resolutions 2005-B27, 2006-B102, 2010-B26, 2011-B50, 2011-B129, 2013-B32, 2013-B105, and 2015-B58) (Union of BC Municipalities, 2016a). For example, in 2013, Port Alberni sponsored resolution 2013-B105, which stated:

WHEREAS the majority of Vancouver Island communities draw drinking water from an active working forested watershed;

AND WHEREAS logging companies are not required to submit a long range forestry plan:

THEREFORE BE IT RESOLVED that the Province of British Columbia enact legislation that requires all land and tenure holders logging in a local government watershed to have in place a one hundred year cut rotation plan;

AND BE IT FURTHER RESOLVED that all logging companies have environmental policies in place that protect the integrity of local governments’ drinking water. (Ministry of Community, 2014, p. 133)

Other local elected officials who have noted concerns about the CCCW include Alberni-Pacific Rim MLA Scott Fraser and Dr. Judith Sayers, the former Chief of the Hupacasath First Nation. Dr. Sayers spoke at a rally outside of Port Alberni City Hall in 2014 and said that Alberni Valley residents “must be vigilant to assert our human right to clean water over corporate profit” (Wilderness Committee, 2014). Mr. Fraser has been active on the issue of logging and water quality for many years. In 2013, he co-signed, along with 23 local organizations, foresters, and scientists, a letter to the province expressing significant concern over the logging of the CCCW (see quote in Figure 4.1) (Hume, 2015).

Port Alberni City Engineer Guy Cicon has also weighed in on the issue of logging and water quality. During a tour of private watershed land guided by TimberWest, Mr. Cicon initiated a debate by “wondering out loud” whether or not the City would need to pay for water treatment if there were no logging in the Bainbridge Lake area, which acts as Port Alberni’s secondary water supply (Bertrand, 2013). Additionally, in 2014, Mr. Cicon was interviewed as part of an investigation of forest practice standards in the CCCW. The report states the following:

Mr. Cicon attributed much of the turbidity exceedances to [Island Timberlands’] operations, particularly road building and road traffic during rain events. He indicated that he and others from the city staff had observed sediment-laden run-off from roads entering [China Creek] and its tributaries, though he states that IT was generally quick to address specific problem sites when made aware of them. (Butt & Hughes-Adams, 2014, p. 47)

Local NGOs such as the Watershed Forest Alliance (WFA) have been voicing concerns about the CCCW for half a decade. Often, their focus is the conservation of old growth forest, but they also frequently mention the issue of water quality (Slepian, 2014). In 2013, the WFA and other conservation groups proposed the creation of a “$40-million-a-year, 10-year Parks Acquisition Fund” in order to purchase lands at risk of logging such as the CCCW (Stueck, 2013).

Then in 2014, the WFA received unanimous support from Port Alberni City Council for their motion to request a moratorium on logging in McLaughlin Ridge, a section of the CCCW that contains old growth forest (Slepian, 2014). The motion included a request to set up meetings with Island Timberlands and the provincial government for discussion of the issue (Slepian, 2014). Other NGOs and environmental groups have also expressed concerns about logging and water quality in the area, including the Wilderness Committee, the Save Our Valley Alliance, the Vancouver Island Water Watch Coalition, Sierra Club BC, and the Ancient Forest Alliance (Caproff, 2014; Coste, 2015; Pierce, 2014; J. Ross, personal communication, April 26, 2016).

In February 2015, the B.C. Teachers’ Federation (BCTF) voted to ask Island Timberlands to sell the McLaughlin Ridge section of the CCCW to “an organization(s) that will conserve and preserve forest lands” (Plummer, 2015). Ken Zydyk, president of the Alberni Teachers Union, said that

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CHAPTER 4: ISSUE IDENTIFICATION

“there are many teachers concerned about the current practices of Island Timberlands” and that these teachers are uncertain as to whether harvesting within the CCCW ensures “the protection of our watershed so that Port Alberni can continue to have high quality, clean water” (Plummer, 2015). The BCTF’s request was then passed on to the B.C. Investment Management Corporation, which is a major Island Timberlands shareholder and which is responsible for investing teacher pensions (Plummer, 2015).

Finally, many other local community members have questioned the practice of logging within the CCCW. A number of “letters to the editor” from concerned citizens have appeared in the Alberni Valley News over the past few years (see Crowley, 2015; Mannix, 2013; Randles, 2014a, 2014b; Thompson, 2014). There have been anecdotal reports of discoloured water and sediment settling in toilets following major rainstorms (S. Thomas, personal communication, November 17, 2014). A 2007 report by Macauley & Associates Consulting Inc. surveyed Port Alberni residents and reported a range of concerns (Figure 4.2) (Gordon et al., 2007).

4.2 Forestry Industry Perspective

Faced with all of these concerns from elected officials, NGOs, and citizens, Island Timberlands and TimberWest have been quick to defend their practices. The following sections include comments from each company in the media and from personal communications. Western Forest Products, a forestry company who operates on Crown land within the watershed, were not contacted for comment as this report focuses primarily on private land issues.

4.2.1 Island Timberlands

Island Timberlands President and CEO Darshan Sihota has stressed that the forestry company is “inextricably linked to the community” and that Island Timberlands has a “long-term” commitment to its local operations in the CCCW area (Kari, 2009). He explains that present logging operations should not be compared to the operations that took place on Vancouver Island in the past, because “[t]he way it was in the past is not efficient” (Kari, 2009). According to Mr. Sihota, “[t]here has to be some recognition of the long-term outlook for our industry” (Kari, 2009).

Figure 4.2: Citizen concerns regarding private forestry regulations

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A 2007 report by Macauley & Associates Consulting Inc. identified the following Port Alberni citizen concerns related to forest management practices on private lands:

• There are inadequate environmental standards on private lands with respect to (i) protection of water for human consumption and use, (ii) protection of fish, (iii) soil conservation, and (iv) wildlife management.

• There is a lack of confidence that the results-based approach to environmental protection will work. Once a fish run has been lost, it cannot be recovered.

• Logging on private lands introduces additional adverse environmental impacts. The size of cut blocks impacts biodiversity. Risk of flooding is increased due to denuded hillsides; riparian zones are insufficient. The federal Department of Fisheries and Oceans does not appear to be willing to protect fish in streams flowing through private lands.

• In comparison to the forest practice management regime on Crown lands, the regulation of forestry practices on private land seems insufficient.

• Over harvesting of private lands and harvesting of ‘juvenile” stands results in reduced wildlife habitat, reduced tourism and recreational opportunities and potential future loss of a local economic employment base.

The report went on to note that “[w]hile such concerns are often strongly felt, public perception cannot always be supported by technical analysis. The expert hired by the Private Managed Forest Land Council and a Ministry of Environment staff member both found no evidence of increased amounts of water or sedimentation as a result of the timber harvesting activities in cases they investigated in the Beaufort Range” (Gordon et al., 2007).

Morgan Kennah, Sustainability Manager for Island Timberlands, has explained that Island Timberlands works cooperatively with the City of Port Alberni in order to ensure water quality is maintained (Slepian, 2014). Ms. Kennah and has spent time explaining specific harvest practices such as riparian buffers and hillslope retention in the media in an attempt to educate the public about what goes on in the watershed (Slepian, 2015a). Island Timberlands also works with professional geologists, engineers, Registered Professional Biologists, and foresters who specialize in watershed-related studies, and Kennah explains that the company “voluntarily imposes stricter regulations on the logging contractors” that they employ (Francoeur, 2011; Slepian, 2015a).

4.2.2 TimberWest

TimberWest Sustainability Vice-President and Chief Forester Domenico Iannidinardo has explained that TimberWest closely monitors water quality during operations (Sun, 2013). While conducting a tour of operations near Bainbridge Lake, Mr. Iannidinardo stated that “[t]here is no science saying that what we’re doing here has an effect [on the city needing water treatment]”

(Bertrand, 2013). He also said that “[s]ociety is better off making use of local wood” (Bertrand, 2013).While discussing operations in nearby Comox Valley, Mr. Iannidinardo defended the company’s use of the clearcutting technique, explaining that TimberWest does “selective harvesting” and that clearcutting can be necessary because it allows the sunlight required for forest regeneration (Stanfield, 2013). Iannidinardo explained that “[i]t’s very difficult to regenerate a stand in most places in the Comox watershed without some form of clearcutting. We plant trees right away and they need sunshine right away, or invasive species and other non-desirable species take over and start to devalue the forest ecosystem” (Stanfield, 2013).

He went on to state that selective harvesting can be even more impactful than clearcutting because of the need to build and maintain a larger road network: “it’s active roads that are the biggest risk for turbidity” (Stanfield, 2013). Finally, Iannidinardo has stated that “[w]ater quality is an integral part of our forest planning process,” outlining how TimberWest leaves riparian buffer strips and monitors for turbidity (Stanfield, 2013).

Figure 4.3: Logging road in the China Creek Community Watershed. Island Timberlands and TimberWest explain that they consider environmental impacts throughout all forestry operations, including road construction, use, and maintenance.

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CHAPTER 4: ISSUE IDENTIFICATION

Assessing the impact of logging on water quality in the CCCW is the primary objective of this report. However, there are numerous other ecosystem features and services provided by watersheds like the CCCW that need to be examined. This section serves to briefly introduce these features, acknowledging their importance and providing impetus for future study in the CCCW. While drinking water was a major concern amongst those stakeholders described in the previous section, these groups—the NGOs in particular—have also urged the protection of the CCCW for many of the reasons below.

5.1 Old Growth Forest

Old growth forest is a “slowly changing but dynamic ecosystem” containing live and dead trees of various species, heights, canopy sizes, age classes, and densities, along with downed and decaying logs, herbs, shrubs, moss, and lichen (Figure 5.1) (E. Piikkila, personal communication, May 24, 2016; Franklin et al., 1981; Franklin & Spies, 1991a). The age, successional stage, and structure of an old growth forest varies due to a number of factors, including the type,

intensity, and frequency of past disturbances, the forest type, and the Biogeoclimatic Zone (E. Piikkila, personal communication, May 24, 2016).

In B.C.’s coastal region, old growth is defined as forest more than 250 years old (Ministry of Forests Mines and Lands, 2010). Old growth forest provides crucial habitat for forest-dependent and especially old growth-dependent flora and fauna. Studies by Schaeffer and Pruitt (1991), Selva (1994), and Chubbs et al. (1993) have shown that the structures and microenvironments in old growth forests can be critical to the “survival of a whole range of organisms from lichens … to certain wide-ranging mammals such as caribou” (as cited in Mosseler, Thompson, & Pendrel, 2003). Additionally, old growth forests play an important role in nutrient cycling, carbon sequestration, and the protection of both soil and water resources (Mosseler, Thompson, & Pendrel, 2003). Nutrient losses and erosion both tend to be low in old growth forests (Franklin & Spies, 1986).

The protection of old growth forests in the CCCW is a major motivating factor behind many citizen and NGO

Figure 5.1: Old growth forest in the China Creek Community Watershed

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CHAPTER 5: WATERSHED ECOSYSTEM FEATURES AND SERVICES

calls for the elimination of logging in the watershed. Jane Morden of the Watershed Forest Alliance has stated that McLaughlin Ridge in the CCCW “is the largest remaining intact old growth Douglas fir forest in our area” and has estimated that only about 50 percent of the old growth on McLaughlin Ridge is left (Gulliver, 2013; Slepian, 2014).

Across Vancouver Island, environmentalists have described the harvesting of old growth forest as an “ecological emergency,” with the Sierra Club stating that only one-tenth of Vancouver Island’s productive old growth forest remains unharvested (Figure 5.2) (Hunter, 2016). The Government of B.C. has estimated that 46 percent of all Crown forest land is covered by old growth, but the Sierra Club claims that this “figure is inflated because the province includes less productive ecosystems such as bogs or sparsely treed high elevations” in their definition of old growth (Hunter, 2016).

Other threatened species that live in the CCCW include the Vancouver Island water shrew, the red-legged frog, and the saxatilis subspecies of white-tailed ptarmigan (Barlak, 2011a). There have also been historical observations of the Vancouver Island marmot, another endangered species (Figure 5.5). Additional wildlife in the CCCW includes cougars, black bears, and many other mammals and birds (Barlak, 2011a).

Figure 5.2: Remaining productive old growth in B.C.

Figure 5.3, 5.4, and 5.5: Queen Charlotte goshawk, Marbled Murrelet, and Vancouver Island marmot (top to bottom)

5.2 Critical Wildlife Habitat

The forests and streams of the CCCW provide valuable habitat for a variety of species, many of which are listed as threatened or endangered. The old growth on McLaughlin Ridge provides “very high value winter range for blacktail deer and habitat for the Queen Charlotte goshawk,” which is on the B.C. Red List of legally designated endangered or threatened species and is considered threatened by the Committee On the Status of Endangered Species In Canada (COSEWIC) (Figure 5.3) (Barlak, 2011a, p. 13). The Marbled Murrelet, another threatened species in B.C., spends much of its time at sea but depends on old growth forest for nesting habitat, and the species struggles when old growth stands become fragmented (Figure 5.4)

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5.3 High Value Fisheries

The lower 11 km of China Creek is a high-value fisheries resource (Koers and Associates Engineering Ltd., 2010). Species present in China Creek include pink, coho, chinook, and chum salmon, rainbow trout, steelhead, and Dolly Varden char (Figure 5.6) (Barlak, 2011a). Additionally, there is cutthroat trout in both Duck Lake and Bainbridge Lake, and Lizard Lake contains rainbow trout (Barlak, 2011a). Aquatic wildlife depends on healthy riparian vegetation which helps to control debris, sediment, and stream temperatures (Ministry of Forests Mines and Lands, 2010).

be given to protection of this very productive landscape that supports diverse ecological systems” (Barlak, 2011b, p. 5).

Figure 5.6: Wild coho salmon

Figure 5.7: Karst landscape digram

5.4 Karst Formations

According to Bates and Jackson (1984), karst is “[a] type of topography formed over limestone, dolomite, or gypsum by dissolution and that is characterised by sinkholes, caves, and underground drainage” (as cited in Francoeur, 2011, p. 17). Over time, the host bedrock dissolves, forming water-storing caves and conduits that can rapidly transport water over great distances (Barlak, 2011b). Figure 5.7 shows a simplified karst landscape diagram (Francoeur, 2011). These landscapes are vulnerable to disturbances such as logging (Francoeur, 2011).

A study by Guthrie (2005) identified karst formations in the upper Williams Creek portion of the CCCW (as cited in Barlak, 2011b). Other preliminary studies have found that karst aquifers may play a role in recharging the China Creek water system (Caproff, 2014). A 2011 report by the B.C. Ministry of Environment stated that the karst formations in the CCCW are “highly sensitive, valuable and non-renewable” and that “[s]pecial consideration should

5.5 Water Quantity

In addition to water quality, forestry activities have provoked concerns about water quantity in Port Alberni. A mild winter in 2014-2015 followed by a hot, dry summer in 2015 led to water shortages across much of Vancouver Island (Slepian, 2015b). While Port Alberni did not experience critically low water levels, there was still concern. Port Alberni mayor Mike Ruttan said in 2015 that ““[i]f you do not permit any logging in the watershed then you have a far greater retention of water in that area” and emphasized that steps could be taken to maximize snow retention. However, Port Alberni’s City Engineer Guy Cicon has indicated that Port Alberni’s water system does not currently suffer from water quantity issues and that “[t]here’s sufficient capacity within our infrastructure to accommodate future growth within and outside the city” (Butt & Hughes-Adams, 2014; Slepian, 2016).

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5.6 Climate Change

Forests play a key role in minimizing the impacts of climate change. Trees act as carbon sinks, capturing and storing CO2 as long as they remain undisturbed (although if timber is used to fabricate long-lasting wood products, then the impact of harvesting can be minimal in this regard). Additionally, mature trees can mitigate the impact of extreme weather by stabilizing the soil and reducing erosion during heavy rainfall events, which are expected to increase in frequency as climate change continues (Kirilenko & Sedjo, 2007).

Kuraś, Alila, and Weiler (2012) found that forest harvesting can increase both the severity and magnitude of floods. This effect could be worsened as climate change produces more heavy rainfall events, leaving watersheds vulnerable to erosion (Kirilenko & Sedjo, 2007). It is unclear whether or not these impacts would occur within the CCCW, as any impacts would depend on site-specific precipitation, topography, harvest technique, and any locally implemented mitigation systems. A 2008 report by the Alberni Valley Climate Change Committee explained that extreme weather events “pose the greatest climate

risk for the [Alberni] Valley” and predicted that the area would experience more intense winds and precipitation, more frequent hot spells, and an increase in unseasonable and unusual weather such as hail and lightning storms (as cited in Francoeur, 2011, p. 169).

5.7 Erosion and Landslides

The root systems of mature forests help to stabilize soil, thus reducing the impacts of erosion. This is especially important in steep-sloped watersheds such as the CCCW, as these slopes are particularly susceptible to failure during high overland water flows resulting from precipitation events (Figure 5.8) (Kirilenko & Sedjo, 2007). Slope failure can contribute sediment to stream channels (Kirilenko & Sedjo, 2007). The Alberni Valley has experienced landslide problems in the past, with landslides in 2006 bringing gravel into residents’ homes in Beaver Creek (Slepian, 2014). Some have speculated that those landslides were a result of clearcutting in the Beauforts—a mountain range north of Port Alberni—that was followed shortly by heavy precipitation (Slepian, 2014).

Figure 5.8: Logging along the steep slopes of McLaughlin Ridge in the China Creek Community Watershed. Proper harvesting techniques can mitigate the risks of harvesting on steep slopes.

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5.8 Cultural and Aesthetic Values

An Alberni Valley without forests would be only a shadow of its current splendour. The forest has great cultural value to the First Nations who have long inhabited the land as well as to those who migrated to the area more recently, many of whom came to work in the forestry industry. Clearly, logging is an important part of the area’s heritage and should be celebrated as such, but even more important are the forests themselves. There is a deep intrinsic value in the CCCW that, it could be argued, should be preserved for future generations.

Many municipalities are beginning to take advantage of their forests’ aesthetic values. With the forestry industry in decline, parts of the Alberni Valley are shifting towards tourism and recreation, with hiking becoming a popular regional attraction (Alberni-Clayoquot Regional District, 2010; Dobson, 2015). Dan Hager, President of the Port Renfrew Chamber of Commerce, has explained that “tourists who come to see the majestic trees have created a multimillion-dollar economy along the coast and the highest value would come from stopping the logging” (Theodore, 2015).

In Port Alberni, Economic Development Manager Pat Deakin is instead “focusing on water as the region’s primary attraction,” stating that there is “an opportunity to market not only the community’s abundance of drinking water but the quality of it”—a strategy meant to entice millennials that are conscious of “water issues in communities” (Slepian, 2015c). Logging in Port Alberni’s drinking watershed seemingly runs counter to this marketing strategy.

Hiking is popular in Port Alberni as well, with logging roads providing access to hiking trails on private lands in the CCCW (Figure 5.9) (Koers and Associates Engineering Ltd., 2010). Some trail users are concerned that logging will negatively impact these forest trails, reducing access and destroying scenery (Dobson, 2015). However, residents should be cautious in calling for increased recreational opportunities in the watershed, because recreational activities—especially unregulated activities—can create significant water quality problems. This issue will be discussed later in the report.

Figure 5.9: Hiking in the China Creek Community Watershed

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This chapter examines water quality, which is the primary focus of this report. Both the technical aspects and regulatory framework behind water quality in B.C. are complex, but understanding these complexities is crucial when attempting to link particular land uses to water quality issues.

6.1 Water Quality Overview

“Water quality” is a general term that is typically used to describe “the chemical, physical, and biological characteristics of water, usually with respect to its suitability for a particular use” (R. Pike, Feller, & Stednick, 2010, p.401). For example, the water quality standards required for potable water are quite different than those required for watering gardens or for industrial uses (Schreier, Wilson, & Pang, n.d.). Table 6.1 lists parameters and example measures for each of the three general categories of water quality. In order to ensure that the scope of this report remained manageable, this discussion of water quality in the CCCW focuses predominantly on turbidity. Turbidity was chosen as a focal point because it is “the primary parameter of concern that must be addressed in order to make the Alberni Valley surface water sources suitable for drinking” (Koers and Associates Engineering Ltd., 2010, p. 29). Other water quality measures will be briefly touched upon at various points in this report.

6.2 Turbidity

Turbidity is simply a “measure of the relative clarity or cloudiness of water” (Figure 6.1) (Vancouver Island Health Authority, n.d.). The Vancouver Island Health Authority (VIHA) (n.d.) further explains that turbidity is “an indirect measure of the suspended particles in the water and is a general measure of the scattering and absorbing effect that suspended particles have on light.” The standard measurement for turbidity is nephelometric turbidity units (NTU), which are measured by a nephelometer, a device that detects the amount of light that is scattered off particles in the water (Francoeur, 2011). As turbidity increases, water will appear cloudier ; water is clear to the naked eye at 1.0 NTU, detectably cloudy at 5.0 NTU, and visibly cloudy at 10 NTU (Vancouver Island Health Authority, n.d.).

CATEGORY PARAMETERS EXAMPLE MEASURESPhysical Water temperature Temperature

Sediment Total suspended solidsTurbidity

Chemical Ions, dissolved constituents, and nutrients pHElectrical conductivityTotal dissolved solidsDissolved oxygenIons (e.g. sodium, potassium, calcium, magnesium, iron)Nitrogen (nitrate, ammonium)Phosphorus (various forms)

Toxic parameters Pesticides (insecticides, herbicides, fungicides)Metals (e.g. lead, mercury, cadmium, aluminum, copper, selenium, zinc)

Biological Biological parameters Chlorophyll aFecal coliformBenthic invertebrate communities

Table 6.1: Forest water quality parameters and example measures (R. Pike et al., 2010, p. 406)

Figure 6.1: Turbidity Sample

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CHAPTER 6: WATER QUALITY PARAMETERS AND REGULATION

There is a distinction between suspended sediments an turbidity (Butt & Hughes-Adams, 2014). Turbidity is a function of the suspended sediment concentration in a body of water, but it is also a function of the shape, colour, and size of the sediment particles (Butt & Hughes-Adams, 2014). While there is no single correlation between the two measures, turbidity at a given site will exhibit “site-specific correlation” with the suspended sediment concentration (Butt & Hughes-Adams, 2014, p. 47).

Turbidity is an important measure for a number of reasons. Vancouver Island Health Authority indicates that while turbidity itself does not actually cause health problems, it can interfere with disinfection processes and it serves as an indicator of the presence of pathogenic organisms (Medical Health Officer & Vancouver Island Health Authority, 2014). When turbidity levels become elevated, there is an increase in the total available surface area of suspended solids upon which bacteria can grow (Ministry of Environment, Lands and Parks & LandData BC, 1998). These bacteria can then be sheltered by the suspended solids, rendering disinfection methods such as chlorination and ultraviolet light (UV) treatment ineffective at destroying pathogens (Vancouver Island Health Authority, n.d.).

Additionally, turbidity is aesthetically unpleasant, although it is important to note that drinking water can appear cloudy and discoloured yet still be safe to consume based on other water quality parameters (Ministry of Environment, Lands and Parks & LandData BC, 1998). Turbidity also reduces light penetration, impairing the photosynthesis of submerged vegetation and algae, which can in turn suppress fish productivity (Ministry of Environment, Lands and Parks & LandData BC, 1998).

Turbidity is highly variable and often fluctuates seasonally, with increased turbidity occurring during the spring freshet (depending on rainfall events and the melting season) (H. Schreier, personal communication, May 2, 2016). There are many causes, including suspended organic or colloidal materials such as silt, clay, and bacteria (Medical Health Officer & Vancouver Island Health Authority, 2014). Natural events such as weathering, erosion, and landslides, combined with surface runoff, increase turbidity (Medical Health Officer & Vancouver Island Health Authority, 2014). Elevated turbidity is often noticed when major disturbance events (either natural or anthropogenic) are quickly followed by heavy rainfall, which washes sediment into water bodies. Surface water is particularly susceptible to sudden turbidity increases following these rainfall events.

Anthropogenic sources of turbidity include road construction and usage, forest harvesting, agriculture, mining, urban development, sewage treatment plant effluents, and industrial effluents (Ministry of Environment, Lands, and Parks & LandData BC, 1998). The numerous potential sources of turbidity make it difficult for water purveyors to accurately identify the specific types of particulate matter in the water or their corresponding health risks; therefore, VIHA expects purveyors to apply a precautionary approach by promptly notifying customers of any potential issues. Short-term Boil Water Notices can be issued for a variety of reasons, including disinfection equipment malfunctions and increased turbidity due to natural and anthropogenic events (Medical Health Officer & Vancouver Island Health Authority, 2014).

6.3 Water Quality Regulations

In Canada, drinking water quality legislation is developed at the provincial level, meaning that each province or territory may have different regulations (Koers and Associates Engineering Ltd., 2010). The provinces can use Health Canada’s Guidelines for Canadian Drinking Water Quality (GCDWQ) to guide them in writing their own regulations as they see fit, but this is not a requirement (Koers and Associates Engineering Ltd., 2010). In British Columbia, the most important pieces of legislation for determining and enforcing water quality standards are the Drinking Water Protection Act (DWPA) and Drinking Water Protection Regulation (DWPR), which are under the provision of the Ministry of Health (Ministry of Health, 2014).

Under the DWPA, water suppliers such as the City of Port Alberni are mandated to “provide, to the users served by its water supply system, drinking water from the water supply system that (a) is potable water, and (b) meets any additional requirements established by the regulations or by its operating permit (Government of British Columbia, 2015). “Potable” is defined as water that “(a) meets the standards prescribed by regulations, and (b) is safe to drink and fit for domestic purposes without further treatment” (Ministry of Health, 2014). Part 4, Section 23 of the DWPA outlines the “prohibition against contaminating drinking water or tampering with system” and can be read in full in Figure 6.2.

In B.C., the five regional health authorities—Fraser Health Authority, Interior Health Authority, Northern Health Authority, Vancouver Coastal Health Authority, and Vancouver Island Health Authority—are responsible for

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the administration and implementation of the DWPA (B.C. Office of the Ombudsmen, 2008). As the name implies, the Vancouver Island Health Authority (VIHA) administers the DWPA on Vancouver Island. The DWPA authorizes Drinking Water Officers (DWO) in each of the regional health authorities to enforce the Act and Regulation by granting permits, stipulating directives to water purveyors, conducting inspections, and initiating compliance and enforcement actions (B.C. Office of the Ombudsmen, 2008; Koers and Associates Engineering Ltd., 2010). These

legislative powers can be delegated to medical health officers, public health inspectors, environmental health officers, and public health engineers if necessary (Ministry of Health, 2014).

Despite the various powers granted to DWOs, a report by the B.C. Ombudsman found that “ultimately however the DWPA puts much of the responsibility for testing, issuing notices and advisories, planning for emergencies and reporting, on the various public, not-for-profit and

Figure 6.2: Drinking Water Protection Act, Part 4, Section 23

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Drinking Water Protection Act (Government of British Columbia, 2015)Part 4 — Drinking Water Protection

Prohibition against contaminating drinking water or tampering with system

23(1) Subject to subsection (3), a person must not(a) introduce anything or cause or allow anything to be introducedinto a domestic water system, a drinking water source, a wellrecharge zone or an area adjacent to a drinking water source, or(b) do or cause any other thing to be done or to occur,

if this will result or is likely to result in a drinking water health hazard in relation to a domestic water system.

(2) Subject to subsection (3), a person must not(a) destroy, damage or tamper with any part of a domestic water system,(b) open or close any part of a domestic water system,(c) introduce anything or cause or allow anything to be introduced into a domestic water system, a drinking water source, a well recharge zone or an area adjacent to a drinking water source, or(d) do or cause any other thing to be done or to occur,

if it is reasonably foreseeable that, as a result, the owner of the domestic water system would have to limit the use of the water provided by the system on the basis that there may be a risk of a drinking water health hazard.

(3) The prohibitions in subsection (1) and (2) do not apply(a) in relation to anything required for the proper operation, maintenance or repair of a domestic water system or the treatment of water in the system,(b) if the introduction or activity is authorized or required under an enactment or the person is otherwise acting with lawful authority,or(c) in relation to an activity prescribed by regulation that is undertaken in accordance with any conditions prescribed by regulation.

(4) For the purposes of prosecuting a contravention of subsection (1) (a), it is not necessary to prove that the thing, if diluted at or subsequent to the point at which it was introduced, continued to result in or be likely to result in a drinking water health hazard.

private water suppliers” (B.C. Office of the Ombudsmen, 2008). Water purveyors are tasked with ensuring that their water meets the applicable standards, while the DWOs are meant to ensure that purveyors are acting appropriately (B.C. Office of the Ombudsmen, 2008). Additionally, where there is overlap between the responsibilities of DWOs and officials from other government agencies, DWOs can “collaborate” and in some cases “rely on steps being taken by other agencies if and to the extent those may address concerns held by drinking water officers in relation to the decisions of the other officials (and vice versa)” (Ministry of Health, 2014).

In 2008, the VIHA adopted the “4-3-2-1-0 Drinking Water Objective” for water treatment, a province-wide initiative that set new treatment standards for water purveyors (Koers and Associates Engineering Ltd., 2010). Figure 6.3 explains the objective in full, but the most relevant items to this report are items one and two. Item one calls for a maximum turbidity of 1.0 NTU, with VIHA explaining that the “health risk increases as turbidity increases and the health risk will increase before cloudy water is noticed” and that “[f]or disinfection and treatment systems to be effective, the water must be less than 1 NTU” (Medical Health Officer & Vancouver Island Health Authority, 2012, p. 2).

Item two calls for two separate treatment processes—typically filtration and disinfection—for all drinking water sources at risk of containing pathogens, which includes all surface water sources (Medical Health Officer & Vancouver Island Health Authority, 2012, p. 2). VIHA explains that there is “no single treatment technology that can assure drinking water safety on its own” (Medical Health Officer & Vancouver Island Health Authority, 2012, p. 2). However, the 4-3-2-1-0 regulation also states “for systems with very high quality sources and effective and ongoing

watershed protection, 2 forms of disinfection may be permitted. This will generally be chlorination and UV light disinfection” (Medical Health Officer & Vancouver Island Health Authority, 2012, p. 2). Municipalities that believe their water sources meet this level of quality can apply to VIHA for a “filtration deferral,” which allows them to legally provide water without installing a filtration plant. In order to receive a filtration deferral, a water system must meet the following conditions (Koers and Associates Engineering Ltd., 2010 ; B. Sims, personal communication, April 27, 2016):

• Daily average source water turbidity must be 1 NTU or less for 95% of the days and not above 5 NTU on more than 2 days in a 12 month period;

• Escherichia coli must be 20/100 ml or less in 90% of source water samples;

• Two primary disinfectants are provided, which together achieve a 4-log removal/inactivation of viruses and 3-log removal/ inactivation in Giardia and Cryptosporidium (usually UV and chlorination);

• Watershed protection or management plan is in place.

6.4 Filtration Deferral in Port Alberni

The City of Port Alberni has requested a filtration deferral from VIHA, which may be granted pending the approval of a watershed management plan. As of May 2016, the City had just released the Drinking Water Source Assessment and Preliminary Protection Plan Development, which serves as this plan. Port Alberni anticipates being able to achieve this filtration deferral because of generally high water quality, but also because of the redundancy that is built into their water system; when turbidity becomes elevated in China Creek, the City switches over to Bainbridge Lake (Koers and Associates Engineering Ltd., 2010). While lakes and other still water sources tend to have a higher base turbidity than flowing water, lakes experience fewer fluctuations in

4-3-2-1-0 Objective (Medical Health Officer & Vancouver Island Health Authority, 2012)

4 refers to a 4-log (99.99%) reduction in viruses;3 refers to the 3-log (99.9%) removal or inactivation of parasites;2 refers to two treatment processes for all surface water or unprotected groundwater, usually filtration and disinfection;1 refers to maintaining a turbidity of less than 1 NTU;0 refers to Bacterial Indicators (E. Coli, fecal coliform and total coliform)

Figure 6.3: 4-3-2-1-0 Objective for drinking water in B.C.

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turbidity from high flow and surface runoff events such as storms and freshets, making them a relatively stable backup water source (S. Thomas, personal communication, January 21, 2016).

Despite this redundancy, the City of Port Alberni was still required to upgrade their water treatment facility, as they were using only one disinfectant (chlorine) to treat their drinking water. In December 2015, the city opened a new $4 million water treatment plant at Bainbridge Lake that treats water from both China Creek and Bainbridge Lake using chlorine and UV disinfection (Figure 6.4) (Slepian, 2015e). The chlorine system has also been upgraded from chlorine gas to a liquid chlorine system, which is safer for both operators and the environment (Slepian, 2015d).

Receiving the filtration deferral from VIHA is important for Port Alberni because it would mean avoiding the construction of an expensive filtration facility, which could cost as much as $50-70 million based on plants that were

recently completed or commissioned in Nanaimo and Comox Valley, respectively (Slepian, 2015d). Chapter 10 describes these cases in greater detail.

Figure 6.4: Port Alberni’s new treatment facility

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This chapter presents the results of a literature review on the impacts of logging on water quality in the Vancouver Island context. This section is not focused specifically on the CCCW. Rather, it provides an overview of forest hydrology and the potential impacts of logging within watersheds, without implying that all of these impacts are currently occurring within the CCCW. The primary objective of this report is to examine the effect of logging on water quality, but other forestry impacts such as stream temperature and water quantity will be briefly described.

7.1 Overview of Natural Forest Hydrology

Before discussing the impacts of logging on water quality, it is first necessary to gain a basic understanding of how water normally moves through a forest ecosystem. Understanding the base hydrological condition of an undisturbed forested watershed allows researchers to make pre- and post-disturbance comparisons. To start, it is important to recall that water, nutrients, sediments, organic matter, and other dissolved substances generally flow with gravity from the headwaters to the lower reaches of a watershed. This means that disturbances on hillslopes all throughout the watershed—including even the uppermost reaches—could eventually impact downstream reaches (Figure 7.1) (Watts & Tolland, 2013). According to Moore, “[i]t is this connectivity that necessitates consideration of the hydrologic impacts of forest operations within a watershed context” (Watts & Tolland, 2013, p. 122). Erik Piikkila, a forest ecologist who studies the history of logging on the landscape, offered his expertise for this report. In addition to learning through his own professional experience, Mr. Piikkila studied under Dr. Jerry Franklin, a professor at the University of Washington who specializes in forest ecology and sustainable resource management (Franklin, 1988; Franklin et al., 1981; Franklin & Spies, 1986; Franklin & Spies, 1991a; Franklin & Spies, 1991b). As a result, Mr. Piikkila has acquired a significant amount of knowledge pertaining to forest and landscape ecology, especially relating to old growth forest. Mr. Piikkila uses the phrase “Slowing Water on the Landscape” to describe the way that water moves in natural forest ecosystems, and in particular in the old growth forests of Coastal B.C. and the Pacific Northwest region of the United States. In their undisturbed, centuries-old state, these forests slow the movement of water across the landscape and directly affect the amount of water available for streamflow (E. Piikkila, personal communication, May

4, 2016; Winkler, Moore, Redding, Spittlehouse, Carlyle-Moses, et al., 2010). Trees of various species, ages, and heights can intercept a significant amount of precipitation, after which it either evaporates, sublimates, or drips slowly to the ground (E. Piikkila, personal communication, May 4, 2016; Winkler, Moore, Redding, Spittlehouse, Carlyle-Moses, et al., 2010; Watts & Tolland, 2013).

Numerous studies have demonstrated that interception tends to increase as forests age, because the leaf area index—and hence, the interception potential—increases as trees grow (Watts & Tolland, 2013). Interception reduces the total amount of water reaching the Earth’s surface and minimizes splash erosion (Department of Primary Industries, Parks, Water and Environment (Tasmania), 2016). In addition to the trees themselves, lichens and moss that hang from tree branches increase the vegetative surface area that can capture precipitation, thereby increasing the amount of interception (Figure 7.2) (E. Piikkila, personal

Figure 7.1: Water flowing downhill in the watershed

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CHAPTER 7: A SCIENTIFIC REVIEW OF THE IMPACT OF LOGGING ON WATER QUALITY

communication, May 4, 2016).

Once water passes through the tree canopy, it encounters even more obstacles. Undergrowth such as salal, salmonberry, and ferns will intercept precipitation, while rotting logs and “thick mats” of moss, fungus, and fine debris such as decaying leaves and needles will absorb moisture (Figure 7.3) (Franklin et al., 1981). Water that is not lost through evaporation, sublimation, or absorption may become surface runoff, working its way downhill into rivulets, streams, rivers, wetlands, lakes and eventually the ocean (Figure 7.4). Because this water is impeded by surface vegetation, its erosive force is reduced (E. Piikkila, personal communication, May 4, 2016). All of the layers of a forest, from the top of the canopy to ground vegetation, have an important role to play in “Slowing Water on the Landscape,” and this is especially critical during large rain and rain on snow events (E. Piikkila, personal communication, May 4, 2016).

Some of the water that reaches the forest floor will also infiltrate the soil. A portion of this infiltration is captured and absorbed by massive subterranean fungal and tree root systems (E. Piikkila, personal communication, May

4, 2016). The rest will gradually percolate through layers of soil, getting filtered by these layers as it recharges soil moisture levels (Schreier, Brown, & Pang, n.d.; E. Piikkila, personal communication, May 4, 2016). Water stored as soil moisture will eventually make its way back into the flowing water system or become stored in groundwater aquifers (Schreier, Brown, & Pang, n.d.; E. Piikkila, personal communication, May 4, 2016).

Forests, as part of the water cycle, also contribute to the production of precipitation. Transpiration—the release of water vapor by vegetation—contributes about ten percent of the moisture present in the atmosphere (U.S. Geological Survey Water, n.d.). Additionally, mushrooms on the forest floor can release millions of spores that are blown high into the atmosphere, triggering condensation and producing rain (Hassett, Fischer, & Money, 2015). This is similar to the action of dust and air particles in the atmosphere.

Finally, undisturbed forests will naturally contain well-established riparian areas, which are crucial to water quality and flow characteristics in a watershed. A riparian area is “[a]n area of land adjacent to a stream, river, lake or wetland that contains vegetation that, due to the presence of water,

Figure 7.2: Lichen intercepts water Figure 7.3: Fungal growth on the side of a tree

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is distinctly different from the vegetation of adjacent upland areas,” and these areas are influenced by and influence the adjacent body of water (Roger G. Pike et al., 2010, p. 761).

Riparian vegetation performs a number of critical functions: it buffers water bodies from sedimentation and pollution in surface runoff, provides food, nutrients, and organic matter to streams, stabilizes soils and stream banks thanks to a vigorous mass of roots, and moderates stream temperatures by providing shade (Government of British Columbia, 2006; Private Managed Forest Landowners Association, 2001; Richardson & R.D. Moore, 2010). Large woody debris from streamside vegetation helps regulate streamflow, contributes to channel stability, and creates pools and riffles which enhance fish habitat (Private Managed Forest Landowners Association, 2001). Ultimately, any disturbance to forest composition, canopy size, undergrowth characteristics, or riparian areas can disrupt the water quality, flow, and balance in a watershed (E. Piikkila, personal communication, May 4, 2016).

7.2 Natural Causes of Water Quality Issues in Forests

A variety of natural events can cause turbidity and other water quality issues in forested watersheds. This can make it extremely challenging to determine the exact source of a turbidity event (H. Schreier, personal communication, May 2, 2016). Harr and Fredriksen (1988) have found that processes such as weathering and erosion, landslides, wildfire, and blowdown can impact water quality by “creating temporarily increased concentrations of sediment, increased stream temperatures, and (or) increased nutrient concentrations” (as cited in R. Pike et al., 2010, p. 401). Surface erosion in undeveloped forested watersheds is typically “limited to exposed mineral surfaces at landslide scars” because “the soil surface is protected by the surface organic horizons and root network,” as described above (Watts & Tolland, 2013, p.139). Water chemistry can be altered as a result of soil, vegetation, and bedrock interactions, as natural contaminants like arsenic and uranium may be present (R. Pike et al., 2010; Francoeur, 2011). Wildlife excrement also introduces harmful pathogens into the water. Additionally, storm events and seasonal variations in streamflow contribute to variations in water quality over time (R. Pike et al., 2010). When streamflow in forests increases, the concentration of dissolved constituents generally decreases, a relationship that can be measured using electrical conductivity as a proxy (R. Pike et al., 2010). In areas like the CCCW, natural turbidity is generally higher in the fall and winter months due to heavy rainfall events (Vancouver Island Health Authority, n.d.). Turbidity can also increase during the spring freshet as rapid snowmelt occurs (H. Schreier, personal communication, May 2, 2016). Table 7.1 provides an overview of naturally occurring potential contaminant sources.

7.3 Effect of Logging on Water Quality

7.3.1 Roads

In order to access logging sites and transport timber, roads must be constructed (assuming truck logging is the method being conducted) (Figure 7.5). Numerous studies have shown that road construction and usage is “a dominant source of fine sediment in most harvested watersheds” (Watts & Tolland, 2013, p. 141). How and where roads are constructed is critical in determining their impact on the

Figure 7.4: Water flowing in the CCCW

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Table 7.1: Naturally occuring contaminant sources and the contaminants commonly associated with them (Ministry of Health, 2010)

Figure 7.5: Logging road on McLaughlin Ridge in the China Creek Community Watershed

SOURCE HEALTH, ENVIRONMENTAL OR AESTHETIC CONTAMINANT(S)Rocks and soils Aesthetic contaminants: iron and iron bacteria; manganese; calcium and magnesium

(hardness)Health and environmental contaminants: Arsenic; asbestos; metals; chlorides, fluorides; sulphates; sulphate-reducing bateria and othermicroorganisms

Contaminated water Excessive sodium; bacteria; viruses; low pH (acidic) waterSediment sources Increases TurbidityWildlife Pathogens including E-Coli, Cryptosporidium parvum; Giardia lamblia; Toxoplasma

gondiiDecaying organic matter Bacteria; odour; colour, tasteGeological radioactive gas Uranium deposits; radon gas100-year floodplain Surface water contimation of well; sediment, bacteriaUpstream reservoirs (surface water only) Sediment during and after a storm

Natural hydrogeological events and formations

Salt-water/brackish water intrution (or intrutions of other poor quality water); contamination by a variety of substances through sink-hole infiltration in limestone terrains

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watershed, as proper construction and management can mitigate impacts. However, when improperly managed, roads can be a major source of turbidity.

For example, it can be cheaper and easier to build roads near or along a floodplain, but this clearly results in a greater flood and sedimentation risk (E. Piikkila, personal communication, May 5, 2016). Additionally, if construction leaves large amounts of gravel on the sides of the road or the fill slope enters the floodplain, these deposits can end up washing into nearby water bodies (E. Piikkila, personal communication, May 5, 2016). All road sections must be properly constructed, as Henderson and Toews (2001) have found that even a relatively small portion of the road network is capable of producing the majority of all road-generated sediment in a given watershed (as cited in Watts & Tolland, 2013).

Roads disrupt the natural flow of water over the landscape, intercepting surface runoff and shallow groundwater and channeling it into gullies or ditches (Horel, 1998). This can both concentrate the flow and increase the speed of the water, enhancing its erosive potential (Horel, 1998). The size and placement of culverts is also important; they should be positioned in a way that minimizes the channeling of surface runoff and they must be built large enough to withstand heavy precipitation and flood events (E. Piikkila, personal communication, May 5, 2016). These culverts must be kept clear of debris to ensure that they do not back up and inundate the road, as this can cause the road bed to fail, releasing significant amounts of sediment (E. Piikkila, personal communication, May 5, 2016; Watts & Tolland, 2013).

Stream crossings are particularly problematic, as they “are known to be common contributors of sediment in watersheds” (Butt & Hughes-Adams, 2014, p. 22). Standard practice when constructing a road in a watershed is to leave a riparian buffer strip between the road and any bodies of water, but this is clearly impossible when constructing a bridge. Sediment can enter the water from drainage ditches on the sides of the crossing, from road surface erosion, and from the wheel wash of trucks and other machinery (Figure 7.6) (Butt & Hughes-Adams, 2014). Wheel wash is more likely to occur when operating in wet conditions, which are quite common due to the coastal climate—it would be prohibitively expensive and inefficient to halt all logging in watersheds on Vancouver Island every time that the roads were wet from rain (Butt & Hughes-Adams, 2014).

The intensity of road usage is also a key factor, as Reid and Dunne (1984) demonstrated that “intensely used roads generated 130 times more sediment than abandoned roads” (as cited in Watts & Tolland, 2013, p. 141). Roads that will not be used until a later date need to be seasonally deactivated with cross ditches and waterbars—a raised surface similar to a speed bump—in order to direct water from the roads’ surfaces onto the hillsides, especially if the road segments have a steep grade (E. Piikkila, personal communication, June 1, 2016).

However, even unused logging roads will continue to release sediment into the watershed, so when roads will no longer be used, they need to be properly decommissioned. This includes fill slope pull back and recontouring the road surface and cut slopes above and below the road, restoring natural runoff pathways by removing culverts, digging cross ditches or large, deep trenches, and replanting the roadway and disturbed fill slopes in order to prevent large volume water events that can erode forest soils (E. Piikkila, personal communication, May 5, 2016).

7.3.2 Harvesting

Timber harvesting may also negatively impact water quality, particularly by increasing the rate of sediment input into streams (Watts & Tolland, 2013). Landslides, gullies and stream channel bank erosion are some of the primary forestry-related sources of sediment (Horel, 1998). These problems result from soil instability, which itself occurs due to the removal of stabilizing forest vegetation (Figure 7.7).Landslides and erosion can occur immediately after

Figure 7.6 Sand and fine gravel on a bridge in the CCCW. This material is deposited primarily by truck tires when hauling. Sand and gravel does not contribute to turbidity, but mud has likely already washed into the creek (Butt & Hughes-Adams, 2014)

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harvesting as a result of direct soil disturbance, but they may also occur years later when the root systems of harvested trees decay, compromising the internal soil cohesion (Buschhaus, 2010; Watts & Tolland, 2013). Sidle (1992) found that “[t]here is a critical period from about 5 to 15 years following logging, in which the strength of dead roots has decayed below critical levels, and before new roots become sufficiently established to restore soil cohesion,” when landslides are especially likely to occur (as cited in Watts & Tolland, 2013, p. 140). If left unvegetated, landslide scars can continue contributing sediment long after the initial event (Watts & Tolland, 2013). Another non-immediate harvesting impact is windthrow, where exposed trees in unharvested riparian buffers are blown over. Windthrow reduces the buffer size and further destabilizes soil, and it can occur anywhere from 3 to 15 years after harvesting (Buschhaus, 2010).

The sediment that results from these soil disturbances must be washed into channels in order to impact water quality. Harvesting changes the way that precipitation and overland flow affect a watershed (Figure 7.8). A reduction in forest cover can result in an increase in net precipitation, because while gross precipitation remains unchanged, the amount that is intercepted and lost due to evaporation and sublimation will decrease after harvesting (Winkler, Moore, Redding, Spittlehouse, Smerdon, et al., 2010). While some understory will remain postharvest, interception from this vegetation tends to be smaller than that from intact forest canopies (Winkler, Moore, Redding, Spittlehouse,

Smerdon, et al., 2010). At the same time, the increase in direct throughfall will cause more splash erosion to occur.

Studies in B.C. have shown that anywhere from “5–70% more water can accumulate as snow in clearcuts than in the forest, depending on the winter precipitation in a given year and forest cover type” (Winkler, Moore, Redding, Spittlehouse, Smerdon, et al., 2010, p. 179). Harestad and Bunnell (1982) and Moore and McCaughey (1997) found that “[r]eductions in snow interception and increases in net precipitation are generally proportional to reductions in canopy cover or to percent basal area removal” (as cited in Winkler, Moore, Redding, Spittlehouse, Smerdon, et al., 2010, p. 180). While a larger snowpack will accumulate in harvested areas, it will generally melt faster because it will be exposed to greater amounts of wind and incident solar radiation (Watts & Tolland, 2013). In fact, Toews and Gluns (1986) found that exposed snow can melt as much as 30 to 50 percent faster than snow protected by a forest canopy (as cited in Watts & Tolland, 2013). This has consequences for water retention and flow rates.

As a result of increased net precipitation as well as alterations to the physical properties of soils, soil moisture levels will increase after harvesting (Winkler, Moore, Redding, Spittlehouse, Smerdon, et al., 2010). Some studies have reported that harvesting raises the water table, which can increase the risk of slope failure in steep, mountainous watersheds (Winkler, Moore, Redding, Spittlehouse, Smerdon, et al., 2010).

Figures 7.7 and 7.8: Harvesting on McLauughlin Ridge in CCCW (left); water flowing post harvest on McLaughlin Ridge

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Surface runoff can also increase because of reduced infiltration rates from soil compaction (Winkler, Moore, Redding, Spittlehouse, Smerdon, et al., 2010). Higher soil moisture and increased runoff can each increase the water available for streamflow, resulting in greater peak flows that can erode stream banks (Winkler, Moore, Redding, Spittlehouse, Smerdon, et al., 2010). Overland flow not only causes its own surface erosion, but may also wash sediments caused by other soil disturbances into stream channels (Watts & Tolland, 2013).

Part of harvesting timber is transporting the logs to the market, which occurs in a three-stage process. Primary transportation involves moving logs from the stump to a nearby location where intermediate transportation begins (Vyse, Bendickson, Hannam, Cuzner, & Bladon, 2010). Yarding and skidding are examples of primary transportation (Vyse et al., 2010). Log skidding can produce sediment as it involves dragging logs along the soil surface (Watts & Tolland, 2013).

Intermediate transportation (e.g. truck hauling) involves the accumulation of logs on landings to prepare them for more cost-efficient movement—this stage uses roads and therefore can contribute sediment, as discussed above (Watts & Tolland, 2013). Logs are brought to a dryland sort where the logs are bundled by grade and dumped into the ocean (E. Piikkila, personal communication, June 1, 2016).

Market transportation is the third stage, where large amounts of logs are transported from the forest operation’s sort or dump site to a mill for processing (Watts & Tolland, 2013). For over a century, water transportation has dominated this stage because it is by far the most efficient method available (Watts & Tolland, 2013). Increasingly, truck transportation of logs, especially Second Growth, is occurring directly from the landing out in the woods to a mill, or a dryland sort or log dump

located at the ocean; however, water transportation of logs is still the dominant method on Western and Northern Vancouver Island, the Central and North Coast, and Haida Gwaii (E. Piikkila, personal communication, June 1, 2016).

It is important to note that not all sediment generated by forestry operations will end up in a stream or lake and furthermore, not all streams or lakes connect to the water body containing the water intake in a drinking watershed. When sediment is generated directly adjacent to a channel (at a stream crossing, for instance), it is highly likely that the sediment will wash into that channel (Watts & Tolland, 2013). However, the impact of soil disturbances that occur further from a stream channel are less certain; if there is no continuous line of overland flow from the point of disturbance to the channel, the sediment will simply be deposited on the soil surface (Watts & Tolland, 2013). In a study of watersheds in southeastern B.C., Henderson and Toews (2001) “estimated that only 36% of the sediment eroded from road surfaces was delivered to the channel network” (as cited in Watts & Tolland, 2013, p. 139).

As mentioned in previous sections, sedimentation is not the only forestry-related risk to water quality. Table X [Forest Related Sources] provides a brief overview of some of these additional sources of contaminants, as described in by the Ministry of Health (2010). Factors such as water chemistry and stream temperature also play important roles in water quality and watershed ecosystem health. However, these issues will remain topics for further study, as the scope of this report is limited to a discussion of sediment-based water quality issues.

Table 7.2: Forestry-related contaminant sources and the contaminants commonly associated with them (Ministry of Health, 2010)

SOURCE HEALTH, ENVIRONMENTAL OR AESTHETIC CONTAMINANT(S)Landslides connected to water source Suspended sediments; turbidity

Log sorts Leachate from decomposing wood wasteLogging camps Fecal coliform; motor fuel; oilLogging roads Suspended sediment; turbidityCutblocks Elevated concentrations of nitrate; decrease in pH (small watersheds most susceptible)Channels in logged areas Turbidity due to increased channel scour and destabilization

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8.1 Geographic and Biogeoclimatic Characteristics

The CCCW has an area of 5,681 ha and measures 14 km in length from its headwaters to the municipal water intake at its base (Barlak, 2011a; Koers and Associates Engineering Ltd., 2016). It is actually part of a larger watershed called the China Creek Watershed, which has an area of 11,158 ha (Barlak, 2011a). CCCW ranges in elevation from 190 m at the water intake to approximately 1,575 m at the headwaters near Mount McQuillan (Barlak, 2011a).

The main watershed valley is “a narrow U-shape with a narrow valley floor,” with moderate to steep valley slopes rising up to rounded or hummocky bedrock ridges at the watershed drainage divide (Horel, 1998, p. 4). Rugged rock ridges with evidence of rockslides and avalanches characterize certain portions of the headwater area (Horel, 1998). While there are no perennial snow packs or icefields, the higher elevation areas in the upper watershed sustain snow throughout much of the winter (Figure 8.1) (Horel, 1998).

The water intake is located on China Creek, a fourth-order stream measuring 21 km in length (Barlak, 2011a). Stream orders are a hierarchical system in which headwater streams with no tributaries are classified as first order streams (Schreier, H., Brown, S., & Pang, G., n.d.). When two first order streams merge, a second order stream is created; when two second order streams merge, a third order stream is created, and so on (Schreier, H., Brown, S., & Pang, G., n.d.) (Figure 8.2). China Creek is the mainstem in the CCCW and is “a fairly high energy system with a large peak to low flow ratio,” meaning that flow levels change significantly with the seasons (Figure 8.3) (Horel,

1998, p. 3). There are several small tributaries to China Creek within the CCCW boundaries, including McLaughlin Creek, Mineral Creek, McQuillan Creek, and Williams Creek, which connects to Lizard Lake (Barlak, 2011a).

Vancouver Island contains a number of Biogeoclimatic Zones, which are defined as geographic areas “having similar patterns of energy flow, vegetation and soils, as a result of

Figure 8.1: Snow in the upper reaches of the CCCW

Figure 8.3: Low flow (top) vs. high flow (bottom) at the CCCW intake dam

Figure 8.2: Stream order classification diagram

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CHAPTER 8: CHINA CREEK COMMUNITY WATERSHED DESCRIPTION

a broadly homogeneous macroclimate” (Forest Practices Board, 2016b). The CCCW is located in the Coastal Western Hemlock CWH xm2 (xeric (dry) maritime) subzone from 0 – 650 m in elevation and the CWH mm2 (montane moist maritime) subzone from 650 – 1000 m in elevation, with areas above 1000 m in elevation falling within the Mountain Hemlock (windward moist montane, MHmm1) subzone and areas above 1,600 m in the Alpine Tundra parkland (ATp) zone (Figure 8.4) (Barlak, 2011a; Green & Klinka, 1994). The approximate area breakdown is shown in Table 8.1 (Barlak, 2011a; E. Piikkila, personal communication, June 2, 2016):Douglas-fir is the dominant tree species in the CWH

includes Alaskan blueberry, salal, oval-leaved blueberry, and black huckleberry (Barlak, 2011a).

CCCW receives approximately 2450 mm of precipitation per year (Buschhaus, 2010). In the lower reaches, only about six percent of this precipitation occurs as snow, but 81 percent falls as snow in the upper reaches, “giving the watershed a hybrid, or rain and snow dominated, hydrological regime” (Buschhaus, 2010, p.7). The nearest Environment Canada weather station is the “Port Alberni Cox Lake” station, about 10 km away at an elevation of 100 m (Environment Canada, 2013). Data from this station indicates that between 1981 and 2010, mean annual rainfall was 2,114 mm, with 79 percent of that falling between October and March (Environment Canada, 2013). The month of January averages 340.2 mm of rain, compared to an average of only 31.3 mm in July (Environment Canada, 2013).

8.2 Watershed Ownership

The CCCW is almost entirely privately owned. Of the 5,681 total hectares, Island Timberlands owns 4,958 ha (87.3%) and TimberWest owns 336 ha (5.9%) (Koers and Associates Engineering Ltd., 2016). The remaining 387 ha (6.8%) is Crown land within Tree Farm Licence (TFL) 44 and is managed by Western Forest Products (Koers and Associates Engineering Ltd., 2016) (Figure 8.6). When compared to B.C. forests as a whole, this ownership structure is unusual; as shown in Figure 8.6, 95 percent of all land and forests in B.C. are owned by the Crown, while only about four percent is privately owned (Ministry of Forests Mines and Lands, 2010). However, private forest ownership is common along the east coast of Vancouver Island due to the Esquimalt & Nanaimo (E & N) Land Grant, a massive 19th century land grant of great significance.

In 1875, the Esquimalt and Nanaimo Railway Act transferred 760,000 ha of land from the Crown to the Esquimalt and

Table 8.1: Breakdown of Biogeoclimatic Zones in the CCCW

Figure 8. 4: Elevational profile of biogeoclimatic units for south central Vancouver Island

Biogeoclimatic Zone/Subzone Estimated AreaCWH mm2 45%CWH xm2 35%MH mm1 20%

ATp 0%

xm2, and is dominant or relatively dominant in 6 out of 10 Site Series in the CWH mm2 (Green & Klinka, 1994). The CCCW has the exact same Biogeoclimatic Zone and subzone elevational profile that exists from the shores of Cameron Lake and Cathedral Grove in MacMillan Provincial Park, up ever-increasing slopes to the top of Mt. Arrowsmith, a UNESCO Biosphere Reserve (Green & Klinka, 1994; E. Piikkila, personal communication, June 2, 2016).

The soils of the CCCW consist primarily of volcanic rock, glacial deposits, and limestone (Barlak, 2011a). The limestone bedrock can contribute calcium inputs into the water, which causes a “neutral to slightly basic pH” (Barlak, 2011a, p. 10). The forest is composed primarily of Douglas-fir, western red cedar, amabilis fir, and western hemlock (Figure 8.5) (Barlak, 2011a). Understory vegetation

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Figure 8. 5: The CCCW is dominated by Douglas-fir

Total land base: 94,872,896 ha

Private Ownership4,188,346 ha

Crown Federal1,037,102 ha

Crown Provincial89,512,571 ha

First Nations134,878 ha

Total land base:5,681 ha

Private:Island Timberlands4,958 ha

Crown Provincial387 ha

Private: TimberWest

336 ha

PRO

VIN

CE O

F B.C.

CCCW

Sources: Ministry of Forests, Mines and Lands, 2010; Koers and Associates Engineering Ltd., 2016

Figure 8. 6: Comparison of forest ownership between the province of B.C. and the CCCW. Green represents public (Crown) ownership, whereas brown represents private ownership.

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Nanaimo Railway Company, run by Robert Dunsmuir (Watts & Tolland, 2013; Taylor, 1975). Known as the “E & N Land Grant,” this transfer was one of many that occurred in the 19th century to promote railway construction—for example, the federal government received 5.6 million hectares from the province of B.C. to build the Canadian Pacific Railway (Watts & Tolland, 2013). While much of this land eventually reverted back to the province, all of the land from the E & N Land Grant remained private (Figure 8.7). According to Dr. Haley from the Faculty of Forestry at the University of British Columbia, the E & N lands “comprise the most important area of private forestland in the province” (Watts & Tolland, 2013, p. 2).

The private forestry giant MacMillan Bloedel owned most of the land in the CCCW for much of the twentieth century (Gordon et al., 2007). Throughout this time, MacMillan Bloedel was the largest forestry company in B.C. and in the Port Alberni area, where the company owned sawmills, pulp and paper mills, and plywood mills, and also had tenure over a large area of Crown land (Gordon et al., 2007).

In 1955, Tree Farm Licence (TFL) 44 was granted to MacMillan Bloedel, giving them a one million hectare tenure that included over 70,000 hectares of private land in the area (Steel, 2011). A TFL is “[a]n area based tenure agreement that issues the rights to harvest an allowable annual cut in a specified area” but under the general supervision of the provincial Forest Service, which provides cutting services to the licence holder (Forest Practices Board, 2016b). When TFLs were established in the 1950s, the condition for receiving a TFL was that all private land had to be included within the TFL as Managed Forest Land (Sloan, 1956). According to the Honorable Gordon Sloan, the Chief Justice of British Columbia in 1956, the tree farm legislation was “an attempt to compel other owners of forest land, even small parcels, to manage their properties on a sustained-yield basis, under equally, rigid Government control, in the same manner as forest management licensees” (Sloan, 1956, p. 142).

In 1999, MacMillan Bloedel requested the release of its private land from TFLs 39 and 44 but was denied by the provincial government because of “significant and negative public reaction” (Office of the Auditor General of British Columbia, 2008, p. 32). That same year, the Weyerhaeuser Corporation acquired MacMillan Bloedel’s forest assets (Gordon et al., 2007). Then in 2004, Weyerhaeuser requested the removal of private lands from TFLs 39 and 44

and was granted approval, which removed 80,000 ha from the TFLs, including 74,000 ha around the CCCW (Office of the Auditor General of British Columbia, 2008). Again, there was a significant negative reaction from the public and from First Nations (Office of the Auditor General of British Columbia, 2008).

This negative reaction was due to the fact that “[t]he public, rightly or wrongly, equated the deletion of private land to increased harvesting on private land and increased export of timber from private land” (Office of the Auditor General of British Columbia, 2008, p. 40). First Nations also strongly objected to the lack of consultation over the decision to remove these lands. Furthermore, there was concern that the new regulatory framework would lack the ability to protect the watershed. The Auditor General of B.C. indicated in a report that “once a private land removal decision is made the land is no longer subject to the regulatory requirements of a TFL and instead can fall under the less stringent requirements of the PMFLA [Private Managed Forest Land Act]. This change can have economic, environmental and social consequences” (Office of the Auditor General of British Columbia, 2008, p. 53).

In 2005, Weyerhaeuser sold all of its assets on Vancouver Island to Brascan (now Brookfield Asset Managements), who then moved all the private lands to Island Timberlands, which had been formed as a result of the initial purchase (Island Timberlands, 2016b; Dodd, 2005). Island Timberlands has been the majority landowner in the CCCW since

Figure 8.7: Map of the E & N Land Grants of 1884-1925

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then. Only a few small pockets of TFL 44 land remain in the CCCW. This history is relevant because it explains why the CCCW is predominantly private land, which has important legislative implications that are described in the next section.

8.3 Regulatory Framework

8.3.1 Regulatory Overview

The regulatory framework for the CCCW is complex due to a myriad of overlapping pieces of legislation and because of the private land throughout the watershed. It is important to understand this framework in order to assess what can and is being done to regulate water quality and land uses within the watershed. While the key pieces of legislation with respect to logging and water quality exist predominantly at the provincial level, there are numerous other parties involved in this framework.

Firstly, the entire watershed is on the unceded territory of the Tseshaht and Hupacasath First Nations (Hupacasath First Nation, 2016; Tseshaht First Nation, 2012). The First Nations are key stakeholders in the CCCW as they continue to live in the area and rely on drinking water from the CCCW.

Next, there are relevant pieces of federal legislation such as the Fisheries Act and the Species at Risk Act. For example, the Fisheries Act prohibits the deposit of “deleterious substances”—anything that degrades water quality—in water frequented by fish, such as China Creek (Government of Canada, 2016). CCCW is also within the jurisdiction of three different Regional Districts: the bulk of the watershed falls within the Alberni-Clayoquot Regional District, but small sections also extend into the Regional District of Nanaimo and the Cowichan Valley Regional District (Figure 8.8) (Government of British Columbia, 2016).

Finally, the City of Port Alberni clearly has a significant interest in the CCCW as it relies on drinking water from China Creek. The City owns a small piece of land at the base of the watershed where the municipal water intake is located (Figure 8.8). While the City frequently meets with the private landowners to discuss watershed issues, the municipal government has no jurisdiction over what happens on private land within the CCCW.

There are many pieces of provincial legislation under different ministries that are relevant for the management of logging and water quality in the CCCW. Provincial water quality regulations were discussed in Chapter 6, although other water-related legislation such as the Water Act and

Figure 8.8: Overview of land ownership in the China Creek Community Watershed

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the Water Sustainability Act are also relevant (Managed Forest Council, n.d.). Additionally, the Assessment Act, Environmental Management Act, Environmental Assessment Act, Groundwater Protection Act, Fish Protection Act, Foresters Act, Integrated Pest Management Act, Land Act, Mines Act, Wildlife Act, and Wildfire Act all contain passages relevant to either the management of forest land or the protection of drinking water (Managed Forest Council, n.d.; R. Pike et al., 2010).

Likely the most relevant pieces of legislation to this report are the Forest and Range Practices Act (FRPA), which governs Crown land and any private land land under a Tree Farm License (TFL), Forest License (FL), woodlot license, or community forest agreement, and the Private Managed Forest Land Act (PMFLA), which governs forestry activities on privately managed forest land. Prior to 2005 when the private land in the CCCW was managed under TFL 44, the entire watershed was managed under the FRPA. However, when private lands were removed from TFL 44, the PMFLA become the principal piece of legislation governing activities within the watershed. Many people see this change in regulation as a critical moment in the tale of the CCCW; therefore, it is necessary to review and compare the Crown and private legislation (Office of the Auditor General of British Columbia, 2008).

8.3.2 Forestry Regulations on Crown Land

FRPA was born out of the former Forest Practices Code (1995 – 2003) and enacted in 2004 (Forest Practices Board, 2014). At the time of this legislative change, the former Forest Practices Code was considered by the incoming provincial government as “complex paper processes” rather than “actual work on the ground,” which is why the FRPA was created (Ministry of Forests, 2004). The FRPA “maintains high levels of protection for forest values including watersheds and wildlife habitat,” “creates efficiencies for both government and industry through streamlined planning processes,” and “encourages innovation by skilled resource professionals and holds industry responsible for outcomes” (Ministry of Forests, Lands and Natural Resource Operations, 2016). It is a relatively long and detailed act with major sections on the plans required prior to harvesting, forest practices, and the protection of resources, along with compliance and enforcement (Government of British Columbia, 2002). The Act is accompanied by the Forest Planning and Practices Regulation (FPPR), a lengthy document that details everything from road maintenance and culvert

construction to fish passage and invasive species protection (Government of British Columbia, 2004a).

The FRPA is a Results-Based Code, meaning that it is the end result that is important, not the way in which that result was achieved (Ministry of Forests, 2004). There are regulations that prohibit forest licensees from negatively impacting water quality, fish habitat, and many other elements, but how the licensee goes about “not impacting” these elements is left up to them—as long as they are following all regulations in the FRPA and all other provincial and federal legislation.

An important component of the FRPA is the requirement to prepare a Forest Stewardship Plan (FSP) and submit it to the Minister of Forests, Lands and Natural Resource Operations for approval prior to the commencement of any road construction or harvesting, as compared to the previously required Forest Development Plan (FDP) (Government of British Columbia, 2002). The FSP is the only plan that is subject to public review and comment as well as government approval, making it a key element in the forestry process (Forest Practices Board, 2016b). In a FSP, licensees are required to identify measurable results and strategies that are consistent with ten specific government objectives that are outlined in the FPPR (Forest Practices Board, 2016b; Government of British Columbia, 2004a):

• Soils• Timber• Wildlife• Water, fish, wildlife and biodiversity within riparian

areas• Fish habitat in fisheries sensitive watersheds• Water in community watersheds• Wildlife and biodiversity — landscape level• Wildlife and biodiversity — stand level• Visual quality• Cultural heritage resources

Another notable element of the FRPA is that it mandates the existence of community watersheds. Community watersheds were originally designated in 1995 under the Forest Practices Code and were grandfathered into the FRPA in 2004 (Forest Practices Board, 2014). To qualify, a watershed must contain a licenced water intake that is on a stream (Ministry of Environment, 2016). The designation “infers a level of protection,” as the purpose is “to conserve the quality, quantity and timing of water flow or prevent cumulative hydrological effects” (Barlak, 2011a, p.

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4). Watersheds are designated if there is reason to believe that they require “special management” in order to achieve the objectives listed above (Ministry of Environment, 2016). However, because community watersheds are legislated under the FRPA, they only have legal effect on Crown land and not on private land such as the CCCW (Barlak, 2011a, p. 4). Prior to the removal of CCCW from TFL 44, community watershed legislation applied in the CCCW.

Currently, there are 466 community watersheds in B.C., covering an area of over 1.4 million hectares—about 1.5 percent of B.C.’s total land area (Ministry of Environment, 2016). Seventy-four percent of all community watershed area is on Crown land while the remaining 26 percent is on private land, First Nations reserves or treaty land, or provincial and federal park and reserve land (Ministry of Environment, 2016). Prior to their designation in 1995, 295 of the 466 community watersheds had experienced harvesting activity (Ministry of Environment, 2016). While harvesting has continued in many of these watersheds, the pace has slowed down significantly since their designations in 1995 (Ministry of Environment, 2016).

Forest practices on land administered under the FRPA are monitored by the Forest Practices Board, “BC’s independent watchdog for sound forest practices” (Forest Practices Board, 2016a). While the Forest Practices Board was created by the province, it operates at “arm’s length” from the government, performing audits and investigating complaints (Forest Practices Board, 2016a). The Forest Practices Board cannot enforce the FRPA by imposing penalties, but by its own admission, “its recommendations have led directly to improved forest practices such as stronger government decision-making processes and better communication among forestry professionals to manage risks to the environment” (Forest Practices Board, 2016a). The Forest Practices Board examines forestry practices on Crown lands only and has no jurisdiction on private managed forest land (Forest Practices Board, 2016a).

8.3.3 Forestry Regulations on Private Managed Forest Land

For the purposes of forestry regulation, there are two types of private land: Private Managed Forest Land (PMFL) and private unmanaged forest land. On unmanaged land, no forestry legislation applies because it is not classified as PMFL or included in a TFL, woodlot licence, or community forest agreement (Gordon et al., 2007). This typically occurs on smaller parcels of land owned by individual

landowners. By contrast, the major forestry companies such as Island Timberlands and TimberWest operate on PMFL, which is subject to all private forestry regulations (Gordon et al., 2007). In order to call a parcel of land “private managed forest land,” the landowner must submit a “proposed management commitment” to the Managed Forest Council that contains details about the site, long-term forest management objectives, inventories of existing roads and forest cover, and other details (Government of British Columbia, 2007).

The Managed Forest Council (formerly known as the Private Managed Forest Land Council) is a provincial agency that administers PMFL legislation and performs four broad functions: strategic planning, reporting, program administration; setting and monitoring forest practice standards; enforcing standards and performing audits; and reviewing landowner applications to enter managed forest class (Managed Forest Council, n.d.). The Council consists of two provincially-appointed members and two members who are elected by private managed forest landowners, plus one chair jointly appointed by the other four council members (Managed Forest Council, n.d.).

The main piece of private forestry legislation is the PMFLA, which came into effect in 2003. Sections 12 to 16 of the PMFLA mandates that the Managed Forest Council address five areas of concern: soil conservation, water quality, fish habitat, critical wildlife habitat, and reforestation (Government of British Columbia, 2003). The PMFLA contains administrative procedures for managed forest land and prescribes some basic forestry regulations pertaining to sediment transportation, stream buffers, and road maintenance (Government of British Columbia, 2003). The PMFLA is significantly shorter in length and less detailed than the FRPA.

The Private Managed Forest Land Council Regulation provides additional detail on aspects such as the placement of roads next to streams and soil conservation (Government of British Columbia, 2007). This regulation is essentially the private land equivalent of the FPPR, although it is less comprehensive. Next, the Private Managed Forest Land Council Matters Regulation is a very short piece of legislation consisting mostly of definitions and explanations of the Managed Forest Council’s powers (Government of British Columbia, 2004b). Finally, the Private Managed Forest Land Regulation is another short piece of legislation that deals with critical wildlife habitat (Managed Forest Council, 2015b).

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The most detailed document dealing with forestry practices on private land is the Managed Forest Council’s Field Practices Guide. The guide is meant to “aid owners in their field decisions and meeting their practice obligations, providing a brief overview of land administration, road construction, maintenance, and deactivation, harvesting, reforestation, stream classification, and riparian tree retention (Managed Forest Council, p. 2). The guide contains definitions, pictures, and drawings that help to illustrate the points, making it a very user-friendly document. However, this document contains only guidelines and recommendations, not legally mandated requirements.

Like the FRPA, the suite of private managed forest legislation uses results-based language, emphasizing proper due diligence on the part of the forestry companies. If a problem occurs on private land and it is determined that the owner did not follow the guidelines in the Field Practice Guide, then they would be found by the Council to have not practiced due diligence, putting them in contravention of the legislation. Therefore, although the Field Practices Guide is not legally mandated, there is legal incentive for foresters to follow the guidelines. The Managed Forest Council hire independent Registered Professional Foresters, Biologists, and Engineers to perform annual audits of their members, while the Forest Practices Board hires these same types of professionals to perform inspections, investigations, and sometimes comprehensive audits (E. Piikkila, personal communication, June 2, 2016).

8.3.4 Forest Certification Systems

Forest certification systems inspect and audit forest management practices against a set of standards, with the end goal of certifying that a product on the market comes from a “well-managed forest” (Pearce, 2008). A company may choose to become certified for a variety of reasons, including enhancing their image and credibility, risk reduction, and to reach new markets (Forest Certification and BC Community Forests may 29 2008). These systems

are complementary to regulatory systems and thus not directly part of the regulatory framework, as they are voluntary and independent of government (Pearce, 2008). Both Island Timberlands and TimberWest are certified, a fact that is often used to defend the rigor and sustainability of their practices. Therefore, it is worth briefly examining the different standards being used in B.C.

The three main forest certification standards in B.C. are the Forest Stewardship Council (FSC), the Sustainable Forestry Initiative (SFI), and the Canadian Standards Association (CSA) (se Figure 8.9) (Masters, Tikina, & Larson, 2010). In B.C., CSA and SFI are much more common than FSC, although FSC has the strongest international reputation (Ministry of Forests, Mines and Lands, 2010). Island Timberlands and TimberWest are each certified under the SFI, which has been common practice on private land in the region since 2007 (S. Thomas, personal communication, May 5, 2016). CSA, meanwhile, is Canada’s official national standard for sustainable forest management and is used on Crown land (CSA SFM User Group, 2016).

Island Timberlands and TimberWest are also each certified under The International Organization for Standardization (ISO) 14001, which sets requirements for environmental management systems, helping organizations to “improve their environmental performance through more efficient use of resources and reduction of waste, gaining a competitive advantage and the trust of stakeholders” (ISO, 2015; TimberWest, 2010; Island Timberlands, 2016a). ISO is not specific to the forestry industry, but it adds an extra layer of due diligence to operations.

When assessing forest certification systems, it is important to differentiate between system standards and performance standards (Ozinga, 2004). System standards specify management practices within an organization and can be powerful tools to improve organizational performance (Ozinga, 2004). However, they do not actually specify a minimum standard of performance that must

Figure 8.9: The three primary forest certification standards in B.C.

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be achieved: e.g., a system standard may say “biodiversity should be monitored” (Ozinga, 2004). According to FERN, a group that promotes sustainable forestry in Europe, “[t]he lack of defined performance requirements means that two forest companies both certified to the same system standard could achieve very different results in the forest;” therefore, “system standards do not provide any guarantee of product quality” (Ozinga, 2004, p. 10). Performance standards, meanwhile, specify actual results that must be achieved on the ground: e.g. one might specify that “10% of a forest management unit must be set aside for conservation” (Ozinga, 2004).

FERN found that CSA and SFI consist primarily of system-based elements without clear performance standards, while FSC’s standards are all performance-based (Ozinga, 2004). They state that “FSC remains by far the most independent, rigorous and, therefore, credible certification system,” which is why the B.C. Teachers’ Federation recently passed a motion requesting Island Timberlands to adopt FSC rather than SFI (Ozinga, 2004, p. 21; Plummer, 2015).

The David Suzuki Foundation, Greenpeace, and numerous other environmental organizations recently co-signed a similar letter to the U.S. Green Building Council and Canada Green Building Council, requesting that they do not give out LEED credits for using SFI-accredited products (at the time,, the two Councils only endorsed FSC products but were considering endorsing SFI products as well) (Moola et al., 2009).The letter describes an analysis by the Ivey Foundation that compared SFI and FSC. It found that “SFI’s system requires significant strengthening before it can be considered a legitimate tool for advancing sustainability” (Moola et al., 2009, p. 1). SFI’s audit teams were on average three times smaller than FSC’s, spent five times less time in the field completing the audit, and were comprised, on average, of only two foresters (Moola et al., 2009). This was in contrast to FSC teams that “consistently were comprised of 2 foresters and at least 1 ecologist/biologist and 1 aboriginal/community consultation specialist” (Moola et al., 2009, p. 2).

Additionally, SFI audits were extremely easy to pass: while FSC audits found an average of 23 non-conformances between the company’s operations and FSC standards, SFI audits found on average only two (Moola et al., 2009). Essentially, SFI audits represent a “[c]ertification of near status quo” (Ozinga, 2004, p. 23). Furthermore, SFI’s independence has been questioned. The American Forest & Paper Association, whose members control most of the

industry-owned forests in the US and whose board is “still dominated by forestry industry interests” (Ozinga, 2004, p. 23), initiated the SFI. Environmental group Stand (formerly Forest Ethics) has accused SFI of “greenwashing” and producing misleading labels, stating that SFI is “an industry creating its own watchdog” (Dharmarajah, 2015).

The new SFI 2015-2019 standards have added performance measures to address water, wetland, and riparian protection, which is a step forward (The Sustainable Forestry Initiative Inc., 2015). Overall, however, it appears to be a relatively weak certification system.

8.4 Land Uses

8.4.1 Water Source

While logging is the focus of this report, there are a variety of other land uses in the CCCW that could potentially impact water quality. Given that the CCCW is a designated community watershed, its role as a water source should be considered a primary “land use,” even if this is more of a protective use than an active use. Waterworks infrastructure has existed in the CCCW since the 1930s (Turner, 1990). Currently, there are six different water licences issued for the China Creek mainstem, but only two of these licences are actually located within the boundaries of the CCCW (Barlak, 2011a). The City of Port Alberni owns a water intake at the base of the CCCW and can withdraw 8,935,454 cubic metres per year for domestic use (Koers and Associates Engineering Ltd., 2016). The City can also store 645,110 cubic metres per year in Lizard Lake for use in relieving low summer flows (Koers and Associates Engineering Ltd., 2016).

Bainbridge Lake, Port Alberni’s secondary water supply, is located just outside of the CCCW in the McFarland Community Watershed (Koers and Associates Engineering Ltd., 2010). The lake drains into McFarland Creek, a tributary of China Creek that joins the mainstem below the City’s water intake (Koers and Associates Engineering Ltd., 2010). The Somass River, also outside of the CCCW, is used only as an emergency supply because the water quality is poor compared to China Creek and Bainbridge Lake (Koers and Associates Engineering Ltd., 2010). Water from China Creek enter a gravity-feed system, whereas water from Bainbridge Lake can be gravity fed but requires pumping during high demand periods (Francoeur, 2011). The Somass River requires pumping at all times (Francoeur, 2011).

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8.4.2 Mining

Historical records describe mining activity, which includes excavations, road and dam construction, and water diversions, as early as the 1860s in the CCCW (Butt & Hughes-Adams, 2014; Horel, 1998). Placer mining, as well as mining for other minerals, have occurred in the area, and the potential exists for further activity in the future (Butt & Hughes-Adams, 2014; Koers and Associates Engineering Ltd., 2010). Table 8.2 summarizes the mining activities in the CCCW (Barlak, 2011b).

Between 2005 and 2010, a “considerable amount of exploration activity” occurred around the Mineral Creek gold zone in the upper portion of the CCCW (Butt & Hughes-Adams, 2014). As part of conducting its broader investigation into community watersheds provincially, which included the CCCW, Forest Practices Board investigators observed one inactive placer mine operation that seemed to pose a potential risk to water quality; however, an assessment of the risk was not undertaken (D. Wahl, personal communication, May 13, 2016). A study by Koers & Associates Engineering Ltd. explained that “within a relatively small watershed such as China Creek, an extensive mining operation would have a significant and potentially negative impact on fisheries and drinking water quality and the two uses are likely not compatible” (Koers and Associates Engineering Ltd., 2010, p. 22).

Mining can impact water quality by introducing high concentrations of metals and sediment into the water supply and by contributing to acidification (Barlak, 2011a). There are several examples of the negative impacts of mining legacies on water quality in Coastal B.C. One case is the Tsolum River at the base of Mount Washington in the Comox Valley, which has suffered decades of acid mine drainage due to copper leaching from an abandoned copper mine (Kangasniemi & Erickson, 1986). Another

case is acid mine drainage from the Britannia Mine, which caused severe pollution in Howe Sound (Britannia Mine Museum, 2016).

8.4.3 Hydroelectric Power Generation

Upnit Power Corporation, a small 6.5 MW run-of-the-river hydroelectric project, has a water intake 2.5 km upstream of the City’s intake on China Creek and a licence to remove 16,396,000 m3 per year for power generation (Barlak, 2011b). That water travels down a four km penstock to a power station on China Creek and is released back into the mainstem 2.9 km downstream of the municipal intake (Koers and Associates Engineering Ltd., 2010; Barlak, 2011a). The Hupacasath First Nation, in partnership with Synex Energy Resources Ltd., Ucluelet First Nation, and the City of Port Alberni developed this project in 2005 (Barlak, 2011b). At peak operation, the plant produces power for 6,000 homes (Barlak, 2011b). Due to low flows, the project does not operate in August and September, and it is sometimes forced to shut down earlier due to dry conditions (Barlak, 2011a).

The Upnit project necessitated the construction of a two km road along China Creek between the Port Alberni water intake and the hydroelectric intake (Barlak, 2011a). This road “is travelled weekly by an operator on an ATV from November through March, but not by any licenced vehicles” (Barlak, 2011b, p. 11). The road was built through deep glacial deposits, resulting in “difficult construction with very large, steep and potentially unstable cutbanks and fillslopes” (Figure 8.10) (Butt & Hughes-Adams, 2014, p. 35). Aerial imagery from Google Earth appears to show exposed soil along the penstock route where the road is located, but it is unclear from these images whether or not this exposure poses any risk to water quality.

Table 8.2: Summary of mining activities within the China Creek Community Watershed

MINE TYPE MINE NAME METALS MINED MOST RECENT EXPLORATIONAbandoned/closed Grizzly Arsenic, silver, gold 1924Abandoned/closed Gillespie Gold, silver, copper, lead, zinc 1936–39Abandoned/closed Havilah Gold, silver, copper, lead, zinc 1936Abandoned/closed Debbie Gold, silver, copper, zinc 1989Placer China Creek Gold 1895Developed prospect 900 Gold 1987Prospect Regina Gold, silver, copper, lead, zinc 1987

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8.4.4 Recreation

While no formal studies have been conducted to determine the recreational usage of the CCCW, numerous reports indicate that it is a well-used recreational destination. There are three categories of trail in the region: those on public land with public trails; those on private land with marked trails and an agreement in place with the landowner for public access; and those on private land with no marked trails, but which see occasional public use regardless (S. Thomas, personal communication, January 21, 2016). Users of the latter trails could be asked to leave by the landowner, as it is private land (S. Thomas, personal communication, January 21, 2016).

Hikers, hunters, people fishing, and all-terrain vehicle (ATV) users are the primary trail users in the CCCW (Barlak, 2011a). There is “a significant network of ATV trails located in the upper watershed that are utilized on a regular basis” (Barlak, 2011a, p. 12). Picnics and campfires are common, resulting in garbage dumping and human waste deposits (Francoeur, 2011). This type of recreational use can be problematic in terms of water quality and is very difficult to manage and enforce, as watersheds are large areas that can be accessed in a variety of ways by individual users at any given day or time.

8.4.5 Logging History in the China Creek Community Watershed

There is a long history of logging the CCCW, with forest cover maps from MacMillan Bloedel indicating that harvesting began in 1921 (Horel, 1998). Harvesting proceeded at a rapid pace: according to Epps et al. (2010), approximately 70 percent of the CCCW was logged in the 1930s and 1940s (as cited in Buschhaus, 2010). Until the 1940s, logging in the CCCW was done by rail (Figure 8.11) (Turner, 1990; E. Piikkila, personal communication, May 5, 2016). This included the use of an Incline Railroad above Lizard Lake (Figure 8.12) (E. Piikkila, personal communication, May 5, 2016). In fact, sections of the China Main road were built on old railway grade (Horel, 1998; E. Piikkila, personal communication, May 5, 2016). Turner (1990) states that the conversion from railroad logging to truck logging in the CCCW area occurred in 1946.

Early logging techniques were much more destructive than the techniques practiced today. Much of the harvesting in the 1930s and 1940s went right to the streambank (Buschhaus, 2010). Aerial photographs from the 1950s show “[e]xtensive logging of riparian zones” and “severe disturbance of the alluvial channel reaches (Reach 9, 11 and 19) of China Creek and McQuillan Creek including bank erosion, sediment aggradation and channel widening” (Horel, 1998, p. 5). This was due to logging methods that “employed cross-stream yarding and did not leave stream buffers” (Horel, 1998, p. 5). By the 1950s, much of the main valley had been logged, from China Creek well into the upper portions of the watershed (Horel, 1998).

Figure 8.10: Upnit penstock road. Butt & Hughes-Adams (2014) state that the through-cut left high and excessively steep cutbanks in deep glacial till deposits, and they point out cracks in the fill slope in the lower right of this photo.

Figure 8.11: Logging by rail in B.C.

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Techniques advanced throughout the years: truck logging replaced railroad logging beginning in the 1940s and continues to this day as the primary method of transporting logs out of the woods (E. Piikkila, personal communication, May 5, 2016). Large steam donkey spar tree yarding systems lasted until the 1960s (Figure 8.13) and were replaced by steel towers up to the 1980s (Figure 8.14) (E. Piikkila, personal communication, May 5, 2016). Grapple yarding and mechanical cutting were introduced in the 1980s and the 2000s respectively (Figure 8.15) (E. Piikkila, personal communication, May 5, 2016). Today, a combination of these techniques is practiced.

The introduction of grapple yarders to replace steel tower systems in the 1980s necessitated the construction of additional roads across logging sites because the distances that these machines could reach out to grab logs was less than steel towers and steam donkey yarding systems (Krag, Wong, & Henderson, 1993). Additionally, until the mid-1990s, most areas across B.C. were clearcut (Ministry of Forests, Mines and Lands, 2010). Today, the most common silvicultural practices in the province are clearcutting, clearcutting with reserves, and some variable retention harvesting, and the percent of harvested area taken up by roads has declined since the 1990s (Ministry of Forests Mines and Lands, 2010).

Figure 8.12: Incline Railroad for logging in B.C. Figure 8.13: Donkey spar tree yarding system

Figure 8.14: Steel tower yarding system

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In summary, it is important to keep in mind that the CCCW has a history of intensive logging using damaging techniques, and this legacy may still be affecting the watershed. As of 2010, much of the watershed consisted of 70 to 80-year-old second growth forest (Buschhaus, 2010). Horel (1998) compared airphotos from 1952 and 1994 and found that “channel positions in these disturbed reaches have stabilized, the banks and bars have revegetated, and the heavy sediment accumulations in the channel have diminished” (Figure 8.16) (Horel, 1998, p. 5). However, as Chapter 9 will discuss, legacy impacts remain evident in the watershed.

In recent years, logging has ramped up in the CCCW. In a recent analysis of Island Timberlands operations, Butt and Hughes-Adams (2014) compared the equivalent clearcut area (ECA) of the CCCW in 2005 and 2013 and found that Island Timberlands “has been logging intensively in China Creek watershed in that period” (p. 10). Despite this increase in harvesting, the ECA was an average of 16

Figure 8.15: Grapple yarding system

Figure 8.16: China Creek Channel in 1952 (left) and 1994 (right), showing recovery of riparian vegetation

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percent, which is below the “generally accepted threshold” of 30 percent (Butt and Hughes-Adams, 2014).

Equivalent clearcut area describes a second-growth block of trees in terms of its hydrological equivalent as a clearcut; “[a]s second growth develops, the hydrological impact on a site is reduced” (Government of British Columbia, 1996). The height of second growth trees is used to calculate ECA: “[f]or example, a 20 ha block with 6 m tree heights is 50 per cent recovered so the ECA of the block is 10 ha (20 ha x 50 per cent)” (Government of British Columbia, 1996). The ECA, plus the amount of road in a watershed, is then used to calculate the peak flow index, which “describes the risk of a change in peak flows for an entire watershed” (Government of British Columbia, 1996).

Maps created using the Hansen et al. Global Forest Change data show where exactly this logging has taken place (Hansen et al., 2013). This data is at a spatial resolution of 30m and shows tree cover extent, gain, and loss (allocated annually) (Hansen et al., 2013). Figure 8.17 shows forest cover extent in the year 2000, acting as a reference point for the other maps. It is important to note that while old growth forest remains in the CCCW, a significant amount also consists of second growth forest. Figure 8.18 shows forest cover gained (in blue) and lost (in red) between

2000 and 2014. During this time, approximately 18 percent (1,000 ha) of the CCCW was harvested.

Figure 8.19 shows forest cover loss by year, with lighter colours representing older cuts and darker colours representing the most recent cuts. Recent logging along the steep slopes of McLaughlin Ridge is evident (Figure 5.8). As described in Section 5.1, McLaughlin Ridge contains a significant amount of old growth forest, which is typically good at preventing erosion (Gulliver, 2013; Slepian, 2014; Franklin & Spies, 1986). Data for forest gain by year was unavailable.

KM631.50

Sources: Hansen/UMD/Google/USGS/NASA; DataBC

LegendRoads

Streams

Lakes & RiversChina Creek Community WatershedMcFarland Community Watershed

Municipal Water IntakeAlberni-Clayoquot Regional DistrictRegional District of NanaimoCowichan Valley Regional DistrictPublic Land under Tree Farm Licence 44

Private Land

China Creek

Bainbridge

LizardLake

Lake

McLaughlin Ridge

100%0%

Forest Cover (2000)

Defined as canopy closure for all vegetation taller than 5m in height

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Figure 8.17: Forest cover in the China Creek Community Watershed (2000)

KM631.50


LegendRoads

Streams



Private Land

China Creek

Bainbridge

LizardLake

Lake

McLaughlin Ridge

2000 2014

Forest Cover Loss Events by Year

Data encoded as either 0 (no loss) or else a value in the range 1-13, representing loss detected primarily in the year 2001-2014, respectively.

For example, the lightest patches represent forest loss from 2000-2001, while the darkest patches represent forest loss from 2013-2014.

KM631.50


LegendRoads

Streams



Private Land

China Creek

Bainbridge

LizardLake

Lake

McLaughlin Ridge

Forest Cover Loss during the period 2000–2014

Forest Cover Loss & Gain (2000–2014)

Forest Cover Gain during the period 2000–2014

Note: From 2000-2014, approximately 18% of the watershed was harvested

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Figure 8.18: Forest cover loss and gain in the China Creek Community Watershed between 2000 and 2014

Figure 8.19: Forest cover loss events by year in the China Creek Community Watershed between 2000 and 2014

9.1 List of Studies

Over the years, numerous studies have been conducted by government agencies, academics, NGOs, and engineering firms on the impact of logging on water quality in the CCCW. Table 9.1 lists the studies that were analyzed as part of this report.; The list is not meant to be exhaustive, as other studies may exist. Table 9.1 also lists the study recipient, i.e. the group who commissioned the study. While each study should, in principle, be scientific and unbiased, it is important to understand a study’s background before assessing its findings. Most of these studies have already been referenced at various points throughout this report, but this chapter will specifically examine their findings with respect to the impact of logging on water quality in the CCCW.

9.2 Coastal Watershed Assessment (CWAP) of China Creek Watershed (1998)

This is the most dated study that was examined, so while it provides useful background context, the situation in CCCW today could be quite different than indicated in this study. At the time of this study, private forest lands were still being managed under Tree Farm Licences, so the regulations were different than they are today. Horel (1998) states that riparian impacts “rank high throughout the watershed, reflecting extensive past logging of riparian zones” (p. 9). The logging of erodible channel banks in the alluvial reaches of China Creek caused “increased bank erosion, channel widening and severe sediment aggradation” (Horel, 1998, p. 9). Horel (1998) performed a historical analysis, examining airphotos from 1952 and comparing them to airphotos from 1994, and found that there has been “significant recovery of the channel” (Figure 8.16) (p. 9).

There are still residual impacts from past logging in riparian areas, including moderate sediment aggradation and some bank erosion in some stream reaches (Horel, 1998). Additionally, alder dominates much of the second growth riparian forest, which is problematic because this species of tree does not provide the same large woody debris that would be deposited in stream channels by coniferous trees (Figure 9.1) (Horel, 1998). This has implications for water quality because, as described in Section 7.1, large woody debris contributes to channel stability, thus reducing erosion and sediment input into streams (Private Managed

Forest Landowners Association, 2001).

This study contained a number of other useful findings. Horel (1998) states that high turbidity and peak streamflows are closely related in the CCCW; high turbidity typically only lasts for a few days, and turbidity levels decrease rapidly when flows return to normal. Horel (1998) also found that “[t]here is considerable sediment stored in the low-gradient alluvial reaches of the channel available to mobilize and transport downstream during peak flow events,” which at the time of Horel’s writing were the main sources of sediment in the channel (p. 12). Additionally, there is “a low potential for post-harvesting open-slope or gully failures” and a low frequency of post-harvest landslides (Horel, 1998, p. 12). Finally, it should be noted that there are no swamps or lakes to act as sediment sinks along the mainstem or major tributaries, so “events in the watershed are felt directly at the dam” (Horel, 1998, p. 12).

Horel (1998) indicates that the management of the road system is the primary concern with regards to sediment sources in the CCCW. In 1994, there were approximately 99 kilometres of road in the CCCW, giving the watershed a “moderate” road density (Horel, 1998, p. 8). Horel (1998) recommended practicing good road construction and maintenance, deactivating unused roads in a timely manner, assessing stream crossings, stabilizing roads as necessary, and minimizing the construction of new roads.

Figure 9.1: Much of the riparian area in the CCCW’s second-growth forest is dominated by alder, which provides insufficient large woody debris for the stream channel.

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CHAPTER 9: REVIEW OF EXISTING STUDIES

YEAR TITLESTUDY AUTHOR STUDY RECIPIENT

NAME TITLE ORGANIZATION NAME CATEGORY1998 Coastal Watershed

Assessment (CWAP) of China Creek Watershed

G. Horel P. Eng., Geological Engineer

Ostapowich Engineering Services Ltd.

MacMillan Bloedel Limited, West Island Woodlands Division

Forestry Industry

*2005 Watershed assessment – China Creek watershed

Unknown Unknown Streamline Environmental Consulting Ltd. and Ostapowich Engineering Services Ltd.

Weyerhaeuser South Island Timberlands West Island Timberlands

Forestry Industry

2010 Alberni Valley Regional Water Study Update: Final Report

D.A. Koers (Project Manager)

P .Eng. Koers & Associates Engineering Ltd.

Alberni-Clayoquot Regional District

Government

2010 China Creek Water Quality: A Comparison Before and After Timber Harvest and Independent Power Project Construction

C. Buschhaus

B.Sc. Candidate, Forest Sciences

Faculty of Forestry, University of British Columbia

Faculty of Forestry, University of British Columbia

Academic

2011 Water Quality Assessment and Objectives for the China Creek Community Watershed (Overview and Technical Reports)

R. Barlak Water Stewardship Division staff

Ministry of Environment

Ministry of Environment

Government

2011 Alberni Valley Drinking Water Reference Guide (Mapping Our Legacy project)

A. Francoeur

BSc. Water Resource Consultant

Consultant Save Our Valley Alliance Public Education Committee

NGO

2014 Forest Practice Standards and Water Quality in Privately Managed Land in the China Creek and Honna River Watersheds

G. Butt & K. Hughes- Adams

M.Sc.,P .Ag., P.Geo. & M.Eng., P .Eng.

Madrone Environmental Services Ltd.

Private Managed Forest Land Council (now Managed Forest Council)

Forestry Industry

†2016 Drinking Water Source Assessment and Preliminary Protection Plan Development

K. Doll & C. Downey

P.Eng, & P.Eng Koers & Associates Engineering Ltd.

City of Port Alberni

Government

Table 9.1: Existing studies on the China Creek Community Watershed

Island Timberland’s Watershed Assessment Plan is a key planning document that describes detailed watershed attributes and harvest plans. Unfortunately, this report is not a public document and, though requested, access was not granted. Therefore, the report was not examined.

This plan was released on June 1, 2016, which was after the research period for this study had ended. Therefore, there was insufficent time to examine it for this study.

*

†

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9.3 Alberni Valley Regional Water Study Update: Final Report (2010)

Due to the fact that the Alberni-Clayoquot Regional District commissioned this study, it has a regional focus, describing the Alberni Valley water system and assessing future water quality and quantity requirements. The only specific reference to logging and water quality in the CCCW is a brief description of the watershed assessment that was carried out by Streamline Environmental Consulting Ltd. and Ostapowich Engineering Services Ltd. in 2005. This watershed assessment “reported on the general condition of the watershed, identified impacts of past forest development activities on the condition of streams, and provided guidance to develop appropriate management strategies for future forest operations in the watershed while minimizing such impacts” (Koers and Associates Engineering Ltd., 2010, p. 21). As mentioned earlier, the 2005 watershed assessment report is not accessible to the public and can only be viewed with permission from Island Timberlands or the City of Port Alberni (S. Thomas, personal communication, May 2, 2016).

This study also notes the City of Port Alberni meets regularly with forestry companies to discuss harvesting plans and mitigation strategies to address water quality concerns, and that “[i]n general, this has resulted in reasonable protection of the public water supply” (p. 22). However, the authors do encourage Port Alberni “to strive for stricter control measures in the watershed, if not future ownership” (Koers and Associates Engineering Ltd., 2010, p. 22).

9.4 China Creek Water Quality: A Comparison Before and After Timber Harvest and Independent Power Project Construction (2010)

A student in the Faculty of Forestry at the University of British Columbia conducted this study, and as such it takes a very technical approach to the analysis of water quality, relying on statistical analysis of stream temperature and water chemistry. Additionally, the study focuses on chemical and biological water quality, as opposed to physical water quality (the primary focus of this report). However, there are still useful findings to report.

Buschhaus (2010) found that “[m]odelled relationships between key physical variables collected at the Port Alberni water intake weir, including daily maximum stream

temperature (°C), daily maximum air temperature (°C), and daily average specific conductance (μS/cm) showed a statistically significant difference before and after disturbance” (p. i). During low flows, stream temperature increased by approximately 1°C following disturbance (Buschhaus, 2010, p. i). While it was not shown that stream temperature increased in the summer months following harvest disturbance, Moore et al. (2005) indicate that this is not unusual because “there is a faster temperature response where streams are shallower than in deeper reaches and pools” (as cited in Buschhaus, 2010, p. 26). The sonde used to record data is located in an artificial pool on China Creek, so Buschhaus (2010) believes that “it may be that the volume of water buffers changes in temperature, and hence the impacts of forest harvest in increasing stream temperature are only observed during low flows” (p. 26).

Both timber harvesting and the construction of the Upnit hydroelectric project disturbed the CCCW during the study period. Buschhaus (2010) explains that “[t]he overlapping disturbances make it complicated to determine whether changes are due to harvesting, [independent power project] weir intake construction, or natural factors such as storm events” (p. 27). Additionally, Buschhaus (2010) had incomplete knowledge of harvesting dates, making it difficult to make comparisons to other watershed studies.

According to Moore et al. (2005), even if the harvest information had been comprehensive, the comparison of logging impacts across different watersheds and studies can be very complex due to variations in watershed characteristics (as cited in Buschhaus, 2010). These characteristics can cause compounding effects: for example, a change in vegetation type may alter the watershed’s hydrology and increase shading on a stream (Buschhaus, 2010). This was discussed in one of the Carnation Creek studies, as “the physical conditions that changed with logging recovered at different rates” (Buschhaus, 2010, p. 28).

Carnation Creek is an experimental watershed located approximately 20 km northeast of Bamfield on the south shore of Barkley Sound, relatively close to Port Alberni (Tschaplinski, 2010). Since the 1970s, the watershed has been used to analyze the impacts of logging on water quality in the Vancouver Island context (Tschaplinski, 2010). Due to its proximity to the CCCW, the Carnation Creek experiments could serve as a good comparison to the CCCW; due to time constraints, however, a detailed

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analysis of these experiments was not included in this study.

Buschhaus (2010) states that there was “insufficient data to conclude whether significant changes in chemical or biological water quality measures occurred after disturbance in the watershed by timber harvest and a power plant weir construction” (p. 31). However, regardless of whether or not these changes were caused by logging, power plant construction, or some other factor, overall water quality measures “remained largely below BC Water Quality Guidelines,” meaning that the water was safe to treat and consume (Buschhaus, 2010, p. 31).

9.5 Water Quality Assessment and Objectives for the China Creek Community Watershed (Overview and Technical Reports) (2011)

For this Ministry of Environment study, water quality was monitored between 1998 and 2005 (Barlak, 2011b). It is worth noting that since 2005, logging has increased significantly in the CCCW (see Section 8.4.5 of this report). Additionally, the report states that “[a]s there was little activity upstream of the China Creek Port Alberni intake during the time of this study site, [all water quality] objectives [proposed in this study] were developed using the background concentration approach, whereby data collected from this site up until December 2004 reflects the natural or background conditions in the watershed” (Barlak, 2011a, p. 21). Nonetheless, “[t]he results of this monitoring indicated that the overall state of the water quality is very good,” as “[a]ll chemical, physical and biological parameters meet provincial water quality guidelines with the exception of turbidity and Escherichia coli, which exceeded the drinking water guidelines on occasion” (Barlak, 2011b).

The study describes the impact of the various land uses in the CCCW. For example, the study address the risks posed by recreation, which include the possibility of water contamination from vehicle fuel and fecal waste from humans and domestic animals (Barlak, 2011a). It indicates that while no studies have been conducted on the impact of recreation within the CCCW, “they are likely to be significant due to the high use of the area by ATV vehicles and other recreational users” (Figure 9.2) (Barlak, 2011a). Wildlife in the watershed also poses a risk of water contamination from microorganisms such as Giardia lamblia (Barlak, 2011a).

Mining was identified as a risk, with the author recommending “continued monitoring for metals” in order to ensure the protection of aquatic life, which is especially sensitive to mining inputs (Barlak, 2011a, p. 19). The study also states that “the history of mining activities within the watershed, coupled with the possibility of future mining, suggest that acid rock drainage may be a concern and pH should be monitored on an ongoing basis” (Barlak, 2011b, p .18).

Road runoff is seen as a potential source of turbidity, especially during road grading and construction (Barlak, 2011a). In 2004, the length of roads in the CCCW measured 123.2 km, meaning that about 24 km had been constructed since 1998 (Barlak, 2011b). Of the 123.2 km of roadway, the study indicates that “7.2 km was considered to have a high sediment delivery potential, 10.9 km was considered to have a moderate sediment delivery potential, 5.7 km a low sediment delivery potential and the remainder (99.4 km) a very low sediment delivery potential” (Barlak, 2011b, p. 11).

The Ministry of Environment report states “[t]urbidity is a significant water quality concern in China Creek, as elevated turbidity levels force the City of Port Alberni to switch to an alternative water source” (Barlak, 2011b, p. 22). However, the study found that turbidity levels based on Ministry of Environment readings “are generally very good throughout the year” (Barlak, 2011a, p. 19). Turbidity values ranged from <0.1 NTU to 5.5 NTU and averaged only 0.6 NTU for the 43 samples collected throughout the Ministry of Environment monitoring program (Barlak, 2011b). Elevated levels tended to occur in the winter months and were typically associated with rainfall events (Barlak, 2011a).

Figure 9.2: CCCW users are warned to respect the water

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The study also examines turbidity data collected by the City of Port Alberni between 1994 and 1997, finding that “maximum monthly turbidity values exceeded 5 NTU on nine occasions, always between the months of October and March when peak flows occur, with a maximum value of 50 NTU recorded in November 1995” (Barlak, 2011b, p. 22). Furthermore, automated data collected between 2003 and 2005 shows that turbidity remained below one NTU for over 94 percent of the time (see Table 9.2) (Barlak, 2011b). Turbidity exceeded five NTU only 3.7 percent of the time (Barlak, 2011b). However, the study explains that “[t]urbidity is notoriously difficult to measure accurately with automated equipment due to the wide variety of factors that can affect measurements, including fish and other aquatic organisms, algae, and air bubbles” (Barlak, 2011b, p. 22).

The study emphasizes that when considering the impact of turbidity on drinking water, “[i]t is important to consider not

only the total amount of time the criterion was exceeded, but also how long each exceedance lasted”—for example, a turbidity event of five consecutive hours is more likely to affect water quality than five one-hour events that are spaced apart (Barlak, 2011b, p. 23). Figure 9.3 shows that turbidity events in the CCCW occurred mostly in the fall

Figure 9.3: Turbidity levels in China Creek between May 2003 and January 2005 as measured on 15-minute intervals by the automated water quality monitoring sation near the City of Port Albrni intake. Due to equipment malfunction, data gaps exist for the winter of 2004.

Table 9.2: Summary of automated turbidity data measured at China Creek at City of Port Alberni intake station from May 2003 to Feb 2005 (Barlak, 2011b)

TURBIDITY (NTU)

NUMBER % CUMULATIVE %

≤ 1 52,933 94.4% 94.4%> 1, ≤ 5 1,066 1.9% 96.3%> 5, ≤ 10 442 0.8% 97.1%> 10, ≤ 50 1,016 1.8% 98.9%

> 50 593 1.1% 100.0%TOTAL: 56,050 100.0%

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and winter and were of relatively short duration (Barlak, 2011b).

As part of the study, the Ministry of Environment set a number of water quality objectives for the CCCW (see Table 9.3). The study states that these objectives “provide direction for resource managers, serve as a guide for issuing permits, licences, and orders by MOE, and establish benchmarks for assessing the Ministry’s performance in protecting water quality” (Barlak, 2011b, p. 1). The objectives are guidelines rather than requirements; binding water quality legislation is found in the Ministry of Health’s DWPA, as outlined in Chapter 6.

On a related note, more recent City of Port Alberni water quality data indicates similar trends to those found in the Ministry of Environment report. Figure 9.4 displays all turbidity levels between January 2004 and August 2014 as recorded at the China Creek Intake Turbidity Meter (City of Port Alberni, 2014). During this time, a total of 2,380 measurements were taken, which covers 60% of all days. Turbidity exceeded one NTU only 114 times (4.8% of total readings) and exceeded five NTU only 13 times (0.5% of total readings) (City of Port Alberni, 2014). The incidences of turbidity exceeding 5 NTU occurred predominantly between 2005 and 2007, with the last reading over 5 NTU coming in January of 2012 (City of Port Alberni, 2014).

9.6 Alberni Valley Drinking Water Reference Guide (Mapping Our Legacy project) (2011)

This report provides an extensive overview of drinking water issues in the Alberni Valley, including watershed history, pertinent legislation, and the water systems and requirements of each community. Chapter 4.1 of the study discusses Port Alberni’s water system, conducting an asset inventory and describing the water testing procedures. Section 4.1.5 contains “identified threats to water supply” (Francoeur, 2011, p. 133).

Francoeur (2011) indicates that these are “real and perceived” threats that have been identified by a combination of her own research and that of the Save Our Valley Alliance Public Education Committee, “an Alberni Valley alliance that invites participation from volunteer organizations, individual citizens, all levels of government, First Nations, labour groups, and the business sector” (Save Our Valley Alliance, 2016). These identified threats are climate change, the lack of a watershed protection plan, the lack of zoning bylaws to protect the watershed, the lack of community involvement, and the industrial operations occurring within the watershed (Francoeur, 2011). Francoeur (2011) also identifies challenges to water management in B.C.: accountability, legislative continuity,

Table 9.3: Summary of proposed Water Quality Objectives for the China Creek Community Watershed

Designated water uses: drinking water, aquatic life, and wildlife

VARIABLE OBJECTIVE VALUEEscherichia coli ≤ CFU/100 mL (90th percentile) Dec-Sept

(based on a minimum 5 weekly samples collected over a 30-day period)Turbidity October to April: 5 NTU maximum

May to September: 2 NTU maximumpH 6.5 - 8.5 pH unitsTemperature 15°C maximum (long-term)True colour 15 TCU maximumTotal organic carbon

4.0 mg/L maximum

Non-filterable residue (TSS)

October to April: 28 mg/L maximum in a 24-hour period 8 mg/L average (based on a minimum of five weekly samples collected over a 30-day period) May to September: 26 mg/L maximum in a 24-hour period 6 mg/L average (based on a minimum of five weekly samples collected over a 30-day period)

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enforcement, funding, and sustainable water use. These will be discussed further in Chapter 11.

9.7 Forest Practice Standards and Water Quality in Privately Managed Land in the China Creek and Honna River Watersheds (2014)

This Madrone Environmental Services Ltd. Study, conducted by Butt and Hughes-Adams, was initiated by the Managed Forest Council in response to forest management concerns from the Forest Practices Board (Butt & Hughes-Adams, 2014). The study consisted of a one-day field visit, a review of past studies, and interviews with “key operational staff members of the private managed forest land owner (Island Timberlands)” (Butt & Hughes-Adams, 2014, p. 1). Importantly, Butt and Hughes-Adams admit that “[t]he assessment is subjective: no specific measurements were taken; we did not quantitatively evaluate the effectiveness of riparian buffers, nor measure turbidity above and below stream crossings” (Butt & Hughes-Adams, 2014, p. 1).

The study found that Island Timberlands was “performing

above the coastal average in areas of terrain stability, blowdown, and hydrological assessments” and was in high compliance with its forest certification standards (Private Managed Forest Land Council, 2014). There were “minor isolated instances of sediment generation relating to road construction and maintenance, bridge maintenance, and riparian blowdown which could cumulatively impact water quality,” but “outside of legacy issues associated with past forest management activities, it was the development of non forest related industries (e.g. independent power projects, abandoned mines) that could possibly have the greatest impact on water quality and fisheries resources in the watersheds that were studied” (Private Managed Forest Land Council, 2014).

Butt and Hughes-Adams (2014) found “isolated instances of sediment generation,” including (p. ii):

• Sloughing cutbanks depositing sediment in ditches that will eventually deliver sediment to streams

• Culvert intakes (and outlets) being partially buried by fill because roads were built wider than necessary

• Bridges acting as collection points for wheel-splash sediment accumulations in some cases from water

Figure 9.4: Turbidity levels in China Creek between January 2004 and August 2014 recorded at the City of Port Albrni intakeTurbidity (N

TU

)

22

20

18

16

14

12

10

8

6

4

2

0

Date

2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Data Source: City of Port Alberni, 2014

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flowing down adjacent road grades. • Blowdown along riparian areas disturbing channel

banks or on gully sidewalls triggering small slides that deliver debris to streams

The authors explain that while these issues are very minor in isolation, “collectively there will likely be cumulative effects on water quality, although these would be very difficult to quantify” (Butt & Hughes-Adams, 2014, p. ii). Another issue identified was that blowdown was in some cases limiting the effectiveness of riparian buffers, with one particular incident in 2006 resulting in debris accumulation in the municipal water intake (Butt & Hughes-Adams, 2014). However, Butt and Hughes-Adams (2014) state that blowdown was insignificant in the majority of the watershed’s riparian buffers.

The study indicates that while turbidity occasionally exceeds the water quality objectives for the CCCW, these “[e]xceedances only occur for short durations associated with heavy rainfall” and “[i]t is not clear that these exceedances are associated with land use activities” (Butt & Hughes-Adams, 2014, p. iii). In response to concerns about turbidity in the watershed, Butt & Hughes-Adams said the following (2014, p. iii):

All logging operations cause elevated turbidity over and above natural levels. While the City of Port Alberni water purveyor may believe that IT operations are a principal cause of periodic high turbidity, it would be very difficult to disentangle the source of turbidity from ‘legacy’ issues (China and Queen Charlotte mainlines), background turbidity (such as naturally occurring avalanches in the upper watershed) and operations for which IT is not responsible…. The amount of data that would be required to disentangle the sedimentation caused by IT’s activities from the confounding factors made it impractical to measure the results of those activities, at least within the time and budgetary constraints [under] which this report was prepared.

Legacy issues, as mentioned in the passage above, are a major focal point in the Butt & Hughes-Adams study. Legacy issues are things that occurred prior to Island Timberlands taking possession of the land and prior to current forestry regulations being in place. For example, the China Creek Main road, which was built prior to existing regulations, is identified as a significant sediment risk, as it was constructed too close to the mainstem stream channel and therefore lacks adequate riparian buffering (Figures 9.5 and 9.6) (Butt

& Hughes-Adams, 2014). Truck traffic along this road during heavy rain results in sediment deposition in China Creek (Butt & Hughes-Adams, 2014). However, roads such as this are “grandfathered” into the watershed as legacy features and are not subject to the regulations (Butt & Hughes-Adams, 2014, p. 19).

Another legacy problem is that of the alder-dominated second growth in riparian areas, which was discussed in Section 9.2. Butt and Hughes-Adams (2014) explain that China Creek is “depauperate in effective LWD [large woody debris], and has been for decades” (p. 33). This large woody debris “might offer opportunities for storing some of the suspended sediment responsible for turbidity

Figure 9.5: China Creek Main road. Island Timberlands has placed riprap on the road side to stabilize the channel, because the road was built too close to the channel.

Figure 9.6: A breach in the grader berm along China Creek Main road allows sediment-laden water to flow into the creek.

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(e.g. very fine sand)” (Butt & Hughes-Adams, 2014, p.33). Additionally, alders do not provide the same bank stability as large conifer roots, so there is greater potential for channel erosion (Butt & Hughes-Adams, 2014).

Overall, this study is quite complimentary of Island Timberland’s forestry practices. The authors state that “IT has done its homework with respect to management of hazardous terrain and watershed assessment; in our opinion they have made investments in knowledge well above the industry standard. We have not seen a higher level of [cut]block and road layout, mapping and instruction to contractors” (Butt & Hughes-Adams, 2014, p.39).

Furthermore, they explain that while there are minor improvements in forestry practices that could be made, “IT is a business that cannot operate for sustained periods with a loss and as such must always consider costs in all activities” (Butt & Hughes-Adams, 2014, p.39). One final interesting point addressed in the study is the observation that whereas in the past, water quality was strongly influenced by a small number of high-magnitude events, today water quality in watersheds is more often “influenced by the cumulative effects of many small sources” (Butt & Hughes-Adams, 2014, p.40).

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This section of the report steps outside of the Port Alberni area and briefly examines other watersheds, both near and far. The CCCW is certainly not the only watershed in the world, or even on Vancouver Island for that matter, to run into issues of land use and water quality. The case studies that follow are divided into two categories: “unprotected watersheds” like the CCCW, where a number of different land uses and users are allowed within the watershed boundaries, and “protected watersheds,” which purposefully restrict all human access (other than for the purposes of operating a municipal water intake). These case studies focus primarily on examples that are local to the Coastal B.C. area, but a few notable international examples are also included.

10.1 Unprotected Watersheds

10.1.1 Regional District of Nanaimo

The City of Nanaimo gets its drinking water from the Jump Lake Community Watershed (JLCW) (Regional District of Nanaimo, 2016). The water source is the South Fork of the Nanaimo River, which has been dammed to create the Jump Lake Reservoir (Regional District of Nanaimo, 2016). The JLCW shares many similarities with the CCCW; as part of the E & N Land Grant, the watershed has long been private land and is now owned by Island Timberlands and TimberWest (City of Nanaimo, 2016b; Manly, 2014). The watershed has been actively logged since 1943 (Turner, 1990).

In April 2015, the City of Nanaimo opened a new Water Treatment Plant with filtration technology, which cost upwards of $70 million to construct (Figure 10.1) (City of Nanaimo, 2016a; General Electric Canada Inc., 2016). The facility was built in order to comply with the VIHA regulations that were implemented in 2008 (City of Nanaimo, 2016a). According to the City of Nanaimo (2016a), filtration deferral—the option that Port Alberni is pursuing—was not possible because the City’s water source turbidity “exceeds 1 NTU an average of 35 days per year, and exceeds 5 NTU 5-8 days per year,” with extreme weather occasionally raising turbidity above 50 NTU (City of Nanaimo, 2016a). Additionally, Nanaimo was only using a single disinfection treatment (chlorine), whereas two are required for deferral (City of Nanaimo, 2016a).

Many community members and environmental groups claim that logging in the JLCW is what necessitated investment in the costly filtration facility. June Ross, Acting Chair of the Vancouver Island Water Watch Coalition, has

stated that “[i]t is our belief that if the watershed was not privately owned by Island Timberlands and Timber West and all but clear-cut, we would have never needed our multi-million dollar water filtration plant” (J. Ross, personal communication, April 26, 2016).

June Ross and Paul Manly, a documentary filmmaker with Manly Media, have expressed concerns about the City of Nanaimo’s lack of control over the privately-owned watershed, as “[t]here are no written agreements with the logging companies that guarantee the city access to the watershed” (Cunningham, 2015; Manly Media, 2013). Those who share similar concerns in Port Alberni are worried that if logging in the CCCW continues, the city will eventually have to purchase a filtration plant just like Nanaimo’s or else pursue an alternative source, which would also be costly.

However, Bill Sims, the City of Nanaimo Water Resources Manager, explains that “this is a far more complex issue than drawing a straight line between forestry and the need to build a filtration plant. This is a popular and understandably intuitive line to draw, but it is simply not that simple. The reality is that they are two separate issues” (B. Sims, personal communication, April 25, 2016). Sims explains that raw water quality in Nanaimo has improved—not decreased—over the years, but “public expectation and regulations have evolved to a much higher standard,” culminating with the VIHA regulations in 2008 (B. Sims, personal communication, April 25, 2016).

According to Sims, “there is likely relatively little direct impact from harvesting activities” in Nanaimo’s drinking watershed,” and he observed, “current forestry practices are actually being managed from the viewpoint of protecting drinking water quality and environmental values” (B. Sims, personal communication, April 25, 2016). Instead, changes in turbidity in the watershed are largely due to heavy rainfall and rapid snowmelt (B. Sims, personal communication, April 25, 2016). Sims indicated that while the watershed

Figure 10.1: City of Nanaimo’s new $70 million filtration facility

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CHAPTER 10: EXTERNAL CASE STUDIES

is a large 200 km2 area, the drinking water ends up being funnelled through a narrow 50 m wide canyon towards the municipal water intake (B. Sims, personal communication, April 25, 2016). During heavy precipitation and snowmelt, river levels can rise rapidly, causing scour and sediment transport (B. Sims, personal communication, April 25, 2016). Sims stated “[t]he relative land area that is logged and ‘exposed’ to the elements at any given time is very small, relative to the size of the watershed” (B. Sims, personal communication, April 25, 2016).

Additionally, Sims explained that on Vancouver Island, there has not been the same level of investment in drinking water systems as elsewhere in B.C. because historically, water quality has always been “very good,” especially compared to other parts of the continent (B. Sims, personal communication, April 25, 2016). Many people across the Island feel that water quality is already “good enough” and “are struggling to understand the need for filtration plants” (B. Sims, personal communication, April 25, 2016). Sims emphasized that “untreated water from Nanaimo’s watershed, even during turbidity events, is of good quality,” but that still does not guarantee safety for all users, especially vulnerable segments of the population such as infants, the elderly, and the immunocompromised (B. Sims, personal communication, April 25, 2016). Therefore, the VIHA regulations are simply a “raising of the bar” to ensure that water quality is sufficiently safe (B. Sims, personal communication, April 25, 2016).

While the filtration plant was an expensive investment for the City of Nanaimo, Sims said that it is worth it: “[i]f you were to conduct a survey of citizens and municipal water suppliers, I’d wager that very few people would suggest that having water quality of the highest standard isn’t of the utmost importance” (B. Sims, personal communication, April 25, 2016). He indicated that the City has received positive feedback from Nanaimo citizens about the upgraded water quality and “very few complaints (zero) about having clearer, better tasting water with less chlorine” (B. Sims, personal communication, April 25, 2016).

10.1.2 Comox Valley Regional District

Another community affected by the historic E & N Land Grant, the Comox Lake Watershed is also a “multi-use watershed with multiple owners,” which poses significant management challenges for the Comox Valley Regional District (CVRD) (Comox Valley Regional District, 2016). There are nine different categories of landowners or

responsible jurisdictions along the shore of Comox Lake, and the watershed is a popular recreational destination (Figure 10.2) (Comox Valley Regional District, 2016). On top of that, there is active logging throughout the watershed as well as hydroelectric power generation (Comox Valley Regional District, 2016). Due to the VIHA regulations, Comox Valley is considering the construction of a filtration plant, which is estimated to cost between $50 and $70 million (Caulfield, 2015; Slepian, 2015b).

Logging around Comox Lake began around 1929 near the shoreline and moved inland after 1934 when railroad logging took over as the harvesting system (Mackie, 2009). Railroad logging continued until the 1940s, at which point truck logging began (E. Piikkila, personal communication, June 5, 2016). Truck logging lasted until the 1980s, when the remaining old growth was deemed too expensive to harvest and the second growth was not yet old enough to harvest (E. Piikkila, personal communication, May 6, 2016). In 1995, the logging returned to the watershed thanks to the use of helicopter logging and mechanical harvesting, which allowed for cost-effective harvesting (E. Piikkila, personal communication, May 6, 2016). Logging continues to this day, but this study has not identified a link between logging and the need for filtration in the Comox Valley.

A watershed assessment was completed by CH2M Hill in 2006 and describes a number of potential hazards to water quality from land uses within the watershed. The report indicates that land use in the watershed “is dominated by the forestry industry, with the majority of the uplands surrounding Comox Lake Reservoir being privately-owned lands managed for forestry” along with a number of forestry properties in the lower portions of the watershed (CH2M Hill, 2006, p. 3-2). The two major forestry companies are TimberWest and Hancock Timber Resource Group, which together own 65 percent of the watershed (CH2M Hill, 2006; Gower, 2016).

The watershed assessment report identifies transportation on logging roads over the Puntledge River Bridge as well as near the Puntledge River as some of highest risk contaminant sources in the watershed (CH2M Hill, 2006). The other highest risk sources identified were boating on the Puntledge River and intentional harm to the water source (CH2M Hill, 2006). The assessment report also indicates that mining, agriculture, residential developments, and recreation are all potential sources of contamination (CH2M Hill, 2006).

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To address the management of the watershed, the CVRD prepared the Comox Lake Watershed Protection Plan (WPP), an updated and more intensive version of the CH2M Hill plan that was approved in April 2016 but was not yet publically available at the time of writing. However, Tanis Gower, a Registered Professional Biologist from the Comox Valley who works on projects for the Watershed Watch Salmon Society, has reviewed the new WPP. Gower (2016) explains that the WPP identifies 29 different risks of various severities and reports that “[t]he risk relating to logging extent and locations is “high,” while off-road vehicle use, camping in undesignated areas, wildfire, flooding and augmentation/concentration of streamflows are the risk factors that are “very high.”” Most of the 54 recommendations in the WPP deal with aspects other than logging, which Gower says is unsurprising given that the CVRD has no jurisdiction over logging practices on private land (Gower, 2016).

According to Gower (2016), “[d]rinking water quality is a hot topic in the Comox Valley, especially since we taxpayers will be required to pay for upgrades to our water

system.” She poses the question: “[h]as our drinking water quality declined over time, or have standards changed? It looks to be a bit of both” (Gower, 2016). David Stapley, Project Manager for the Comox Valley Conservation Strategy Community Partnership, contends that “slides that deposited sediment into a creek may have been caused by the cumulative impacts of a century of timber harvesting, even when the loggers are observing best forest management practices” (Shore, 2015). Additionally, many community members have written letters to local newspapers and have posted online “rants” that blame logging for the deposition of sediment into Comox Lake (Shore, 2015).

Despite this concern from community members, water quality in Comox Lake is generally good. Marc Rutten, General Manager of Engineering Services at the CVRD, explains that high turbidity during storm events is the number one issue for water quality (Caulfield, 2015). These storms occur frequently enough that turbidity ratings exceed VIHA requirements (Gower, 2016). While storms are a natural phenomenon, environmental groups such

Figure 10.2: Comox Lake is a popular destination for recreation

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as the Comox Valley Conservation Strategy Community Partnership are concerned that “extreme weather events are coming more frequently than ever and that simply logging by existing rules and regulations may not be good enough in a changing world” (Shore, 2015).

10.2 Protected Watersheds

10.2.1 Capital Regional District

The Capital Regional District (CRD), home to the city of Victoria, has a vastly different watershed management situation than Port Alberni, Nanaimo, or the Comox Valley. The Sooke and Goldstream watersheds currently supply drinking water to the CRD, with the Leech Watershed reserved as a future source for when additional capacity is required (Capital Regional District, 2016). The vast majority of each of these watersheds is owned by the CRD: the Sooke is 98 percent CRD-owned, the Goldstream 97 percent, and the Leech 92 percent (A. Constabel, personal communication, May 10, 2016).

As such, the regional district has total control over these watersheds, as opposed to the above case studies where regional districts and municipalities have little to no jurisdiction over their own watersheds. Currently in the CRD, watershed access is fully restricted: there is no commercial forest harvesting, no mining, and no recreation allowed within the Sooke and Goldstream watersheds, with the water intake being the only anthropogenic use (Figure 10.3) (A. Constabel, personal communication, May 10, 2016). In the Leech watershed, which is not yet being used as a water source, there are placer and mineral tenures as well as limited recreational use.

As with the previous examples, the CRD’s watersheds were at one point included in the E & N Land Grant. In 1915, the CRD decided to acquire the Sooke watershed, followed by the Goldstream watershed in 1925; the CRD purchased most of the land and expropriated the rest (A. Constabel, personal communication, May 10, 2016). Annette Constabel, Senior Manager of Watershed Protection with the CRD, believes that the vision behind this historic purchase was simply that controlling what happens in the watershed is the best way to protect the land and the water that it provides (A. Constabel, personal communication, May 10, 2016).

However, in 1926, the City of Victoria issued a timber harvesting agreement with the first logging company to log

the Goldstream and Sooke Lake watersheds (Sooke Region Museum, 1990). The Sooke Lake watershed harvesting was to occur in the Leechtown area (Sooke Region Museum, 1990). In 1928, another logging company began logging operations near Sooke Lake, and in 1934, a cash-strapped City of Victoria issued more harvesting permits to the second company for logging in the Goldstream Watershed for the small sum of $62,000 on the condition that no logging would occur within 400 feet of a lake shore and that the company would minimize and take responsibility for any fire hazards (Sooke Region Museum, 1990). Another company was logging near the Sooke Road summit in the 1920s and 1930s (Sooke Region Museum, 1990).

All of these logging companies used Railroad Logging systems (Sooke Region Museum, 1990). A fourth logging company began operations south of the Leechtown area in 1934 but used logging trucks on a planked road (Sooke Region Museum, 1990). In 1938, this last company used gravel logging roads to begin logging in the Leech River drainage system (Sooke Region Museum, 1990). In the 1950s, the Greater Victoria Water District continued logging in the watersheds and using the timber sale profits to fund infrastructure construction and maintenance (A. Constabel, personal communication, May 10, 2016).

Harvesting continued until the early 1990s, when a controversial and highly-publicised court case resulted in a moratorium on logging (A. Constabel, personal communication, May 10, 2016; Manly Media, 2013). Ms. Constabel notes that while this decision was celebrated as a victory for environmentalists against the logging of watersheds, the verdict in the court case did not rule whether or not logging is harmful to watersheds (A. Constabel, personal communication, May 10, 2016). Rather,

Figure 103: The water intake on Sooke Lake is the only anthropogeic use allowed in the watershed

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the case was won on a technicality related to the water district’s authority to sell timber products (A. Constabel, personal communication, May 10, 2016).

Nonetheless, logging in the watershed was halted, and since that time, the CRD watersheds have been under strict management—“you can’t even walk your dog up to Sooke Lake” (Coste, 2015). Ms. Constabel explains that this is necessary because the CRD’s water treatment system does not include filtration. The system therefore has little capacity to deal with large sediment inputs, meaning that the watersheds must remain in pristine condition (A. Constabel, personal communication, May 10, 2016).

According to Jack Hull, former General Manager of Integrated Water Services with the CRD, water treatment costs in the CRD are very low because the watershed is fully protected and also because their water sources were of very high quality to begin with (Manly Media, 2013). Based on the success of this arrangement, the CRD decided to purchase the Leech watershed in 2007 and 2010 so that it could be restored and protected for future use (A. Constabel, personal communication, May 10, 2016; Manly Media, 2013). Prior to the purchase, 95 percent of the Leech was logged, so the CRD “is undertaking an extensive watershed restoration program to prepare for future water supply needs” (Capital Regional District, 2016).

Interestingly, even fully protected watersheds can invite complaints from the public. Upon purchase of the Leech watershed, some elected officials and community members argued that recreation by permit should be allowed in the watershed until such a time that the area is actually needed for drinking water supply (A. Constabel, personal communication, May 10, 2016). Those arguing for recreational access say that the watershed likely won’t be needed for at least 27 years, during which time community members “can continue to access these lands that were purchased on their behalf in a safe way to provide for their quality of life” (Cleverley, 2016). At the time of writing, a final management decision on the Leech watershed had not yet been made (A. Constabel, personal communication, May 10, 2016).

Postel and Thompson (2005) explain that compared to the construction of costly filtration infrastructure, proactive watershed protection is a relatively inexpensive alternative to filtration and provides myriad other benefits, such as carbon sequestration and biodiversity conservation.

While this may be true, managing three large watersheds certainly comes with a cost. The CRD has an entire division of 24 full time employees dedicated to watershed protection (A. Constabel, personal communication, May 10, 2016). CRD staff deals with all sorts of issues, from invasive species management to watershed security (A. Constabel, personal communication, May 10, 2016). These are things that are dealt with, and paid for, by the private landowner—i.e., the forestry companies—in the Nanaimo, Comox Valley, and Port Alberni watersheds. However, the CRD’s philosophy is that it is ultimately less expensive (and more environmentally friendly) to spend resources on source water protection than on filtration facilities (A. Constabel, personal communication, May 10, 2016).

10.2.2 Metro Vancouver

Metro Vancouver’s drinking water comes from the Capilano, Seymour, and Coquitlam watersheds, all of which are owned by Metro Vancouver and closed to the public to protect them from erosion, pollution, fire, and other hazards (Metro Vancouver, 2015). Railroad logging began in the Capilano watershed in 1918 and continued until 1934 when the Capilano Timber Company dissolved after several disastrous forest fires and increasing environmental conditions imposed by the Vancouver Water District (Rees-Thomas, 1979; E. Piikkila, personal communications May 6, 2016). The regional district took control of the watersheds in 1927, and Water District Commissioner E.A. Cleveland is credited with putting a stop to logging in the watersheds (Smith, 2006).

Logging in the watersheds resumed in the1960s and continued for almost 40 years (B.C. Tap Water Association (BCTWA), n.d.). A public campaign by the Western Canada Wilderness Committee (now known as the Wilderness Committee) in 1988 brought attention to logging in the watersheds, which contributed to the initiation of a public enquiry in 1991 and, eventually, a halt to logging in 1995 (B.C. Tap Water Association (BCTWA), n.d.).

Like the CRD, Metro Vancouver now has a fully protected watershed. However, unlike the CRD, Metro Vancouver recently installed a filtration plant. The Seymour Capilano Filtration Plant was completed in 2009 and filters water from the Seymour and Capilano watersheds (Metro Vancouver, 2013). This is the largest filtration plant in Canada, with the capacity to produce 1.8 billion litres of filtered water per day (Metro Vancouver, 2013).

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10.2.3 Notable International Examples

Numerous examples of watershed protection exist around the world, and providing a comprehensive overview of these cases is beyond the scope of this report. However, Postel and Thompson (2005) have provided a useful overview of some of the best examples of filtration avoidance in the U.S., where municipalities have been able to avoid the construction of expensive water filtration facilities by protecting their watersheds. Table X International Examples [POSTEL] (Postel & Thompson, 2005) lists these examples and shows how much money each city saved as a result of their actions.

Cities such as Boston and Seattle were able to achieve these savings because their municipal water authorities owned their watersheds, as in Metro Vancouver and the CRD. New York City’s Catskill-Delaware watershed, however, is 75 percent privately owned, so the state has relied on “a multi-faceted agreement with watershed communities,” purchasing land from willing sellers and negotiating contracted conservation easements in many other cases (Postel and Thompson, 2005, p. 99). New York

City’s Watershed Protection Program “is by far the largest scheme in the world putting into effect direct payments by a beneficiary of hydrological services to the providers of those services” and “[i]t demonstrates that watershed protection can be a highly cost-effective alternative to technological treatment in meeting specific water quality standards” (Postel and Thompson, 2005, p. 105).

New York City’s Watershed Protection Program includes restoration on hundreds of thousands of acres in upper New York State and is based on a 2007 Filtration Avoidance Determination (FAD). The FAD includes a voluntary Watershed Forestry program that “provides financial incentives and technical assistance to loggers, foresters, and landowners to encourage the protection and restoration of riparian buffers through long-term forest stewardship” (NY State Department of Health, 2011). The Watershed Forestry Program’s primary purpose “is to maintain unfragmented forested land and promote the use of management practices to prevent non-point source pollution during timber harvests” (NY State Department of Health, 2011). This is an interesting model of watershed protection that deserves further examination.

METROPOLITAN AREA

POPULATION (thousands) AVOIDED COSTS THROUGH WATERSHED PROTECTION

New York City 9,000 $1.5 billion spent on watershed protection over 10 years to avoid at least $6 billion in capital costs and $300 million in annual operating costs. The City is currently being required to construct a $687 million filtration plant for the more-developed Croton watershed, which supplies about 10% of the city’s water. The filtration waiver applies to the Catskills/Delaware watershed, which supplies 90% of the city’s water.

Boston, Massachusetts 2,300 $180 million (gross) avoided costSeattle, Washington 1,300 $150-200 million (gross) avoided costPortland, Oregon 825 $920,000 spent annually to protect watershed is avoiding $200 million

capital costPortland, Maine 160 $729,000 spent annually to protect watershed has avoided $25 million in

capital costs and $725,000 in operating costsSyracuse, New York 150 $10 million watershed plan is avoiding $45-60 million in capital costs

Auburn, Maine 23 $570,000 spent to acquire watershed land is avoiding $30 million cost and $750,000 in annual operating costs

Table 10.1: Selected US cities that have avoided construction of filtration plants through watershed protection

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11.1 Overview of Results

The story of logging and water quality in the CCCW is complex, with a plethora of factors at play both within the watershed itself and out in the greater Port Alberni community. Based on the scientific literature, government reports, and numerous studies, logging within a watershed clearly poses a potential risk to water quality and many other environmental and cultural elements if proper forest management practices are not followed. The likelihood and severity of these risks is dependent on multiple factors, including climate, topography, and harvesting technique, so the actual outcome of harvesting will be watershed-specific or even site-specific. This makes it difficult to apply the findings of a study in one watershed to another watershed, even if they are in close proximity to one another. The review of existing CCCW studies presented in Chapter 9 found that at the moment, logging in the CCCW is not impacting water quality to any significant degree. Various studies found evidence of sedimentation from roads and landslides, but it was difficult to isolate and identify the actual source(s) of the turbidity in the water. Additionally, water quality was shown to be relatively good in the CCCW. During a 2014 assessment of Crown land activities in the CCCW, which was part of the broader special investigation of community watersheds, a number of roads belonging to Island Timberlands or TimberWest were observed and appeared to be well managed with no obvious signs of erosion or sedimentation into creeks (D. Wahl, personal communication, May 3, 2016). However, as long as logging continues in the watershed, the potential for water quality impacts remains present, especially if climate change results in more frequent and intense rainfall events in the Alberni Valley. There is some question as to whether or not the institutions and regulatory framework that are currently in place have the capacity to address these potential impacts. This report has raised a lot of questions about forestry regulations in B.C. The following section will dig into this issue as well as some of the other broader questions that arose during the researching and writing of this report. Hopefully, this discussion will inspire future research, as many questions remain unanswered.

11.2 Questions of Interest

11.2.1 Are provincial institutions and legislation adequately managing source water and protecting community watershed ecosystems in British Columbia?

As described throughout this report, the legislative framework dealing with the issue of logging and water quality is relatively complex. Numerous regulations, acts, and provincial ministries each address small pieces of the puzzle, but there is no single department nor act that has the authority to manage it all. This web of legislation can be difficult to untangle, as are the individual pieces of legislation.

Forestry and watershed protection are indeed complex subjects, so it follows that the corresponding legislation would also be complex. However, if the legislation is too difficult to navigate, this could potentially lead to inefficiencies or mistakes. Francoeur (2011) explains that in B.C., it is difficult to determine “which government agencies have which responsibilities and to whom they are accountable,” noting that “[a]t each level of governance, multiple acts and regulations exist, many of which contain escape clauses embedded in other pieces of legislation enacted by other government ministries and departments” (p. 36).

Furthermore, even the Forestry Practices Board—a provincial agency tasked with examining forestry practices on provincial land—puts a fair bit of effort into correctly interpreting the precise meaning of FRPAs requirements (D. Wahl, personal communication, May 3, 2016). If the government finds their own regulations confusing, how can the general public or those conducting business on Crown land be expected to fully understand the requirements?

Doug Wahl indicates that the sharing of information between various government departments is also a challenge. For example, as part of its effectiveness monitoring regime, the Ministry of Forests, Lands and Natural Resource Operations (MFLNRO) collects information on sediment deposited into streams (D. Wahl, personal communication, May 3, 2016). However, the FRPA “has very little authority on source drinking water protection outside of community watersheds” The primary authority is with the Ministry of Health, who administers the DWPA (D. Wahl, personal communication, May 3, 2016). Therefore, the Ministry that

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really needs information on sediment levels in watersheds is the Ministry of Health.

Unfortunately, this information may not be shared between these two ministries, meaning that those officials with the authority to enforce drinking water regulations are left without useful information about water quality (D. Wahl, personal communication, May 3, 2016). The MFLNRO has stated that “source water protection is a shared responsibility and can only be achieved through cooperation between all levels of government, industry and the public” (Ministry of Community, 2014, p.50). This cooperation is not even happening at the government level, let alone between industry and the public.

Enforcement of the DWPA can be challenging compared to enforcement of the FRPA, because whereas the FRPA has many staff members across B.C., there is only one Drinking Water Officer (DWO)—the individual with the authority to enforce the DWPA—in each health region. DWOs prioritize their assignments based on immediate risk to human health, so something like a chemical spill or meat cutting will likely command their attention before elevated turbidity in a watershed. This is because the former examples represent a more severe health risk and also because the DWOs know that there are FRPA staff who are watching out for water quality in forested areas.

The Ministry of Health’s Drinking Water Officers’ Guide states that “[t]he multi-barrier approach to drinking water protection begins at the water source, and this can raise complex questions regarding the relationship between the Act and Regulation and other legislation, including potentially complex and controversial issues associated with competing land use decisions. This is particularly for situations in which limiting activities to protect a water source would benefit a water supplier and users of a water supply system, but might have adverse consequences for other parties” (Ministry of Health, 2014, p. 100). According to this guide, there are a number of “options or steps that drinking water officers should consider and pursue as appropriate when source protection issues exist.” (Ministry of Health, 2014, p. 100). Drinking Water Officers can order the completion of a water source assessment as well as the establishment of a drinking water protection plan (Ministry of Health, 2014). They can also recommend that a provincial health officers reports to the minister about problems concerning government action (Ministry of Health, 2014).

The Guide notes that “[t]hese provisions complement, but do not replace, informal consultation among agencies and individuals involved in drinking water protection issues” (Ministry of Health, 2014, p. 101). The question is, are DWOs regularly consulting with MFLNRO staff to address watershed issues? Mr. Wahl explains that the MFLNRO and the Forest Practices Board receive complaints from citizens about turbidity and drinking water (D. Wahl, personal communication, May 3, 2016). Who should be responding to these complaints? The MFLNRO, who are watching out for forestry issues but have no real jurisdiction over source water quality issues? Or should it be the DWO, who has the legislative authority but who is likely busy dealing with a water quality issue that does not already have an entire institution watching over it?

11.2.2 Are the laws governing forestry on private land sufficient to ensure the protection of drinking water sources?

An in-depth comparison of the detailed forestry practices mandated in each of the Crown and private regulations is beyond the scope of this report and would be impossible without expert knowledge of forest harvesting, forest hydrology, and silviculture. However, based on more general aspects of the legislation as well as the findings of various studies, it is possible to identify some key differences between these two sets of legislation.

Arguably the most significant and practical difference between Crown and private forestry regulations is the requirement on Crown land to present a publicly-accessible Forest Stewardship Plan to the province for approval before any logging activities begin. This initial step instantly provides public oversight and accountability to all harvesting operations. Additionally, once that plan is approved, a licensee still needs to acquire specific approvals for forestry activities, such as road building permits and harvest permits, and in some cases Silviculture Site Plans for specific cutblocks. No such approvals are required on private land—the closest parallel to a Forest Stewardship Plan on private land is the initial management commitment that must be submitted when registering managed forest land.

Another clear difference is that the PMFLA only contains five primary objectives, compared to ten in the FRPA (these objectives were listed in the previous sections). Elements such as biodiversity, visual quality, and cultural

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CHAPTER 11: DISCUSSION

heritage are not considered or mandated in the private forest and land legislation. The protection or management of these elements is not seen as the responsibility of a private landowner, meaning that for something like wildlife protection, there is a much greater level of regulation on Crown land. However, despite the lack of legally-binding regulation, a large company like Island Timberlands will often voluntarily work with the local community to meet some of these extra objectives in the interest of being a good neighbour and community member. This does not happen in all cases and this extra work may focus on one issue over another—basically, it is up to the good will of the company to manage many of these issues.

As noted earlier in this report, a study by the Office of the Auditor General of British Columbia (2008) reported significant concerns about the impact that switching from the FRPA to the PMFLA had on the CCCW. West Coast Environmental Law has stated that the objectives set out in the PMFLA are too general and has indicated that the “minimal” forest practice rules on private land are resulting in negative impacts to community watersheds, although the nature of these negative impacts was not specified (Francoeur, 2011, p. 62). Gordon et al. (2007) noted that the PMFLA regulations “were substantially transferred from Forest Land Reserve Act and there is a widespread concern that they do not provide sufficient rigour… In particular, the concern is that standards prescribed are not sufficiently developed to permit effective enforcement” (p. 34).

Over the years, the Union of BC Municipalities has presented the provincial government with a number of resolutions seeking to address the imbalance between private and Crown forestry regulations. In 2006, the Alberni-Clayoquot Regional District (ACRD) sponsored resolution 2006-B102, which resolved “that the Union of BC Municipalities petition the provincial government to change the legislation and policies to enable a local government to establish a Community Watershed Bylaw that extends over any public or private lands within the watershed” (Ministry of Community Services, 2006, p. 109). This is an important resolution because currently, the “community watershed” designation has absolutely no meaning on private land.

Resolution 2010-B26 sought to address the fact that the PMFLA “does not impose ecosystem-based riparian regulations and permits selective harvesting to the water’s edge on all water courses including fish-bearing streams

and community drinking watersheds” (Union of BC Municipalities, 2010, p. 18). Resolution 2011-B50 stated that “...WHEREAS private managed forest land regulations are inferior to Crown land forest regulations with respect to protecting key environmental, watershed and community interests: THEREFORE BE IT RESOLVED that UBCM petition the Province of B.C. to revise the Private Managed Forest Land Act and appurtenant regulations to improve forestry practices on private managed forestlands to a standard equivalent or better than Crown forest land regulations, thereby better protecting community interests” (Union of BC Municipalities, 2011, p. 50).

In part, the province’s response to resolution 2011-B50 stated that “[i]n British Columbia, governance for environmental stewardship on private land is a multi-agency responsibility,” explaining that the Ministry of Health, Ministry of Environment, and Fisheries and Oceans Canada all play a role (Ministry of Community, 2011, p. 70). The response went on say that “[b]ased on the monitoring results received to date, government is satisfied that current standards are ensuring that the objectives for key environmental values as set out in the Private Managed Forest Land Act are being met” (Ministry of Community, 2011, p. 70). As noted earlier though, those objectives are less detailed and encompassing than those in the FRPA.

In defense of the private regulations, it is difficult to compare them directly to Crown regulations because they apply across different scales. The reason that private regulations are more general on private land is that there is a massive difference in the scale of operations of the various private managed forest land plots; while companies like Island Timberlands manage immense areas of land, some private landowners occupy relatively small pieces of land with tiny forestry operations. These small operations would be disproportionately impacted by more detailed regulations. Additionally, the regulations should be judged on the results that they produce, rather than the size or complexity of the legislative document.

Another aspect worth mentioning is the perception that private forestry lacks rigour and accountability. This perception is due to the fact that the plans and operations of private forestry companies are not typically open to the public, and they are not required to get the same public approvals as Crown forestry operations. However, this does not mean that there is no legal accountability behind these private operations. Professional foresters, biologists, and engineers are accountable to their own sets of professional

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ethics and by-laws, and the province uses a “professional reliance model” that puts the responsibility for complying with applicable regulations on these professionals (C. Cole, personal communication, May 30, 2016). Therefore, it is the professional associations that provide oversight on private land. This oversight is less visible to the public, which has contributed to these negative perceptions. These professional ethics and standards were not evaluated as part of this study.

On top of that, the FRPA is far from perfect, so the Crown regulations should not be held as the model regulation to follow. In a special investigation on community watersheds, the Forest Practices Board (2014) found that FRPA protection of community watersheds is inadequate, finding “issues at all levels of the FRPA framework, from objectives through to practices on the ground” (p. i). Additionally, the investigation found that the FRPA “seems to emphasize water treatment at the waterworks instead of source water protection” (Forest Practices Board, 2014, p. 10). Therefore, while it could be argued that the Crown regulations are more rigorous than the private regulations, they are not guaranteed to protect source water such as the CCCW. Ultimately, both sets of regulations are in need of an update—and perhaps a merger at the same time that could draw some wisdom from the Forest Stewardship Council guidelines.

11.2.3 Who should have control over a community’s water supply?

Is it purely chance that the province’s two largest, richest, and most influential centres—Metro Vancouver and the Capital Regional District—enjoy pristine, protected watersheds, while elsewhere in B.C., communities have unprotected watersheds and are struggling to meet filtration requirements? Of course it makes sense that these larger regional districts would have more funds available to purchase their watersheds, but for something as important as source drinking water protection, it should be expected that upper levels of government would assist smaller communities in protecting their watersheds. Whereas the CRD has an entire department for watershed protection, in B.C.’s interior, virtually anything can happen within a watershed: forestry, rangelands, utilities, recreation, and even private cabins at the edges of lakes that serve as drinking water sources for downstream communities (D. Wahl, personal communication, May 3, 2016).

This lack of protection is the case throughout most of the province, as evidenced by Vancouver Island communities such as Nanaimo, Comox Valley, and Port Alberni. In fact, this is the norm throughout most of world (J. Honey-Rosés, personal communication, June 1, 2016). This has resulted in struggles for many communities regarding all sorts of land uses, not just logging.

For example, in 2015, the Shawnigan Residents Association held a rally at the B.C. legislature in Victoria to fight against a gravel company that was dumping contaminated industrial soil into pits next to Shawnigan Lake Creek, an important source of water for Shawnigan Lake, the community’s drinking water source (Coste, 2015). At the rally, Shawnigan Residents Association head Calvin Cook exclaimed that “[w]e’ve had to fight our own Ministry of Environment for clean drinking water” (Coste, 2015). While reporting on that rally for the Huffington Post, Wilderness Committee campaigner and spokesperson Torrance Coste commented that “[s]urely the right to safe, clean water isn’t only for those of us in municipalities with large enough tax bases to purchase our watersheds” (Coste, 2015).

Chris Cole of TimberWest makes an interesting point, saying that there is little disagreement about the need to balance environmental protection, economics, and social interests; what many discussions about watershed management truly boil down to is the issue of “control” (C. Cole, personal communication, May 30, 2016). Municipalities, understandably, want control over their key assets, such as drinking water watersheds. However, there is some question as to whether government control is really the best way to protect a watershed.

Governments, whether federal, provincial, regional, or municipal, are tasked with protecting the “greater good,” or the interests of the people over which they govern. This would imply crafting and implementing a long-term vision, as governments should be striving to ensure that their citizens thrive both now and in the future. At the same time, however, the nature of politics means that there is rapid turnover of elected officials and, thus, values; one government may prioritize environmental protection while the next may prioritize economic growth, which can mean very different results on the ground. Government staff may remain in place and dedicated to their work throughout the government turnover, but budgets and priorities can be reallocated, taking away the staff ’s abilities to follow through with certain projects.

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Meanwhile, it could be argued that if a watershed is governed by a private company that is insulated from the election cycle, there may at least be more consistency in the management of that watershed. Chris Cole explains that “watershed management is a long-term commitment that is currently implemented by dedicated Professional staff at forestry companies who commit their entire working career to managing and improving a watershed’s health while balancing environmental protection, economics, and social interests with the goal of leaving a well-balanced healthy watershed to the next generation of staff and local public citizens” (C. Cole, personal communication, May 30, 2016).

This argument holds as long as the staff and, more importantly, the management of these forestry companies truly value and prioritize environmental protection throughout their operations. If a company is committed to sustainable operations and is a good neighbour to the local community, private management could be beneficial—the company acts as watershed stewards while saving taxpayer dollars. On the other hand, if a forestry company does not prioritize environmental protection and is instead focused solely on short-term economic gain, this could cause serious problems for local communities that are dependent on a private watershed.

Ultimately, the safest course of action may be some sort of co-management arrangement, where the government, forestry companies, and potentially other important stakeholder groups such as NGOs, First Nations, and citizen groups, come together to ensure balanced watershed management. In that way, the dedicated industry professionals can remain removed from the election cycle, but government and other stakeholders can maintain public oversight to ensure that social, environmental, and economic aspects are considered at all times. While this sort of arrangement could present logistical challenges, it would likely provide peace of mind to citizens and allow forestry operations to function with much less opposition than the current situation.

11.2.4 Should private managed forest landowners take on increased responsibility for legacy and non-forestry issues on their land?

The Madrone Environmental Services Ltd. study described in Section 9.7 noted that legacy issues such as poor harvesting

and road building practices continue to negatively impact the CCCW (Butt & Hughes-Adams, 2014). For example, China Creek Main road presents a risk of sedimentation in the CCCW (Butt & Hughes-Adams, 2014). If the China Creek Main road were to be constructed today by Island Timberlands, “it would contravene Section 16 of the PMFLC Regulation that requires a road to be more than 30 m from a Class A or B stream” (Butt & Hughes-Adams, 2014, p. 25). As noted earlier, roads such as this, which were built prior to current regulations, are “grandfathered” as legacy features and are not subject to the regulations (Butt & Hughes-Adams, 2014, p. 19).

The problem is, Island Timberlands continues to use this road today, despite the fact that “[w]ith the proximity to the creek it is inevitable that some sediment will be transported from the road to the stream” (Butt & Hughes-Adams, 2014, p. 27). Butt and Hughes-Adams (2014) indicate that while typically, there is a grader berm along the roadside to restrict sediment-laden water from washing off the road into the creek, that berm must be breached in places in order to keep road dry enough for truck hauling, which allows water (and sediment) to runoff into the stream (Figure 9.6). The authors of the report do indicate that Island Timberlands, “to its credit, has moved the road away from the mainstem channel in two locations” (Butt & Hughes-Adams, 2014, p. 27).

Even if they are legally allowed to do so, should Island Timberlands be using the China Creek Main road at all if they know that it does not meet modern standards and is contributing sediment into China Creek? Private forestry regulations state that road use must not adversely impact water quality or fish habitat, so Island Timberlands is required to factor in the potential impacts before using a road. Additionally, the regulations require Island Timberlands to maintain all of the roads that they use, regardless of whether or not they were the ones who built those roads in the first place. Therefore, having a legacy road in the watershed does not provide a forestry company with a ‘free pass’ to use it as they please; they are still bound by regulation. As discussed above, however, there is some question as to whether or not these private regulations are tough, or detailed, enough to deal with issues such as this.

The Upnit Hydroelectric project is another interesting case. The power generation facility is located on private Island Timberlands property, meaning that it is out of the Crown’s jurisdiction. As described in section 8.4.3, the project necessitated the construction of a two km road

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along China Creek, which was built on relatively unstable terrain (Barlak, 2011a; Butt & Hughes-Adams, 2014). Butt and Hughes-Adams (2014) indicate that while the road has been stabilized, there remains ongoing risk of sedimentation. Furthermore, Butt and Hughes-Adams believe that “this road in terms of location, design, construction, maintenance and drainage does not meet modern coastal industry standards or the [Managed Forest Council] Regulation … it is likely that this development has affected turbidity in [China Creek] at some time in the past and may continue to do so” (Butt & Hughes-Adams, 2014, p. 36).

It is important to note that roads constructed for non-forestry purposes are not legally required to meet any Managed Forest Council regulations. Barlak (2011) has indicated that “[d]ue to the proximity of the road to the creek, and the fact that the road is located just upstream from the City of Port Alberni intake, this road will likely be a significant source of turbidity” (p. 14). According to Port Alberni City Engineer Guy Cicon, the Upnit roads are poorly rehabilitated and introduce sediment into China Creek, but he feels that “this represented only a minor source of turbidity” (Butt & Hughes-Adams, 2014, p. 47).

All roads in the CCCW have the potential to divert natural water flows and increase sedimentation, regardless of whether the person driving on that road works for Island Timberlands, the Upnit Power Corporation, or a mining

exploration company. Various sources have indicated that Island Timberlands meets or exceeds the high road building standards required of private forestry companies (D. Wahl, personal communication, May 3, 2016; Butt & Hughes-Adams, 2014). Why are non-forestry roads not held to the same standards? As mentioned earlier, even a relatively small portion of the road network is capable of producing the majority of all road-generated sediment in a given watershed (Watts & Tolland, 2013). Therefore, it follows that even if the forestry roads in the CCCW are perfect, the unregulated Upnit road could still be a significant problem.

The only regulations that apply to the Upnit road are the water quality and fisheries regulations from the provincial and federal governments (D. Wahl, personal communication, May 3, 2016). These regulations prohibit the deposition of deleterious substances, but they do not offer any road building guidance, like that provided in the FRPA and the PMFLA. This section is not meant to blame Upnit Power Corporation for all sediment problems in the watershed or to paint them as a negligent company. Simply put, if all land uses on private managed forest land were required to follow a set of overarching community watershed regulations, everyone would at least be on the same page, potentially making watershed management more efficient and effective.

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12.1 Closing Thoughts

For many B.C. communities, watershed management has become more and more challenging over the years. Provincial water treatment requirements have become stricter and municipalities are on a timeline to comply. Meanwhile, many communities have no control over their source water, meaning that their only option is to purchase expensive filtration systems or to switch over to alternative sources, which comes with its own costs and challenges. This lack of control over drinking water has left many elected officials, NGOs, and community members concerned. In certain cases, such as in Nanaimo and the Comox Valley, filtration is the only option: the source water in these areas is simply not good enough to comply with the new water quality regulations.

Port Alberni differs from these municipalities in that at the moment, water quality within the CCCW is good enough to qualify for a filtration deferral, contingent on the approval of a watershed management plan. This is thanks to a generally high-quality water source, built-in system redundancy, and recent investments in disinfection technology. However, a filtration deferral is not permanent: if source water quality in the CCCW were to drop below provincial standards, the deferral would be revoked and the City would be forced to install costly filtration infrastructure or seek out alternative water sources. The City of Port Alberni is at a crossroad between filtration and deferral, and it wants to avoid passing the provincial water quality threshold and being forced down the costlier path.

Logging is paramount to the heritage and economy of many B.C. communities, and private companies have the right to operate on their property and to seek a profit. However, this right should not come at the expense of clean drinking water, or any other public or environmental good such as the protection of endangered species or the preservation of culturally important land. Water quality does not currently appear to be an issue in the CCCW, but the research process revealed a number of questions and concerns about forestry and watershed management in British Columbia as a whole. These issues have the potential to negatively impact the CCCW at some point in the future, so in order to be safe, the precautionary principle should be followed: “[w]here there is the possibility that a practice may cause serious or irreversible damage to the environment, that practice should be modified or curtailed” (Francoeur, 2011). On that note, a few actions are recommended.

12.2 Recommendations

For one, the provincial legislation that deals with logging in drinking watersheds should be updated and better explained, as these regulations are negatively perceived by many citizens and community groups. Clarification of the roles and authority of the ministries involved in the protection of drinking water with respect to forestry operations is also necessary. There are many overlapping regulations and institutions that are tasked with protecting water quality in watersheds, creating possible confusion as to the roles and responsibilities of various government departments and potentially resulting in inefficiencies. Source water protection needs to be prioritized and given a clear chain of authority because at the moment, it seems to be floating between various ministries without truly grabbing the attention of any one in particular.

Communication and data sharing across institutions needs to be improved, as does general communication with the public. The perceived lack of transparency and public oversight has damaged the reputation of private forestry companies. Clearing up some of the misconceptions related to logging impacts, regulations, and professional accountability would go a long way towards reducing the conflicts between private industry, government, and citizens. When logging is negatively perceived in a “logging town” like Port Alberni, this issue can quickly become divisive in the community. There may be proprietary information that forestry companies do not want to share, but all information about harvesting and water quality that can be shared, should be shared.

Forestry companies should also consider seeking certification under the Forest Stewardship Council (FSC) program. Island Timberlands and TimberWest are already certified under the Sustainable Forestry Initiative (SFI) program, which is a positive step that adds a layer of due diligence to their operations. However, the SFI certification program has been accused of having relatively weak standards, producing misleading labels, and lacking independence from the forestry industry. This has damaged its credibility in some circles, particularly amongst the NGOs and community groups that frequently oppose logging. FSC certification is internationally renowned for its strict regulations and environmentally friendly results, so certification under this program would instantly provide added credibility for the forestry companies.

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CHAPTER 12: CONCLUSION

The issue of watershed control is also important to consider. Postel and Thompson (2005) explain that “[i]n the parlance of ecological economics, watersheds are natural assets that deliver a stream of goods and services to society. Commercial markets, however, value these services only partially if at all” (Postel and Thompson, 2005, p. 98). They found that watersheds lacking adequate protection “inevitably deliver less clean, less reliable water to their downstream dependents” (Postel and Thompson, 2005, p. 99). Postel and Thompson (2005) emphasize the importance of acting early to protect watersheds: “[t]he opportunity costs of watershed protection are rising over time as land values and the worth of foregone land uses increase; delaying action therefore often makes watershed protection costlier or even prohibitive. Where outright purchasing of watershed land is not feasible, regulations or payment schemes are necessary to ensure that the use of land within the watershed does not unduly compromise the watershed’s purification and water-supply functions” (p. 106).

It is important to remember that government control does not automatically ensure clean drinking water. For one, there are many natural sources of turbidity and pathogens in a watershed, so closing the watershed to anthropogenic uses does not guarantee a filtration deferral. Additionally, as discussed in Section 11.2.3, the effectiveness of government protection can be impaired by the short-term nature of the election cycle, meaning that a seemingly great management scheme can quickly be deprioritized and have its budget reallocated.

Therefore, while it seems prudent that local and provincial governments should continue to strive for increased control over forestry practices in community watersheds, it could be argued that full control is not necessary, nor necessarily beneficial, in all cases. Some sort of co-management scheme with the private landowners and other important stakeholders may be the best option for watersheds like the CCCW. Co-management is an appealing option because it would allow professional industry foresters that are removed from the election cycle to care for the watershed, while simultaneously creating enhanced oversight from elected officials who are directly accountable to the local community and from third-party stakeholder groups who provide an independent opinion. While potentially complicated, this management scheme could help to ease tensions surrounding watershed logging.

On top of any management scheme, the “community watershed” designation should be adjusted so that it applies across all land, instead of only on Crown land. This designation implies the need for greater care and protection in the interest of protecting drinking water, so it makes sense that this extra attention should be given to both public and private watersheds.

According to Port Alberni mayor Mike Ruttan, the City currently has “both very high-quality water and good relations with the forest companies,” which is a testament to the quality of current forestry practices in the CCCW (Caulfield, 2015). It is important that the City of Port Alberni maintain those good relations, because in the current regulatory framework, it is essentially up to the forestry companies to maintain water quality. This may work when the regulations are strong and the forest companies follow sustainable forestry practices, but it leaves the community vulnerable to any changes in land ownership or management style.

The CCCW Drinking Water Source Assessment and Preliminary Protection Plan Development, which has recently been produced by the City of Port Alberni in communication with watershed stakeholders, including Island Timberlands, represents a crucial step towards ensuring the continued presence of high quality drinking water in CCCW. Hopefully, the contents and implementation of that plan will provide a path towards effective source water protection and natural filtration, ensuring clean drinking water for current and future Port Alberni residents.

Figure 12.1: Sunset over the China Creek Community Watershed

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Figure Credits

Figure Credits

Cover Images (front, back, and chapters): Patrick Bell

Figure Author

i TJ Watt 1.1 TJ Watt1.2 TJ Watt 2.1 Patrick Bell, with data from DataBC, Hansen/ UMD/Google/USGS/NASA 3.1 Ministry of Forests Mines and Lands, 20103.2 Ministry of Forests Mines and Lands, 2010 4.1 Mutiple sources (listed in Figure 4.1)4.2 Gordon et al., 20074.3 TJ Watt 5.1 TJ Watt5.2 Sierra Club BC (found in Hunter, 2016)5.3 Center for Biological Diversity5.4 US National Park Service5.5 Marmot Recovery Foundation 5.6 Our Children’s Trust5.7 Vancouver Island University5.8 TJ Watt5.9 TJ Watt 6.1 P. Teti6.2 Government of British Columbia, 20156.3 Medical Health Officer & Vancouver Island Health Authority, 20126.4 Katya Slepian 7.1 TJ Watt7.2 TJ Watt7.3 TJ Watt7.4 TJ Watt7.5 TJ Watt7.6 Butt & Hughes-Adams, 20147.7 TJ Watt7.8 TJ Watt 8.1 Sarah Thomas8.2 Federal Interagency Stream Restoration Working Group, 19988.3 Horel, 1998

8.4 Green & Klinka, 19948.5 TJ Watt8.6 Ministry of Forests, Mines and Lands, 2010; Koers and Associates Engineering Ltd., 20168.7 Taylor, 19758.8 Patrick Bell with data from DataBC8.9 Real Cedar; TerraMai; Logging and Sawmilling Journal and TimberWest Journal8.10 Butt & Hughes-Adams, 20148.11 Museum at Campbell River8.12 Mendocino Coast Model Railroad & Historical Society8.13 Museum at Campbell River8.14 Madill Equipment (heavyequipmentforums.com)8.15 Contract Logger (heavyequipmentforums.com)8.16 Horel, 19988.17 Patrick Bell, with data from DataBC, Hansen/ UMD/Google/USGS/NASA8.18 Patrick Bell, with data from DataBC, Hansen/ UMD/Google/USGS/NASA8.19 Patrick Bell, with data from DataBC, Hansen/ UMD/Google/USGS/NASA 9.1 Butt & Hughes-Adams, 20149.2 Ancient Forest Alliance9.3 Barlak, 2011b9.4 Patrick Bell, with data from City of Port Alberni, 20149.5 Butt & Hughes-Adams, 20149.6 Butt & Hughes-Adams, 2014 10.1 Kenaidan10.2 VancouverIsland.com10.3 VibrantVictoria.ca

12.1 TJ Watt

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