Good afternoon Janice – on behalf of Ntityix Resources, Gorman Bros, Tolko Industries, BCTS and MFLNRORD please find a consolidated response to your questions. We felt it would be more effective to provide our response imbedded within your questions and quotes. Our collective response is highlighted in orange.
Thank you for your interest and request for clarification.
We recently listened with interest to your joint presentation to the Mayor and Council of the District of Peachland. As you are aware, Peachland is building a new water treatment plant to treat our drinking water as almost every spring Peachland resident are required to boil the water as a result of sediment entering Peachland Creek. As the water treatment plant is to open in time for the 2021 freshet, we were hopeful to hear that the recommendations in the Watershed Assessment report for specific mitigation and mitigation planning have been addressed now that two years have passed since the report was released in order to safeguard our plant. However, the presentation left us with more questions than answers. As a consequence, we would like to have clarification on the following: (items in italics are taken directly from the Watershed Assessment Report)
“As suggested at the February 26, 2018 forest licensee meeting with the District of Peachland an integrated list of water quality concerns should be developed by a watershed technical working group that can be used to develop surface erosion mitigation strategies to minimize water quality issues at the District of Peachland water intake. The integrated list could aid in identifying funding, responsibility and timelines for mitigation.”
In your presentation it was stated that work on establishing a Watershed Technical Working group has started, but it appeared that no meetings of this group have been held. We are concerned that licensees are beginning work in the watershed but have not developed the integrated list of water quality concerns as recommended and to be used in part to guide new work. We question whether any work in the field should commence without these key recommendations in place.
Licensee and BCTS Response:
It is our understanding that through the District of Peachland’s water license requirements that they are responsible for setting up a Watershed Technical Working Group. The licensees and BCTS look forward to being invited to participate when this committee “get up and running”.
“Numerous legacy issues associated with erosion and sediment delivery to Greata Creek and Peachland Creek were identified in this watershed. A plan to mitigate these issues should be developed.”
In your presentation, you mentioned you are dealing with legacy roads in areas that are being cut, but no mention was made of an overall strategy or plan for legacy road mitigation. Is there an overall plan for the watershed or is the work being undertaken ad hoc? Have the other agencies as noted in the report under this recommendation been contacted to begin this planning process?
Licensee and BCTS Response:
All licensees and BCTS are addressing legacy roads that are adjacent to their current activities. If issues are identified through our road inspection or timber development programs, then a plan is made to address them. In many cases, some of these issues are associated with roads that the licensees and BCTS don’t have the authority to carry out work on. When the District or licensee identify an issue there are active conversations between the parties to identify an appropriate solution.
“Careful consideration should be given to the maintenance of healthy riparian areas that adequately buffer water courses from potential effects of forest development and other land uses.”
When asked by Mayor Fortin if you have stated minimums for riparian buffers it was reported that each of the licensees have standards that they work to. Is there an alignment of this
Licensee and BCTS Response:
Currently our riparian management strategies exceed the standards that are laid out in legislation. Each licensee may have slightly different approaches they manage to, but at the bare minimum every stream has a 5m no-machine zone and buffering through the retention increases as the stream size increases. Each licensee and BCTS meet and often exceed their Forest Stewardship Plan riparian requirements, which are located on the following organizational websites.
We also work with extensively with First Nations Bands in the Peachland watershed including Westbank First Nations and the Penticton Indian Bands who review our blocks and provide comments for consideration into our plans including the protection of water features within and adjacent to our blocks.
“a list (refer to Section 4.3) of cut blocks and associated access roads were highlighted as requiring further on the ground assessment or planning to ensure increased surface erosion or delivery of sediment is minimized”
Of the list in Section 4.3, which cut blocks are currently planned to be developed in the next five years and has the groundwork as noted in this recommendation been undertaken?
Licensee and BCTS Response:
The list of recommendations in section 4.3 has been utilized by BCTS and the licensees as they are developing the roads and blocks in the area. Through this information they can integrate planning, construction, maintenance as well as an appropriate deactivation plan for the blocks and roads in question. Below is the status of the identified blocks
Block KP1094 has had the recommendations completed, below block KP1167 the Ester road had full contour deactivation completed in 2018, blocks KP1128, KP1129, KP1149, KP1168 are not being developed at this time. However, recommendations will be reviewed and integrated into the plan when the decision is made in the future to move these blocks forward.
All of the blocks on the list in section 4.3 are actively being developed and all recommendations from section 4.3 of the report are being integrated into the plans for these blocks and roads. Further integration of these recommendations will occur as detailed on the ground assessments are completed as BCTS Professionals have Engineering and Terrain Stability work undertaken.
Munroe FSR was noted in the presentation to be under application to be moved to Ministry responsibility. What does that mean with respect to the implementation of sediment mitigation which is recommended to be a priority – or has the work been completed?
Licensee and MFLNRO Response:
Road maintenance requirements on the Munroe FSR road are current. The District of Peachland worked with Emergency Management BC (EMBC) to carry out emergency instream work that was identified as a concern during the 2017 freshet. Any additional work would have to fit the criteria to receive an EMBC response and or funding. The District MFLNRO is willing to visit this and other sites of importance with the Peachland monitoring committee to look for opportunities to address any other identified concerns
|Michael Bragg, R.P.F.
Woodlands Manager Forestry | Tolko Industries Ltd.
M (250) 318-4187
6275 Old Hwy 5 | Heffley Creek, BC | V2H 1T8
Dear Mr. Bragg and Colleagues
Thank you for your email and responses to our earlier queries. We have forwarded your response to the Mayor and Council of the District of Peachland and expressed our hopes for the commencement of the Technical Working Group at their earliest convenience. It is our belief that the interests of all the stakeholders of the watershed will be well served by the work of this group.
Our overriding concern is that the Water Assessment Report Recommendations appear to be implemented to the extent that they can be dealt with within current working areas. However, the recommendations within the report are much more broad reaching, speak to the entire watershed area and ask for landscape level planning with the input by a broad group of stakeholders. Without this level of strategic planning the core problems that are affecting our water quality remain at risk. Without this broader scope and assignment of responsibility, it appears items are falling through the cracks. By way of example only and by no means comprehensive, the following items appear unresolved two years after the report issuance: (text in italics was taken directly from the Watershed Assessment)
Photo #10 (Field Stop #2): Location: Munro FSR bridge over Peachland Creek Notes: Barrier used to minimize delivery of sediment off of the bridge deck into Peachland Creek requires maintenance. The barriers look to be in the same condition as the photos in the report.
Photo #11 (Field Stop #5): Location: Munro FSR southwest of Peachland Creek Notes: Rubber belting used to divert surface flow of water and sediment along surface of Munro FSR needs to be replaced. The belting looks to be in similar condition to the photos in the report
Photo #14 (Field Stop #5): Location: Munro FSR southwest of Peachland Creek (situated at first switchback southwest of Peachland Creek) Notes: Mineral soil is exposed along cutbank. Extensive rill erosion was present along cutbanks. The photos in the report matched what we viewed this week.
We look forward to the commencement of the work of the committee and the resolution of all of the recommendations.
Janice Liebe and Alison Moore
Co-Chairs, Peachland Watershed Protection Alliance
cc Shawn Grundy, Chief Operations Officer, District of Peachland
Kevin Kreise, Chair BC Forest Practices Board
PWPA Board and Members