|
Hon. Pat Bell, Minister of Forest and Range
Parliament Buildings
Victoria BC
V8V1X4 CANADA
July 5, 2008
Dear Pat Bell,
Most of the public thinks that spring water is perfectly purified by long percolation cycles through soils and gravels, and the safest possible high quality drinking water. Cavers know that this is not necessarily the case, and even less so in karst, where transport of contaminants from source to tap can be very swift.
The folks at Walkerton, Ontario learned this at their peril. This isn't a common worry in British Columbia, but the South Island Forest District may have the best example where numerous karstified limestone units are a direct and indirect water source for many small (less than 500/people) and large (more than 500/people) commercial and domestic water supplies.
The complex geology of the Beaufort Range for example, plays a major role in catchment, recharge, storage and release of large quantities of groundwater that resurface as numerous springs from the Alberni Highway to the Ash River valley, a distance of approx. 22kms.
Field observation of karst terrain/features, including an unusual deposit of precipitated calcite in a surface stream, personal communication, topographic and karst mapping and chemical analysis of various water supplies STRONGLY suggest that major karst drainage systems have developed in the limestone bedrock deposits. These karst systems play a major role in the catchment of surface water, storage and lateral distribution of groundwater intersecting geologic faults, fractures and non-karst sedimentary bedding planes.
Calcareous deposit VANISL 76 for example, has two major karst groundwater systems that flow basically in opposite directions. One of these groundwater systems appears to flow towards Lacy Lake, while the other recharges the Cascade Cave/Hobbit Hole system. Its downstream resurgence is the primary water supply for residents of the Elkford Road, Mountain View Mobile Home Trailer Park, Export Road, Alberni Highway, and Alberni Veterinary Clinic. In 2002, 34 area residents petitioned the Ministry of Forests "to act to protect our water supply" from "proposed logging and road building on Carbonate Unit 76 Karst Lands".
The other VANISL 76 karst system appears to support the Cherry Creek Water Works’ intake which is installed in a small river reservoir located a short distance downstream from Lacy Lake. A submerged resurgence within Lacy Lake provides the primary recharge for the lake, downstream reservoir and Cold Creek. Dry tracing would eliminate the element of uncertainty. The Cherry Creek Water Works provides drinking water for approx. 2500 residents.
Chemical analysis of the China Creek water supply for the City of Port Alberni, plus personal communication, topographic and karst mapping, indicate a hydrologic connection to calcareous deposit VANISL 129. Preliminary evidence suggests there are at least two major karst systems associated with VANISL 129 as well, one recharges Duck Lake while the other recharges Lizard Lake (plus non-karst catchment). During summer the main valve at the Lizard Lake reservoir is opened to satisfy demand. Both lakes contribute water to the city’s China Creek water supply.
Approx 80 to 90 percent of the total catchment area for all of the above mentioned water supplies is located on privately owned land subject to Private Managed Forest Land Council (PMFLC) regulations.
The absence of karst-specific regulatory standards to protect and conserve key public environmental resource values such as drinking water source areas, wildlife and fisheries on private managed forest lands is a major concern for most water purveyors, area residents and environmental groups.
If on the other hand the remaining 10 to 20 percent of catchment area were located within provincial forests, then under Government Actions Regulation (GAR) Section 5, the Ministry of Forest and Range could issue a GAR karst order with the intent to protect in the publics’ interest, key environmental values related to karst resource features.
However, definitions for key karst environmental resource features are not provided in the text of GAR karst orders, and do not exist in previous or current legislation.
In a 1992 report prepared for the Ministry of Forests by G.G. Runka, noted a major oversight in Federal and State legislation in the US with regard to cave protection, and advised against the use of pragmatic terms. Never the less, terms such as, significant/important surface karst features, karst cave, and very high and high vulnerable karst terrain are utilized in the absence of definition in the legal texts. As a result, existing karst orders are not enforceable and do not effectively or rationally protect the public interest in water quality and quantity, soil conservation, reforestation, critical wildlife habitat or fisheries.
We have recently been informed that BC Timber Sales has offered standing timber for public tenure and plans to construct and rehabilitate forest roads for access. There is no legally supported protection for karst resources in the South Island Forest District with out a GAR karst order.
Some of these forest lands scheduled for development are on or in the vicinity of high vulnerable karst terrain and yet, the South Island Forest District has not issued a legal requirement to protect the natural ecological processes or elements associated with karst. As a Result, not only are key karst environmental resources threatened, but opportunities for regional recreational and economic diversification could also be dramatically impacted.
For example, approx. 800 hectares on the south side of Sproat Lake, near Fossli Provincial Park, is underlain by karst terrain. In the Sproat Lake karst area the Central Island Caving Club has discovered 28 caves and more than 100 significant/important surface karst and non-karst features including rare fossils, a large karst dependant insect community, a previously unknown species to science, blue listed bats, and unusual animal bones. With a surveyed length close to 2 kms, Blak-T is the longest relatively visitor-friendly cave on southern Vancouver Island.
Crown land adjacent to Fossli Provincial Park could be developed in much the same way that the Nanaimo Regional District has chosen to accommodate boating and overnight camping adjacent to Horne Lake Caves Provincial Park. Additional development could include a cable car system that could transport visitors from privately and/or A/CRD operated park to the top of the karst mountain plateau. Once on top, visitors could have a number of choices to return by using the cable car, trails or a combination of trails and zip line.
Services that could be offered include guided tours of surface karst features and caves, certification courses for those wishing to become licensed guides, single rope technique and caving gear training, and underground search and rescue training.
Some caves could be open at all times, whereas the Blak-T cavern and others could be used as commercial show caves. A 1984 assessment of commercial tour opportunities in Horne Lake Provincial Park provided by Stephen E. Fairchild at the request of the Ministry of Lands, Parks and Housing states in part;
The economic gain to the area’s economy can be assessed. If a figure of 500 visitors/day is assumed for 120 days/season, and we can assume about $25.00/day each visitor, we see about $1,500,000/year direct income. Since money is usually circulated several times, the multiplication factor would bring the total gain to about $4 million, or about 150 to 200 jobs. There may be additional gains if the draw of this cavern encourages other attractions, perhaps even another commercial cavern, to open nearby or at least elsewhere the island.
I can conclude, then, from the above analysis that the project is probably highly warranted and feasible. It would be a good investment if done with private capital and could be self supporting if done as a provincial park. (1985, Horne Lake Caves Provincial Park Master Plan)
In addition, the abundance and broad variety of karst features, systems and related resources close to high population centers, hydro and major vehicle corridors, make the Port Alberni area an ideal location to establish a karst-specific learning institute. The karst water related incident at Walkerton provides more than one example why BC forest and non-forest professionals should have karst-specific training.
In British Columbia, government documents identify the Ministry of Forest and Range as having the primary responsibility for identifying, managing and protecting karst resources in provincial forests.
Therefore, as the new Minister of Forest and Range, we ask that criteria based definition for karst and those elements currently identified as resource features in existing and future GAR karst orders, be well-defined and established in legislation.
Sincerely Yours,
Reid Robinson
On behalf of, Alberni Environmental Coalition, SOVA Public Education Committee, Central Island Caving Club | 
