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Your reference: 315780

June 5, 2018

Honourable George Heyman
Minister of Environment & Climate Change Strategy
The Executive Council Victoria
PO Box 9063
Victoria BC V8W9E2

Dear Minister Heyman:

Re: Tetrahedron Provincial Park consultation process

I received Mr. Jim Standen's reply with reference no. 315780 on May 2nd to my earlier letter regarding the public consultation process on proposed changes to Tetrahedron Provincial Park. I attended the May 2nd open house in Sechelt. I subsequently submitted my comments to the survey questionnaire prepared by BC Parks.

The May 2nd open house was tightly scripted and lacked meaningful dialogue. A hired facilitator received questions written on Post-it notes from the public. There was no public microphone. The context of the questions was sometimes misunderstood by the BC Parks panel so the answers were off topic or inconsequential to the question. For example, I wrote down a question about possible dam and road construction being authorized, an option that was raised by the Sunshine Coast Regional District as a preferred option in a 2007 study by Dayton & Knight Consulting Engineers. The lack of a road made if infeasible to consider raising Chapman Lake dam as a park permit is required to build one. I was looking for the panel to address that specific issue in light of any possible re-designation option but the panel completely misunderstood the point of the question and did not elaborate adequately. Often, the panel resorted to reading out loud from the park master plan in response to questions. The delivery was wooden. Lots of backpedaling was evident as the public repeatedly came round to the concern that the status quo was not an option, which led to rambling, pedantic explanations that all options were on the table but that BC Parks would recommend one of the three re-designation options. It was a farce, in my opinion and poorly planned. The public interest was ill-served.

It is a basic principal of surveys that you ask all survey participants the same set of questions. BC Parks held two open houses on the Sunshine Coast and gave out a printed questionnaire to attendees. For those who were unable to attend, BC Parks directed them to an online questionnaire. The printed and online questionnaires are substantially different. Different questions were asked.

The printed version itemized three re-designation options plus an additional, unnumbered option to preserve the park as is—the status quo. In contrast, the online version only asks the respondent for thoughts on three re-designation options without itemizing what those options are and neglecting to mention the status quo as an option. The online version also did not invite for comments on the status quo.

The printed version includes check boxes by which a preferred option is selected—one of the three numbered options plus the status quo option. Selection is an unambiguous yes or no. The online version does not allow for selection of an option unambiguously. There is no clear yes or no question.

A statistician would say the survey is invalid. Not only are there two different sets of questions but the online version is clearly biased against the status quo. The survey is worthless.

The printed open house comment form can be viewed here: Tetrahedron Open House Comment Form (2018-05-02)

The online comment form can be viewed here: Tetrahedron Online Comment Form (2018-05-02)

If you think about it, the lack of an open house in Metro Vancouver is troubling enough. Tetrahedron Park, due to its hut system and proximity to the large Metro population makes it a feasible and attractive overnight destination for Metro residents. Many Metro residents are strong supporters of the status quo option. They are more likely to fill out the online questionnaire since attending an open house on the Sunshine Coast is costly and takes up a full day including travel on the ferry. Those submitting the online questionnaire are less likely to know that the status quo is an option because it was not presented as an option. Metro residents would be unduly influenced by the bias on the questionnaire towards the re-designation options.

The integrity of the entire process is brought into disrepute by the unscientific survey developed by BC Parks. Whether or not the bias and errors in methodology are intentional or not, there is no choice but to disregard the worthless survey results and start the entire consultation process over again from the beginning. There can be no legitimate decision reached from such a tainted process.

However, I would rather suggest that the Minister use provisions in the Water Sustainability Act of B.C., enacted in 2016, to start a Water Sustainability Plan for the Sunshine Coast. It deeply troubles me that the SCRD has not properly balanced growth with provision of adequate water supply and infrastructure. It has allowed growth and demand to exceed water supply capacity. Poor planning by the regional district led to the current debacle. It is not the ecological integrity of Tetrahedron Provincial Park that should be at risk because of it. The SCRD took a politically expedient path of least resistance in asking the Minister for approval of the Chapman Lake water supply expansion project. It is a divisive and environmentally unsustainable project. I request that the Minister cancel the public consultation process, discard the survey as worthless and begin looking holistically at the Sunshine Coast region's water supply in the context of current and future needs of the Sunshine Coast putting ecological integrity and wild salmon as foremost principals of a water sustainability plan.

Paul Kubik
co-founder Backcountry BC

Website: https://backcountrybc.ca

Facebook: https://www.facebook.com/groups/backcountrybc/

cc: Jim Standen, Assistant Deputy Minister, BC Parks and Conservation Officer Service Division