Created: 27 February 2019

I’m pleased to announce that, in a late afternoon phone call yesterday, I was advised by senior Ministry of Environment staff that Minster Heyman had in fact decided on the future of Tetrahedron Provincial Park.

To quote the press release, “…the minister… evaluated the Chapman Lake expansion project and after careful consideration, is not prepared to move forward with a park boundary amendment… As a result, the Sunshine Coast regional District’s proposed expansion of the community water supply system infrastructure in the park cannot proceed.”

Read the full article on the FMCBC's Website here:  https://mountainclubs.org/minister-george-heyman-decides-the-fate-of-tetrahedron-provincial-park/?fbclid=IwAR1T-W6J3as2z0jQ2MHgxsLQMMxAujv5mmHjxtzJ4DAut1Vc5D83S0W4keg

Press release is here: https://news.gov.bc.ca/releases/2019ENV0006-000185#
News article here: https://www.coastreporter.net/news/local-news/province-rejects-tetrahedron-park-boundary-adjustment-1.23627350

Created: 05 June 2018

Created: 03 June 2018

I spoke with a statistician friend of mine today about the Tetrahedron Provincial Park survey. The survey was prepared by BC Parks to gauge public support for three options to enable additional water extraction beyond what is currently allowed in the Class A provincial park. The options would re-designate the park as a conservancy or protected area with lesser protection. Thee designations would allow development of additional water infrastructure and perhaps ancillary infrastructure and development such as dams, logging and roads, even. The terms of what is allowed are determined by the Minister of Environment or delegates as guided by the Protected Areas of British Columbia Act.

The three lesser protection options are:

1. Option 1: Re-designate the entire park to a protected area.
2. Option 2: Re-designate a portion of the park to a protected area, presumably Chapman and Edwards lakes, Chapman Creek etc. with the remaining area left as Class A park.
3. Option 3: Re-designate the entire park as a conservancy.

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 the three options above 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 the 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 checkboxes by which a preferred option is selected—one of the three numbered options above 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 not a clear yes or no question. The tone is different. The first two questions are somewhat problematic. In answering, the respondent would enable the survey analyst to assess the respondent's depth of knowledge of the issues. The fact the same questions do not appear on the printed version is concerning.

Both versions contain an optional contact information section. However, the printed version would more than likely originate from a Sunshine Coast resident. But, by the response to the first question in the online version, the survey analyst would be able to make a reasonably accurate guess as to where the respondent lived, be it on the Sunshine Coast or elsewhere. It could be indicative of geographic profiling that could be used by an analyst to bolster or discount certain survey responses based on where the respondent is imputed to live. For example, an analyst may choose to boost responses from the Sunshine Coast and discount responses from Metro Vancouver.

According to the statistician, the survey is invalid. Not only are there two different sets of questions but the online version is clearly biased against the status quo. Even someone with only rudimentary knowledge of survey techniques would understand there is bias and 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.

Created: 02 May 2018

Reference:  315780

May 2, 2018

Paul Kubik

Dear Mr. Kubik:

Thank you for your email of April 29, 2018, regarding the proposed changes to Tetrahedron Provincial Park.

Let me begin by acknowledging and thanking you for your strong commitment to Tetrahedron Park as well as the broader BC Parks system. You clearly care deeply about BC’s natural spaces. With respect to Tetrahedron Park, it may be helpful to summarise the history of this particular park and the associated management plan for the park (the Management Plan) as this is germane to the current issues around the Sunshine Coast Regional District’s (SCRD) domestic water supply.

A park management plan is a document that outlines the vision and direction for a protected area. This will include direction on the types, location and threshold of uses and activities appropriate within different parts of a protected area including appropriate levels of visitor use and facility development. Management plans are the result of a well-established management planning process that see plans developed with input from First Nations, local governments, the public and other interest groups. 

Tetrahedron Park was established in 1995 to protect the integrity of the SCRD’s community watershed and preserve the significant wilderness, natural and recreational values of the area. As I am sure you are aware, the Chapman Lake watershed is a managed system, with the regional district having built dams on Chapman Lake in 1978 and Edwards Lake in 1991 to allow for additional storage. In recognition of the historic importance of the Chapman Lake watershed as a domestic water supply, the 1997 Tetrahedron Park Management Plan emphasizes the ongoing use of the watershed for domestic water and restricts recreational use to only limited camping and backcountry recreation. For example, the Management Plan identifies the “roles of Tetrahedron Provincial Park are to maintain and enhance the area’s water quality and community watersheds for Sunshine Coast residents and preserve its wilderness characteristics by offering limited backcountry recreation opportunities.” The Management Plan also states: “Government, upon park designation, made a commitment to allow for continued management and enhancement of the Chapman/Gray Creek watersheds as future community water supply sources for the Sunshine Coast residents. However, the Park Act does not allow for improvements to existing watershed infrastructure in the park, and new methods of land designation must be reviewed in order to permit this type of non-conforming use with Tetrahedron Provincial Park.”

In response to the significant droughts in 2015 and 2017, the SCRD has developed a long-term drinking water supply strategy which includes the implementation of demand management and the development of several longer-term water supply options as well as enhancements to the Chapman Lake infrastructure. In support of their plan, SCRD has submitted an application to BC Parks for authorization to install permanent piping in Chapman Lake and increase the allowable drawdown of the lake. If the permanent works are to be allowed, redesignation of part of or the entire park to another protection designation will be needed, which requires an Act of the Legislature. While there are some in the community who may take issue with the decision of the SCRD to pursue the request, BC Parks is not in a position to revisit or question the decisions of the duly elected board of the regional district.

BC Parks initiation of the process prescribed in the Management Plan should not be interpreted as BC Parks support for changes to Tetrahedron Park, but rather a matter of adhering to the commitments made at the time the park was established and reiterated in the Management Plan.  BC Parks has the same level of commitment to Tetrahedron Park as we do to any other park or protected area in our system and will strive to limit any impacts to the greatest extent possible. At the same time, the Ministry is committed to ensuring that the residents of the Sunshine Coast have access to a safe and adequate water supply. In the long-term, BC Parks expects to see the regional district develop out-of-park options that will contribute to sustaining the long-term water supply for the community and that will reduce the reliance on Chapman Creek as a water supply.

In seeking out a designation option to enable the currently proposed works, BC Parks would not support any option that would see a reduction in the overall area under protection. What would be required is a full or partial redesignation to another protected area status. Through redesignation BC Parks will be able to issue the necessary permits while ensuring that there is no overall loss of protected area and be able to manage the redesignated area consistent with the management of the current Tetrahedron Park. In order to further safeguard Chapman Lake, BC Parks will ensure that permit conditions restrict the use of any additional capacity to limited emergency use and that other out of park solutions to reduce future dependence on Chapman Lake water are developed.

As identified by the Park Management Plan, BC Parks is preparing to initiate a 30 day public consultation process, the intent of which will be to solicit public input on redesignation options for consideration by the Province. The consultation process will “kick off” with a Public Open House on the evening of May 2nd followed by an open comment period, with written comments welcomed both directly and via the BC Parks website. A second Open House is being planned for later in May to ensure that all voices have an opportunity to be heard. Unfortunately, there is an impression in the public that there are only two options to be considered when in fact any and all suggestions for options consistent with the Park Act, the Tetrahedron Park Management Plan, and the protection of public health and park values are encouraged. Feedback from the consultation will provide a clearer indication of the best options moving forward.

Thank you again for writing to express your concerns. I hope that you will participate in the upcoming consultation and if you have any further questions or concerns, please feel free to write me again.

Sincerely,

Jim Standen

Assistant Deputy Minister

From: Paul Kubik
Sent: Sunday, April 29, 2018 12:17 PM
To: Heyman.MLA, George LASS:EX; Standen, Jim ENV:EX; Minister, ENV ENV:EX
Subject: 315780 Tetrahedron Provincial Park Public Open House in Sechelt

April 29, 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 Public Open House in Sechelt

I am protesting the sham process to engage public opinion on the proposed deletion of Tetrahedron Provincial Park as a Class A park or the alternative option which is the gutting of the park by removing Chapman and Edwards lakes. I call it a sham process because (1) there is no option to retain the park as is, (2) the cowardly way in which BC Parks has attempted to minimize public involvement. It strongly suggests that Minister Heyman and his leading bureaucrat, Mr. Jim Standen have already made a decision to accede to the pressure exerted by the Sunshine Coast Regional District to declassify Tetrahedron as a Class A park. It is shameful abdication of the duty for comprehensive public consultation and a scandalous betrayal of the public trust.

Mr. Standen disingenuously says it is a misunderstanding that lands would be deleted from Tetrahedron. Rather, they would be "re-designated" but under the Environment and Land Use Act as a "protected area." That is sophistry on Mr. Standen's part. If it is an equivalent designation then why have Class A provincial parks? The Environment and Land Use Act allows all manner of resource development whereas the Park Act doesn't. Perhaps Mr. Standen is misleading the public at the behest of the NDP government. The government realizes it is a potentially damaging and inflammatory issue that conflicts with the green credentials it tries to cloak itself in and hopes to quickly sweep the issue under the rug before there is public reaction.

I would suggest that the Minister has been briefed by the SCRD on the proposed benefits of its proposal and been given assurance that the environmental damage is acceptable. Myself and others totally disagree. The SCRD has embarked on environmental misadventure with its proposal. I would even venture the case that your actions in this matter will eventually lead to the roading and logging of Tetrahedron and its old growth forests. I bring to your attention the plan prepared by Dayton & Knight Consulting Engineers in 2007, that was commissioned by the SCRD, to raise the dam on Chapman Lake by an additional four meters. The option to raise the dam was saddled with two major problems. (1) It is located in a provincial park and there would be land use and permitting issues inside a provincial park. (2) The core material and concrete for the dam would need to be imported from outside the park. Without road access, material would have to be delivered by air. The plan was updated in 2013 by AECOM Canada Ltd. Declassification of the park to a protected area would mean that a road could be built without going through a permitting process in a provincial park. The new dam would be 4 meters higher and would flood an additional 5.6 hectares of old growth forest, which would be logged.

I can assure you that will become the legacy of the BC NDP — promoting unbridled urban sprawl of luxury homes in the SCRD, contributing to the housing affordability crisis and the destruction of lakes and wild salmon.

BC Parks has given insufficient time to adequately engage public opinion. The single open house scheduled in Sechelt next week does not give Metro Vancouver residents a fair hearing. Tetrahedron is a regionally important provincial park. It is the only reason for many Metro residents to make the ferry trip to the Sunshine Coast.

BC Parks in its website says the SCRD is proposing to enhance the community water supply. It makes no mention that the first option is to remove the entire park from the park system. The second option is to gut it. It presents no third option — preservation of the park, as is without additional park use permits or water licenses.

I call on the Minister to shut down the sham process and properly engage the public, including Metro residents, and present a third option, which is the status quo.

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