No to proposed Federal Pacific Aquaculture regulations

Ed Porter, Team Leader, Regulatory Operations
Fisheries and Oceans Canada
PAR-RPA@dfo-mpo.gc.ca

Dear Mr. Ed Porter:

I am responding to the 60-day public comment opportunity on the proposed Federal Pacific Aquaculture Regulations http://www.gazette.gc.ca/cg-gc/about-sujet-eng.html (left column “Part I Notices and Proposed Regulations” Vol. 144, No. 28, page 1933).

It was brought to my attention by Ms. Alexandra Morton that the purpose of the proposed amendments is to reduce, not increase, the safeguards in place to regulate aquaculture along Canada’s Pacific coast. In particular, the proposed new regulations would provide government with the ability to grant and renew licenses without public or First Nations input nor further environmental assessments. One of the reasons given for this amendment in the Canada Gazette of December 19, 2009 is to enhance our aquaculture industry’s ability to compete on international markets. These draft regulations, I am told, ignore the International (OIE) and the Canadian Food and Health Inspection Agency standards by exempting salmon feedlots from full disease reporting.

This is so wrong on so many levels.

First, at a time when sockeye runs are collapsing (this year’s exceptional and joyfully abundant return notwithstanding), more – not less – regulation is required to ensure that the aquaculture industry does not interfere with the threatened life cycles of our beloved wild salmon.

Second, introducing regulation which is aimed at keeping the public and First Nations out of the decision making process is yet another instance of the neoliberal “privatization of the commons” agenda, resulting in massive transfer of public wealth in the hands of private interests. It is yet another attack against our society’s democratic principles.

Third, the government’s official rationale for introducing such changes (as stated in the Gazette) are extraordinarily and inexplicably short-sighted. What is the point of enhancing Canada’s potential ability to compete on international markets for, say, the next 3 or 4 years, if after that period there is no aquaculture left to compete over? The 2009 sockeye collapse and ongoing Cohen Commission are tangible proof, if needed, that the disappearance of our fisheries has ceased to be a merely theoretical threat.

In this context, such amendments make no sense at all, unless the non-stated goal is to eradicate wild salmon runs altogether as a means of establishing the fish farming industry’s monopoly over the “production” of salmon. An extravagant and outlandish conspiracy theory, no doubt! Yet, it is one which is gaining traction in the general public, as people attempt to rationalize a truly irrational set of decisions on the part of their government in recent years and months. For my part, I refuse at least for now to believe that our government could be involved in such a cynical, abject, and counter-nature plan.

Mr. Porter, I am asking you to help me restore my trust in my government’s truthful intentions. The aforementioned proposed amendments to the existing aquaculture regulations must be rejected.

Yours truly,

Ivan Doumenc

Vancouver, BC

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Fish farms - critical public input required

This urgent call from Alexandra Morton. Please pass on ASAP to your mailing lists.

In Alex's own words:

"I know it is very hard to react to everything that comes at us, so I have tried to make this easy for you. However, I can’t turn this looming disaster, it requires each and everyone of you and your friends and family. Please pass the petition to all you know."

Hello All

The federal government has released their proposed Federal Pacific Aquaculture Regulations with a sixty-day public input period.  These regulations role back the safe-guards we have in British Columbia to prevent heavy industrialization and privatization of the coast at the expense of our communities. Once these regulations pass there will be no further public input on how each salmon feedlot licence is written, how many wild fish they can take and what diseases they must report. The federal licences will be issued without First Nation or other consultation and can be expanded without an environmental assessment.  I feel there has to be enormous response or else we all lose, even the people working in the industry, because no retailer is going to want to be in possession of a seafood product authorized to “Harmfully Alter, Disrupt and Destroy” parts of the North Pacific. Oddly these regulations will not apply to the east coast of Canada, where the Minister of Fisheries resides.

There are several options for you to act by the deadline September 12:

• See my letter below/attached which interprets the proposed regs and provides a direct link to them
• write to Ed Porter who is accepting public input PAR-RPA@dfo-mpo.gc.ca
• Sign the petition http://spreadsheets.google.com/viewform?hl=en&formkey=dElVTFY0d1JqMGRYR2F6Vnp3QjEzRnc6MQ#gid=0
  

You can see my presentation on the strong correlation between disease in salmon feedlots and decline of Fraser sockeye "What's New"
http://www.sfu.ca/cstudies/science/

I know it is very hard to react to everything that comes at us, so I have tried to make this easy for you. However, I can’t turn this looming disaster, it requires each and everyone of you and your friends and family. Please pass the petition to all you know.

To stay up to date please frequent www.salmonaresacred.org I will let you know how many people have signed.  Volunteers are hosting events throughout BC this summer to link all of us together and this information will be posted. The T-shirts left from the migration are on my website www.alexandramorton.ca and proceeds go to this effort.  

The Get Out Migration brought thousands of people together, but government does not want to hear from our communities nor of our need for good health in our environment and our bodies. Clearly there needs to be more public response.  That is all that is required to fix this. I will continue to push for protection for salmon feedlot workers, as this is a government mistake and they need not bear the cost of this to our coast.

I think we will have a good Fraser sockeye run this summer and that should tell us the ocean and the river are still highly capable of feeding this coast!  This generation of sockeye has shown one of the least declines and we need to investigate why this run is good and the others have failed so badly.  If we allow government to let salmon feedlot companies hide their disease outbreaks this investigation will be incomplete.  If there is no salmon feedlot disease problem, there should be no reason for secrecy.

Hundreds of people have said “I am behind you Alex,”  but this is not working. We have to stand shoulder to shoulder, where we are all peacefully and strongly visible. This is the only way to save ourselves and our planet.  



Alexandra Morton



July 28, 2010
 
Ed Porter, Team Leader, Regulatory Operations
Fisheries and Oceans Canada
PAR-RPA@dfo-mpo.gc.ca

Dear Mr. Ed Porter:
 
I am responding to the 60-day public comment opportunity on the proposed Federal Pacific Aquaculture Regulations http://www.gazette.gc.ca/cg-gc/about-sujet-eng.html
(left column “Part I Notices and Proposed Regulations” Vol. 144, No. 28, page 1933).  
 
When BC Supreme Court ruled that the federal government must take over regulation of salmon feedlots, the intent was to bring the industry into compliance with the Constitution of Canada.  But what Stephen Harper’s Conservatives are trying to do instead is remove safeguards established by previous governments and open the door to privatizing the ocean, which is prohibited by the Canadian Constitution.
 
With his document Harper not only licences massive ecological damage, he depreciates the market value of BC feedlot salmon. No reputable retailer can afford to be seen with a seafood product raised under a licence to “harm, alter, disrupt and destroy” the ocean.  The federal licences will be issued without consultation with First Nations.
 
“Increasingly stringent international standards are driving seafood importing nations to require Canada to certify health (disease) status, not just food safety, of live aquatic animals and their products. … Canada cannot meet these standards, and is facing increasing challenges to export market access. Canada is already subject to a lesser market access than the United States, Europe ...“ http://www.gazette.gc.ca/rp-pr/p1/2009/2009-12-19/html/reg1-eng.html
 
Canadian pathologists warn against holding millions of diseased salmon in pens (Traxler et al. 1993) and the graph below demonstrates the reason. There is a strong correlation between salmon feedlot epidemics and the declining Fraser sockeye.  This must be examined, but the provincial government is stonewalling release of salmon feedlot disease records and Harper is stepping in to help.
 
These draft regulations ignore the International (OIE) and the Canadian Food and Health Inspection Agency standards by exempting salmon feedlots from full disease reporting. Harper is not only offering Norwegian companies the right to leave infected salmon in the water, he is protecting them from liability. If government and the industry are willing to throw away premium market value for disease secrecy we are warned this is a dangerous and strong priority.
 
Prime Minister Stephen Harper is also offering these Norwegian companies blanket authorization for “Harmful Alteration, Disruption or Destruction” of fish habitat (Section 35(1) Fisheries Act). This ignores the value of the oceans to communities across British Columbia. Oddly, these rules will not apply to eastern Canada, where the Minister of Fisheries resides.
 
Harper is going to legalize destruction of wild fish that become trapped in the pens, attracted by the bright lights and food in the water. There are no surplus wild fish and so this by-catch will compete with fishing quotas.  Many feedlots are in rock cod conservation areas where fishermen are not allowed, but the feedlots will continue trapping unknown amounts. This is bad management and will affect herring, sable fish, salmon, lingcod and other important wild fish.
 
The federal Conservatives are proposing salmon feedlot licences be granted and amended without environmental assessment.  This violates strong public demand for healthy coastal waters, but neatly resolves the irreconcilable issue of dumping over a ton/day/site of industrial waste into salmon habitat. These are the only feedlots that never have to shovel manure and chemical waste as it flows conveniently into public waters.  
 
It is dangerous to humanity, (risking food security, drug resistance, disease mutation) to allow feedlots to contaminate natural environments with disease. Feedlots remove all the natural disease control mechanisms and thus allow viruses to mutate, multiply and jump to new species.
 
Because Mr. Harper is proposing to remove standards designed to protect the ocean from Norwegian feedlots, retailers like COSTCO will have to decide if their mission statements honor government or their customers. Promising to “Exceed ecological standards required in every community where we do business,” is meaningless if there are no ecological standards.
 
Salmon feedlots are an “ecology of bad ideas,” struggling to control disease with drugs, corrupting the foodchain by using warm-blooded animal products, plants and fish from the southern hemisphere as feed, displacing local businesses, turning a public resource into a corporate commodity with no public access, dyeing their fish pink to resemble salmon. If jobs were the goal, the federal Conservatives and BC Liberals would be working with the BC companies developing sustainable land-based aquaculture to create a viable, world-class product. Instead Mr. Harper is proposing to change the laws of Canada to allow unchecked pollution by a 92% Norwegian-owned industry associated wild salmon declines worldwide. Wild salmon are thriving everywhere this industry does not exist (Alaska, Iceland, western Pacific, areas of BC).
 
These proposed regulations are a signpost. If this was about fish, attention would have been paid to the market value of the product. Instead it risks one of the last naturally producing salmon regions in the world for a depreciating commodity. What these draft regulations do is clear away legislation established to protect Canadians and our coast from industrialization and privatization.
 
Ed Porter, the proposed Federal Pacific Aquaculture Regulations do not protect the interests of Canadians or the world and must not be adopted.
Sincerely,
 
Alexandra Morton
 
 
The Fraser sockeye decline began at the same time government failed to cull millions of IHN virus infected feedlot salmon on the Fraser River migration routes. Government ignored federal scientists who state infected Atlantic salmon should not be permitted in pens (Traxler et al 1993). The federal government also ignored warnings from their scientists that would have saved the North Atlantic cod.  When the cod went extinct the Hibernia Oil wells appeared on the Grand Banks – the most generous food-producing area humanity will ever have was exchanged for oil.

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Avatar Grove - Part 2. Logging? What logging?

Part 1. What's with the name?

Shayn  McAskin at the Avatar Grove. 

Photo Tom Jaugelis.

After we finished inspecting the bizarre red cedar known as the 'knotty tree', most of us assumed that our job at the Avatar Grove was done for the day, and so we started our slow descent back to the logging road.

But Shayn McAskin, the Environmental Technology student of our group, was not moving. Instead, he was focusing his attention uphill. He was looking for something in the dense vegetation. There, he said after a moment, pointing to a grayish patch in the trees about 200 meters above our heads. I’m going to check that cliff to see what it's made of. You guys go ahead, I won't be long. What are you looking for? I asked. Limestone karst, he answered. I shrugged. Did we really need to embark on a nerdy geological expedition so late in the day and in this lousy weather?

Searching for limestone

But then Shayn explained. Limestone karst is potentially critical for our purpose of protecting the Avatar Grove, because logging companies are usually not permitted to clearcut a forest which lies on a limestone bedrock. Limestone reacts to water and so it weathers away very quickly once it's exposed. This can result in catastrophic soil erosion which may prevent the forest from ever growing back. It recently happened near Campbell River in an area called the Tahsish River Valley. After the forest was clearcut 10 years ago, the soil gradually washed away, and last July a wild fire turned the entire zone into a moonscape. That area is wasted, Shayn said, it will take hundreds of years for the forest to reclaim it. He added: I recently checked a geological map which indicates that a limestone karst deposit could be located right under our feet, so I hope we can find evidence of it.

Moonscape caused by limestone erosion, Tahsish River Valley.  

Photo Carol Ramsey, Canwest News Service.

After a few minutes, our little group reached the cliff. It was made of granite, not limestone. But around us, there were several yellowish boulders which Shayn immediately identified as limestone and he proceeded to take pictures of them as evidence. Well that’s cool, you've found the limestone, it's game over for the logging company, eh? I asked in excitement. I wish it were that simple, he said. Yes, there's definitely limestone here but it could have been brought down by the glacier. We'll have to establish that the bedrock itself is made of limestone. We may have to go to the top of that hill, he pointed out with his extended arm, and inspect the cutblock that’s already been harvested up there, maybe the bedrock is exposed enough for us to see the limestone. And so off we went. But the vegetation was getting increasingly dense as we climbed, and time was running out. The forest was resisting our intrusion. After an hour or so of hardcore bushwhacking, we finally spotted a more accessible area that we could use as a pathway to the top of the hill. We noted its location and planned to return in a couple weekends to continue our inspection.

'Local kids just fooling around'

Back in Port Renfrew, we stopped at a local coffee shop to warm ourselves a little. On its wall, there was an anonymous home-made leaflet which stated “Avatar Grove = Ecofraud”. The leaflet claimed that the grove had no environmental value, that many other sections of rainforest in the region were far more worthy of salvation, and that environmentalist Ken Wu (the guy who had initially brought the Avatar Grove into the media spotlight) had done nothing in the past to stop logging in the region. The leaflet then descended into profanity and personal attacks against Wu which I cannot reprint here and called upon local residents to “save your money” by not supporting Wu’s group.

What caught my attention about this pretty incoherent rant on the wall was not so much what was written in it, but rather over it – a hand-written inscription which had probably been added by someone else than its anonymous author and which read: “No Cutting Permit even Applied for, Save Avatar From?” The implication here was that there was no identifiable logging threat against the Avatar Grove and that environmentalists had therefore manufactured a nonexistent crisis. That same opinion was voiced by a local old man who went by the name of Lonesome Dave and was sitting at a table in the coffee shop. Those environmentalists are roaming around looking for causes and they have found one at the Avatar Grove, he commented. But the problem, he added, is that there is absolutely nothing happening here, this is a typical case of a Mouse that Roared.

I told him about the flagging tape which I had seen all over the Grove, and I pointed out that people don’t usually flag an area of old growth forest without a purpose. But Lonesome Dave responded: How do you even know that a logging company did that? The tape may have been placed by hiking enthusiasts opening a new trail, or local kids just fooling around. A few yards of tape don’t prove anything, he concluded.

But the flagging tape that I had seen up there had clearly been placed in a deliberate fashion, so I did not buy old Dave’s 'random act' theory. Later, Shayn explained to me that whoever did that had followed to the letter the guidelines provided by the BC Ministry of Forests, such as axe blazes exactly 10 cm wide by 30 cm long, delimitation of riparian zones, etc. Definitely a professional job, he concluded. Which left me scratching my head over why the locals would be in such denial about a rather self-evident act.

Cutting permit

So, logging or no logging? Back home, I decided to get to the bottom of it and I called the logging company which owns the tree farming license around Port Renfrew. Yes our people recently flagged and surveyed the Avatar Grove, John Pichugin, Manager of Engineering at Teal-Jones, told me. So are you planning to log it? I asked. We are looking at it, but at this point I cannot tell you if we're going to harvest or not, he responded. Have you applied for a cutting permit with the Ministry of Forests? No we have not. Do you know if and when you plan to apply? No I do not. So does it mean that the area is safe for now, say at least until the end of 2010? No I cannot tell you that.

Clearly, I was not getting anywhere with that line of questioning. So I tried something else. Are you aware that there is a possibility of limestone karst deposits in this area? Silence. I almost heard the gulp on the other side. Then after a brief moment, he responded: Personally I am not aware of that, but karst is definitely something that in general we have to take into account in our logging operations. How do you go about performing karst studies? I asked. We have engineers trained to look for karst, it's a very formal process. Have studies begun yet at this specific site? I don't know, I cannot say. Okay then, I asked, is there someone else in your company that would be able to answer that for me?

 Potential limestone karst bedrock at Avatar Grove (in orange). Source: FORREX

At that point, John Pichugin changed his tactic. I need to be careful about the information that I release to the public, he said, so I need to know more about who you are and what are your motivations. After I finished telling him all he cared to know about me, he proceeded to lecture me. We want to engage the public, he said, but we are also running a business. Society has determined that logging needs to take place here. As a society, we all benefit from a high standard of living. Where do we get the tax dollars to pay for our hospital beds? Did you know that 40,000 hectares of old growth forest are protected in the area surrounding our tree farming license? etc.

I swiftly got him back on topic. How do I stay informed about future logging developments at the Avatar Grove? I asked. Well, you can call me, he said. That’s it? Just call you? Do you mean to say that there are no processes in place to keep the public informed? No, was the flat answer. Teal-Jones already went through the Forest Stewardship process in 2006. Back then, the public had an opportunity to voice any concerns. At this stage of the game, we are no longer required to consult with the public. Look, he said, we just follow the legislation here. Perhaps you want to take this up with the government.

So I did. I called Vivian Thomas, the media spokesperson for the BC Ministry of Forests. But before I did that, I took some time to study the documentation posted on the Teal-Jones website regarding the 2006 Forest Stewardship Plan that they signed with the Ministry. And I stumbled upon a map which indicated that, back then, some portions of the Avatar Grove had been marked as “draft old growth forest management areas”.

Old growth forest management areas

Vivian Thomas confirmed to me that cutting permits are granted by the Ministry to the logging company without any input from the public. Essentially, the Forest Stewardship Plan is a blanket agreement for an entire tree farm license, which includes a 60-day public comment period. After that, implementation details take place behind closed doors. In particular, there is no process to keep the public informed about this or that specific cutting permit.

What about old growth forest management areas? I asked. Oh, those areas have been set aside for protection, they cannot be logged, she said. But, I interjected, some sections of the Avatar Grove were marked in the 2006 Forest Stewardship Plan as “draft old growth forest management areas”. How, then, can that particular grove even be considered for logging? “Draft” sometimes means that one area can be subsequently substituted for another, she explained. So for example, for each area that will receive actual protection, you may decide to have 3 or more areas marked as “draft” in the initial Plan, allowing for flexibility when you get to the actual cutting stage. Maybe that’s what’s happening in this specific circumstance, she ventured.

But doesn't that change everything? I asked. It could mean that when people got an opportunity to comment on the Forest Stewardship Plan back in 2006, they did not really know what they were commenting upon. For example, someone may have agreed to the Plan based on the assumption that the Avatar Grove would be untouched. Also, if this is true, then the map gives the false impression that more forest is being protected than there really is. I understand the need for some amount of flexibility, I added. But if an area initially marked as protected is later being considered for logging through a cutting permit application, shouldn't the public be involved in the decision-making process involved in such a sweeping change to the initial Plan?

I’m going to have to get back to you on that one, Vivian responded.

Unanswered questions

Obviously with my two lonesome phone calls and casual research, I've barely scratched the surface in this matter. But already, I have harvested an unexpected amount of rats. Let’s summarize:

• Shayn McAskin has discovered a geological map which uses Ministry of Forests data to locate a potential limestone karst bedrock right under the Avatar Grove. A superficial survey of the area confirmed the presence of limestone rocks. When I addressed that concern with a representative of the logging company, he did not confirm nor deny.
• When asked about the recent flagging at the Avatar Grove, the company representative acknowledged that indeed his company did that, but he did not confirm or deny that the area has indeed been slated for logging.
• Maps provided by the logging company indicate that some sections of the Avatar Grove have been marked as “draft old growth forest management areas”, an appellation which, according to a representative of the Ministry of Forests, provides full protection to those particular sections.
• When asked whether a logging company should be allowed to clearcut a “draft old growth forest management area” without any further public consultation, the Ministry of Forests representative requested a time out, so she could consult with her hierarchy on what response to provide.

Many unanswered questions here! I am no expert, just an average joe doe from the public asking dumb questions to smart people, but my instinct tells me that well organized environmental groups bent on saving this area of old growth forest - and a few others while they're at it - may potentially have some very good cards to play.

Obviously, to be continued.

 .

Avatar Grove - Part 1. What's with the name?

Avatar Grove, British Columbia. Photo TJ Watt.

One morning this past winter, environmental activist Ken Wu went for a hike in an exceptional tract of old growth forest which he and photographer TJ Watt had recently discovered near Port Renfrew, off the rugged west coast of Vancouver Island. That patch of untouched forest, made of approximately one hundred giant red cedar and douglas fir trees, is deep into logging territory, and so Ken had always known that it was under the theoretical threat of being cut to the ground.

When he arrived on that day, a nasty surprise awaited him. The area was covered in flagging tape and many of the giant trees were marked with pink and blue spray paint. That patch of forest had been thoroughly surveyed by someone. It was a recent job, since only a few weeks back the area was still in its pre-industrial virgin state with no visible signs of human disturbance whatsoever.

When Victoria-based social and environmental activist Zoe Blunt heard about that situation, she activated her group, the Forest Action Network. It was decided to map the area using GPS, investigate who owned the tree farm license for that zone, communicate with local communities and First Nations, and invite volunteers to come and discover this exceptional swath of old growth forest, which Ken and TJ had renamed "Avatar Grove".

When I first heard that name, I cringed. Avatar Grove? A catchy name, no doubt. But what happens when the hysteria around James Cameron's movie recedes? Shouldn't such an exceptional part of our natural heritage stand on its own feet rather than rely on Hollywood's hype du jour? Then, I reasoned that time appears to be running out for this particular patch of old growth forest and so, I guess - whatever works to save it from the feller bunchers. I decided to go and see the Grove for myself, and so I joined one of Zoe Blunt's volunteer expeditions.

As we left the logging road to enter the forest on a recent rainy Sunday, it struck me right away that this place stood out of the ordinary. No trail. We had to use a small creek bed to enter the zone. The first 50 meters were almost vertical, so I had to cling to whatever branches and tree roots were available to hoist myself clumsily into the grove. After a few minutes of being slapped in the face by low-lying branches and swallowing spider webs, I finally managed to reach a somewhat flatter section where I was able to stand up straight. A quick inspection of myself revealed that I was soaked in rainwater from head to toe. This forest didn't waste any time in whipping me into shape, I thought, a little annoyed.

My senses quickly adjusted to my new environment. The grove I was standing in was exceptional indeed. A completely untouched old-growth temperate rainforest. Massive 500 year-old giants surrounded by many smaller trees in various stages of growth, some of them not much older than myself, others starting to pile up the centuries. The light was dimmed by the dense canopy. The rain, which was coming down pretty hard on the road, only reached us here as a light powdery mist. I was immediately intoxicated by the primal smell of the wet forest. The floor was made of an inextricable chaos of fallen trunks, ferns, branches, moss, mushrooms and lichens, with baby hemlocks growing out of the flanks of their dead ancestors and striving to reach the sky some day. It was a delicate balance of the very large and the very small, a diverse society drawing its collective strength from the multiple relations of its various dead and living members - an ecosystem, in a word.

The pink flagging tape which I had been told about was indeed prevalent and stood out like a sore thumb in this world of brown and green. Every 50 meters or so, a new flag or spray of paint emerged out of the vegetation to construct an elaborate network of signals which were gibberish to us, but no doubt perfectly legible to a trained professional eye. Our mood, looking at all this flagging tape, was that of wild game which hear hunters approaching in the distance and sense the imminent danger, but cannot comprehend quite yet what's about to hit them.

 Blue spray on a red cedar, Avatar Grove. Photo TJ Watt.

Our group of eight hikers was here to find a specific tree in the forest, a bizarrely deformed red cedar nicknamed "the knotty tree" which we needed to geolocate using the GPS device that one of us was carrying. That tree, I was told, had grown some enormous lumps around its base - or burls in technical terms - as a result of a non-lethal bacterial infection. Allegedly, this was Canada's largest "burly" tree, and as such it needed to be mapped with precision to increase its future chances of being preserved.

As we looked for our freak-of-a-tree, we rode the forest's three-dimensional maze, climbing over, crawling under, and walking along fallen trunks suspended in mid air. I silently thanked the sky for this rainy day. The forest is no doubt magnificent under good weather, but it fully reveals itself only in the rain. I sat on a fallen tree for a few moments, and suddenly I realized with amazement what I was sitting on. A forest within the forest. On the dead trunk, an army of small fern-like plants were springing from a carpet of lichen and struggling for existence, reproducing in small scale the battle of giants taking place over our heads. Each plant had captured a drop of rain in its bizarrely curled stem, and that drop was shining like a gem with an almost unnatural bright translucid yellow color which I initially mistook for tree sap. Yet as soon as I picked one of those drops with my finger, it immediately lost its color and turned back into what it was - rainwater.

At my feet, another miniature ecosystem was asserting its right to existence. This one was mostly made of delicate two to three-inch long bright orange plants which I couldn't decide whether they looked more like mushrooms or flowers. I thought that if I touched one of them, it would suddenly retract, but I did not dare to try. Hmm. It appears that I am allowing myself to be penetrated by the Avatareness of this place, I noted with embarrassment. While I was lost in the contemplation of this small world at my feet, one of my travel companions passed in front of me. Because of the position of the fallen trees, she had no choice but to walk through the field of orange mushroomy flowers (or were they flowery mushrooms?) in which my mind was so deeply immersed. She tiptoed very carefully through them, and at one point I heard her mutter to the attention of the forest "I am sorry". Sorry for stepping on some flowers? Okay... Obviously, I was not the only one going native at the Avatar Grove.

Then, on a gentle slope, we finally found it: our knotty tree. And what a tree it was. It looked like nothing I had seen before, and like everything at the same time, since one could read all kinds of faces, shapes and objects in its bizarre intricate knots. It was both grotesquely ugly, and absolutely sublime in its beauty. I was bewildered. What to make of it!?

The knotty tree, Avatar Grove. Photo TJ Watt.

Shayn, an Environmental Technology student at Camosun College who was operating the GPS device, went to work to obtain the knotty tree's coordinates. No luck. Only one satellite was above our heads, and the signal was too weak. Too much cloud cover and natural obstacles. We're going to need a stronger GPS unit, he concluded, one that carries a larger antenna. I'll borrow one from my school and bring it along next weekend.

For my part, I didn't worry too much about satellites and geo-coordinates. I was simply enjoying the moment and the place, in the weird company of the knotted tree. What's in a name? I thought. Whatever people decide to attach to it, I guess. This place is so beyond its 'Avatar Grove' name. For one thing, it's real. And so are the forces threatening it. It's a more subtle world, too, than the digital one being projected in our cities' multiplexes. You actually had to work a little, you had to pay attention, before its ineffable beauty would set itself in motion. But if the name helps people relate to the place, if it's actually going to facilitate their entry as external witnesses and allies into its delicate eco-society, well then hell yes, Avatar Grove it is. Because one thing that this place shares in full with its virtual counterpart, is that it is worth fighting for.

Next: Avatar Grove Part 2. Logging? What logging?

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Boreal forest agreement - It's even worse than it looked

What were you thinking, dude?
The David Suzuki Foundation is a signatory to the Canadian Boreal Forest Agreement.
Photo johnwmacdonald.com.

A few days ago, I reported here on the questionable agreement signed by environmental NGOs and logging companies over the "joint management" of the Canadian boreal forest.

As it turns out, this agreement is considerably worse than I had initially realized.

One aspect of the agreement which has received particular media attention in recent days is the claim that 29 million hectares of caribou habitat will be preserved from logging for the next three years until a management plan is finalized. "An area the size of New Zealand!" ForestEthics, an NGO which is signatory to the agreement, emphatically proclaimed on its website.

But the Wilderness Committee has investigated that claim and the results are bleak. A close examination of the agreement reveals that this 29 million hectare figure is bogus. Indeed, only 2.5% of that total area (or about 760,000 hectares) had actually been slated for logging prior to the agreement.

Furthermore, the Wilderness Committee reveals that only a tiny fraction of those 760,000 hectares are to be preserved under the agreement, i.e. 72,000 hectares. The other 685,000 hectares - 9 times the amount of the land being allegedly "protected" - will be logged effective immediately.

In addition, the "protection" is really only a 2-year moratorium, meaning that the preserved 72,000 hectares can be logged out of existence as early as April 2012 if a joint management plan is not agreed upon. But as I made clear in my previous post, the agreement is structured in such a way as to give logging companies a virtual monopoly of bargaining power in the upcoming negotiations. The management plan, if it even materializes, will be a mere emanation of corporate will. If those 72,000 hectares are still in the deal two years from now, the free lunch is on me.

But there's more. The Wilderness Committee also found that, of those 72,000 hectares, 40,000 are coming out of the tenure of a logging corporation named Tolko which had already agreed not to log that tenure several years ago, pursuant to a separate agreement with the province of Manitoba.

Once the Wilderness Committee had finished crunching the numbers, 32,000 hectares - not 29 million! - emerged as the actual area of forest that this agreement will "save" from logging companies for the next 2 years.

And that, ladies and gentlemen, is how you do it. Whenever you need to clearcut 700,000 hectares of pristine boreal forest, announce that you're going to save 30 million hectares of it (make it 29 so it looks more real), get some sold-out rotten NGOs on board, and then sit back and listen to the oohs and aahs and bravos emanating from the official corporate media outlets.

The Wilderness Committee has masterfully exposed this boreal forest agreement for what it is: a despicable phony greenwash masquerade which will considerably accelerate - not reduce - the destruction of caribou habitat over the next couple years. A farce of an agreement really, in which some of this country's most reputable environmental NGOs have cynically chosen to play a deceptive and destructive, as well as critically important role - all for a fistful of dollars.

Once again, I am posting FYI and for your action the list of environmental NGOs which have chosen to associate their names to this nauseating deal:

Canadian Parks and Wilderness Society
Canopy
David Suzuki Foundation
ForestEthics
Greenpeace
The Nature Conservancy
Pew Environment Group International Boreal Conservation Campaign
Ivey Foundation
Canadian Boreal Initiative / Ducks Unlimited

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Environmental NGOs sign lousy forest agreement – But why?

Camping in Canada's boreal forest. Photo A Little Mo'.

On May 18, leading environmental NGOs and logging companies announced the Canadian Boreal Forest Agreement. This agreement may appear as a genuine attempt by environmentalists and loggers to cooperate over the future of boreal forests. Sadly, a closer inspection reveals an agreement which is very detrimental to the forest. But why would ENGOs want to get involved in such a bad deal?

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On May 18, some of Canada’s most prominent environmental NGOs and leading logging companies announced the signature of the Canadian Boreal Forest Agreement. On the surface, this agreement is a genuine attempt to move beyond the decades-long warfare which has opposed environmentalists and loggers over the fate of Canada's northern forests.

“The shared challenge”, according to a joint statement released by the signatory ENGOs and logging companies, “is to address sometimes conflicting social, economic, and environmental imperatives” by having “both parties committed to working together in the marketplace and on the ground to support governments in the realization of a stronger, more competitive forestry industry and a better protected, more sustainably managed Boreal Forest.”

I had to read that statement several times before I was able to reach its meaning, but once I did, it struck me as being rather contradictory. A more competitive forestry industry and a better protected forest? What does it mean, and how is it done? Unfortunately the details of the signed agreement were kept secret, and the official information released to the public was too vague and sanitized to provide much assistance.

Leaked agreement

But thankfully, on the same day that the agreement was announced, Vancouver Media Co-op published a leaked draft of the actual agreement. The document, dated May 12, is a 39-page Memorandum of Understanding marked Confidential and co-signed by pretty much every environmental household name in Canada, such as the David Suzuki Foundation, Greenpeace, ForestEthics, CPAWS, the Nature Conservancy, Pew Environment Group, etc., as well as most logging companies which are still left standing in this lousy economy.

The leaked agreement's preamble confirms that the parties are seeking to reconcile two contradictory goals – the protection of the boreal forest, and its commercial logging. In its Whereas section, the agreement states that Canada's boreal forests are “ecologically significant” in a “local, regional, national, and global context”, as well as “economically significant” in a “local, regional, national, and international context”. The symmetry of the two statements is clearly meant to convey the notion that a complete equality of rights exists between those two colliding worldviews. Such balanced language is used throughout the rest of the agreement, reinforcing the subtext that ENGOs and logging companies are equal partners here, working cooperatively in the best interest of the parties involved as well as the forest itself.

The form of the agreement is definitely egalitarian, but sadly the same cannot be said about its substance. In particular, section 28 reveals the true nature of the deal. In it, we learn that whenever a signatory logging company sells its logging rights over a section of the forest – a tenure – to a third party, “such tenure will no longer fall within the scope of the [agreement]”. In other words, any restrictions to logging-as-usual that this agreement may manage to secure over a given tenure are automatically voided as soon as that tenure is being transferred from Company A to Company B. This is a devastating loophole for at least three reasons:

Unequal terms

• 1. This section establishes that private property has absolute precedence over the protection of the forest’s biodiversity. The underlying contradiction between the rights of the forest and that of the market, the decades-long conflict between environmentalists and loggers are indeed brought to a resolution here, but under the following unequal terms: markets have rights, forests do not. Indeed, all it takes to cancel the hard-fought conservation measures obtained by environmentalists over time is the effectuation of the most basic and mundane transaction in a market economy, the sale of a land title.

• 2. The entire biodiversity protection scheme envisioned by the environmental groups is thrown into irrelevance by this section 28. Indeed, according to the agreement, one of the strategic goals championed by the signatory ENGOs is “the completion of a network of protected areas”, in other terms the constitution of a coherent regional biodiversity management plan involving key areas such as species migration corridors, etc. But as soon as Company A decides to sell one of its tenures to Company B, the entire coherence of the management plan falls apart. What is the value, for example, of a migration corridor if one of its central sections has been sold to a third party and subsequently clearcut to the ground?

• 3. Thanks to this fateful clause 28, logging companies have secured the bulk of bargaining power for future negotiations over the joint management of the boreal forest. Said bluntly, they can bully and blackmail their ENGO partners as they see fit. Oh, you don’t like the amendments to the agreement that I am introducing today? says Company A to its enviro friends. Well okay then, I want out of this deal and so I’m selling my tenure to Company B, and oh – that company does not give a damn about our little forest management pet project here, so good luck with them. Faced with such power-play tactics, ENGOs will have little choice but to accept the demands emanating from logging companies.

Toothless dragon

But this is where it becomes interesting. In exchange for the logging companies’ benevolence for joining the agreement, the signatory ENGOs have contractually agreed to lay down their arms forever. As stated in the agreement’s strategic goal number 6, “ENGOs will suspend all activities” that seek to discourage customers from purchasing the products of the signatory logging companies “effective immediately”. Even though the conservation efforts under the agreement have not even been planned in much detail let alone implemented on the ground, NGOs have already taken a solemn pledge: from this day on, no more boycotting campaigns, no more direct action to alert consumers over “partner” logging companies’ unsustainable practices.

This part of the agreement is particularly targeted at Greenpeace, which has made consumer product boycotting campaigns an effective and feared instrument to force logging companies to the negotiation table. Well, no more. The Greenpeace dragon has lost its teeth. I was personally disheartened to learn that Richard Brooks, a Greenpeace forest campaigner who had managed the anti-Kleenex campaign in Vancouver a few years ago and with whom I had done some volunteer work on that campaign, is now one of the official spokespeople publicly championing the new agreement. Times have changed.

Adding insult to injury, strategic goal number 6 further states that “ENGOs will not, in any of their communications, cite forestry operations of [partner logging companies] as negative examples of certified practices”. In other terms, signatory environmental groups forego not only their freedom of action, but also their freedom of speech. They are contractually agreeing to refrain from criticizing their corporate partners even if their logging practices in the boreal forest do not actually meet the environmental standards envisioned in the agreement. If, for example, the logging companies use their position of force to subsequently water down the plan’s implementation, well tough luck. NGOs are still not going to bad mouth them.

Not only that, but whenever third party environmental groups who are not signatories to the agreement will do (what is after all) their job of denouncing bad logging practices in the boreal forest, the agreement expressly states that the signatory ENGOs are to publicly oppose those bad-ass groups by using any appropriate method, such as “responding publicly” to their attacks through campaigns “in the marketplace” or lobbying efforts “in political circles”.

Signatory ENGOs are also contractually committing themselves to – get this – “securing market place recognition” for the products sold by partner companies by using their “advocacy work and other communications” to “expressly acknowledge forestry operations of [partner logging companies] as positive examples of boreal forest management”. Since when has it become the mandate of environmental organizations to commit their limited resources to advertizing forestry products to the individual consumers shopping at Rona and Home Depot? Well, it appears, since May 19.

Let’s recap the type of agreement that we are dealing with here:

• Domination of market logic over environmental concerns;
• A vulnerable biodiversity management plan susceptible to being sabotaged by individual logging companies;
• Corporations ideally positioned to force ENGOs into accepting their future demands;
• ENGOs contractually renouncing their highly effective consumer boycotting tactics and, which is even more troubling, giving up their freedom of speech;
• ENGOs committing themselves to actively fighting non-signatory third party NGOs which may object to bad forestry practices;
• ENGOs actively promoting and advertizing partner company products to consumers.

Why do it?

Why would ENGOs even want to be involved in such a rotten deal? The short answer is, for the money.  I have already referred here to a groundbreaking  PBS/Frontline documentary called “The Money Tree” which dissects how large transnational corporations are using carbon offsets to privatize large swaths of the Amazon rainforest through complex financial montages, with the active complicity of large ENGOs. The mechanics of such schemes are simple to understand. In the case reported by Frontline, three large corporations – GM, Chevron and American Electric Power – invest in 50,000 acres of rainforest as a way to offset their carbon emissions and improve their public image. To that effect, they make a $20 million donation to American NGO Nature Conservancy who works with a Brazilian environmental group to purchase the land and manage the project on behalf of the companies, and helps them obtain the required carbon certificates from the United Nations. In exchange, the corporations earn carbon offsets which they can trade on the carbon markets. In order to ensure that local villagers don’t enter the newly enclosed lands, the corporations demand that the Brazilian government provide a Green Police whose primary mission is to harass and brutalize the locals out of their traditional lands.

In the case of the Canadian Boreal Forest Agreement, the main motivation of the logging companies is obviously logging rather than merely obtaining carbon offsets. The certificate that they need the most is not about carbon but the one provided by the Forest Stewardship Council (FSC) – and having heavyweight ENGOs on board to vouch for their “good logging practices” is a virtual guarantee that they will indeed obtain it. However, the carbon market would represent a tremendous bonus for those companies, especially in this bad economy where they may not even be able to log their forest tenures for lack of a lumber market. If you believe that the logging companies don't care much about carbon offsets, then read carefully the leaked agreement's strategic goal number 4, called “Climate Friendly Practices”. Deep buried in there is a reference to carbon trading in the following terms: “if the federal or provincial governments proceed to include forest management and protection in carbon offset programs”, then the partners of the agreement are to work together on obtaining certification and determining the eligible projects.

This boreal forest agreement vividly illustrates the strategic role played by some of the largest environmental NGOs in the advent of “green” capitalism. The ENGOs whose names are on the agreement are altogether the brokers, guarantors, and underwriters of corporate environmental goodwill in the eyes of the public. In particular, they are the ones which will secure the required certifications. They will receive hefty compensation for their services in the form of corporate grants which will allow them to meet their payroll and continue to grow, which is no small feat in the current context of a rapidly shrinking charitable donation market. In that sense, they are inhabited by the same internal logic as the corporations which they serve – growth for growth's sake.

Those environmental NGOs are enablers of capitalism's nascent environmental-industrial complex, and as such they have become a liability to the environmental movement. Personal donation choices should be adjusted accordingly, which is why I am posting below the complete list of ENGOs which are signatories to this boreal agreement.

Canadian Parks and Wilderness Society
Canopy
David Suzuki Foundation
ForestEthics
Greenpeace
The Nature Conservancy
Pew Environment Group International Boreal Conservation Campaign
Ivey Foundation
Canadian Boreal Initiative / Ducks Unlimited


UPDATE: Boreal forest agreement - It's even worse than it looked


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Salmon Migration - Untangling the spin wheel of "crowd estimates"

Sorry folks, but you were not sitting at this fountain. Photo Reegee Bee.


I could not fathom how the Times Colonist daily paper could have seen "nearly 1,000" people at Alexandra Morton's salmon migration rally in Victoria last Saturday, when I had seen many thousands. I really needed to understand.


So when last Monday, Times Colonist editor Stephanie Coombs kindly responded to my complaint letter about the event's coverage, I seized the opportunity.


"Reporter Katie DeRosa, who attended the rally," Coombs had written in her response to me, "spoke to two different Victoria police officers, as well as two rally helpers, who all estimated about 1,000 people."


Strange. That same day, I had received a message from Rafe Mair who quoted Global News reporter Holly Adams saying that "I spoke with Police outside the Legislature and they estimated just over 4,000 people, and that was just before 5:00."


The Globe and Mail had reported 4,000 people as well. So it appeared as if police officers had been mischievously telling 4,000+ to Global News and the Globe and Mail, and "nearly 1,000" to the Times Colonist.


So I wrote back to Stephanie Coombs asking her if she would care to comment about the Global News reporter's account of 4,000.


Her response: "We have spoken again with Victoria police today, and their official report on the rally indicates a crowd estimate of 1,000 to 2,000 at the legislature."


One to two thousand? But that was already double the number that her paper had initially reported. What was going on here? I figured that if I was going to understand those numbers, I'd better go to the source.


So on Tuesday morning, I called the Victoria Police Department's main line and asked to talk to someone about their attendance estimates for Saturday's rally. The switchboard operator connected me to Kathy Jorgensen from Operational Planning. Let me get back to you on that one, she kindly said when I explained the purpose of my call.


About an hour later, she left a message on my voicemail saying: "Our police estimated the count at maximum 1,500 once it got down to the Legislature Building."


Yet a different estimate. It was the fourth one I had received already. I called her right back. How did the police department go about determining that number, I asked, what's the methodology used? We just ask police officers who were there to give us their estimate; it's a casual count, we don't use a specific method, she explained.


I told her about what the Global News reporter had said - that police officers who were there had told her 4,000. I don't know who told her that, she responded, so I cannot comment.


Do you use photos of the crowd to help you refine your estimates? I ventured to ask. No, was the answer. Then she became a little nervous and told me: I don't know where you are going with this, so you need to call Sgt. Hamilton who is our media person.


Which I did right away. But he never returned my calls, so I was left spinning my wheels about Ms. Jorgensen's responses. No specific methodology to count the crowds... But why not? What's wrong with introducing a little bit of objectivity in estimating a number which is so critical to so many different stakeholders? With modern technology and a bit of planning and brain power, you would think that something could be done.


So I decided to give it a try.



What we saw.


I downloaded the above sample picture (courtesy Don Staniford) which I found among hundreds on the web. I took a snapshot of the BC legislature's lawn in Google Earth and imported it into Google Sketchup. I then plotted a polygon representing the approximate location of the crowd according to the picture. Some distinct features allow you to situate the crowd in the picture fairly easily, such as the fountain, the statue of the Queen, the trees, the flagpole, the stairs where the photographer was standing, etc. Here is what it looked like:



What we saw (continued).


Google Sketchup calculated the area of my polygon: approximately 6,000 square meters. The lawn itself is a 100 by 100 square, or about 10,000 square meters. My polygon therefore occupied about 60% of the lawn.


I then proceeded to estimate how many people could be standing in that polygon according to the picture. Densities vary: people closer to the stairs are clearly shoulder to shoulder, while people towards the statue were able to sit in the grass. Your typical "cocktail party" average density is about 0.5 square meter per person. People close to the stairs were probably using less than that, while people in the back were using more.


I took a very conservative guess: I assumed - which is very unrealistic, based on what the photo shows - that each person used 2 square meters on an exclusive basis. That's a rectangle of one meter by two meters with no one else but its sole occupier on it. Measure that at home, and you will realize that it's a very, very conservative assumption indeed. I also assumed that not a single person was standing to the left or the right of the frame of the photo, and I further assumed that the columns of people still moving toward the lawn in the photo's far background were actually not going to the rally.


In spite of that, I still found that approximately 3,000 people were occupying my polygon. Once you add more realistic estimations that other people must have been standing outside of the picture, that some people in the far background are actually going to the rally, etc. you easily find yourself in that 4,000+ range which was given to Global News on that day by several on-site police officers.


Let's continue my little experiment. Let's assume that the Times Colonist got it right and that "almost 1,000" people attended the rally. At 2 square meters per person, that's a 2,000 square-meter polygon. Here is what the Times Colonist "saw" happening on the lawn of the Legislature last Saturday:   



 What the Times Colonist "saw".


Notice how the Times Colonist's polygon does not even extend to the fountain, which was in actuality covered with people. Does it look to you like they got their numbers right? Well yes, me too.


Now just to be clear - I am not claiming to have discovered a new "methodology"! My point is simply that some methodology would not have hurt. If I was able to hack those estimates in a couple of hours on my home computer using some free software and a publicly available picture, imagine what a trained staff could do with sophisticated software and pictures that were taken with that purpose in mind.


After spending the past three days chasing phantoms in spinland, my head was hurting a little. But then suddenly today, out of nowhere, someone - finally! - made some sense. Sgt. Matt Waterman from Victoria PD Operational Planning returned one of my many calls. He told me that the Department's official estimate was 1,500 to 2,000 people (yes, a fifth different estimate!), and he confirmed what Kathy Jorgensen had already told me - that the Police Department does not use any particular methodology to come up with the number. We just guessed it, he said. Well sure, we could have used pictures and fancy methodologies to come up with a number, he explained quite candidly, but we had no reason to do that! We didn't know it was important. After all, our job is not to count, but to escort and protect people.


I explained to him that it was actually very important to many people, starting with the 5,000 or so people who were at the Legislature, because media used those Police estimates and presented them as reliable hard numbers, rather than the subjective wild guesses that they really were. I told him how the Times Colonist's editor had pointed the finger to the Police Department as soon as I started asking her some hard questions. He was clearly not pleased to hear that. Well, lesson learned! he commented. I will recommend that the Police refrain from making any more such estimates in the future.


Halleluia, brother! I am totally with you on that one. Stop counting, just focus on your job of protecting. Let other spinmeisters trip all over themselves with ridiculously low-balled estimates.


So, two lessons learned here, as the good Sargent Waterman would have said:


1. The Victoria Police crowd estimates for Saturday's event are worthless, according to people working in that very Department.


2. Times Colonist, you have hereby been put on notice. Next time you publish absurdly inaccurate crowd estimates that get people mad at you, don't run to the Police for cover because they will kick your butt.


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