Jun 012022


UPDATE  Spring 2022:   FLNRORD is dismantled.  The Ministry of Forests, Lands and Water STEWARDSHIP  has been created, out of a portion of the rubble from FLNRORD.

FLNRORD (now defunct) = BC Ministery of Forests, Lands, Natural Resource Operations and Rural Development,  which was responsible for the granting of licenses to take water.

UBCM = Union of BC Municipalities 

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I sent to an official:  

What has been accomplished regionally and

through UBCM taking Resolutions to the Provincial Government is significant.

BUT take off the rose-coloured glasses:  global interests are determined to have water under their control.  There is big money to be made in “Resource development”. 

You write (April 29):    I would hope that FLNRORD would recognize  . . .  *

Bruce spelt out what FLNRORD  IS doing.  It does not get any clearer.  Your hopes will fail the protection of water.

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April 23, 2022    (Bruce from Merville has been the carrier of the ball regarding the application for licensing of a water bottling plant in Merville.  He writes:)

I have always wondered why FLNRORD has worked SO hard, and have bent over backwards to accommodate this licensee. 

    • They ignored the objections of CVRD and K’omoks First Nation back in 2017. 
    • They convinced the licensee to reduce the volume of water he was requesting in order to get the application below the threshold for testing. 
    • They fought tooth and nail to have the Environmental Appeal Board rule that I had no standing to appeal.
    • They were hesitant/reticent/scared?? to cancel his license for 15 months after his deadline passed.
    • Now they are entertaining an application for amendment even though his conditional license expired 15 months ago 

I don’t know who or what he knows, but there is some reason this license has been handled with kid gloves from the get-go. 

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(Sandra speaking):  It does not get any clearer than Bruce’s observations. 

FLNRORD is in the business of supporting the Federal (and other Governments in Canada) agenda to commodify water so they and the Corporate Masters can make money from it.  They are NOT in the business of serving the public interest in, and the NEED for the protection of Water.   

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With regard to the  [“Merville” or “Strathcona – Comox Valley”]  application, it is the same license we thought we had dealt with several years ago on Sackville Road.  The province never did cancel his license, despite my regular follow-up prompting them to do so.  Then recently, I was advised that the licensee had applied for an amendment to his license to allow him to extract the water and sell it to bulk water tanker truck operators for supplying water to customers in the Comox Valley who need their wells or cisterns replenished. 

The FLNRORD decision team in Nanaimo has submitted the application for amendment to the CVRD (Comox Valley Regional District)  for their decision on whether the new proposed business plan conforms to the zoning of the licensee’s property.  While we are eagerly awaiting their decision, I am pursuing a legal avenue by working with West Coast Environmental Law. 

We are attempting to stop FLNRORD on the basis of their acceptance of an application to amend a license whose primary condition was not met (“the works must be built and beneficial use of the water must be made prior to Dec 31, 2020”) and whose deadline for meeting that condition passed 15 months ago being “legally unreasonable”.  I have legal advice to that effect, with an opinion that sufficient time has elapsed that it is “legally unreasonable” to amend that license and that the proposed new use of the water is sufficiently different that a completely new application should be required. 

At a higher level, I am trying to connect with Josie Osborne, in her new role as Minister of Land, Water, and Resource Stewardship.  I am encouraged by the fact that water is identified specifically in this new Ministry, and also by the word Stewardship in the name of the Ministry.  I am also encouraged by the naming of Josie Osborne as Minister of this new portfolio.  Josie was very supportive of our campaign and of your groundwater resolution when she was Mayor of Tofino, so I am hoping she has retained that position and will take action to implement the UBCM resolution to protect our groundwater. 

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* The Resolutions that went to AVICC/UBCM a few years ago confirmed that local governments were firmly against the commercial exploitation of groundwater.  Additionally, the applicant’s original proposal was to “bottle” the water and the zoning was denied by the Comox Valley Directors.  I would hope that FLNRORD would recognize that this is just more of the same.

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