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Park--not logging--for NE Kananaskis Country

23 June, 2006

Honourable David Coutts
Minister for Sustainable Development
#420 Legislative Building
10800 – 97 Avenue
Edmonton, AB T5K 2B6

Dear Mr. Coutts:

Re: Logging plans for NE Kananaskis Country

I'm a resident of Bragg Creek, and I strongly object to the prospect of
further logging by Spray Lake Sawmills (SLS) in NE Kananaskis Country.
SLS's local logging of the late 1980s was ill-conceived. Allowing them
to return would be worse.

The logging plans were posted with little fanfare: it was almost by
accident that I discovered them. Our group—the Bragg Creek
Environmental Coalition—then publicized them within our community and
to our Calgary neighbours as best we could, with limited time and
resources. The documents contain no simple summary of what logging is
planned, when, and why. The obvious lack of significant public
involvement in feedback on the plans speaks poorly to the requirement
that significant public involvement must be obtained. Instead, it
appears that SLS wants a free hand to log without scrutiny for a period
of at least 10 years (during which, according to the plans, most of our
local old growth forests will have been clearcut).

The prospect of future logging in an area so critically important for
recreation and water quality to a bourgeoning local city—Calgary—speaks
to a profound failure in past planning. In particular, I wonder why
Sustainable Resource Development (SRD) saw fit to include this area in
a Forest Management Agreement (FMA). Across Canada, forestry on
public lands creates jobs, but does not to enrich government coffers
with lucrative royalties. Typically, the royalties charged roughly
balance the government's costs. NE Kananaskis Country isn't some
forested region in a remote corner of the province, where job creation
is essential to the local economy. This is a forest relied upon by
hundreds of thousands for water and recreation, where logging will
likely be net economic loss!

The logging proposed by SLS is incompatible with recreational use. The
steep upper slopes of Moose Mountain will not be logged, and distant
viewscapes are therefore largely preserved. However, the more gently
sloping lower regions will be extensively logged. Based on incomplete
maps provided by SLS (incomplete because they do not show actual cut
blocks), I estimate that 90% of the lodgepole pine forests (the primary
forest type here) will have been removed in 10 years (when the logging
of 20 years ago is combined with the proposed logging). The
recreational potential of clear cuts is negligible, so an area whose
forests have been removed in this manner is therefore virtually
extinguished. Yet it is in the heavily-used recreational corridor,
extending from Sibbald through West Bragg Creek to Station Flats, where
logging activities will be concentrated. I am unaware of any other
place in SLS's past and present logging where a heavily-used
recreational area will be subject to such a profound negation of its
recreation potential.

The importance of recreation opportunities (hiking, biking,
cross-country skiing, horse trail riding) should not be dismissed, as
any survey of recruiters in large employers in Calgary will attest.
The presence of K-country, the closest public forests to Calgary, is a
big draw. It certainly was the reason my family came to Calgary. This
wonderful juxtaposition of public land and large city is unique in

The proposed logging is also incompatible with maintaining a
high-quality source of water for Calgary. Much of the logging will be
within the Elbow River watershed, from which half of the city draws its
potable water. The potential problems are runoff of nutrients
following logging (particularly N & P, which can lead to taste & odour
events in the Glenmore Reservoir), increased siltation (which
complicates water treatment), and changes in the dynamics of water
runoff (which increases the risk of downstream flooding). For these
reasons, no further logging should be allowed anywhere in the Elbow
River watershed.

The proposed logging is also harmful to biodiversity, in that it
produces patches of regenerating forests that do not mimic the size and
shape and scale of the fire- and insect-disturbed landscape that over
evolutionary time has shaped the fabulous forests as we now see them.
We are essentially converting a heterogeneous environment, maintained
by natural disturbances, with a homogeneous tree farm where logging is
the prime disturbance. Biodiversity, and aesthetics, take the hit.

As a scientist (I'm an ecologist employed at the University of Calgary)
whose research currently includes study of the ecological impacts of
logging, I have many serious concerns with the quality of the science
in the SLS logging plans. I will outline these concerns in a separate
letter, delivered later. But even if these concerns were addressed,
such that the plans were made methodologically sound, they still would
be inappropriate when practiced on forests made so valuable by
proximity to Calgary. So in a sense, feedback at this level of detail
is moot.

I recognize that SLS has certain legal rights to K-Country forests
provided by their FMA. Extinguishment of these rights to make a
provincial park--perhaps named Moose Mountain Wildland Park--will bear
a public economic cost.

I suggest that the Kananaskis Country Interdepartmental Consultative
Committee reconvene and get busy, and that plans for NE Kananaskis
Country be revisited. In particular, the departments of Community
Development, SRD, and Environment need to get together, to discuss
transfer of jurisdiction from SRD to Community Development, in
anticipation of park creation. Such a park would meet current and
future expectations of the vast majority of adjacent residents
(including, of course, Calgarians).

Finally, I would like to see the relevant people at SRD, who were
acting in trust on the behalf of the people of Alberta, held
accountable for their provisioning (5 years ago) of these valuable
forests to SLS without significant public debate and input.
Presumably, it is these same managers who have guided SLS's plans to
remove large tracts of forest along the eastern border of the FMA in
the interests of reducing fire risk. On this latter point, I speculate
that these managers have read too much fire-risk material originating
from the western USA (particularly in ponderosa pine & chaparral
ecosystems), where fire risk and severity increases in an accelerating
manner with time since fire. We're in the boreal/foothills forest
here, with different risk dynamics! Both the ill-conceived awarding of
the FMA, and the attitude to fire, suggest to me that we need to more
closely scrutinize the judgment and activities of the current managers
in our local SRD office.

In sum, I oppose any further logging in NE K-country, and
enthusiastically support park status for all of Kananaskis Country,
including a shiny new Moose Mountain Wildland Park in the NE. These
forests are much more than lumber. Let's do it as a legacy for our
young Albertans!


Bragg Creek