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TIMBERWEST 5-YEAR PLANJuly 27, 2001 at TW Office on Duncan Bay Main Dave Ferguson on behalf of the CV Environmental Council and CV Watershed Assembly met with Electoral Area "A" Director Kel Kelly and Steve Lackey and Bill ??? of TimberWest and Guy ??? who is the contractor that applies pesticides for TW. I had TW's draft PMP in my custody for 24 hours and about 2 hours to read it. It looks a lot like the Model Forest Pest Management Plan For Forest Vegetation Management (DRAFT) which TW and other timber companies helped to draft http://www.elp.gov.bc.ca/vir/pp/ipmweb/pmp/modelpmp.doc but with some good graphics. TW is in the final stages of applying to the Ministry of Water, Land and Air and Protection (WLAP) for approval of a five-year pest management plan. Presently, TW is operating under a three-year permit. Pesticide Management Plans (PMPs) trade off the more specific 'prescriptive' regulatory permit system for a more 'results based', flexible planning system that allows for a more integrated approach to pest management. If this change is properly implemented the advantages will be: "Implementing PMPs has four major goals:
Will the environmental benefits be realized? According to TW, it will allow them the flexibility to go in with pesticide applications once before unforeseen problems require more frequent and more intensive applications that occur now under the less flexible permit system. What about manual brushing? To TW (and other timber companies) the most cost effective means of brush control, in increasing order of cost is aerial spraying (which is not in the plan), ground (backpack) spraying, hack and squirt, manual brushing and doing nothing. Whether it would be to the community's advantage to subsidize (through HRDC, for example) manual brushing is problematic on private lands and likely to open NAFTA challenges. An interesting side exercise would be to calculate and compare the environmental damage of a properly applied one-shot pesticide application vs a series of chain saw brushings with the ensuing engine exhaust. What about stream and water protection? Pesticides are not used within strict boundaries of domestic water intakes, community watersheds, fish bearing streams and other water courses. Manual brushing is used in these sensitive areas. (The question should logging be permitted at all in these zones or whether these buffers are sufficiently wide wasn't asked.) Are these pesticides safe? According to TW, the applicator/contractor, and the pesticide suppliers, they are perfectly safe when "used as directed." According to others such as the Northwest Coalition for Alternatives to Pesticides and others they are not. (This is a hot question. Monsanto has successfully sued at least one testing laboratory for damages from shoddy research leading to the conclusion that Monsanto's products were not safe. On the other hand Monsanto has been successfully sued for false and misleading advertising for ads claiming that their products were 'perfectly safe.') It looks like glyphosate and trichlopyr with the latter replacing the former are the products of choice. Rap sheets for these pesticides and found under Links, below. What comfort do we have that the PMPs will be adhered to? TW is in the business of making money from growing and cutting down trees and selling them to the highest bidder (even if that bidder is down south). They have no interest in poisoning people, fish or spending more money on chemicals than absolutely necessary. Thank you very much! They need to have their plan approved and reviewed by the Ministry of Water, Land, and Air Protection. They cannot use chemicals that have not been approved under the federal Pest Control Products Act. Testing for pesticides in the wrong place and for residues and metabolites is expensive and rarely done. What can we do? We are not going to stop the use of pesticides for forestry, at least not soon. They are using legal products in the legally prescribed manner. Hopefully, by entering into a dialogue with them at every opportunity, by learning as much as possible about all aspects of the business, by offering alternatives, by lobbying the permitting and authorizing agencies, we can hold their feet to the fire and ensure that they do it right. To this end, Steve Lackey (TW) would be willing to come to a CV watershed Assemble meeting in October or November to discuss their PMP. We would also invite representatives from WLAP and the appropriate federal agency for their input--if the CVWA steering committee approves. Is there anything else we can do? Yes, the town of Hudson PQ has had their no cosmetic pesticide bylaw upheld by Supreme Court. We should be lobbying local governments to enact similar bylaws. This will help as when we go to BC Hydro they point at domestic use as a bigger problem, etc. By demonstration that we, the people, will do whatever we can to curb our use of potential health and environment damaging chemicals, we will strengthen our case to the industrial users. Links Pesticide Control Act [RSBC 1996] Chapter 360 http://www.qp.gov.bc.ca/statreg/stat/P/96360_01.htm
An Example For Organizations Developing Operational Forest Pest Management Plans Prepared by: Staff of the Pollution Prevention Program BC Environment and Lands Vancouver Island Region with assistance from: TimberWest Ltd. Western Forest Products Ltd. International Forest Products Ltd. Ministry of Forests, Campbell River November 4, 1998 (updated April 12, 2001) http://www.elp.gov.bc.ca/vir/pp/ipmweb/pmp/modelpmp.doc
The British Columbia Pesticide Control Act has been amended to allow pesticide uses under a Pesticide Use Permit to be authorized under an approved Pest Management Plan (PMP). The ministry intends to replace the existing Pesticide Use Permit system with PMPs 1.3 Differences Between the PMP and Pesticide Use Permit Systems from Guide for Developing A Forest Vegetation Pest Management Plan DRAFT--Integrated Pest Management Program December 1999 at http://www.elp.gov.bc.ca/epd/epdpa/eripm/pmp/gfdafvpmp.html New legislation enabling the authorization of pesticide use through PMPs was passed to enhance environmental protection and to introduce efficiencies. This new system has a number of improvements compared with the Pesticide Use Permit system:
Proponents will submit "Notices of Intent to Treat" (NITs), to inform the ministry before they apply pesticides to specific sites. Proponents are required to prepare and submit Detailed Site Assessments for sites to be treated with herbicides (see section 6.1), to accompany the NITs.
Appendix--Snippets from other documents not integrated into the report "reportable pesticide" means a PERMIT-RESTRICTED, RESTRICTED or COMMERCIAL pesticide as scheduled in Annex 1 under the designation of "reportable" in respect of which a record of sales is required under section 9;Provisions for Permits and Pest Management Plans http://www.elp.gov.bc.ca/epd/epdpa/ipmp/updates/pcaupdat.html Section 6 has been augmented by including: the application procedures from section 8, and provisions for authorizing pesticide application with Pest Management Plans. Approved Pest Management Plans will authorize pesticide use within the context of an Integrated Pest Management Program. They will cover a wider geographic area, will be valid for a longer time span, and will help reduce administrative workload. Most permits are anticipated to be replaced by Pest Management Plans within a few years. What will be the duration of Pest Management Plans? PMPs may be effective for a range of terms up to a maximum of five years, depending on the period of pest management required. One, three and five year terms would be most common Other WLAP links
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