Moratorium on all industrial forest related activities including Road Permits within the Horsefly River Fisheries Sensitive Watershed

April 20, 2023

Josh Pressey
Regional Executive Director
Regional Operations Cariboo
Ministry of Forests
200-640 Borland Street
Williams Lake BC
V2G 4T1

Dear Josh,

Subject: Moratorium on all industrial forest related activities including Road Permits within the
Horsefly River Fisheries Sensitive Watershed.

An Order, signed June 7, 2018 by Michael C. Pedersen, Regional Executive Director of
Ministry of Forests, Lands, Natural Resource Operations and Rural Development declares the
Horsefly River Watershed, identified as FR-5-001, a Fisheries Sensitive Watershed (FSW).
The main objective is to protect the habitat of fish species which include Sockeye,
Kokanee, Chinook and Coho salmon, Bull and Rainbow trout and other fish species.

The following points support a pause in industrial forest activities.

1. The area of clear cut logging set out in the Order is within approximately 5% of its
   allowed Equivalent Clearcut Area (ECA). There are discrepancies between agencies
   regarding current ECA status.
2. The water quality within the FSW has steadily declined, resulting in algae bloom,
   increased siltation, warmer water temperatures and lower water levels which
   negatively affects all aquatic habitat and has caused multiple years of river fishing
   closures.
3. The FSW provides some of the most important fish habitat in the Fraser River
   Watershed. Fisheries resources are comprised in part by Rainbow trout, a unique
   race of world class trophy size fish, which along with Sockeye salmon are biologically
   unique to the FSW at a cellular level. These two special fish along with Chinook,
   Kokanee and Coho rely heavily on the FSW for spawning and juvenile rearing.
4. Over the last 25 years the number of imperiled species in Canada has increased
   exponentially as reported by the Canadian Endangered Species Conservation
   Council. Interior Fraser Coho were assessed as threatened in 2016 by the Committee
   on the Status of Endangered Wildlife in Canada, they were also provided with further
   protective legislation through the Fisheries Act.
5. The BC government is committed to achieving stringent biodiversity objectives and is
   considering retaining more remnant old growth, ancient forest and big treed old
   growth. The untouched portion of the FSW is a wet, high elevation, steep alpine area
   and is integral to biodiversity and ecosystem protection. A portion of the remaining
   untouched area is classified as Interior Rain Forest.
6. Horsefly Lake provides pristine drinking water which is relied upon by all residences.
   Throughout the FSW area subsurface aquifers supplying other local residents are also
   at risk.
7. The FSW sees year round recreational use of fishing, camping, boating, hunting and
   winter activities which are enjoyed by First Nations, locals and visitors from all over the
   globe boosting the tourism sector.
8. Climate change is at a precarious level globally and the effects on fisheries are
   unpredictable, the likelihood of cumulative, preventable watershed damage is probably
   high and increases the risk for further environmental instability and declining water
   quality.

The Horsefly River Roundtable and its stakeholders hereby request a immediate moratorium
on all industrial forest related activities including Road Permits within the FSW while
environmentally sensitive harvest plans are created. We request that the following points be
supported by the Association of BC Forest Professionals and the District Manager.

1. Complete a State of the Watershed Report, including tiers 1 and 2 data.
2. Completed hydrological impact assessments for the entire FSW including each basin
   and sub basin within it.
3. Install and monitor sensors for water temperature, volume and suspended sediment in
   mouths of all streams draining into Horsefly River and Horsefly Lake.
4. Thorough testing and monitoring of water quality of Horsefly Lake.
5. Collaborate and create a standard procedure for collecting and updating ECA data,
   including a definition of stands which are hydrologically recovered and considered
   forest.
6. Special planning and operational measures within areas of the Interior Rain Forest
   that will insure that any future development does not cause landslides, wildfires or
   excess surface erosion.
7. Members of the Association of BC Forest Professionals practice a higher level of
   environmental stewardship and increase the size of riparian areas, assign a higher
   value to wetland complexes and related drainages and minimize allowable
   disturbance levels when prescribing forest activities in the FSW.
8. Collaboration with all stakeholders in long term planning for effective and efficient restoration activities.

It is time to observe “Super Natural BC” and protect the Horsefly River Fisheries Sensitive
Watershed. Forest revenue in BC is forecast to decrease while tourism has been contributing
significant provincial revenue and it is forecast to increase in the coming years. Future British
Columbians depend upon both industries to maintain biodiversity, clean air and water and a
stable economy.

Sincerely,

Brian Englund
President Horsefly River Roundtable

Full Official Letter