Bill 47 is a Step Backward for Forest Protection in BC

Environmentalists have often criticized government for its questionable commitment to enforcing the Forest Practices Code, pointing to the absence of prosecutions against the big forest companies.

There was once a time when government could defend itself to this charge. Government was able to point to a system of administrative penalties which, although usually lower than criminal court fines, were levied in far more cases of noncompliance than would have been practical if offenders were charged and tried in the criminal court system. The administrative penalty system was efficient, with far less evidence required to prove contraventions and fewer technical defences than are available in the criminal court system.

That was then; this is now

This efficiency meant administrative penalties could be imposed far more often and when imposed, were far more likely to stick. According to the government and many academics, the likelihood of enforcement, speed of action, and likelihood of fines, made for an effective deterrent. But that was then and this is now.

Bill 47, the Forest Statutes Amendment Act, passed this summer, severely weakens the Forest Practices Code enforcement regime. In particular, it largely dismantles the system of absolute liability which allowed fast and efficient imposition of penalties. Absolute liability means that violators are liable to a fine whether or not they can produce evidence that they were "duly diligent" in trying to obey the law. It's fast because the enforcement officer doesn't have to collect evidence to rebut specious defences. It's fair because the penalties imposed aren't so high that they are punitive.

It's a bit like parking tickets. If bylaw control officers had to spend a lot of time gathering evidence and going to court to rebut people's excuses, there would be a lot more overparked cars. For the person who gets a fine — even though they were really trying their hardest to plug that meter — the end result may seem a bit harsh, but most people are reasonable enough to realize that society's interest in ensuring compliance is worth the occasional fine to the well-meaning but overparked.

Lyle Fairbairn, one of Canada's leading experts in the area of deterrence and administrative penalties sums it up:

[T]he use of absolute liability may be critical to enabling particular regulatory programs with important preventative objectives to be effective with even minor penalties by giving operational effect to the key principles of deterrence — swift action and the certainty of outcome.

Weakening the Code

Now under Bill 47, if the Ministry of Forests wants to levy a penalty which can be entered on a company's record, and that does more than simply recover damages such as remediation costs or value of illegally logged timber, the Ministry needs to rebut any evidence the company may try to present of due diligence. By forcing enforcement officials to gather evidence on due diligence, requiring Forest District managers to make determinations regarding due diligence, and allowing companies to appeal the issue of due diligence, Bill 47 will likely bog the enforcement process down. One of the Code's strong points — a fast, efficient compliance system — may be lost.

Government may have a chance to limit some of the damage brought by the changes to the Code when it develops regulations telling Ministry of Forests officials how to determine due diligence. Determining due diligence is a difficult legal task even for judges trained in law. Unless workable definitions are developed it could be an impossible task for District Managers and other senior staff to determine.

Other changes

Other changes to the Forest Practices Code also represent backward steps for forest protection in BC:

• The Forest Practices Board's jurisdiction is limited. The Board can no longer ask the Ministry of Forests to review the amount companies are required to pay in compensatory damages (i.e., compensation for the value of wood illegally harvested or for damage that affects governments ability to manage natural resources). The Board's ability to intervene in appeals to the Forest Appeals Commission may also be limited.

• The availability of emergency exemptions from planning requirements is broadened. The Ministry will be able to avoid normal planning requirements by declaring that trees are in danger of an insect infestation or forest fire, regardless of whether the threat is imminent or whether immediate logging is necessary.

• Government's ability to designate plans as being legally binding "higher level plans" is narrowed. Previously, government had a broad discretion to designate plans as legally binding. For instance, innovative solutions like the Clayoquot Sound Scientific Panel Report could be made legally binding. Now, only the objectives contained in resource management zones and similar designations will be binding.

At the same time, the government removes from the criminal court system some violations which should be treated as criminal. Intentional interference with, or intentional misleading of, enforcement staff and Forest Practices Board staff is changed from a criminal offence to a contravention subject only to an administrative penalty. Although administrative penalties are an important enforcement tool, they are inappropriate for wilful offences such as intentional interference.

The manner in which Bill 47 was passed has also raised the ire of environmental groups. Despite the significance of Bill 47, it was pushed through with virtually no consultation with environmental groups, and according to one source, no meaningful consultation within government. While some processes bog down in endless consultation and analysis, politically driven changes are pushed through with no participation from affected public interest groups. Participation seems to be a cynical device for delay, but if there's any chance it might slow or deflect the spin government puts on a piece of important legislation, well, government's opinion seems to be, who needs it?

WCELA's comments on Bill 47 can be seen at our Internet site at
http://vcn.bc.ca/wcel.

New Faces — Welcome to Mark and Sandra!

We're happy to report that there are two new faces at West Coast Environmental Law.

We would like to extend a warm welcome to Mark Haddock as he joins the WCEL team. A lawyer and BC forestry expert, Mark will work on various WCEL projects, including a Forest Renewal BC project which involves writing a comprehensive guide to forestry and land use planning law and policy. The report is needed because of all the recent changes to forestry practices, the Forest Practices Code, and the number of land and resource management plans (LRMPs) being conducted around the province. It's a two-year project, which will produce a written guide and an Internet site.

Before joining WCEL, Mark worked for Forest Policy Watch, Sierra Legal Defence Fund, the Department of Indian Affairs and Northern Development, and he articled with the federal Department of Justice.

As well, Mark isn't exactly a new face around the West Coast offices. He worked here during his two summers of law school, and he is a past board member. Prior to law school, Mark worked for the BC Forest Service for several years, where he developed his interest in and extensive knowledge of forestry issues in BC.

West Coast would also like to extend a warm welcome to Sandra Janzen, our library intern. She started in July, and will be with us for an extended term. Her duties are many-fold. Sandra is expanding our library's cataloguing system, answering library and general research questions from the public, and assisting WCEL lawyers and staff in their library research. She will also be doing public outreach about our library resource. Sandra also works on the West Coast web site, converting our documents to HTML.

Sandra is from Winnipeg, and came to West Coast through the Volunteer Services Program of the Mennonite Central Committee. Sandra has a Masters degree in Engineering, and prior to coming to WCEL, she worked for several years doing contaminated site investigations for a consulting company in Winnipeg.

If you have any questions about our public library, or need help finding material on an environmental issue, please call Sandra at 1 800 330-WCEL.

Impacts of Bill 14 Underemphasized by Government

But the changes are more significant than the Ministry has suggested. The removal of Directors' appeals is a welcome change and the effect of the other changes brought about by Bill 14 might be positive depending upon the policies adopted to guide the implementation of the changes. For example, we will encourage the EAB to use its power to award costs as a means of providing funding for public participation before the EAB.

As the changes were apparently made without consultation with environmental groups or industry(1), (1 - Discussion with Brian Lockhart, Chemical Producers' Association) it is unclear at this point how the EAB intends to use its new powers. WCELA will continue to monitor the development of policies around the new powers. Whether positive or negative, the impact on public participation could be substantial.

EAB — effects of changes uncertain

Three significant changes — the removal of appeals to EAB directors, a new requirement for an up-front deposit to cover potential cost awards, and the opportunity for the board to levy costs — all have significant impacts on the usefulness of the EAB. Whether these impacts are positive or negative remains to be seen. We will be watching the implementation of the changes closely.

Directors' appeals abolished

The appeal to the Director from managers' decisions made under the Waste Management Act was a step which often failed to result in final determinations of environmental issues. Directors' decisions were frequently appealed to the EAB.

On appeal to the EAB, the case would have to be reargued, requiring additional time and expense. The steps taken before the Director were repeated before the EAB. Because of this elimination of one step, industry and many environmental groups, including WCELA, support the removal of this level of appeal.

Requirement to deposit money

The Environment Management Act has been amended, giving the EAB the power to require an appellant to deposit money in an amount sufficient to cover all or part of the anticipated costs of the respondent and the Board related to the appeal. We have written to the Minister of the Environment explaining the potential impact of deposits being required when appeals to the EAB are commenced by concerned citizens. Many citizens groups will not be able to raise the money to commence an appeal if they are required to provide a deposit. Further, when appeals are brought to protect the environment, rather than to further a private interest, many concerned citizens may decide not to risk forfeiting the funds required for a deposit.

If deposits are required from these groups, a much less satisfactory level of environmental protection in this province could result. The EAB's Annual Reports show the extent to which public appeals to the EAB have been successful. In many cases, appeals brought by members of the public or environmental groups have resulted in higher levels of environmental protection. If this new requirement is meant to address the issue of frivolous appeals, we believe use of the power should be limited to situations where the EAB reasonably believes that an appeal is frivolous or vexatious. We will be encouraging the Board to adopt a policy limiting the use of this power against public participants.

Cost awards

Section 14.2 allows the Board to make orders requiring a party to pay all or part of the costs of the other party. If the party has been vexatious, frivolous or abusive, the Board may also require the party to pay the Board's expenses. The impact which this change will have on public participation will depend on the policy adopted by the EAB regarding when to make cost awards. The power to award costs could be used to obtain positive results. For example, the Ontario Energy Board has used similar powers to obtain funds for allocation to public interest groups participating in hearings. If the EAB uses its power in this manner, we will welcome the change. However, this power could also have negative results should the EAB ever require citizens' groups to pay costs. The fear of being required to pay all or part of the costs of another party could discourage some would-be public interest appellants.

If citizens wanting to appear before the EAB are concerned with potential adverse cost awards, it is likely that many important concerns will not be addressed, and the level of environmental protection in the province will decrease.

We will be encouraging the government to draft regulations and the EAB to adopt policies regarding the power to award costs which will facilitate public participation before the Board. We hope that the power will be used to provide funding to public interest appellants.

Waste Management Act — Standing to appeal restricted

Section 44 of the Waste Management Act previously gave "standing" (the right to appeal) to a person "who considers himself or herself aggrieved by a decision…" The section is now changed to grant standing to appeal only to a person who is "aggrieved" by a decision rather than one who "considers him or herself aggrieved." This shift threatens to significantly erode public standing in the province and will likely have substantial implications for public participation. Clearly, it is more difficult to prove that a person is aggrieved than that a person considers him or herself aggrieved.

We have written the Minister stating that this change is completely unacceptable. Environmental degradation affects everyone in the province. All taxpayers must pay to clean up problems where no polluter is available or able to pay. As the province's air, water, soil, flora and fauna are to be shared by all citizens, all citizens should be entitled to bring appeals to protect the environment.

We advocate expanding the terms used to define those with a right to appeal. The change to "aggrieved" from "considers him or herself" aggrieved has the opposite effect and suggests that the government does not support public participation. It is appalling that the provincial government has decided to make the standing requirements under the Waste Management Act more difficult to meet than they previously were.

We advocate replacing the term "a person aggrieved" with the phrase used in the Pesticide Control Act which allows "any person" to appeal.

Water Act — Right to appeal restricted

We are particularly concerned with changes to the rights to appeal under the Water Act. We have made several submissions to government in an attempt to have the standing rights under the Water Act expanded; see our previous Newsletter articles about Lake Windermere Resorts and the East Kootenay Environmental Society.

Prior to the Bill 14 amendment, the Water Act was essentially silent on the issue of standing but had been interpreted not to provide public interest standing. The Bill 14 amendments clearly indicate that the public will now not be given standing under the Act. Decisions made under the Water Act often have effects on individuals and species other than those whose land will be directly affected. For example, permits may be issued under the Water Act to allow activities such as the deposit of fill on a wetland. Wetlands are important for many reasons. They provide vital habitat for many migratory species, they clean and filter water which flows through them, and they provide flood protection for adjacent areas. Excluding the public who don't have property rights in a specific area from decisions made under this Act is unacceptable.

Overall Effect on Public Participation

Costs and standing are the two issues most often identified as barriers to the public's access to the courts. The amendments outlined above could significantly restrict public participation in environmental protection and environmental decision making. However, if the power to award costs is used to provide funding for participation to members of the public, this could increase participation. It is difficult to predict how these powers will be used as the changes were made without notice and the benefit of consultation.

In the absence of regulations or strong policy guidelines directing the exercise of the costs powers by the EAB, a Board unsympathetic to public participation could use the new powers in a manner which would impair access to the EAB. In addition, the limitations placed on standing clearly have the potential to restrict public participation. Individuals and public interest groups should be able to appeal government orders that allow activities detrimental to the environment. It is difficult to see how the environment could be served by the changes which limit standing.

We have written to the Minister supporting the improvement of avenues for public participation in environmental decision making through increased standing rights and financially accessible appeal avenues. If you have concerns about any of these changes, please write to the Minister to request that the standing rights be expanded under all environmental protection statutes and that the power to award costs be restricted to facilitate public participation. The current Minister of Environment, Lands and Parks is Cathy McGregor.

She can be contacted by phone at (250) 387-1187, or by fax at
(250) 387-1356, and by mail at Parliament Buildings, Room 337, Victoria, BC, V8V 1X4.

20/20 Vision and the Earth Need Your Help!

This is a call for action by 20/20 Vision to make the Canadian government live up to its promise to curb greenhouse gas emissions. Please write a letter and help us turn down the heat!

20/20 Vision is a group of dedicated Lower Mainland residents who volunteer their time and research abilities to help others create positive change. 20/20 Vision's goal is to make it easier for concerned individuals to take action — by writing, phoning or faxing a key policymaker. And by making it easier, more people speak up.

West Coast is pleased to be a regular source of information for 20/20 Vision's campaigns. Staff lawyer Chris Rolfe provided the background material for this month's message.

20/20 Vision subscribers use a monthly postcard (with background facts and the name and address of the individual who has the power to act) to use that clout to help build a safe and sustainable future for all life. 20/20 Vision does the research, you do the writing. Twenty minutes a month is all that is required.

Please join the 250 regular letters writers with 20/20 Vision. Together we can make a difference. For more information, write: 20/20 Vision, 5112 Francisco Court, North Vancouver, BC, V7K 1P8, or phone Coordinator Pru Moore at (604) 926-3417.

Climate Countdown: A UN Climate Change Convention in Kyoto

BACKGROUND: By the end of this year, the world's governments will have made a decision that will profoundly affect the future of our planet. Will they act to prevent the earth's climate from changing irreversibly?

The Earth is heating up. Last year, climate scientists advising the world's governments confirmed this, and named our industrial civilization as almost certainly the culprit. Our burning of fossil fuels and the destruction of forests pumps billions of tonnes of gases (mainly carbon dioxide) into the air every year. These gases trap the sun's heat in the atmosphere, increasing the greenhouse effect beyond natural levels. Scientists have identified a warming trend of 1.5^°C during this century alone in northern Canada's Mackenzie Basin. They predict that the world will heat up by as much as 3.5°C over the next century — the most severe climate change since the end of the last ice age. The results could be devastating as oceans rise, deserts expand, forests wither, and species become extinct.

At the Earth Summit in 1992, most of the world's industrialized countries agreed to reduce their own emissions of greenhouse gases to 1990 levels by the year 2000 and to assist Third World countries to reduce theirs. Few are doing either. Global emissions need to drop by 50 to 70 percent below 1990 levels just to stabilize the level of these gases in the atmosphere. Canada has not honoured the commitment made at the Earth Summit to reduce greenhouse gas emissions. As a nation, Canada creates the third largest per capita emissions in the world. We now exceed our 1990 limits by ten percent. However, last year the Liberal party reaffirmed its commitment to a twenty percent reduction of greenhouse gas emissions by the year 2005. Despite its lack of signs of progress toward this goal, our Environment Minister has worked to raise the profile of the greenhouse gas emissions problem.

From December 1 to 10 this year, representatives of the world's governments will attend a United Nations-sponsored conference in Kyoto, Japan. They will discuss targets for reducing emissions beyond 2000. It's vital that the industrialized countries adopt strict targets and timetables at Kyoto, as a first step towards preventing a climate crisis.

But a first step isn't a solution. To avoid devastating climate change, the world's nations have to agree on a yearly global limit of greenhouse gas emissions. This limit must steadily decline year after year to the point the scientists say is safe. This raises a hard question: Who makes what reductions in their use of fossil fuels? Interestingly, despite industry's resistance to cleaning up our air, 2,800 North American economists recently signed a statement saying that: a) climate change is real, and b) there are measures that we can take that would actually benefit our economies, and have no negative effects of living standards, while also reducing emissions.

The Kyoto Conference must:

1. Set reduction standards and rates that apply equally to all industrialized nations. Any attempt to differentiate national commitments will derail negotiations.

2. Set short-term binding deadlines for significant emission reductions. Such specific goals will ensure against a continued delay in dealing with the problem.

The longer we wait, the steeper and deeper will emission reductions need to be in the future. It is important for our government to hear that Canadians are disappointed that we have not honoured our international commitment, made in 1992. We need to "get on board" global efforts to reduce emissions, and thus begin the long process of cleaning up our atmosphere.

ACTION: Please contact Honourable Ralph Goodale, who will be a Canadian negotiator at the Kyoto Conference. Tell him you support our minister of environment's efforts to raise the profile of the climate change issue. Ask him to provide quick and effective leadership to ensure that the above two goals are adopted at the Kyoto Conference. Further, ask him to insist that Canada finally accept its international commitment, made the Earth Summit. If you have time, please send a copy of your letter to Honourable Christine Stewart, Minister of Environment, same address. Add a handwritten note commending her attempts to bring a higher profile to the issue of greenhouse gas emissions.

Honourable Ralph Goodale
Minister of Natural Resources
Parliament Buildings
Ottawa, Ontario K1A 0A4
Phone: (613) 996-2007
Fax: (613) 996-4516

Since 1989, thanks to the generous financial support of the Law Foundation of BC, West Coast's Environmental Dispute Resolution Fund (EDRF) has provided almost two million dollars in grants to hundreds of BC community groups. This assistance has helped groups concerned about the environment participate in land use planning processes, appear before the Environmental Appeal Board, go to court ,and participate in alternative dispute resolution processes.

The EDRF is a natural extension of our free legal advice program. Citizens from around the province can call our office, and speak to a staff lawyer about an environmental issue. Often, the lawyer is able to give advice immediately. Sometimes this summary advice from a lawyer solves the problem. Other times, the issue is more complicated, and requires more extensive legal assistance than we can provide or needs a consultation with an expert (like a biologist). When an issue is more complicated, and cannot be easily resolved, money is often what a community group needs most. This money can help hire the needed legal or scientific expertise. This is when the EDRF takes over.

When it becomes apparent to our staff lawyers that additional legal or expert assistance is necessary, the community group is told about the EDRF and encouraged to apply. The concerned citizen or group submits an application to our office. Applications are reviewed by the EDRF Management Committee at its monthly meeting. If an application is approved, financial assistance is earmarked for the group. This assistance is held in trust for the community group, and is paid out as the group incurs approved expenses for legal and expert assistance.

The EDRF would not be able to function without the support of many dedicated lawyers who work on EDRF-funded files at the pro bono rate of $50 per hour. We are grateful for their support. The Fund works simply and efficiently and has helped many communities through the province protect the environment and participate in environmental decisions that impact their communities.

Following are brief highlights of some of our currently funded files.

Reach for Unbleached: With the support of the EDRF, appealed a decision of the Deputy of Waste Management that permitted MacMillan Bloedel to use grate ash for road bed material and lime dregs as a soil amendment. The group argued that no standards or regulations are in place and no adequate testing was done to ascertain environmental impacts. The Director's decision made several amendments to the permit directed at environmental protection. The Director decided that additional testing of the waste streams must be undertaken prior to any disposal of the material; the data tabulated must be available for public review; the experimental design for the project was flawed; that a design needed to be completed to address all environmental concerns; and, that further studies must be undertaken to determine potential impacts on the environment. The group is satisfied with this decision and will continue to monitor the activity.

Concerned Citizens of Mill Bay: Mill Bay is a small community in the Malahat District on Vancouver Island. Residents rely on an aquifer to supply community water. This aquifer is also the site of a proposed sewage disposal field for a 400-home development slated for the area. In the spring of 1996, in preparation for an environmental appeal, residents discovered that Lot 60, which holds their aquifer, had been rezoned. A 1986 bylaw had amended the zoning to urban residential use without appropriate rezoning procedures being followed. The Concerned Citizens of Mill Bay used EDRF funding to file a petition in the Supreme Court of BC to quash the bylaw. The petition also requests an interim injunction prohibiting any further development or construction activities until the petition is heard.

Environmental Watch: Howe Sound Pulp and Paper has been out of compliance with its air pollution permit on many occasions. Rather than enforcing the current permit conditions, the Ministry of Environment approved Howe Sound Pulp and Paper's application for increased air emissions, allowing the company a 300 percent increase in sulphur dioxide emission levels and an 80 percent increase in nitrogen oxide emissions. With EDRF funding, Environmental Watch commenced a private prosecution in an attempt to bring the mill into compliance with its original permit. As a result of the group's actions, the Crown decided to take over the prosecution. Unfortunately, the Crown decided to stay the charges. The group is proceeding with an appeal of the permit.

Meziadin Lake Fellowship Association: Meziadin Lake Provincial Park is a 335 hectare park site near Stewart. During park improvements and road construction, a spawning stream was seriously damaged. The Association has had a number of meetings with representatives of BC Parks concerning remediation of the damaged spawning stream. Negotiations are continuing in an effort to improve campsite locations and the road entrance. The Association received EDRF funding to hire a lawyer and obtain expert advice. A fisheries biologist report commissioned with EDRF funds has been submitted to MoELP and DFO. The Association has also retained an environmental monitoring consultant who has conducted a field assessment to monitor construction techniques. When complete, this report will also be submitted to MoELP and DFO. No remediation of damaged fish habitat has been done as of yet, however, the group's lawyer continues to negotiate with government.

Fairfield Citizens for Safe Air: The Fairfield Citizens for Safe Air's concerns arose from the practices used to fill holding tanks at a Victoria gas station. The Citizens are residents of an older apartment building adjacent to the station. When the holding tanks were being filled, gasoline vapour escaped through the vents which were close to the apartment and drifted into the building through open windows, causing respiratory and other health problems. The group wanted the gas station to put a vapour recovery system in place.

After negotiations with the station management and the gasoline company the problems were addressed, but not satisfactorily. Vents were moved about 100 feet from their original location, but the building is still downwind. The Health Department inspected and did not approve the new arrangement. The refuelling trucks then started to practice "gasoline vapour diversion" — a process that traps fumes released in refuelling the storage tanks which, instead of recovering the gasoline vapour, simply releases it in a remote location. With EDRF support, the group obtained expert and legal advice to negotiate with their municipal officials and the gas company in an effort to completely resolve the situation and improve health conditions of residents.

Friends of the Similkameen Valley: The Metalex battery slag that was dumped in the Dankoe mine tailing pond has now been removed to Alberta for treatment. The region around Keremeos is mainly agricultural and residents of the area were concerned that the "special waste" found in the slag could contaminate water used both for agricultural and domestic purposes. To protect their water, the Friends launched an appeal. They were denied standing, although it was noted in the decision that an appellant living in closer proximity would likely be given standing. In May, Metalex agreed to comply with the EAB's direction to remove the slag from the Dankoe mine site. The residents of the valley are satisfied that their environmental concerns have been addressed and that their groundwater supplies have been protected.

If you have any questions about how the EDRF works, or would like an application form, please contact our office at (604) 6847378 or (toll-free) 1 800 330-WCEL.

Community Workshops on Conservation Covenants We are pleased to continue to offer workshops on the development and application of conservation covenants to preserve private land in BC. With the support of the Real Estate Foundation, we have held successful workshops in communities around the province over the last year, and look forward to more workshops over this fall and winter. These workshops are based on our publications "Here Today, Here Tomorrow" and "Leaving a Living Legacy". In a workshop format, participants can discuss the specifics of how to negotiate with landowners, how to get covenants drafted and registered with the Land Title Office, how to manage covenants over time, and the benefits of covenants. Topics covered in the workshop will include: the law governing conservation covenants, the potential uses of covenants, appropriate parties to the covenants, issues related to the negotiation and drafting of covenants; and, some of the practical aspects related to covenants. The workshops are held in partnership with community groups. We supply the resource person and pay for her travel to the workshop site; the community group finds participants and arranges for a workshop space. We are delighted that Ann Hillyer, former staff counsel with West Coast Environmental Law, continues to act as our resource person for these workshops. Ann is very knowledgeable on the subject of conservation covenants, and is the co-author of "Here Today, Here Tomorrow." Voluntary stewardship of private land is an essential component of a balanced approach to land use planning. Amendments to the Land Title Act in 1994 allowed conservation covenants, designed to protect a variety of ecological features of land, to be held by any person designated by the Ministry of Environment. Since that change to the law, community groups have started to apply for and receive designation to hold covenants, and we are very keen to provide the background information to community groups involved in this process. If you would like to host a workshop in your community, please call our office at 1 800 330 WCEL. You can also obtain copies of our publications through our office, and check them out of your community library.

We're counting on you! West Coast relies on your support to continue our important work. Together, we are a strong and active voice for environmental protection in BC. And now there are two new ways to make it easier for you to give us that support, and they're both tax-creditable. We are now able to accept your donations by VISA. Call our office for details. And we're pleased to announce our new West Coast Protector's program of monthly donations. Each month, you can make a small automatic donation of $10 or $25 to our work. The amount of your donation will be automatically withdrawn once a month from your VISA or chequing account, on the day of your choice. This type of regular support contributes to our ongoing campaigns. If you would like to be a charter member of our West Coast Protector's program, call us now! We're counting on you!

____ Yes! I want to be a member and receive NEWS           from West Coast Environmental Law. Here's $20. ____ Yes! I want to make a tax-creditable donation.           Here's my cheque for:           ___ $50 ___ $75 ___ $100 Name: ___________________________________ Address: _________________________________ City, Prov: ________________________________ Phone/Email: ______________________________ Postal Code: ______________________________