A Leap in the Wrong Direction

When the provincial government brought in the Forest Practices Codein 1995, the environmental community welcomed the regulatory reform effort as a modest "step in the right direction." More generous praise could not be justified because the Code essentially only took many of the existing policies from regions around the province and elevated them to the status of regulation.

This would improve enforceability, but not necessarily environmental practices on the ground. There were some new improved standards, such as for riparian reserve zones around large fish streams. The Code also brought in some useful tools to encourage sustainable forest practices if or when they are utilized.

However, the Code essentially took a discretionary, planning-based approach to forest practices by specifying the general content requirements of logging plans and granting district managers broad discretion to approve them. Whether the Code would lead to environmental good and increase public confidence in forest management depended in large measure on the quality of the plans submitted by the forest industry, and the diligence of the agencies of government reviewing and approving the plans.

Reacting to a concerted effort by the forest industry to reduce the alleged costs of implementing the Code, on April 2 the provincial government announced a massive overhaul of many of the key regulations. Some of the changes are welcome as they attempt to close former loopholes. However, the overall direction represented by these changes is, in our opinion, a leap in the wrong direction. Our assessment is that the changes cannot be fairly characterized as simply cutting red tape without compromising the environment.

Some of the changes eliminate important content of cutblock plans needed for assessing environmental impact. We foresee the potential for planning abuse around salvage logging "emergencies" in order to increase inventories of approved cutting permits. The changes will restrict the ability of the public to comment on logging plans. Logging companies will get legal approvals for cutblocks before important assessments are done. Green-up rules, which govern how soon after clearcutting the adjacent area may also be cut, will be relaxed, as will some road building standards. Some provisions will reduce the accountability of industry for logging practices, without any apparent cost savings attached to them.

Is there more to come?

Is the government considering getting out of the business of approving cutblock plans altogether? It appears so. Leaked documents we have received from a concerned government employee suggest that a second wave of changes is even more serious. Of the changes recently announced, an informant writes: "The forest industry has been given the power to virtually write the new regulations to their own liking…. The direction is to eventually eliminate the need for operational plans; the logging plan is to be eliminated immediately and the silviculture prescription to be eliminated within the next year or so. The silviculture prescription would in all probability still be required, except not submitted for Ministry of Forests approval."

Supporting documentation in the form of internal correspondence for these claims was also provided. It states: "…[W]e should pursue an option that eliminates the need for district manager approval of the silviculture prescription. This concept is critical to the administrative efficiencies that Operations Division [of the Forest Service] is pursuing … the two divisions are pursuing enabling legislation during the spring sitting to permit us to move down this road later in the year…"

Minister of Forests David Zirnhelt has confirmed to us that this is the direction he is guiding the Forest Service. These changes would overturn requirements which have been on the books since the 1980s, well before the Code.

The consequences of these combined changes would represent a significant step towards deregulating logging on public land in British Columbia. The present regulatory scheme is based on the preparation of plans by logging companies, with the public interest being represented by the agency which reviews and approves them. Removing agency approval of cutblock plans from this regulatory framework will mean the loss of important checks and balances respecting the public interest in fish, wildlife, water, recreation and other non-timber values. The Forest Service is apparently also considering whether to keep a file copy of silviculture prescriptions prepared by industry foresters. Silviculture prescriptions are seen as binding contracts between the landlord and tenant.

We are aware of no other example where access to crown resources is allowed according to the terms of contract
written by the tenant, and produced only if and when the landlord chooses to ask for it. How will the public interest be maintained if the logging industry alone writes this contract? Silviculture prescriptions have a term of between twelve and twenty years. The government's suggestion that accountability will be maintained through spot field audits rings hollow. With so little oversight, who will now ensure that contracts are written in enforceable language?

A Response to the Honourable Sergio Marchi

A statement by the Federal Minister of Foreign Affairs and International Trade has recently been published on the OpEd pages of newspapers across Canada. In that statement, Sergio Marchi claims to be setting the record straight on the MAI by responding to several "myths" that he believes misrepresent his government's efforts to negotiate a Multilateral Agreement on Investment. We have reproduced his arguments in italics below and follow each with our reply.

Let me deal with some common myths about the MAI:

[1] "Transnational companies could not be obligated to hire local workers." All corporations, both domestic and foreign, are currently required to look first in the Canadian labour market to hire employees. This requirement will not change.

In fact, the MAI clearly prohibits requirements that any company, whether foreign or domestic, "hire a given level of nationals" (Performance Requirements, section j). A narrow exception to this general rule would permit governments to continue to attach job creation conditions to government financial incentives. But otherwise, the MAI bans attaching specific job creation targets to policies that influence investment — for example, getting commitments from companies to maximize job creation in return for access to publicly owned natural resources.

[2] "Transnational companies could not be obliged to reinvest in Canadian research and development." Canada's research and development programs, including the granting of tax benefits, actively encourage reinvestment in Canadian research and development activities. The MAI will still allow Canada to attach conditions like job creation to incentive
grants to domestic and foreign companies.

Again, the MAI specifically prohibits a Party from requiring all investors, whether domestic or foreign, "to achieve a given level of research and development in the territory of a Party." (Performance Requirements, section i). Similarly, another MAI provision (Performance Requirements, section f) would prohibit requirements to transfer technology to local companies or persons. Because taxation measures are, for now, carved out of the MAI and a narrow exception is in place to permit governments to attach such conditions to subsidy programs, Minister Marchi's statement is literally true, but still misleading.

[3] "Transnational companies could not be obliged to include Canadian content in the ingredients of their products." These trade-distorting requirements are already prohibited under existing international trade agreements of which Canada is a member. These prohibitions serve Canada's interests abroad and Canada does not impose content requirements on companies operating in Canada.

While existing international trade rules do restrict certain trade-related investment measures, their scope is far narrower than that of the MAI. (Indeed, complaints from the US and transnational corporate lobbies about the limited scope of existing international rules is one of the main reasons why the MAI is being negotiated.) BC governments, of all political stripes, have historically sought to diversify the BC resource-based economy by encouraging local processing, higher value-added and, consequently, greater local economic benefits rather than the export of natural resources in their raw state. Minister Marchi dismisses this historic policy goal as "trade-distorting" and appears to be prepared to sign it away in the MAI.

[4] "Transnational companies could ignore Canadian environmental standards." Foreign companies, like domestic companies, would remain subject to all environmental laws and regulations applicable to businesses operating in Canada. This is fully compatible with the non-discrimination principle of the MAI. Foreign companies failing to comply with Canada's environmental laws and regulations would be subject to the same fines and penalties that Canadian companies face when they break our laws.

Serious concerns have been raised about how the MAI would expose environmental protection, and other laws, to challenge by individual investors. As Minister Marchi well knows, these are not merely hypothetical concerns. Legislation that effectively banned the use of MMT (a harmful fuel additive) that he introduced himself when serving as federal Minister of Environment, is now being challenged under NAFTA's investor-state dispute mechanism. Two separate investor-state challenges against Mexico both involve challenges against decisions of local authorities not to give approval for toxic waste dumps in their communities. Despite Minister Marchi's assurances to the contrary, corporations clearly recognize the MAI investor-state mechanism for what it is: a potent legal weapon enabling foreign investors to challenge environmental protection and other public policy measures.

[5] "Medicare could be weakened because non-Canadian competitors could demand the same subsidies currently directed to non-profit enterprises. This is wrong. Canada's health and social services are not on the table. Canada will retain our ability to maintain and introduce any measures necessary to preserve the integrity of our health and social programs. This would include measures favouring Canadian non-profit service providers.

The MAI is a so-called "top-down" agreement, which means literally that everything is on the table. Canada is trying to negotiate a country-specific exemption to protect its policy flexibility in health care and social services. Minister Marchi asserts that the exemption must be ironclad, but Canadian negotiators have submitted the same flawed exemption that Canada got in the NAFTA. Even this flawed exemption is being resisted and is by no means a foregone conclusion.

[6] "Companies could sue the government of Canada if Canadian laws hurt their business." Under current Canadian law, companies — domestic and foreign-owned — can already submit claims to Canadian courts if they believe that they have been unfairly treated by the government. The government of Canada will retain its ability to regulate. Canada will only accept a MAI that has a narrow interpretation of "expropriation" whereby legislative or regulatory action by government in the public interest is not expropriation requiring compensation, even if it has adverse profitability consequences for companies or investors.

It is true that Corporations, as legal persons, now have the right to sue our governments under Canadian law but only if they have some valid claim under Canadian contract or tort law. Under the MAI however, foreign investors would be given an extraordinary right to sue Canada before an international tribunal for any alleged breach of MAI rules. If the foreign investor stipulates, those proceedings would take place behind closed doors and be closed to public scrutiny and participation. Tribunal rulings would be binding and, under federal legislation, damage awards would be enforceable by Canadian courts. Moreover such claims can be made even where, but for the MAI, they would have no foundation in Canadian law.

Finally we are afraid that the Minister's assurances concerning the meaning of "expropriation" in the MAI is wishful thinking. We will soon have more definitive interpretation from the arbitration panel that is, as we noted, currently considering a claim against Canada by Ethyl Corporation for $300 million in damages. In that claim this US-based corporation argues that federal law restricting trade in MMT represents an expropriation of its business and good will in manufacturing this substance. These very same procedures and "expropriation" rules would now, if Mr. Marchi succeeds, be extended as a right to a much larger global community of foreign investors.

[7] "The MAI will have `standstill' (freeze) and `rollback' (phase-out) provisions that will restrict our freedom to pass future laws in sectors Canada wishes to protect." Canada has stated unequivocally that we will not accept any rollback or standstill in sectors we wish to safeguard such as cultural industries, education, health and social services and aboriginal matters. Canada will retain its ability to maintain existing measures and to introduce new ones.

Minister Marchi may be determined to achieve these negotiating objectives but there will be tremendous pressure on Canada to settle for less, and to accept some form of rollback. However, even if Canada's wish list of reservations is granted, this would still leave many areas of Canadian law and policy entirely exposed to MAI rules and law suits. For example, Canada has listed no reservation from many MAI rules including the one on "expropriation" noted above. Moreover, even if Canada does gain all of the exemptions it is seeking in politically sensitive sectors, these exemptions will be interpreted narrowly by dispute panels, and over time the pressure will grow to negotiate these reservations away. (We have already seen Canada's trade ministers and senior bureaucrats, after losing a key case against Canadian magazine promotion policies in the WTO, float the idea that Canada's policies to protect and promote cultural measures have outlived their usefulness.) Once the MAI is signed, and public attention is averted, negotiators will resume their work to ensure that these vestiges of Canadian sovereignty are submitted to the full force of global free trade rules.

BC Sets One Percent Cap on Wildlife Protection

Species "Thresholds"

Planning "thresholds" or ceilings have been set at regional, district and species levels on the number of WHAs that can be established. The stated goal of these thresholds is to minimize the impact on timber supply. The thresholds contradict the government's previous commitment that the one percent cap would be a provincial threshold and that "there is no plan to establish regionally specific limits."

The General Wildlife Measures (which specify what activities can be permitted within WHAs) are also dominated by timber harvesting considerations.

Of the thirty-four species covered by the General Wildlife Measures, outright protection from logging is only provided to four species (ancient murrelet, cassin's auklet, marbled murrelet, and Lewis' woodpecker). Similarly, outright protection from road construction is only provided to four species (Vancouver Island marmot, mountain beaver, cassin's auklet and ancient murrelet).

Logging and Roads in WHAs

In addition, through use of a variance procedure, the General Wildlife Measures permit timber harvesting in WHAs for at least fourteen species. Road construction can be authorized by variance for over 25 wildlife species and all four plant communities. Permitting such high levels of timber harvesting and road construction inside WHAs will jeopardize the modest habitat protection WHAs will provide. The Endangered Species Coalition believes that there should be no logging or road construction whatsoever inside WHAs.

Despite these significant flaws, the BC government is attempting to present the IWMS as a key component to fulfilling BC's commitments under the National Accord for the Protection of Species at Risk. We believe that this is indefensible, given the one percent cap on protection and the following key deficiencies:

• the IWMS only applies to crown forest land and crown range land and some forest- and range-dependent species;

• habitat protection under the IWMS is often optional and in some cases subject to forest practices;

• there is no independent scientific process to list species at risk;

• there is no legal protection for identified wildlife;

• there is no process in place to develop recovery plans for identified wildlife and no requirement to implement recovery plans in a timely fashion; and,

• there is no requirement to include consideration of identified wildlife or any species at risk in BC's environmental assessment process.

IWMS is Inadequate

In our view, the IWMS comes nowhere near meeting BC's commitments to endangered species protection under the National Accord. Rather, the IWMS represents a piecemeal approach to species protection, relying on a series of disparate and weak initiatives to protect species at risk. To provide "effective protection" for species at risk as required by the National Accord and to address the specific obligations listed in the Accord, BC needs to introduce comprehensive, stand-alone endangered species legislation. All the provinces, with the exception of BC and Alberta, have endangered species legislation in place, have introduced draft legislation or committed to do so. It is now time for BC to follow suit.

The BC Endangered Species Coalition has prepared a detailed critique of the IWMS. To discuss the IWMS, or to obtain a copy of this critique, contact Kate Smallwood at West Coast Environmental Law, at (604) 601-2507, or via email at ksmallwood@wcel.org.

Feds Backtrack on Endangered Species

The federal government is backtracking on strong protection for species at risk. Bill C-65, the Canada Endangered Species Protection Act, is now off the Liberal government's legislative agenda. There is no real indication as to what form replacement legislation will take, and when it will be introduced.

In addition to recent attempts to weaken the National Accord for the Protection of Species at Risk, the federal government is also trying to restrict protection for international transboundary
species to species which have an established migration route into Canada (i.e., grizzly bears, marbled murrelets, caribou and spotted owl would not be covered), and allow national listing of species at risk to be decided by politicians, not scientists. This would be disastrous for species protection in Canada. The provincial governments have proven that political listing does not work. BC's political listing process has resulted in only four of BC's 292 endangered and threatened species being listed.

The New York Times has just published an article — front page news — entitled "Canada No Safe Haven for Birds or Bears." The article drew international attention to the failure of both the federal and the BC governments to provide effective protection for species at risk.

West Coast and the BC Endangered Species Coalition will continue to work for strong endangered species legislation both federally and provincially and ensure that both governments live up to their commitments under the National Accord.

Increased Fees and Long Delays Expected for those seeking Access to Information

The provincial Treasury Board has recently announced changes which will likely make it much more difficult and expensive to access government information. Significant cuts will be made to offices which deal with information requests, and much higher fees will be imposed on those seeking to obtain information.

The changes have been announced despite the fact that an all-party Legislative Committee has been struck to hear submissions from the public and make recommendations on reforms to the Freedom of Information and Protection of Privacy Act (FOIAPPA). The Committee was expected to report to Cabinet this fall. In the several months since the Committee was formed, West Coast, along
with its clients and other public interest groups, has been advocating:

• strengthened access to information;

• a streamlined process to save money for government and time for all those involved; and,

• an assurance that fees — which may constitute a barrier to access — will not be imposed.

Last week, with apparent disregard for ongoing efforts by the Committee and members of the public, the government announced the changes. The Information and Privacy Commissioner responded by saying he fears that the funding cuts signal an attack on the information and privacy rights of British Columbians.

FOIAPPA is a valuable tool for West Coast and its clients. It has allowed access to important documents without which we would have been unable to adequately protect the environment.

If you are concerned about access to information, we urge you to join us in pressuring the government to support and strengthen freedom of information law in the province. You can express your concern about the recent announcement by writing to Minister of Advanced Education, Training and Technology Andrew Petter at 248 Parliament Buildings, Victoria, BC, V6B 1X4. He can also be reached by phone at (250) 387-3751, by fax at (250) 387-5594, or via email at andrew_petter@bc.sympatico.ca.

First Nations and Environmentalists Open the Lines of Communication

At a recent weekend meeting in Vancouver, jointly sponsored by the First Nations Summit and the BC Environmental Network, West Coast was one of a number of environmental groups taking part in discussions with First Nations from all over BC.

The conference included presentations and workshops on topics such as land and resource protection, the BC treaty process and proposed future economies within the province. Beyond the substance of the meetings, the conference provided opportunities — unique for many envi
ronmental groups — to engage in building relationships with First Nations representatives.

The conference was organized in an effort to continue direct dialogue between First nations and sectoral-based interests and to provide a forum to create a greater understanding of the BC treaty process. This is one of many similar initiatives currently being organized by the First Nations Summit.

The conference opened Friday with remarks by Dr. David Suzuki, and continued through the weekend with chaired
sessions and workshops on aboriginal rights, forestry, fisheries and alternative economies.

All present recognized that such dialogue is a beginning, and no one felt the work to be done together was completed after just three days. But the sessions revealed a number of common links between the two groups, including a sense of responsibility toward future generations; an understanding of the Earth's limited carrying capacity; and a mutual desire to work together wherever possible on planning and problem-solving.

WCELA Defends Basel Ban in Malaysia

The Basel Convention — and West Coast's Role

The United Nation's Basel Convention seeks to control the transboundary movement of hazardous waste. The Convention was a response to horror stories of the 1980s, when hazardous waste from developed countries was dumped in Africa, damaging human health and the environment. The problem has not gone away; the rising costs of disposal make it attractive for unscrupulous industries and countries to find ways of dumping hazardous waste in unsuspecting countries.

West Coast Environmental Law has actively sought improvements to the Basel Convention in recent years. Our most recent efforts took place at the Fourth Meeting of the Basel Convention Parties (COP 4), held in Malaysia this February. West Coast president Wally Braul was appointed to the Canadian delegation to represent Canadian environmental group interests.

The Central Issue at COP 4

Since the Basel Convention's inception, the single defining issue has been whether the Convention should ban shipments of hazardous waste from `developed' (i.e., OECD) countries to other countries. In 1995, after vigorous debate, the Third Meeting of the Parties (COP 3) agreed, by consensus, to amend the Convention to include a ban. Canada, while voicing concern over the ban amendment, went along with that consensus in 1995. Many participants at COP 3 were relieved to reach closure on this basic issue.

The Parties instructed technical experts to develop a clearer definition of "hazardous waste" before COP 4, after which, it was assumed, Parties would start the
process of ratification. (For the ban to come into force, two-thirds of the 120 or so Parties must ratify it.)

The new definitions were presented at COP 4 and received solid support, but other complications arose. COP 4 ended up being preoccupied, once again, with the ban issue. The meetings witnessed attempts to undermine the 1995 ban decision by a small but active and influential number of Parties. Canada was one of those Parties. These attempts failed. West Coast argued, in concert with other environmental organizations and Convention Parties, that the ban has received unequivocal world support and should be accepted as a reality. Canada, we argued, should get on with ratifying the ban. Canada has given no indication as to whether it intends to do so.

The Canadian Position

Canada attributes paramount importance to the Convention principle that hazardous waste be handled in an "environmentally sound manner." Few would dispute that hazardous waste should be handled in such a manner. The contentious aspect of Canada's position is that the "environmentally sound management" principle should allow developing countries to import hazardous waste from developed countries to enhance local recycling capacity and economies of scale, that these movements should not be subject to the ban.

Canada's position was roundly criticized by many Parties and environmental groups in Malaysia. In line with many other Parties and environmental groups, West Coast's position was that:

• so-called recycling operations in developing countries can be shams for irresponsible dumping (many cases of sham operators were presented at the meeting);

• the existence of the opportunity to ship hazardous waste from developed to other countries removes the incentive to produce less waste in the first place;

• the ban was adopted by consensus in 1995 and has not yet been given a chance to work; and,

• the Convention has not matured to the point of making a well-informed decision as to whether certain types of shipments could legitimately be exempt from the ban.

Canada was taken aback by the criticism. It had hoped to obtain support from developed and many other countries, but it became evident that Canada had seriously overestimated its support. To make matters worse, Canada was identified in the Asian newspapers as one of few developed countries seeking to erode the ban (earning its place in the "Hall of Shame").

Canada's position attracted widespread speculation at the meeting. Was Canada hiding a current or future shipment to the third world? There is little evidence of this. Is Canada reluctant to amend its laws to effect the Basel ban? No — the existing Canadian Environmental Protection Act, and especially the new CEPA in Bill C-32, is a relatively strict approach which already goes a good distance to implementing the Basel ban.

We also wonder why Canada chose its Basel position when, unlike the positions it took in Kyoto and other Conventions, adopting the ban would not lead to the loss of a single job. Why would Canada not, for domestic political reasons, affirm the importance of the ban?

And Now the Details: The Key Decisions at COP 4

The Parties made more than a dozen decisions. The following three decisions were most significant for West Coast Environmental Law.

1. Defining "Hazardous Waste"

For two years leading to the Malaysia meetings, the Basel Convention's Technical Working Group developed a detailed definition of "hazardous waste." This work was critical, as many Parties stated at the 1995 Meeting that they would not consider ratification of the ban until adequate definitions were in place. The Parties in Malaysia decided to adopt the new definitions.

Many environmental groups, including West Coast Environmental Law, have generally been supportive of the definitional work. Canada supported the adoption of the new definition and showed leadership in the development of the definition.

Controversy arose when certain Parties proposed that industries and countries should be given a unilateral right to undertake a self-assessment to remove an otherwise "hazardous waste" from the definition. We expressed strong reservations about this approach. Canada took the more conciliatory view that, as a matter of principle, there is a need for "testing out" with transparent safeguards (and West Coast does not necessarily disagree with this principle). The Parties did not adopt a particular testing out process at COP 4, but directed experts to prepare proposals before the next meeting of the Parties (1999). We will monitor Canada's position on "testing out."

2. Denying Israel's and Monaco's Applications to Join Annex VII

Israel and Monaco applied to join Annex VII (the Convention's list of `developed,' or OECD, countries which are subject to the ban). Joining Annex VII would mean that these countries could accept hazardous waste from other countries without being subject to the ban. The applications triggered intensive debate, and caused the Parties to consider the larger question of whether Annex VII should ever be changed.

Our position in Malaysia was that accepting the applications would be premature, especially if done prior to ban ratification. We also expressed concern that the applicants were made on the basis of `self-declarations' that their environmental regimes are conducted in an "environmentally sound manner." West Coast argued that, at most, an application for Annex VII status might occur only if:

1. the ban comes into effect,

2. after Step 1 occurs, principled criteria are developed to assess whether it is prudent to even open the Annex VII list,

3. if Step 2 discussions conclude that Annex VII can, in principle, be opened, then the Convention must mature to the point of developing objectively verifiable standards of "environmentally sound manner" (there are few existing standards today), and

4. the Convention creates an arm's length review to consider whether a particular applicant meets the standards.

Canada appeared willing, at least initially, to support the applications from Israel and Monaco. To its credit, Canada eventually went along with the consensus decision of the Parties which rejected the applications, urged the Parties to ratify the ban, and created a process for exploring Annex VII issues. West Coast supported this decision as well.

3. The Decision on the Liability Protocol

The Convention's legal experts are in the process of drafting a civil liability protocol which is primarily designed to provide civil remedies to victims of hazardous waste disposal. The drafting work has been dragging on for some time, and the Parties, Canada included, requested further intersessional work on the draft. Many developing countries emphasized the importance of adopting a protocol, especially since they do not have adequate enforcement and legislative resources. Those Parties made strong representations that a final draft be presented at COP 5 for adoption. Canada does not view the development of the protocol as a high priority, but will likely continue to participate in the drafting sessions.

West Coast expressed the view that Canada should not only continue to be an active participant in the development of the protocol, but that it should also contribute expert and financial resources to ensure that a final draft is presented to COP 5.

Conclusion: The Time is Right for Ratification

Environmental group representatives, West Coast included, were relatively satisfied with the results of COP 4. The next major challenge is to convince Canada to ratify the ban before COP 5 (December 1999).

As noted above, Canada already has relatively strict controls in place. The significance of Canadian ratification is not merely symbolic, however. We believe that Canada has significant influence at Basel Convention deliberations: ratification by Canada would send a clear signal to many other countries that it is time to bring the Basel ban into effect.

A Final Word on Process

Ambassador John Fraser led the Canadian delegation. Aside from the Ambassador, the delegation consisted of four senior federal officials and single representatives from the Canadian Council of Ministers of Environment, industry, and the Canadian Environmental Network (represented by West Coast Environmental Law). It is clear that West Coast disagrees with the Canadian government position on several key policy issues. It is worth emphasizing, however, that Ambassador Fraser's process was fair and even-handed. Frank and candid exchanges of views were conducted in a climate of mutual respect and civility.

— Waldemar Braul, President

Web Site Update: stay tuned... We are working on an overhaul of the WCEL web site, so stay tuned! While the site will boast a brand new look and navigation system, we are also reorganizing the information contained within the site. The site will be subdivided into areas based on our current work, such as: Endangered Species, Climate Change, Forestry and Land Use, and International Trade and Investment. Hopefully, this will make finding what you are looking for a lot easier. If you have any suggestions, drop us a line at admin@wcel.org.

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!

West Coast staff and project workers are: Morgan Ashbridge, David Clark, Andrea Finch, Mark Haddock, Chris Heald, Patricia Houlihan, Sandra Janzen, Catherine Ludgate, Alexandra Melnyk, Linda Nowlan, Chris Rolfe, Steven Shrybman, and Kate Smallwood.

We are grateful to the Law Foundation of British Columbia for core funding of West Coast Environmetnal Law.

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