The Facts
 
The City of Vancouver and its contractor Blackwell Consulting Ltd. have been conducting tree risk and fire prevention operations in Stanley Park since fall of 2023, resulting in the removal of 11,016 trees. So far, the operations have affected approximately 58% of the 263 hectares of native forest in Stanley Park . Another operation to address the remaining 42% is imminent.
  
All the tree removal operations thus far, and the impending operation, are supported by a single TRAQ assessment conducted in spring 2023. References to TRAQ methodology are contained throughout the report. The report states at least one member of each crew had ISA TRAQ credentials. No mention is made of the Wildlife Dangerous Tree Assessor's Course nor is there any representation made that any crew member had completed the Wildlife Dangerous Tree Assessor's Course.
  
The Stanley Park forest is a municipal park and recreation area containing native tree species including coastal western hemlock, Douglas fir, western red cedar, red alder, and big leaf maple.
  
Portions of Stanley Park have been developed into commercial amenities such as restaurants, sports fields, tennis courts, and the Vancouver Aquarium. Non-native trees can be found in these areas. Such developed areas might appropriately be characterized as “urban and/or rural interface areas” because they constitute a transition to the interior undeveloped native forest. Within the interior forest, there are a small number of paved roads and multiple dirt paths, as is typical in parks and recreation areas. The tree removal operations are taking place in the interior forest, not the interface.

The tree removal projects have entailed helicopter operations on steep, unstable terrain. A memo describing helicopter operations states that tree assessments will be made by “an accredited Tree Risk Assessor,” but does not specify that a certified WHTAC assessor will be employed.

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WorkSafeBC Regulations and Guidelines 

The WorkSafe BC Guidelines to Part 26 of the British Columbia Occupational Health and Safety Regulation state at G26.1-1:

For greater certainty, WorkSafeBC considers the following to involve "harvesting trees" and to therefore be "forestry operations":

• Harvesting timber for processing or sale either pursuant to a license or permit from the Provincial Government, or on a private woodlot
• Falling trees in connection with forest fire fighting or fire prevention activities [emphasis added]
• Falling trees in connection with oil and gas exploration and site preparation, including seismic line falling

The WorkSafe BC Guidelines to Part 26 of the British Columbia Occupational Health and Safety Regulation state at G26.11:

For the purposes of section 26.11 of the Regulation, currently there are two training programs acceptable to WorkSafeBC, each with a different focus.
  
In the context of forest harvesting & silviculture, parks & recreation, and wildland fire safety operations, only a person who has completed the Wildlife Dangerous Tree Assessor's Course, administered by the Wildlife Tree Committee (WTC), can complete a risk assessment and make recommendations for managing dangerous trees.
  
The WTC is a multi-agency committee composed of representatives from the provincial Ministry of Forests and Range, Ministry of Environment and Climate Change, WorkSafeBC, industry, labour, and public interest groups from across the province. The training course provides information and technical procedures for assessing dangerous trees and establishing appropriate safe work practices in situations where there is potential exposure of workers.
  
With respect to arboriculture operations, the Tree Risk Assessment Qualification (TRAQ) course provides training with respect to the assessment of dangerous trees that exist in urban areas and urban and/or rural interface areas, and is an acceptable training program to WorkSafeBC for dangerous tree assessors in that industry. The TRAQ course is administered by the International Society of Arboriculture (ISA).

The British Columbia Wildlife Tree Assessor’s Course Workbook: Parks, Recreation Sites & Trails Course Module, updated December 2024 states (p. iii):

The hazard criteria and tree assessment procedures taught in the course can be reliably and defensibly used to inform land managers where to implement mitigation strategies that will promote visitor safety while preserving trees of significance. The majority of assessment procedures recommended in this training are applicable to BC Parks and Recreation Sites & Trails BC. They can also be applied to native tree species found in municipal parks or other wooded areas, such as golf courses and ski hills. 
  
This training program retains the same technical tree assessment procedures recognized as the provincial tree assessment standards developed by the Wildlife Tree Committee and used in the other provincial dangerous tree assessment modules developed to protect workers engaged in Forest Activities and Forest Fire fighting. These worker safety modules are applied to tree assessments in worksites in recognition of employer responsibilities to manage tree hazards under Part 26 of the Occupational Health and Safety Regulation, as administered by WorkSafe BC. 

City of Vancouver Associate Director of Urban Forestry Joe McLeod, for whom the Blackwell TRAQ Assessment was prepared, implied at the July 21, 2025 Park Board Committee meeting in response to a question from Vancouver Park Board Commissioner Thomas Digby that WHTAC is the correct manual for Stanley Park operations (9:45 PM). The exchange went as follows:

Commissioner Digby: So, where we last left off, we were comparing WHTAC (the wildlife hazardous tree assessor's guidance) to the TRAQ, and can you just say that again clearly? Do you think TRAQ applies more to urban parks which is why we use it here in Stanley Park as opposed to WHTAC which is for rural parks, BC campgrounds that sort of thing which have a lot fewer visitors on an annual basis we could say?
  
Joe McLeod: That's correct. TRAQ is definitely well suited, it's well suited to both urban and rural environments, but I think it's better suited to urban environments. The other methodology that you're referring to is more consistently used in industrial forestry applications. There are considerations within those methodologies looking at the use of helicopters, for instance, that are flying overhead where the prop wash from a helicopter can cause trees to fail unexpectedly impacting workers [emphasis added]. There are also considerations around the really the low level of use so the relatively infrequent or occasional use of some of the more rural kind of campsites or rural parks that that this would apply to whereas Stanley Park with you know nearly 20 million visitors a year, definitely we're getting well outside of the applicability of the . . . [inaudible]

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Summary of Violations

WHTAC uniquely provides extensive directives to protect workers and also to consider the value of wildlife trees in making mitigation recommendations and decisions. These considerations are not present in TRAQ.
  
The City of Vancouver and its contractors are required by the WorkSafe guidelines to employ certified WHTAC assessors who conform to the WHTAC standards in performing tree risk assessments in the Stanley Park forest. It is also clear that the City and Blackwell are in contravention of the guidelines for the following reasons:
 

• Blackwell’s work constitutes forestry operations and timber harvesting.
• Stanley Park is a municipal park and recreation area with native tree species.
• The tree removals are taking place in a native forest, not an urban interface.
• The tree removal operations have entailed the use of helicopters.

Moreover, the Blackwell TRAQ Assessment, in addition to employing TRAQ rather than the WHTAC as required, is two- and one-half years old and therefore expired.
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Remedy Sought

For the above reasons, we believe that the City of Vancouver and its contractor should be required to conduct an updated assessment of Stanley Park using WHTAC certified assessors and WTC assessment protocols before additional tree removals are allowed to proceed.

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Four citizens of Vancouver and the Stanley Park Preservation Society appeared before the Supreme Court of British Columbia on November 5 - 7, 2025 to help preserve Stanley Park by blocking further unnecessary and destructive logging.

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Assertions and characterizations made in this document are the opinions of the authors.