Granite spires of the Bugaboo Range rising out of blue cloud and mist at dusk.

Bugaboo Range, Purcell Mountains · Photo: ImagePerson, CC BY-SA 4.0

EDITORIAL · 30 BY 30

NDP minister Nathan Cullen signed B.C.’s $1-billion 30 by 30 deal. We looked at who stands to benefit. It isn’t the public.

The agreement Cullen signed never mentions public access. A mining company books the hectares toward its own goal, a coal miner pays for land where it operates, the charity that holds the land declares $24.1 million from the ministry it lobbies and sets its own rules of entry, and heli-skiing continues by permit in a valley with no road. Darkwoods is permit-only, sleds banned. Here are the names, the money and the receipts.

British Columbia has promised to protect 30% of its land by 2030. It stood at 20.0% at the end of 2025, about 9.5 million hectares short.2 The plan is sold as conservation for everyone. The documents show what each party gets back. A mining company books hectares against its mines. A coal company pays for land where it operates. A charity holds $1.2 billion in land and is paid by the ministry it lobbies. Donors take tax breaks no ordinary gift receives. Governments get the count. The public gets a $1-billion agreement that never once mentions public access.161714122734

Diagram titled How the money reaches the 30% target. Left column, money in: Government of Canada (the Natural Heritage program requires partners to raise $1.50 per federal dollar; $20 million plus $7 million to the Kootenay Forest Lands; up to $500 million under the tripartite agreement); Province of B.C. ($15 million to NCC in April 2023 with no published purpose; $7 million for the Kootenay Forest Lands in 2025; $24.1 million in all as NCC declares it); mining companies (Elk Valley Resources $20 million; Teck $16 million to NCC projects since 2022 toward a 3-for-1 hectare goal); foundations and donors (Wyss, Wilburforce, Rosenfeld Family Fund; ecological gifts carry zero taxable capital gain). Centre: Nature Conservancy of Canada, a registered charity with audited statements, $1.21 billion in conservation lands and agreements, 40.8 per cent of revenue from governments. Below it: public process required? Buying private land, none; Cabinet designating a conservancy, none found in statute. Right column, out: private land held by the charity, 364 B.C. records and 125,411 hectares counted as privately protected areas in 2024 and 2025; tenure bought out then a Crown conservancy, the Incomappleux, 58,654 hectares, where heli-skiing may continue by permit; the charity sets the rules of entry, Darkwoods permit only with snowmobiles banned; counted toward 30 per cent, with B.C.'s entire 0.2 per cent gain in 2024/25 coming from local governments and land trusts.
Pieced together from the Province’s own payment records, the charity’s filings and federal releases. Every figure is cited below.81031112171619271415622212425528

01 Teck, Glencore, the Nature Conservancy of Canada and the NDP government each call 30 by 30 a gift to nature. Their own documents show what each gets back.

Every party to 30 by 30 in B.C. describes its part as a gift to nature. Each one’s own documents show a return. Nothing here needs to break a law to be wrong; legal is not the same as clean. Set the words beside the receipts.

What each party says it gives to nature, and what its own documents show it gets back

Teck Resources

Don Lindsay, then CEO, 2022; Jonathan Price, CEO, 2023

What they say

“Teck is taking action to protect nature” in the Incomappleux.

What they get

Its own goal: conserve at least 3 hectares for every 1 its mines affect. Its $2 million “funded 37,500 hectares” toward that goal.2016

Glencore’s Elk Valley Resources (EVR)

Mike Carrucan, CEO · four steelmaking coal mines

What they say

“EVR is helping to conserve vital habitat while creating lasting social benefits for local communities.”

What they get

$20 million for land “in the region where we operate”, credited as “a key enabler” of the deal.171839

Nature Conservancy of Canada (NCC)

Catherine Grenier, President and CEO; Nancy Newhouse, B.C. regional vice-president

What they say

“Proof of what we can accomplish when we come together for nature.”

What they get

$1.21 billion in land and agreements. 40.8% of revenue from governments. $24.1 million declared from the ministry it lobbies.18141512

Darkwoods carbon

Nature Conservancy of Canada

What they say

A forest “managed for conservation”.

What they get

450,000 offsets sold to a Crown corporation, the Pacific Carbon Trust, for $4.5 million.2526

Wyss Foundation

Founded by Hansjörg Wyss, Swiss billionaire, $4.8B (Forbes)

What they say

“A $1.5 billion campaign to help protect 30% of the planet by 2030.”

What they get

A named funder of the charity’s Incomappleux deal, in a province chasing the same 30% its campaign sells.343919

Heli-ski operators

Permit holder not published

What they say

“Compatible with the conservancy designation.” (the ministry)

What they get

Skiing by permit in a valley with no road access and no hunting.2122

Donors

Named funders include the Rosenfeld Family Fund, Wyss and Wilburforce

What they say

Gifts to protect nature forever.

What they get

Zero taxable capital gain on an ecological gift, no income limit, covenant terms “determined by the donor”, and land closed if access is “against the wishes of the donor”.272519

Governments

Premier David Eby; Randene Neill, Minister of Water, Land and Resource Stewardship

What they say

“Protecting our wild spaces for generations to come is one of the most important things we are doing.”

What they get

Hectares counted toward 30% with no expropriation, no bill and no public hearing, much of the bill paid by others.2018285

The public

What they say

Told 30 by 30 is for everyone.

What they get

No access clause in the $1-billion agreement. Darkwoods: permit only, sleds banned.324

The same circle funds the land, lobbies for it, holds it and counts it. The ministry that pays the charity is the ministry the charity lobbies. The companies that pay are the companies whose mines need the hectares. The governments that count the land never had to buy it, expropriate it or hold a hearing on it. The public, in whose name all of it is done, has no seat at that table and no clause in the agreement.12371617283

All of it happened under the BC NDP. Nathan Cullen, then its Minister of Water, Land and Resource Stewardship, signed the agreement. Its ministry made the payments. Its Premier took the meeting.3113735

In our view, under the NDP, 30 by 30 has become a way to channel public money toward the wealthy and the well-connected: a billionaire’s foundation helping choose what gets protected, mining companies earning credit for their footprint, a charity with a $1.2-billion land bank, and heli-ski permits that outlast the public road.39161421

In our view, that is a structure riddled with conflicts of interest. Nothing in it is hidden and, as far as the record shows, nothing in it is illegal. In our view, that is what corruption looks like when it is legal.

Exhibit Who’s who: the NDP ministers who signed and paid, the officials the charity lobbied, and the companies that put money in
David Eby
BC NDP

David Eby

Premier

Met NCC’s lobbyist with ten ministers on new protected areas. Announced the Incomappleux.

8 Dec 2022; 25 Jan 20233720

Nathan Cullen
BC NDP

Nathan Cullen

Minister, Water, Land and Resource Stewardship, at signing

Signed the tripartite agreement for B.C. Minister when his ministry paid NCC $15 million. Named in 6 NCC lobbying reports.

Apr 2023; 3 Nov 202331137

Randene Neill
BC NDP

Randene Neill

Minister, Water, Land and Resource Stewardship

Celebrated the Kootenay Forest Lands. Named in 4 NCC lobbying reports in 2025. Her ministry paid NCC $1.5 million in April 2026.

2025–2618371138

Lori Halls
B.C. public service

Lori Halls

Deputy Minister, Water, Land and Resource Stewardship

Named in 11 NCC lobbying reports, the most of any official.

Aug 2022–Jun 20263738

Jennifer Psyllakis
B.C. public service

Jennifer Psyllakis

Assistant Deputy Minister, Water, Land and Resource Stewardship

Named in 8 NCC lobbying reports, three of them under the spelling “Psylakkis”.

2022–202637

David Muter
B.C. public service

David Muter

Assistant Deputy Minister, Land Use Policy, Planning and Ecosystems

Named in 2 NCC lobbying reports.

Aug 2022; Feb 202537

Tamara Davidson
BC NDP

Tamara Davidson

Minister, Environment and Parks

Runs BC Parks, which runs the Incomappleux. Named in 2 NCC lobbying reports.

2025373822

Ravi Parmar
BC NDP

Ravi Parmar

Minister, Forests

Named in 3 NCC lobbying reports.

20253738

Bruce Ralston
BC NDP

Bruce Ralston

Then Minister of Forests; earlier Energy and Mines

Praised Teck’s 3-for-1 goal. Quoted on the Incomappleux tenure release.

Jun 2022; Jan 20231620

Steven GuilbeaultJonathan Wilkinson
Government of Canada

Steven Guilbeault, Jonathan Wilkinson

Federal ministers

Signed the tripartite agreement for Canada: up to $500 million.

3 Nov 20233

Julie DabrusinNathalie Provost
Government of Canada

Julie Dabrusin; Nathalie Provost

Federal Environment minister; Secretary of State (Nature)

Announced $20 million for the Kootenay Forest Lands. Provost: public funding can “spur additional contributions from the private sector”.

16 Dec 20251018

Catherine Grenier
NCC

Catherine Grenier

President and CEO, Nature Conservancy of Canada

Files NCC’s B.C. lobbyist registration, which declares $24.1 million from the ministry it lobbies.

2020–20263712

Nancy Newhouse
NCC

Nancy Newhouse

B.C. regional vice-president, Nature Conservancy of Canada

NCC’s lobbyist on 62 of its 67 B.C. reports, including the meeting with Eby.

2020–2026371320

Mike Carrucan
Glencore · EVR

Mike Carrucan

CEO, Elk Valley Resources (Glencore)

Announced $20 million for the Kootenay Forest Lands.

Dec 202517

Jonathan PriceDon Lindsay
Teck

Jonathan Price; Don Lindsay

Teck CEO; former CEO

Set the 3-for-1 hectare goal; tied the Incomappleux gift to it.

Jun 2022; Jan 20231620

Stuart Card
Interfor

Stuart Card

Vice-president, Interfor

Spoke for the company that released 75,000 hectares of tenure. Its payment is not published.

25 Jan 202320

The First Nations Leadership Council signatories of the tripartite agreement: Regional Chief Terry Teegee (BC Assembly of First Nations); Cheryl Casimer, Robert Phillips and Hugh Braker (First Nations Summit); Grand Chief Stewart Phillip, Chief Don Tom and Chief Marilyn Slett (Union of BC Indian Chiefs). Each new area under the agreement requires the consent of the Nations concerned.3

Portraits: Province of British Columbia (Eby, Cullen, Neill, Davidson, Parmar, Ralston, Halls); House of Commons (Guilbeault, Wilkinson, Dabrusin, Provost); Nature Conservancy of Canada (Grenier, Newhouse); Teck Resources (Price); Western Association of Fish and Wildlife Agencies (Psyllakis); Truck Loggers Association (Muter); Elk Valley Resources (Carrucan); Asia Pacific Foundation of Canada (Lindsay); Interfor (Card).

02 In April 2023, Nathan Cullen’s ministry paid the Nature Conservancy of Canada $15 million. The Public Accounts don’t say what for.

Start with the Province. In April 2023 the Ministry of Water, Land and Resource Stewardship paid the Nature Conservancy of Canada $15 million. Nathan Cullen was the minister. Lori Halls was the deputy.1137 The Public Accounts record the payment. They do not record the purpose.

Exhibit 01

Province of B.C. · Public Accounts 2023/24 · Detailed Schedules of Payments, Government Transfers · printed page 642

gov.bc.ca
A line of the Public Accounts schedule of government transfers: THE NATURE CONSERVANCY OF CANADA, 15,000,000; Water, Land and Res Stewardship, 15,000,000. The entry is boxed.
One line. Fifteen million dollars. No purpose.11 Source: gov.bc.ca

NCC declares the same $15 million, dated 6 April 2023, on its own lobbyist registration. That registration declares $24.1 million in all from the ministry.12 Randene Neill now runs the ministry. In December 2025 she said: “Our government celebrates the securement of the Kootenay Forest Lands.” Her ministry’s $7 million went into that deal.1813

$16.5M, no stated purposeFour payments from the Ministry of Water, Land and Resource Stewardship to the Nature Conservancy of Canada. Two of them, $16.5 million together, have no published purpose.

Purpose not publishedPurpose identified
Apr 2023purpose not published$15M
Apr 2024Kwiakah, Old Growth Nature Fund$0.57M
Apr 2025matches B.C.’s Kootenay Forest Lands share$7M
Apr 2026purpose not published$1.5M
Government transfers in the Public Accounts, matched to the dates NCC declares on its lobbyist registration, which totals $24,141,261 from the ministry. The $7 million matches the provincial share reported for the Kootenay Forest Lands.111213

Then Ottawa. Federal ministers Steven Guilbeault and Jonathan Wilkinson signed the tripartite agreement for Canada: “up to $500 million”, and “the funds will be matched”.3

Exhibit 02

Tripartite Framework Agreement on Nature Conservation · clause 11.1 · page 16 of 20

canada.ca (PDF)
Clause 11.1: To support implementation of this Agreement, Canada will contribute up to $500 million over the duration of the Agreement from the Enhanced Nature Legacy, Old Growth Nature Fund, Nature Smart Climate Solutions Fund, and 2 Billion Trees Program, where initiatives align with program requirements. The funds will be matched as per the terms and conditions of the funds. The first and last phrases are boxed.
Matched money is where private money comes in.3 Source: canada.ca (PDF)

The match is the point. Every federal dollar through the Natural Heritage Conservation Program must bring $1.50 from somewhere else. The rule began at two to one. It was cut to 1.5 “at the request of the recipient”, in the words of Environment and Climate Change Canada (ECCC), and NCC delivers the program.89 In December 2025 the federal Environment Minister, Julie Dabrusin, announced $20 million more for the Kootenay Forest Lands, on top of $7 million.10 The federal Secretary of State for Nature, Nathalie Provost, said it plainly: “public funding can spur additional contributions from the private sector and philanthropic donors.”18

The same design runs through the larger deals. The Great Bear Sea combined $200 million from Canada, $60 million from B.C. and $75 million from philanthropy.30 The Province’s $300-million Conservation Financing Mechanism is $150 million of public money, “matched by a commitment to raise an additional $150 million from the BC Parks Foundation.”31

Neill’s ministry has not said what the $15 million bought.

03 The Nature Conservancy of Canada holds $1.2 billion in land, takes 40.8% of its revenue from governments, and lobbies the ministry that pays it.

All of it lands on one balance sheet. The Nature Conservancy of Canada carries $1.2 billion in conservation lands and agreements.14

Exhibit 03

Nature Conservancy of Canada · audited financial statements, year ended 31 May 2025 · Statement of financial position · page 4

natureconservancy.ca (PDF)
The statement of financial position. Boxed: Conservation lands and agreements, note 5, 1,205,901,526 dollars in 2025.
$1.2 billion of land and agreements, held by a private charity.14 Source: natureconservancy.ca (PDF)

Governments supplied 40.8% of its revenue in the last year on file: $38.8 million federal, $43.7 million provincial.15 It spent $50.2 million buying land in a single year.14

Exhibit 04

Nature Conservancy of Canada · audited financial statements, year ended 31 May 2025 · Statement of operations · page 5

natureconservancy.ca (PDF)
The statement of operations. Boxed: Other donations and grants, 150,821,189; total revenue, 191,366,164; conservation lands and agreements purchased, 50,165,886.
$191.4 million in. $50.2 million spent buying land.14 Source: natureconservancy.ca (PDF)

The charity also lobbies the government that pays it. Its B.C. registration is filed by its CEO, Catherine Grenier. Its lobbyist on 62 of 67 reports is Nancy Newhouse, its B.C. regional vice-president.3713 On 8 December 2022 Newhouse met Premier David Eby and ten ministers to “Support Creation of new Indigenous Protected and Conserved Areas”.3712 Four months later the ministry paid the $15 million.11 Nothing in the record links the two. Nothing in the record explains the payment either.

In 2025 NCC lobbied Randene Neill four times. On 26 June it met Neill, Environment and Parks Minister Tamara Davidson, Forests Minister Ravi Parmar and Deputy Minister Lori Halls together. On 2 September it met Neill, Halls and Assistant Deputy Minister Jennifer Psyllakis. Halls appears on 11 of NCC’s reports, more than any other official.37 Her ministry is the one that pays.11

Halls is named in eleven lobbying reports by the charity her ministry funds. Her ministry has not published what came of them.

04 The agreement Cullen signed counts land a charity holds toward 30 per cent, and sets no condition on public access.

The target comes from the Kunming-Montreal Global Biodiversity Framework. Its Target 3 says nothing about who may walk in.1 Nathan Cullen signed the tripartite agreement for B.C. on 3 November 2023. Its counting rule takes any protected area or conserved area that is “reported in CPCAD”, the national database.3

Exhibit 05

Tripartite Framework Agreement on Nature Conservation · clauses 6.3 and 6.4.1 · page 9 of 20 · signed 3 November 2023

canada.ca (PDF)
Clauses 6.3 and 6.4.1 of the agreement. Boxed: B.C. Cabinet and Treasury Board approval to confirm funding requirements to address existing tenures; at least 30% of B.C.'s land base by 2030; meet national accounting standards and are reported in CPCAD.
Two conditions on every new area: First Nations’ consent, and Cabinet money “to address existing tenures”. None on public access.3 Source: canada.ca (PDF)

Charities report into that database. Last year they were the whole gain.5

Exhibit 06

Tripartite Framework Agreement on Nature Conservation · Second Annual Report, 2024/25 · page 7 (PDF page 9) · March 2026

gov.bc.ca (PDF)
A column of the second annual report. Boxed: government organizations (for example, land trusts) also report into CPCAD; and rose by 0.2%, fully attributed to the contributions provided by local levels of government and land trusts.
Every hectare B.C. added in 2024/25 came from local governments and land trusts. None from a new provincial park.5 Source: gov.bc.ca (PDF)

The database has a category for it: land governed by “Non-profit organizations”. It lists 364 B.C. records from the Nature Conservancy of Canada, 125,411 hectares, all counted for the first time in 2024 and 2025.6 Land a charity bought, some of it years ago, now counts toward a government’s target.

Exhibit 07

ECCC · Canadian Protected and Conserved Areas Database, User Manual 2025 · Governance Type · PDF page 28

data-donnees.az.ec.gc.ca (PDF)
A row of the CPCAD governance-type table. Boxed: Non-profit organizations, Non-governmental organisations or institutions. Above it, Individual landowners; below it, For-profit organizations.
Land governed by a charity is its own category in the national count.6 Source: data-donnees.az.ec.gc.ca (PDF)

20.0% → 30%B.C. was 20.0% conserved at the end of 2025. Reaching 30% by 2030 means adding roughly 94,600 square kilometres.

ProtectedOther conservedGap to 30%
Protected areasparks, conservancies, ecological reserves15.9%
Other conserved areasmostly province-wide records from 20194.1%
Still to addabout 9.5 million hectares10.0%
Share of B.C.’s 944,735 km² of land and fresh water, end of 2025. The gap is our arithmetic: 30% of 944,735 km² less the 188,862 km² already counted.2

Most of the other 4.1% is five province-wide records from 2019, including old-growth management areas, a practice the Province has since “paused”.7

Search the agreement’s 20 pages for the people who use the land. “Recreation”: zero. “Hunt”: zero. “Trail”: zero. “Public access”: zero. “Access” appears six times, every time about data.3 The BC NDP platform promises 30% “and preserve public access”.35

Cullen signed it. Neill runs it. Neither has said where the access clause is.

05 The ministry, the charity, two mining companies and heli-ski operators all get something from 30 by 30. The public gets no right of access.

Everyone at the table gets paid, protected or counted. The people who use the land get nothing in writing.

What the ministry, the charity and the companies got

$24.1Mdeclared by NCC from the Ministry of Water, Land and Resource Stewardship12
$1.21Bheld by NCC in land and agreements14
$20Mfrom Glencore’s Elk Valley Resources, for land where it operates17
$16Mfrom Teck to NCC projects, toward its goal of 3 hectares for every 1 its mines affect16
$4.5Mpaid by a Crown corporation for Darkwoods carbon offsets26

What the public got

No access clauseThe agreement has no public-access clause. Darkwoods is permit-only and bans sleds. The Incomappleux has no road and no hunting.32422

Ministry of Water, Land and Resource Stewardship (WLRS)

Randene Neill, minister; Lori Halls, deputy

$24.1M

NCC declares $24.1 million from the ministry. The hectares count toward 30% with no expropriation and no public hearing.123828

Nature Conservancy of Canada

Catherine Grenier, CEO

$1.21B

The charity holds $1.21 billion in land and agreements, and it decides who may enter.1425

Government of Canada

Steven Guilbeault, signatory

$500M

Ottawa committed up to $500 million. Its national count missed the 2025 target, and charities’ land tops it up.325

Glencore / Elk Valley Resources

Mike Carrucan, CEO

$20M

Elk Valley Resources put $20 million into conserved land “in the region where we operate”.17

Teck Resources

Jonathan Price, CEO

3 for 1

Teck aims to conserve three hectares for every one its mines affect. It has given $16 million to NCC projects since 2022.1620

Interfor

Stuart Card, vice-president

Price unpublished

Interfor was paid to release 75,000 hectares of tenure in the Incomappleux. The Province has not published how much.20

Foundations and donors

Rosenfeld Family Fund, Wyss, Wilburforce

No tax

Donors pay no tax on the capital gain from an ecological gift, and they can set the terms of the covenant.271934

Heli-ski operators

Permit holder not published

By permit

Heli-skiing may continue by permit in a valley closed to roads and hunting. The permit holder has not been named.2122

Carbon buyers

Pacific Carbon Trust, a Crown corporation

$4.5M

The Crown corporation paid NCC $4.5 million for 450,000 Darkwoods offsets to make government “carbon neutral”.26

First Nations

Leadership Council signatories

$173M

Each new area needs the consent of the Nations concerned. Ottawa set up to $173 million for Indigenous Guardians nationally, and $16.1 million for Qat’muk.33233

The public gets nothing in writing.

The $1-billion Tripartite Framework Agreement on Nature Conservation has no clause that guarantees public access to the land it protects.3

Teck says it is “taking action to protect nature”. Its own goal is three hectares conserved for every one its mines affect, and it says its $2 million in the Incomappleux “funded 37,500 hectares” toward that goal.2016

The Incomappleux itself is in the national count as a protected area.6

Mike Carrucan, the CEO of Elk Valley Resources, says the company is helping “to conserve vital habitat”. He also says the $20 million protects land “in the region where we operate”. EVR ties it to no permit or offset.17

The Incomappleux hectares count toward Teck’s mining goal and toward the Province’s 30%. Neither Price nor Neill has said whether that is the same hectare counted twice.

06 Routing land through a charity instead of a park brings tax breaks, matched federal money and private rules, and skips the public process.

NCC is a registered charity with audited statements and public returns.141544 The question is what routing the target through it does that a park does not. Five things.

01

Donors of ecological gifts pay no tax on the capital gain.

An ecological gift sits outside the usual 75%-of-income limit. Its taxable capital gain is zero. NCC’s B.C. arm is an approved recipient.27

02

Every federal dollar needs $1.50 from elsewhere, and a charity brings it.

Natural Heritage dollars arrive only with $1.50 of other money each. Donated land counts as match. A charity unlocks the federal money.89

03

Buying private land skips the Land Act and Park Act process.

Buying private land needs no Land Act or Park Act process. Cabinet creates a conservancy by order. The only comment period comes after.28

04

The charity’s land is private, and a donor’s wishes can close it.

“Our lands are privately-owned.” A property can close if access is “against the wishes of the donor”.25

05

The charity can buy first, then hand land to BC Parks or keep the title.

A $10-million bridge facility lets it buy first. Skaha Bluffs went to BC Parks. Grace Islet went the other way: the Province paid $5.45 million and the charity kept title.1429

Exhibit 08

Nature Conservancy of Canada · Land Use page · read 15 October 2026

natureconservancy.ca
NCC's Land Use page. Boxed at the top: Our lands are privately-owned and managed for conservation. Boxed at the bottom, the last of three reasons a property may be closed to visitors: Access is against the wishes of the donor who solely enabled the securement of the property or donated the land.
Whose land it is, and whose wishes can close it, in the charity’s own words.25 Source: natureconservancy.ca

For a government in a hurry, each is an advantage. The hectares count with no expropriation, no bill and no hearing, and donors and companies carry part of the cost. What drops out is the part of a park the public owns: a say before, and a right of entry after.

Neill has not said why a donor’s wishes, and not a public process, should decide who gets in.

07 The charity’s Darkwoods is permit-only with sleds banned, and the Incomappleux conservancy has no road and no hunting.

NCC says of the Kootenay Forest Lands: “Public recreation access will continue.” Wildsight, a Kootenay conservation group, says “current closures remain in place”. No hunting or motorized rules are published.18 NCC’s own Darkwoods shows what its rules look like: permit only, July to September, sleds and off-road vehicles banned, and anyone without a permit “will be trespassing”. Its 2011–16 plan had let three snowmobile clubs in.24

Exhibit 09

Nature Conservancy of Canada · Darkwoods project page · read 15 October 2026

natureconservancy.ca
Text from the Darkwoods page: Darkwoods is accessible for low impact recreational day use from July through September. Permits are required for entry. Camping, off-road vehicles, snowmobiles, fires, trapping and cutting firewood on the property are prohibited. Permits are required for entry, and off-road vehicles, snowmobiles, are boxed.
A rule set by the owner, not by a public process.24 Source: natureconservancy.ca

The Incomappleux became a Crown conservancy. That did not open it. BC Parks says it has no road access. Hunting is banned, because the regulation does not list it in Schedule B.2223 Heli-skiing, the ministry said, can continue by park use permit.21

Exhibit 10

BC Parks · Incomappleux Conservancy · read 15 October 2026

bcparks.ca
Text from the BC Parks page for the Incomappleux Conservancy. Boxed: This conservancy has no road access, trails, or facilities; and, under Special notes, Hunting is not permitted in this conservancy.
Closed to the hunter and the driver. Heli-skiing, the ministry said, may continue by permit.22 Source: bcparks.ca

Tamara Davidson runs BC Parks. Her ministry has not named who holds the heli-ski permit.

08 On Vancouver Island, Mosaic runs the same model without the target: pension funds own the forest, a private manager sets the gates, and the carbon is sold.

Vancouver Island shows the same model without the target. Mosaic Forest Management runs “over 550,000 hectares of private forest land on Vancouver Island and the Sunshine Coast on behalf of Canadian pension funds”. It says it is owned by “two of Canada’s largest public sector pension funds”.40 One of the buyers, in 2011, was the British Columbia Investment Management Corporation, now BCI, which invests B.C. public-sector pensions. It and PSP Investments agreed to pay about $910 million for TimberWest.41

Public-sector pension money owns it. A private manager decides who gets in. The public gets weekends, 6 a.m. to 6 p.m., on gates that “may close on short notice”. In Mosaic’s own survey, 37% rated their experience with its gates as poor. Its own review says “limiting access is not the same as managing risk”, and a pilot is opening three more gates near Sooke this fall.40

The conservation value is sold too. Mosaic’s BigCoast program defers logging on nearly 40,000 hectares for 25 years and sells the carbon as credits. A ratings firm said the boundary was drawn to include regions “that are not additional”; Mosaic disputes it.42 And when the Province wanted 312 hectares at Skutz Falls in 2025 for a treaty-related transfer, it bought them from Mosaic for about $8.6 million.43

The difference matters. Mosaic’s land was private long before 30 by 30, a deferral is not legal protection, and no WLRS, Old Growth Nature Fund or NCC money to Mosaic appears in the record, nor any Mosaic hectare counted toward 30%. Mosaic is the model without the target: pension money owns the land, a manager sets the gates, and the carbon is sold. 30 by 30 adds the public count.

BCI invests B.C. public-sector pensions. Ask it why the forest those pensions own opens on weekends only.

09 Neill, Parmar, Davidson and both governments have left five questions about money, permits and access unanswered.

Five answers sit with named offices. None is published.

01

What did the $15 million buy?

Ask Minister Randene Neill and Deputy Minister Lori Halls. Their ministry paid it in April 2023. No published document says what for.111238

02

What was Interfor paid to give up the Incomappleux?

Ask Forests Minister Ravi Parmar and the Province. 75,000 hectares of tenure were released. The price is not published.2038

03

Who holds the heli-ski permit?

Ask Environment and Parks Minister Tamara Davidson. Her ministry’s conservancy has no road and no hunting. Heli-skiing may continue by permit.212238

04

What is B.C.’s own dollar share?

Ask the Province. It calls the agreement “over $1 billion” and says its half comes “through existing programs”. It has published no figure.4

05

Where is the access clause?

Ask every signatory government: Ottawa and Victoria. The agreement never says “recreation” or “public access”.3

10 Before the 24 October election, ask every candidate to put public access in writing for land counted toward 30 per cent.

They counted your land and wrote you out of it.

The target is public. The money is public. The access is not. Conservation is not the problem, and neither is the Nations’ consent. The general election is scheduled for 24 October 2026.36

Three commitments to ask every candidate for before 24 October

  1. Put public access in writing. Published access terms for every area counted toward 30%, and an access clause in the tripartite agreement.
  2. Publish what public money buys. For every payment to a land trust: the property, the hectares, the price and the access rules.
  3. Open the count to the public. Public comment before land is designated or reported toward the target.

Thirty per cent is a target. Access is a right. Ask every candidate which one they will put in writing before 24 October.

Share this story

These seven images are made to be posted. The first carries the headline and Nathan Cullen’s photograph, and each of the rest carries one document: the agreement, the $15 million, the lobbying, what they say against what they get, what protection means for access, and what to ask.

Suggested caption

The Nature Conservancy of Canada declares $24.1 million from B.C.’s land ministry, including $15 million in April 2023 with no published purpose.

Nathan Cullen, then the NDP minister, signed B.C.’s $1-billion 30 by 30 deal. It never mentions public access.

NCC’s lobbyist met Premier David Eby and ten ministers in December 2022, and Randene Neill, the NDP Minister of Water, Land and Resource Stewardship, four times in 2025.

In 2024/25, every hectare B.C. added toward 30% came from local governments and land trusts. Darkwoods is permit-only and bans sleds. The Incomappleux has no road and no hunting; heli-skiing may continue by permit.

Ask your candidates to put public access in writing, publish what public money buys, and open the count to public comment.

Share this with someone who sleds, hunts or hikes on land counted toward 30 by 30.

backcountry.cx/editorials/thirty-by-thirty-who-benefits/

#BCpoli #BCElection #30by30 #PublicLand #PublicAccess

Sources

  1. ↩ Convention on Biological Diversity, Decision 15/4, Kunming-Montreal Global Biodiversity Framework, 19 December 2022, page 9, Target 3: at least 30 per cent of land and inland waters conserved “through … systems of protected areas and other effective area-based conservation measures, recognizing indigenous and traditional territories”. cbd.int (PDF)
  2. ↩ Environment and Climate Change Canada, Canadian Environmental Sustainability Indicators: Canada’s conserved areas, page dated 30 July 2026, data current to 31 December 2025: Canada at 14.0%, the admission that “the pace of progress was not fast enough to reach the 2025 target”, and British Columbia at 20.0% (188,862 of 944,735 km²; 15.9% protected, 4.1% other conserved). The 9.5-million-hectare gap is our arithmetic on these figures. canada.ca
  3. ↩ Tripartite Framework Agreement on Nature Conservation between Canada, British Columbia and the First Nations Leadership Council, signed 3 November 2023, 20 pages; signature block (page 19 and 20): Steven Guilbeault and Jonathan Wilkinson for Canada, Nathan Cullen for British Columbia, and for the First Nations Leadership Council Regional Chief Terry Teegee (BC Assembly of First Nations), Cheryl Casimer, Robert Phillips and Hugh Braker (First Nations Summit), and Grand Chief Stewart Phillip, Chief Don Tom and Chief Marilyn Slett (Union of BC Indian Chiefs); goal 4.1 (b) and objective 6.4.1 (“at least 30% of B.C.’s land base by 2030”, counted in CPCAD), clause 6.3 (free, prior and informed consent, and Cabinet and Treasury Board approval “to address existing tenures”), clause 11.1 (“Canada will contribute up to $500 million”, matched), clause 13.2 (“not legally binding”). A text search of the agreement finds “recreation”, “hunt”, “trail” and “public access” zero times; its six uses of “access” concern data. canada.ca (PDF)
  4. ↩ Province of British Columbia, Tripartite Framework Agreement on Nature Conservation page: “a combined commitment of over $1 billion”, with B.C. “matching Canada’s funding through existing programs and funding commitments”; and the First Annual Report, page 4: the two governments “have each committed to contributing $500 million”. gov.bc.ca · first report (PDF)
  5. ↩ Tripartite Framework Agreement on Nature Conservation, Second Annual Report, March 2026, covering 2024/25: page 7 of the report (PDF page 9), “Parks and OECMs count toward the 30% X 2030 target”, land trusts “also report into CPCAD”, and the CPCAD area “rose by 0.2%, fully attributed to the contributions provided by local levels of government and land trusts”; PDF page 11, the progress table (19.9% from CPCAD 2024, on a base of 94,498,991 hectares); PDF page 14, Kootenay Forest Lands. gov.bc.ca (PDF)
  6. ↩ Environment and Climate Change Canada, Canadian Protected and Conserved Areas Database (CPCAD) User Manual 2025: PDF page 24, “IPCAs that are not PA or OECM should not be reported to CPCAD”; PDF pages 26 and 28, ownership and governance type 8, “Non-profit organizations”. And the CPCAD 2025 data release, queried for British Columbia: 364 records from the Nature Conservancy of Canada, all “Privately Protected Area” held in fee simple, totalling 125,411 hectares before overlaps are removed, 339 of them first counted in data year 2024 and 25 in 2025; and the Incomappleux Conservancy, 58,654 hectares, counted as a protected area from 2023. data-donnees.az.ec.gc.ca (PDF)
  7. ↩ The Narwhal, “B.C. old growth and conservation targets”, 29 January 2024, quoting a provincial spokesperson: “The province has paused reporting of other effective conservation measures for the time being”; and the CPCAD 2025 records, in which B.C.’s 4.1% of other conserved areas is almost entirely five province-wide records from 2019, including legal Old Growth Management Areas. thenarwhal.ca
  8. ↩ Environment and Climate Change Canada, Natural Heritage Conservation Program: “For every dollar of federal funding, the Natural Heritage Conservation Program matches a minimum of $1.50 from non-federal sources, including in-kind matching, such as land donations”; delivered through agreements with the Nature Conservancy of Canada, Ducks Unlimited Canada and Wildlife Habitat Canada. And the 2019 backgrounder, which set the original match at “a minimum of two dollars”. program page · 2019 backgrounder
  9. ↩ Environment and Climate Change Canada, Évaluation du Programme de conservation du patrimoine naturel et du Défi de l’objectif 1, 2025, section 2.2.4: the 2-to-1 ratio was lowered to 1.5 to 1 “en raison de la COVID-19, des défis économiques et à la demande du bénéficiaire”; phase one reached 2.3 to 1; recipients raised $635 million in matching funds against $261 million paid out by ECCC. canada.ca
  10. ↩ Environment and Climate Change Canada, “Canada invests in conserving 45,000 hectares of forest in the Kootenays,” 16 December 2025: $20 million through the Nature Smart Climate Solutions Fund, complementing $7 million from the Old Growth Nature Fund; quote from Julie Dabrusin, Minister of the Environment, Climate Change and Nature. canada.ca
  11. ↩ Province of British Columbia, Public Accounts, Consolidated Revenue Fund Detailed Schedules of Payments, Government Transfers: 2023/24, printed page 642, The Nature Conservancy of Canada, Water, Land & Resource Stewardship, $15,000,000; 2024/25, $573,461 and $7,000,000; 2025/26, $7,000,000 and $1,500,000. Payments made in April appear in two years’ schedules and are counted once. gov.bc.ca
  12. ↩ Office of the Registrar of Lobbyists for British Columbia, open-data export dated 20 September 2026: the Nature Conservancy of Canada’s declared government funding ($24,141,261 from the Ministry of Water, Land and Resource Stewardship, including $15,000,000 on 6 April 2023, $573,461 on 2 May 2024, $7,000,000 in April 2025 and $1,500,000 on 10 April 2026); its 67 lobbying reports, 22 of them on “Support Creation of new Indigenous Protected and Conserved Areas” between 23 April 2021 and 16 October 2023, including LAR-23055 of 8 December 2022 with Premier David Eby and ten ministers; and the Yellowstone to Yukon Conservation Initiative (34 reports on 30% by 2030) and CPAWS-BC (38 reports on “30% of lands by 2030”). lobbyistsregistrar.bc.ca
  13. ↩ Black Press Media (The Progress), “Historic 45,000-hectare land conservation buy confirmed for southeastern B.C.,” 17 December 2025, which reports the provincial government’s $7 million and quotes “NCC BC regional vice president Nancy Newhouse”. theprogress.com
  14. ↩ The Nature Conservancy of Canada, audited financial statements for the year ended 31 May 2025, Ernst & Young LLP, 8 October 2025 (unqualified opinion): page 4, conservation lands and agreements $1,205,901,526; page 5, total revenue $191,366,164, other donations and grants $150,821,189, lands and agreements purchased $50,165,886, support expenses $41,475,541; note 6, a $10,000,000 revolving facility for bridge financing of land. natureconservancy.ca (PDF)
  15. ↩ Canada Revenue Agency, T3010 registered charity information return, Nature Conservancy of Canada (BN 119246544RR0001), fiscal period ending 31 May 2024, from CRA open data: federal government revenue $38,827,084, provincial $43,678,249, total revenue $202,789,080 (40.8% from governments); 454 permanent full-time positions, one of the ten highest-paid in the $350,000-and-over band. cra-arc.gc.ca
  16. ↩ Teck Resources, “Teck Sets Nature Positive Goal,” 5 June 2022, with CEO Don Lindsay’s quote and Bruce Ralston, then B.C. Minister of Energy, Mines and Low Carbon Innovation: “I commend Teck on committing to conserve or rehabilitate at least three hectares for every one hectare affected by its mining activities” (at least three hectares conserved or rehabilitated for every hectare affected; $2 million for Next Creek and $12 million in new funding to the Nature Conservancy of Canada); and Teck and NCC, Incomappleux release, 25 January 2023: Teck’s $2 million “funded 37,500 hectares, or half, of the total lands protected in the Incomappleux Valley”. teck.com
  17. ↩ Elk Valley Resources (Glencore), “EVR contributes $20 million to conserve land in the Elk Valley”: CEO Mike Carrucan, “protecting land in the region where we operate for generations to come.” EVR does not tie the contribution to an offset or regulatory requirement. glencore.ca
  18. ↩ Nature Conservancy of Canada, Kootenay Forest Lands project page and release “Landmark conservation partnership: 45,000 hectares protected in southeastern BC”, 16 December 2025 (“Public recreation access will continue”; quotes from Catherine Grenier, NCC President and CEO, Nathalie Provost, Secretary of State (Nature), Randene Neill, B.C. Minister of Water, Land and Resource Stewardship, and Mike Carrucan of EVR; funders include the Government of Canada, Elk Valley Resources, the Province of B.C. and Elana Rosenfeld); and Wildsight, “A new era begins for the Elk Valley’s Kootenay Forest Lands,” 23 October 2025: “For now, current closures remain in place”. No published hunting or motorized-access rules were found. project page · release · wildsight.ca
  19. ↩ Nature Conservancy of Canada, Incomappleux project page: NCC worked “to facilitate and fundraise for the conservation of the Incomappleux Valley”, with funders including the Government of Canada through the Canada Nature Fund, the Rosenfeld Family Fund, Teck Resources, Wilburforce Foundation and Wyss Foundation; and NCC’s chief executive in Policy Options, March 2023: “NCC played a key role by raising $4 million.” natureconservancy.ca · policyoptions.irpp.org
  20. ↩ Province of British Columbia, 2023PREM0005, 25 January 2023: the Incomappleux Conservancy, after “Interfor has released 75,000 hectares of its forest tenure”. Quotes from Premier David Eby (“Protecting our wild spaces for generations to come is one of the most important things we are doing to create a healthier future”), Nancy Newhouse, B.C. regional vice-president of the Nature Conservancy of Canada, Teck CEO Jonathan Price (the project “supports Teck’s work to become a nature-positive company”) and Stuart Card of Interfor. Interfor’s compensation is not published; the Valhalla Wilderness Society gives its “understanding” of $3.75 million. news.gov.bc.ca · vws.org
  21. ↩ Revelstoke Mountaineer, “Conservancy status announcement for Incomappleux Valley,” 1 February 2023, quoting a Ministry of Environment spokesperson: heli-skiing “would be able to continue, subject to approval of a park use permit.” No published record names the permit holder. revelstokemountaineer.com
  22. ↩ BC Parks, Incomappleux Conservancy: “This conservancy has no road access, trails, or facilities.” “Hunting is not permitted in this conservancy.” Established by Order in Council 37/2023, 58,654 hectares. bcparks.ca
  23. ↩ Park, Conservancy and Recreation Area Regulation, B.C. Reg. 180/90, sections 28 and 29 (firearms may be possessed and discharged for hunting only in the parks, conservancies and recreation areas listed in Schedule B) and Schedule B, which does not list the Incomappleux Conservancy. bclaws.gov.bc.ca
  24. ↩ Nature Conservancy of Canada, Darkwoods project page: day use July through September, “Permits are required for entry”, off-road vehicles and snowmobiles prohibited, and a visitor without a permit “will be trespassing”; and the Darkwoods property management plan summary, 2011–2016, pages 7 and 13, under which three local snowmobile clubs had winter access by agreement with the Association of BC Snowmobile Clubs. natureconservancy.ca
  25. ↩ Nature Conservancy of Canada, Land Use page: “Our lands are privately-owned and managed for conservation”, and the reasons a property may be closed to visitors, including that “Access is against the wishes of the donor who solely enabled the securement of the property or donated the land”; and the Hunting on Conservation Lands page, which sets hunting rules property by property. land use · hunting
  26. ↩ Office of the Auditor General of British Columbia, An Audit of Carbon Neutral Government, Report 14, March 2013, PDF page 30: “The Pacific Carbon Trust paid $4.5 million for 450,000 Darkwoods offsets ($10 per offset)”. oag.bc.ca
  27. ↩ Income Tax Act, R.S.C. 1985, c. 1 (5th Supp.), section 118.1 (1), “total gifts” (ecological gifts are added outside the 75%-of-income limit) and “total ecological gifts” (only governments and charities approved by the Minister of the Environment may receive them); section 38 (a.2) (the taxable capital gain on a certified ecological gift is zero); and Environment and Climate Change Canada’s Ecological Gifts Program pages: covenant terms “determined by the donor”, and the list of approved recipients, which includes the Nature Conservancy of Canada – British Columbia. s. 118.1 · s. 38 · Ecological Gifts Program
  28. ↩ Land Act, R.S.B.C. 1996, c. 245, section 1 (“Crown land” is land “vested in the government”); Park Act, R.S.B.C. 1996, c. 344, section 5 (1) (Cabinet may establish a park or conservancy on Crown land by order) and section 20 (3) (the minister “may” give the public an opportunity to comment before a permit decision); and BC Parks, Management plan process, whose 30-day public review applies to draft management plans. No statute or policy requiring public consultation before a park or conservancy is designated was found. Land Act · Park Act · bcparks.ca
  29. ↩ Province of British Columbia, 2012ENV0014, 31 March 2012: the Skaha Bluffs property, bought in 2008 for $5.25 million, transferred to BC Parks by NCC and The Land Conservancy; and 2015FLNR0013: “The Nature Conservancy of Canada now holds title to Grace Islet”, after the Province contributed $5.45 million. Skaha Bluffs · Grace Islet
  30. ↩ Fisheries and Oceans Canada, Great Bear Sea Project Finance for Permanence, June 2024: $335 million, including $200 million from Canada, $60 million from British Columbia and $75 million from philanthropic organizations; and the Prime Minister’s release of 7 December 2022 on up to $800 million for up to four such initiatives. canada.ca
  31. ↩ Province of British Columbia, 2023FOR0061: a $300-million Conservation Financing Mechanism, “$150 million from the Province, matched by a commitment to raise an additional $150 million from the BC Parks Foundation.” news.gov.bc.ca
  32. ↩ Environment and Climate Change Canada, “Government of Canada announces $340 million to support Indigenous-led conservation,” 12 August 2021: “up to $173 million will fund new and existing Indigenous Guardians initiatives.” canada.ca
  33. ↩ Ktunaxa Nation Council, via the Wyss Campaign for Nature, “Ktunaxa Nation Council celebrates decades-long battle to safeguard Qat’muk,” 21 January 2020: $16.1 million from the Canada Nature Fund, leveraging $5 million in private funding. (The Wyss project page gives $13 million and $3.5 million.) wysscampaign.org
  34. ↩ Wyss Campaign for Nature, “a $1.5 billion campaign to help protect 30% of the planet by 2030”; and Nature Conservancy of Canada magazine, Winter 2021, guest letter signed by Elana Rosenfeld as “National Board Chair”. wysscampaign.org
  35. ↩ BC NDP, “Build B.C. Strong” platform commitments: “protect 30% of B.C.’s land by 2030, conserve the environment, protect wildlife habitat, and preserve public access.” bcndp.ca
  36. ↩ Elections BC, 2026 Provincial Election: Final Voting Day scheduled for 24 October 2026. elections.bc.ca
  37. ↩ Office of the Registrar of Lobbyists for British Columbia, Nature Conservancy of Canada registration 8902-3258-52 and lobbying activity reports, open-data export dated 20 September 2026. Designated filer: Catherine Grenier, President & CEO. In-house lobbyists: Dawn Carr, Scott Jones, Lisa McLaughlin, Nancy Newhouse, Hillary Page and Janelle Wyman. Nancy Newhouse is named on 62 of the 67 reports. Officials named: Lori Halls, Deputy Minister of Water, Land and Resource Stewardship, in 11 reports (LAR-20800, 28231, 33330, 35626, 40475, 41592, 43963, 46152, 49262, 49851 and 53139, from 15 August 2022 to 16 June 2026); Jennifer Psyllakis, in 8 (LAR-20800, 40475, 46152, 49261 and 49262, and LAR-27019, 40473 and 53138, which spell her name “Psylakkis”); Nathan Cullen, in 6 (LAR-23055, 24421, 27019, 28231, 31221 and 32453), including LAR-24421 of 8 February 2023 as minister; Randene Neill, in 4 (LAR-41592, 27 March 2025; LAR-43963, 26 June 2025; LAR-44792, 22 July 2025; LAR-46152, 2 September 2025); Ravi Parmar, in 3 (LAR-40474, 42196 and 43963); Tamara Davidson, in 2 (LAR-41592 and 43963); David Muter, Assistant Deputy Minister, Land Use Policy, Planning and Ecosystems, in 2 (LAR-20800 and 40473); and Premier David Eby, in 1 (LAR-23055, 8 December 2022, with Newhouse as lobbyist). lobbyistsregistrar.bc.ca
  38. ↩ Province of British Columbia, Cabinet ministers (updated 8 September 2026: Randene Neill, Water, Land and Resource Stewardship; Tamara Davidson, Environment and Parks; Ravi Parmar, Forests) and Deputy ministers (6 July 2026: Lori Halls, Water, Land and Resource Stewardship). ministers · deputy ministers
  39. ↩ Forbes, Hansjoerg Wyss profile, real-time net worth $4.8 billion as of 15 October 2026; citizenship Switzerland; a fortune that “stems from his 2012 sale of medical device manufacturer Synthes”. Wilburforce Foundation, About: “a private philanthropic organization”, founded in 1991. And NCC’s Kootenay Forest Lands release: Elk Valley Resources “operates four steelmaking coal mines in the Elk Valley”. forbes.com · wilburforce.org
  40. ↩ Mosaic Forest Management: “Mosaic to open three gates in Sooke area under recreation access pilot”, 29 September 2026 (“Mosaic manages over 550,000 hectares of private forest land on Vancouver Island and the Sunshine Coast on behalf of Canadian pension funds”); Access page (weekend access “from 6:00 am to 6:00 pm”, updated every Thursday; gates “may close on short notice”); Moving forward on recreation and access, July 2026 (owned by “two of Canada’s largest public sector pension funds”; “limiting access is not the same as managing risk”); and What We Heard, September 2025 (“37% of respondents rated their experience with Mosaic gates as poor”). Sooke pilot · access · review (PDF) · survey (PDF)
  41. ↩ PSP Investments, “British Columbia Investment Management Corporation and Public Sector Pension Investment Board enter into an arrangement agreement to acquire TimberWest Forest Corp.,” 11 April 2011 (about $910 million, $1.03 billion with debt); and the 2018 release on affiliating TimberWest and Island Timberlands under one manager. 2011 · 2018
  42. ↩ Canadian Forest Industries / Wood Business, “Mosaic to defer logging on 40K hectares for next 25 years,” March 2022 (the BigCoast Forest Climate Initiative, with the deferred carbon sold as credits); and The Globe and Mail, 21 June 2024, on a February 2024 Renoster review that said the project boundary “has been drawn so as to selectively include regions that are not additional”, which Mosaic “forcefully disputes”. woodbusiness.ca · theglobeandmail.com
  43. ↩ Province of British Columbia, 2025IRR0020, 22 May 2025: “B.C. purchased the private forestry land parcel from Mosiac [sic] Forest Management”, 312 hectares valued at about $8.6 million, transferred to Lyackson First Nation and Cowichan Tribes. news.gov.bc.ca
  44. ↩ Charity Intelligence Canada, Nature Conservancy of Canada profile: “a 4-star charity” with “above average disclosure”. charityintelligence.ca

Every source was read on 15 October 2026. Nothing on this page alleges illegality. Each path described is provided for in law: the Income Tax Act, the Park Act and the Land Title Act. The opinions are ours, and the facts they rest on are cited.