To the Registrar, Forest Professionals BC, and to the Complaints Department, Engineers and Geoscientists BC,
I am filing a complaint under Bylaw 12-2(1) against two registrants of this College. They are responsible for a professional document that will permanently destroy a public forest service road built in 1901, and the copy the Province put into the hands of contractors and published to the public does not identify a single professional anywhere in its forty-two pages.
The registrants. Michael Ferguson, RFT-1624, Engineering Officer, Selkirk Natural Resource District, who commissioned the document. Jordan Pyette, RFT-2122, named in the document as Road Activity Professional of Record and Coordinating Registered Professional.
This complaint reaches two regulators, because the document does. Mr Ferguson and Mr Pyette are registrants of Forest Professionals BC. The seal that was covered is a professional geoscientist’s, and the firm that prepared the report, SNT Geotechnical Ltd., holds an Engineers and Geoscientists BC permit to practise, number 1001083, which is itself covered in the issued copy. I am sending the same facts to both bodies so that neither has to decide whether they belong to the other.
For Engineers and Geoscientists BC specifically. I make no allegation against R. J. Williams, P.Geo. #45161, whose seal, signature and date appear to have been properly applied, nor against the reviewing geoscientist. My concern is the opposite: their work was sealed correctly and then distributed with the seal removed. I ask EGBC to consider whether a sealed professional document bearing its registrant’s seal may be republished by a client in a form where the seal, the signature, the date, the reviewer and the permit number are all obscured, and what obligation the permit holder has when that occurs. Engineers and Geoscientists BC treats a firm as a registrant in its own right, so this limb of the complaint concerns SNT Geotechnical Ltd. as permit holder, number 1001083, and not only the individuals named.
The document. Rady FSR Road Deactivation Prescription, report 26.510.01.01.16, dated 8 September 2026, prepared by SNT Geotechnical Ltd. for the Ministry of Forests and issued to contractors with BC Bid tender EN27DSE008. It is published on the Province’s own website.
The facts I ask you to verify.
1. The document’s opening sentence names Mr Ferguson as the officer at whose request it was prepared, and a later section names Mr Pyette as Professional of Record and Coordinating Registered Professional.
2. The document states its own requirement: a Qualified Registered Professional “must prepare, sign, and seal” a prescription for road deactivation works.
3. In the copy the Province published and issued to bidders, no professional is identified anywhere in forty-two pages — no seal, no signature, no date of signature, no reviewing professional, no consulting firm, and neither registrant’s name.
4. Those elements are in the file. They are covered by white rectangles drawn in the document’s own separation colourspace at zero tint, which render as paper. Removing them recovers a professional seal, a signature written across it, a hand-written date of 8 September 2026, and a second reviewing professional.
5. The covering is selective rather than a rendering fault: on one page the consultant’s name appears uncovered in scanned body text while the identical name is covered wherever it occurs in the text layer.
6. The Ministry’s own earlier prescription for this road, dated 7 October 2020, retained all-terrain vehicle access and recorded that it did so “at the expense of stability.” It was revised on 11 May 2021 and the covering email states: “it has been decided that there will be NO ATV ACCESS.” Mr Ferguson was sent that revision on 21 June 2021 and forwarded it to the District Manager the same afternoon.
7. The 2026 document states that the Ministry’s earlier prescription “is not dated.” It carries the date 7 October 2020 on its face, and the file Mr Ferguson received in 2021 carried its revision date in the filename.
8. On 9 November 2021 the District Manager advised the local recreation club that the geotechnical input behind that earlier prescription was given on site and that “there was no subsequent report.”
The grounds.
(a) Bylaw 8-2. A registrant must ensure that responsibility for professional work is identified. On the document as issued, it is not.
(b) Bylaw 8-3. Registrants remain accountable regardless of whether the work is sealed, stamped or signed, or whether responsibility is otherwise identified. I ask who is accountable for the document in the condition it was released.
(c) Standard 2(e), Code of Ethical and Professional Conduct. Professional judgment on this road was overruled twice on the record — in 2021 when ATV access was removed by decision, and in 2026 when the consulting geoscientist advised that an ATV trail “may be possible” at additional cost and the Ministry replied that access “is not required.” I ask whether the consequences were presented clearly, and to whom.
(d) Accuracy. Whether a professional document may describe a superseded prescription as undated when the registrant who commissioned it held a dated copy.
What I am formally requesting.
This is not a request for the College to reverse a road-closure decision. That is outside its jurisdiction and I am not asking for it. What is squarely inside its jurisdiction is whether two of its registrants may put their names to a document that ends public access and then release it in a condition where no name can be read. I am formally requesting that the College:
1. Investigate both named registrants under Bylaw 12-2(2) for professional misconduct, conduct unbecoming, and breach of Bylaws 8-2 and 8-3.
2. Establish who applied the covering, on whose instruction, and at what point between the consultant’s office and the Province’s web server it was applied.
3. Rule on whether a document issued in that condition can satisfy Bylaw 8-2 at all — because if it can, the bylaw means nothing.
4. Publish the outcome. This document was published. The public is entitled to know whether the conduct behind it met the standard the College sets.
The public did not get a meeting, a mailing, or a name. The Ministry has stated that the decision is final and has budgeted round-the-clock security against the people who use this road. The College is the only body left that can require the people responsible to account for their own professional work.
The evidence. Every document relied on above is linked below. Engineers and Geoscientists BC asks for exactly this — “links to websites containing the relevant documents and information.” Nothing is withheld and nothing requires a request to me.
Each was downloaded and archived with a SHA-256 checksum when it was found, and the copies below are held independently of the Province’s servers. That was not a precaution against something hypothetical.
The Ministry’s own earlier prescription for this road was published at deactivation_prescription_map_-_trout_lake-rady_fsr.pdf. That address now returns 404, the filename is still in the search index pointing at nothing, and the Internet Archive never captured it. The BC Government Directory, which records Mr Ferguson’s job title, has since been closed to the public. I can put the earlier prescription in front of you only because a copy was released to a local recreation club in July 2021 and kept.
The document complained of
Rady FSR Road Deactivation Prescription, report 26.510.01.01.16, 8 September 2026, as published by the Province — the copy in which no professional is identified
https://www2.gov.bc.ca/assets/gov/farming-natural-resources-and-industry/natural-resource-use/resource-roads/local-road-safety-information/selkirk/trout_lake_rady_creek_deactivation_prescription_map.pdf
The same prescription as issued to bidders with tender EN27DSE008
https://drive.google.com/file/d/1j99SRpTahMSJ16ZC_l7BOu7zOuKg3B01/view
Tender EN27DSE008, Offer Form and Quoted Price Schedule
https://drive.google.com/file/d/1Tq9Nio1y7gMSQfXUZxnZ6bQQq0ljzRKH/view
Tender EN27DSE008, wet weather shutdown criteria
https://drive.google.com/file/d/1pCKXuZQyano5_BIHf6uYDVApU2wnjS1_/view
Tender EN27DSE008, 2025 site photographs and inspection
https://drive.google.com/file/d/1i9oAG-MI9XOxT-6WLaebZDOZ2LWugVft/view
The Province’s own prescription waypoint file, 81 waypoints, still served from the district’s asset path
https://www2.gov.bc.ca/assets/gov/farming-natural-resources-and-industry/natural-resource-use/resource-roads/local-road-safety-information/selkirk/rady_creek_fsr_deactivation_prescription.kmz
The Ministry’s own earlier prescription, which the 2026 report calls undated
Rady FSR 0321.02 permanent deactivation summary table, prescribed 7 October 2020, revised 11 May 2021. Prescriber recorded as B. Zimmermann, RFT; the signature and date lines are ruled blanks in both versions
https://drive.google.com/file/d/1fm9GSw7ph92Rb0p0xiJ65ohMVRg4JhMD/view
Both versions side by side as released — the 7 October 2020 original headed ’Access Level Remaining after Deact: ATV’ against the 11 May 2021 revision, ’NO ACCESS’
https://drive.google.com/file/d/1Ce_iDGGS6Kbd8biebJym_z-6eRnxQIId/view
Rady Creek deactivation project map, 1:30,000, 26 April 2021
https://drive.google.com/file/d/1HnYIO5l8jhhW6JCbMb3QIGO8fySpthNh/view
The correspondence
11 May 2021, amendment to the deactivation works: ’it has been decided that there will be NO ATV ACCESS’
https://drive.google.com/file/d/10nyzTxXAcPC8pB6cpzW-cfiynqUYUkDU/view
21 June 2021, Zimmermann to Ferguson: ’Attached is my amended prescription once no ATV access was decided.’ Forwarded by Mr Ferguson to the District Manager the same afternoon
https://drive.google.com/file/d/11_Qhj_w87T3H2fXVVFtgFgf9TqLz-ACe/view
6 July 2021, District Manager’s briefing note on s.56 FRPA and a Land Act offer for this road
https://drive.google.com/file/d/1Ef55LGaK82uHY4nfJ_PLeEvffzC2_pHh/view
12 July 2021 transmittal and the reply of 9 November 2021: ’I believe the recommendations were made on site and there was no subsequent report’
https://drive.google.com/file/d/1PwT2AsuefgYN0-Swdxu8Jg7lZUDqWieI/view
Mr Ferguson’s fact sheet setting out three alternatives to deactivation, and the released district emails including his of 11 July 2022
https://drive.google.com/file/d/17gXOQYIqEvW73q3DvLbUC6j1KE5IzxPW/view
17 November 2025, deactivation notification to the road permit holder
https://drive.google.com/file/d/1glM44nxQdip5J3JndDRxeL1BNTV7Wt-V/view
27 November 2025, the District Manager’s response to the Trout Lake Recreational Club
https://drive.google.com/file/d/1LeyoWbB01fO7vvycnGmz83Ek0ixKAtjW/view
14 January 2020, the earlier deactivation referral chain for this road
https://drive.google.com/file/d/1W90EkuBhyJ5UpS84kY-9GTBgZZh9-NsF/view
The policy that decides which roads are kept
Engineering Program Funding Policy, signed fiscal 2019 edition — not published by the Province
https://drive.google.com/file/d/1XlzP_3bmsb0z16-cekMzEzGQ_ag_SXj6/view
Engineering Program Funding Policy, fiscal 2015/16 edition
https://drive.google.com/file/d/1DvvZnWZNpSwK0bglXGT5_yiJFX0Dws6v/view
Office of the Auditor General of British Columbia, Management of Forest Service Roads, November 2020 — Appendix C reproduces the policy and its risk table
https://www.oag.bc.ca/app/uploads/sites/963/2024/08/OAGBC-20210119-Management-Forest-Service-Roads_RPT.pdf
The rules relied on
Forest Professionals BC Bylaw 8, Use of Professional Seal and Signature, consolidated 11 December 2024
https://www.fpbc.ca/wp-content/uploads/2024/12/2024-12-11-FPBC-Bylaws-BYLAW-8-USE-OF-PROFESSIONAL-SEAL-AND-SIGNATURE.pdf
Forest Professionals BC Bylaw 12, Complaints, Investigations and Discipline
https://www.fpbc.ca/wp-content/uploads/2024/12/2024-12-11-FPBC-Bylaws-BYLAW-12-COMPLAINTS-INVESTIGATIONS-AND-DISCIPLINE.pdf
Forest Professionals BC Code of Ethical and Professional Conduct
https://www.fpbc.ca/wp-content/uploads/2024/12/2024-12-11-FPBC-Bylaws-BYLAW-9-STANDARDS-OF-ETHICAL-AND-PROFESSIONAL-CONDUCT.pdf
Selkirk Natural Resource District road safety information, the page that lists every road posted closed or for deactivation
https://www2.gov.bc.ca/gov/content/industry/natural-resource-use/resource-roads/local-road-safety-information/selkirk-natural-resource-district-road-safety-information
Everything together
The full documentary record, with the covering removed — the recovered seal and signature, the three-way comparison of the prescriptions, and the covering as it appears in the published file
https://backcountry.cx/editorials/michael-ferguson-jordan-pyette-rady-creek/
I am one of the people who use this road. I am not asking the College to reverse a decision about it — I am asking whether the registrants who prepared, commissioned and issued the document that ends it met the standards the College sets, and I am asking to be told what you find.
Thank you for your time.
A mail link cannot carry this letter. Browsers and Outlook cut a mailto at about two thousand characters; the complaint is fourteen thousand, and its seventeen source documents are the reason it carries weight. So press Copy the full letter first, then Send, then paste over the placeholder that opens. If Send does nothing at all — common on a phone with webmail only — use Copy all addresses as well and paste both into Gmail or Outlook.
Nobody is hidden. Both regulators are on the To line and everyone else is on Cc, in the open — the District Manager, the Regional Executive Director, the district office, the Forest Practices Board, the Minister and the Superintendent of Professional Governance. They can all see who has been told.
Change the wording if you want to. A letter in your own words carries more weight than a hundred identical ones. The part worth keeping is the question itself.
We are not telling anyone how to answer. We are asking you to find out where they stand.
Who this goes to
| Who | Address | Why |
|---|---|---|
| Registrar, Forest Professionals BC | complaints@fpbc.ca | Regulates both named registrants. The only body that can discipline them. |
| Complaints, Engineers and Geoscientists BC | complaints@egbc.ca | Regulates the geoscientist whose seal was covered, and the firm that holds the permit. |
| Charlene Strelaeff, District Manager | Charlene.Strelaeff@gov.bc.ca | Copied. |
| Russ Laroche, Regional Executive Director | Russ.Laroche@gov.bc.ca | Copied. |
| Selkirk District Office | FOR.SelkirkDistrictOffice@gov.bc.ca | Copied. |
| Forest Practices Board | FPBoard@bcfpb.ca | Copied. Has an open file on this road. |
| Minister of Forests | FOR.Minister@gov.bc.ca | Copied. |
| Superintendent of Professional Governance | OSPGEnquiries@gov.bc.ca | Copied. Oversees both regulators. |
| Backcountry Coalition | contact@backcountry.cx | Copied so we can count how many went out. |
All five questions
Five questions, one for each. Each opens in your own mail app.
- BC provincial election · you are here Where do you stand on public access to public lands? The opening question. Asks every candidate where they stand on reasonable public access to public lands.
- BC provincial election What happens to access when forestry leaves? What should happen to a resource road that industry no longer needs but the public still uses.
- BC provincial election What should be tried before access is lost? Which alternatives should be considered before a high-value access route is permanently removed.
- BC provincial election What will you do for access in the community you represent? How a candidate will make sure recreational access is weighed before local routes are closed.
- BC provincial election What is your long-term plan for backcountry access? The closing question. Asks for a province-wide, long-term plan for public access.