Topic 2: Provincial protection of species at risk



The Province is interested in hearing your thoughts about what makes a successful species at risk policy framework.

WHAT’S THE ISSUE?

The Province of British Columbia recognizes that there are gaps in the protection of species and ecosystems at risk. While there are many opportunities through our current tools and legislation to protect species at risk, equivalent protection is not available for all species (e.g., plants and invertebrates) on all lands (e.g., non BC Crown land or private lands) and is not consistently applied across all sectors.

BACKGROUND

Canada has developed a national approach to protecting species at risk. In 1996, the federal and provincial governments developed the Accord for the Protection of Species at Risk, committing to enact complementary legislation to protect species at risk. In 2005, BC entered into a bilateral agreement with the federal government on species at risk in order to coordinate government activities. The Province is obligated to consider these agreements in managing species at risk.

In 2002, the federal government passed the Species at Risk Act (SARA). The Province of British Columbia is expected under SARA to ensure that there is effective habitat protection for species at risk within the province. Currently, protection of BC’s species at risk utilizes a suite of provincial legislation and regulatory tools including the Wildlife Act, the Forest and Range Practices Act, the Oil and Gas Activities Act, the Land Act, the Park Act, the Ecological Reserves Act, and the Environmental Assessment Act.

Across Canada, all provinces and territories have developed programs, policies and/or legislation to support their ability to protect species at risk. Some jurisdictions, like BC, use a variety of legislation and policy tools to protect species at risk. Other jurisdictions have stand-alone species at risk legislation, including Ontario, Quebec, Manitoba, Newfoundland and New Brunswick.

To balance ecological diversity, protection and recovery of species at risk and a vibrant natural resource economy, the management of species at risk should be supported by a policy and regulatory framework that:

  • promotes positive conservation outcomes for all species and ecosystems at risk regardless of where they are found;
  • meets commitments made in agreements signed by British Columbia and expectations under SARA; and
  • supports a prosperous natural resource economy and ensures a level playing field across all sectors.

 

Please provide your answers to the following questions:

  • What are your thoughts on how to improve the current provincial policy and legislative framework for protection of species at risk?
  • Are you aware of successful initiatives that governments in other jurisdictions have used to support the protection of species at risk?
  • Do you have any other thoughts on how we can achieve a balance between protecting species at risk and supporting a vibrant natural resource economy?

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110 responses to “Topic 2: Provincial protection of species at risk

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    [-] Nesa7

    Collaboration with Indigenous groups. Increase funding and monitoring, enforcement and research.
    Transitioning to renewables. Education. Awareness.
    Tighter hunting and fishing regulations and more Conservation officers.

    More habitat protection and greater focus on protecting biodiversity. Integrated efforts and holding industry accountable.

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    [-] Jemma

    There is no viable alternative to achieving protection for species at risk in BC besides new and effective provincial species-at-risk legislation and the associated laws through which it might be enforced. It is imperative that the government of BC address the protection of species at risk within the province by enacting species-at-risk legislation that incorporates the knowledge and advice of scientists, Indigenous Peoples, environmental lawyers, and the public.
    Because of BC’s high species richness, representativeness, and endemism, it is critical for endangered species within the province to receive effective protection through legislation, both for responding to the threat of species extinctions and honouring Canada’s international commitment under the Convention on Biological Diversity. The responsibilities of the BC government arising from the international Convention on Biological Diversity were defined in agreements between the provinces and territories and the federal government in the National Accord for Species at Risk in Canada, established in 1996. Article 8(k) of the Convention on Biological Diversity states that signatory parties “shall, as far as possible and as appropriate… develop or maintain necessary legislation and/or other regulatory provisions for the protection of threatened species and populations”. In keeping with Canada’s agreement, the Accord committed the provincial and territorial governments to establish domestic legislation and programs that provide for effective protection of species at risk throughout Canada. Although at the time eight other provinces opted to enact endangered species legislation, the government of British Columbia chose the alternative of piecing together what it believed was effective protections using existing laws.

    BC has the second-highest number of species at risk of all the provinces in Canada. According to the Conservation Data Centre, 826 species and subspecies are threatened with extinction or extirpation (red-listed) and 772 species are listed as being of special concern (blue-listed), bringing the total number of species at risk in BC to almost 1600, 39 of which are endemic species (Pearson and Healey 2011). These estimates include at least 67% of the province’s reptiles and turtles, 47% of its amphibians and freshwater fish species, and 43% of its vascular plants (Moola and Devon Connolly 2007: 4). The majority of the species listed by the CDC are found in four hotspots associated with high human population densities, including southern Vancouver Island and the Okanagan Shuswap region, where habitat loss, development, and fragmentation, as well as the introduction of invasive species, have threatened the existence of native species.

    Ominously, BC has lost a total of 49 species and subspecies to extinction or extirpation since European settlement began, not including any species which may have disappeared from the province before being discovered. This same fate may befall the species that are currently at risk, as only 68 (or approximately 5% of the total number of species at risk) receive any form of protection under BC’s existing laws. Further, none of these species have received protection of critical habitat and even those species under the strongest form of protection currently available in BC are on the verge of extinction or extirpation. The list of success stories given on this website does not accurately reflect the poor track record of the Province in successfully recognizing, addressing, and managing the recovery of the many species at risk.

    Legislation which allows the government to legally designate large areas as parks, protected areas, or ecological reserves for the purposes of biodiversity conservation is successful when it allows species and ecosystems to function naturally and in perpetuity, relatively undisturbed by human activities. There are currently a number of acts in BC which may be combined for this purpose, including the Park Act, the Protected Areas of British Columbia Act, the Ecological Reserve Act, and the Environment and Land Use Act. The combined number of designated areas under the aforementioned acts totaled over 900 as of 2010. Together, BC’s network of parks, protected areas, ecological reserves and conservancies cover over 14% of the province’s land base, exceeding the recommendations of the UN World Commission on Environment and Development. These numbers are indeed impressive; however, despite the array of policies and associated regulations, there are a number of reasons why current parks and protected areas are insufficient for protecting species at risk in BC.

    There are many failings and biases within BC’s park system that show that it is not based upon fundamental ecological principles such as ecosystem-based management, habitat connectivity, and population viability. BC’s network of parks and protected areas generally do not overlap with species’ habitat needs. This is because designated areas are restricted mainly to high elevation, resource-poor, “rock and ice” areas that are, at best, preserved for scenic or recreation values or, at worst, because they are of low ecological and economic value. Protection of such areas is questionable because they are of little risk of being developed and are unlikely to be used for resource extraction. A very small percentage of species listed by the CDC are found exclusively within the parks and protected areas system and approximately half of species at risk are not found in protected areas at all. Clearly, the areas richest in at-risk species are not prioritized by the parks and protected areas system.

    BC’s parks and protected areas also fail to incorporate fundamental conservation biology criteria for successful habitat reserves, rendering them useless for most species. In general, BC’s designated areas are too small and too isolated to maintain viable populations of many species, particularly those which are migratory or have broad distributions, such as large carnivores and ungulates. In BC, it is the most biologically rich areas which are the least represented by parks and protected areas and the most altered by human land uses. These problems arise because economics have been prioritized over ecology during the process of identifying and selecting protected areas. Consequently, the Protected Areas Strategy, which was developed in the 1990’s in an attempt to encourage more representativeness within the park system, has been considered a failure by many.

    Existing parks and protected areas are too exposed to human disturbance, including recreation, logging, mining, and hunting, both from within and outside of the system. This is because the policies which would serve to protect habitat from extractive uses are not legally binding or enforceable. To make matters worse, BC’s parks are being downsized and managed with shrinking budgets.

    BC’s parks and protected areas system cannot be relied upon for the protection of species at risk because the vast majority of the species listed as being at risk by the CDC have populations that range both within and outside of the system or are not found in the system at all. Even those populations that do exist within protected areas are unlikely to survive if they lose the genetic diversity which results from breeding with external populations. Furthermore, should disease or natural disaster strike protected populations, the ability to boost their numbers above critical levels with individuals from other populations might not be possible if those external populations are not adequately protected from extirpation themselves. Another concern is that, without adequate protection outside of the park system, a wide-ranging animal might receive protection in one part of its range but be targeted by hunters or killed on a logging road in another, defeating the purpose of the park system for that species.

    Now we come to the Forests and Range Practices Act. Forests are the most species rich of the terrestrial ecosystems in BC; there are more species per unit area in forests than anywhere else in the province. At the same time, forest harvesting is a major industry in BC; in fact, most of the province’s land base is used for forestry. However, a conflict arises when we consider that many species endemic to BC are forest obligates or require forests for some aspect of their life history. It seems obvious that BC should have forestry regulations that appropriately address species at risk if they are to be sustainable. The key piece of legislation which manages forest operations and their impacts on species and ecosystems outside of designated parks and protected areas is the Forest and Range Practices Act (FRPA), which includes the Identified Wildlife Management Strategy (IWMS). According to the provincial government, the goals of the IWMS are to “minimize the effects of forest and range practices on Identified Wildlife situated on Crown land and to maintain their limiting habitats throughout their current ranges and, where appropriate, their historic ranges”. These goals are to be achieved by the creation of Wildlife Habitat Areas (WHAs) and the implementation of General Wildlife Measures (GWMs). The very existence of the IWMS would indicate a conservative, prudent approach to land management; however, in reality the Strategy is riddled with limitations, discretionary language, and a reliance on voluntary compliance.

    The first problem with the IWMS is that is leaves the listing of Identified Wildlife to the discretion of the Minister of Environment. This may lead to a conflict of interests as the minister is required to authorize the listing of species under FRPA in consultation with the Ministry of Forests and Range, stakeholders, and other resource ministries. Under this system, there is likely to be heavy pressure to maintain the status quo of resource extraction and very little pressure to consider the protection of species at risk. Furthermore, the listing of Identified Wildlife under the IWMS is made independently of scientific lists, such as those compiled by the CDC or the Federal Government’s Committee on the Status of Endangered Wildlife in Canada (COSEWIC). This is also problematic because it means that the decision to legally list a species is political and subject to approval or rejection on bases other than science.

    Another problem with the IWMS is that it is limited by regulatory constraints on species protection. Regulation 14/04 7(1) states that measures for species protection can only be taken “without unduly reducing the supply of timber from British Columbia’s forests”. In accordance with this regulation, the IWMS specifies that there is a “limit of 1% to the allowable impact to short-term harvest levels that may result from implementing measures for Identified Wildlife”. This threshold of 1% is set for the entire province but it is also set for each individual forest district, regardless of differing numbers of species at risk or threshold allowances. Ultimately, the imposition of a 1% cap ensures that species at risk protection cannot affect the rate of harvest, provincially and by forest district, irrespective of the threats to species at risk in individual districts, such as the aforementioned ‘hot spots.’ This constraint means that the strategy intended to protect species from the effects of logging cannot significantly affect logging – effectively rendering the policy useless. In this way, the IWMS is yet another example of the government’s blatant prioritization of short-term economic gains above protection of species at risk. The Province cannot continue to allow species at risk management to be about avoiding the opportunity costs of lost timber supply. Protecting species at risk involves protecting their habitat, and for forest-dependent species that will undoubtedly result in a loss of timber supply.

    Yet another issue with the IWMS is that it applies only to those species that “are negatively affected by forest or range management on Crown land and are not adequately protected by other mechanisms”. The first problem with this statement is that its language allows for the reliance on ‘other mechanisms,’ such as forest harvesting practices outlined in FRPA. There is too great a reliance on these mechanisms. Further, the BC Forest Practices Board, the agency that monitors the effectiveness of FRPA, found that most of the mechanisms for conserving biodiversity have not been adequately implemented since FRPA’s predecessor came into effect in 1996. The second problem with this statement is that it leaves those species at risk which might be affected by other land uses, such as mining, agriculture, urban development, road construction, etc, without a specific policy aimed at minimizing physical harm or impacts to their habitat. Therefore, all species at risk which do not reside in parks and protected areas and which are threatened by land uses other than forest and range operations are unprotected from the threat of extirpation or extinction without a more general, last resort, species at risk law applicable wherever the species reside in the province.

    The provincial government claims that there is a policy currently in place to address the protection of species at risk that are not protected by other means (i.e. parks and protected areas or by the measures outlined for Identified Wildlife under the IWMS). This policy is the Wildlife Act. According to the Ministry of Environment, the goal of the Act “is to maintain and restore the rich diversity and abundance of native wildlife species, based on accepted biological and ecological principles”. According to basic ecological principles, and as required in the Convention on Biological Diversity, legislation for species at risk protection, such as the Wildlife Act, requires some form of recovery strategy. Such a recovery strategy would involve efforts to recover the number of species to stable levels within its natural or restored habitat. However, the creation and implementation of recovery plans are not legally required for species listed under the Wildlife Act. This fact assumes greater importance when one considers that there is no legal requirement for species at risk recovery under any provincial policy. Without implementing a recovery strategy for each species at risk, their status is not likely to change for the better; they will remain as species at risk or they will become extinct.

    A tiny fraction of BC’s species at risk are legally listed under the Wildlife Act. This is the case despite the CDC’s monitoring, reporting, and scientific listing of hundreds of threatened and endangered species and ecosystems. Accounting for the species listed under the IWMS, less than 10% of species listed by the CDC receive any legal protection by the province. If the Wildlife Act exists to protect species that are not protected by other means, what justification does the government have to reject the other 90+ percent of species for legal listing? Key decisions in the process of elimination involved the arbitrary decision to reject the CDC’s hundreds of blue-listed species and hundreds more species for which there was insufficient data or for which there was no independent assessment made by a partner organization to the CDC (disregarding the ecological precautionary principle). This leaves just a few species that are known to exist only in protected areas and hundreds of species that are unprotected because they are not at risk from forest and range practices. None of these justifications for rejecting species are ecologically sound and none of them correspond to the stated objective of the Act. Ultimately, it is this discrepancy between the scientific lists of the CDC and the legal lists of the government that are a clear indication of the government’s failure to address species at risk and the need for more effective legislation.

    Even if more species were to assume listing under the Wildlife Act, there are still problems associated with the voluntary, highly discretionary wording of the Act. Section 6. (1) of the Act states that the lieutenant governor in council has the authority but not the duty to list species under the Act: “where he considers that a species of wildlife is threatened with imminent extinction throughout all or a significant portion of its range in the province owing to the action of man, the Lieutenant Governor in Council may, by regulation, designate the species as an endangered species”. As long as legal listing under the Act is voluntary and left to a government bureaucrat’s discretion, the number of species listed under the Act will remain at 4. Further, the Act prohibits hunting, killing, or physical damage to species listed under it but does not require that their habitat be protected or a recovery plan be developed and implemented. Contrary to the government’s claims, as long as the Act remains in its current state, there is no allowance for contemporary scientific approaches to conservation.

    It should be clear at this point that BC’s existing laws are inadequate for the protection of species at risk. One alternative to a new provincial species at risk act would be to allow the federal government to assume jurisdiction over provincial species at risk where the province is failing to protect them. Under federal jurisdiction, BC’s species at risk would become protected under the federal Species at Risk Act. Although Canada’s Constitution Act, 1867, normally limits federal jurisdiction over wildlife to migratory birds, marine species, fisheries, and species residing on federal lands (which make up less than 1% of BC), there is a “safety net” provision within SARA which would allow the federal government to supersede provincial authority on provincial land if the federal government believes the province to be insufficiently protecting a nationally threatened or endangered species. It has been argued that a reinterpretation of the federal Species at Risk Act is what is needed to address the protection of BC’s species at risk, and this is an enticing suggestion. On paper, SARA meets all of the requirements of the Convention on Biological Diversity, including the identification of critical habitat and its protection, as well as the creation and implementation of recovery plans for all species within 2 years of their listing. Furthermore, the federal government’s list of legally protected species has kept pace with the scientific lists maintained by COSEWIC.

    At present, existing legislation for the protection of species at risk in BC is a patchwork assemblage of policies, none of which are strong, comprehensive, well-enforced, or well-designed. As a result, the majority of BC’s species at risk are without any protection under existing provincial or federal laws. The remaining 13% are offered only minimal protection, the majority of which is provided by SARA.

    What is needed in BC is a comprehensive provincial policy which supports a consistent, systematic approach to protecting species at risk, including the mandatory identification and protection of critical habitat and legal requirements for species recovery. New legislation should also incorporate contemporary ecological principles. Such an act would recognize the protection of ecological integrity as a priority, protect of a “full range of ecosystem types,” maintain “viable populations of native species,” sustain ecosystem services, and be resilient to the effects of climate change.

    So what can the provincial government do to meet its international and national commitments to the protection of species at risk in the interests of conservation biodiversity? First and foremost, the provincial government should amend the Wildlife Act so that it pertains to all species, wherever they reside. In this way, the Wildlife Act would serve its intended function as ancillary means of species at risk protection when other mechanisms, such as designation of parks and protected areas and protection of species and their habitats from harm from forest and range practices, fail or as a primary means of protection when these do not apply.

    Secondly, the government must address the discrepancy between the scientific lists maintained by the CDC and its own legal lists. Legal lists can be extended by including blue-listed species, species for which there is “insufficient information,” species residing in protected areas, and species which are at risk from activities other than forest and range practices. In short, comprehensive species at risk legislation would recognize that there is no justification for legal lists that are not in line with scientific lists. Furthermore, the provincial government must ensure that the CDC continues to receive necessary support and funding so that its lists of species legally protected under species at risk legislation can be measured against those obtained through independent scientific assessments.

    Finally, the government must reprioritize. Instead of favouring profits and unsustainable rates of resource extraction, the government must favour ecosystem health and the sustainable use of resources. Instead of cutting funding for the implementation and enforcement of species at risk laws, the government should increase funding and staff for this purpose. Instead of rejecting species based on a lack of information, the government should protect those species according to the precautionary principle. And instead of avoiding taking responsibility for species at risk within its jurisdiction, relying instead on the federal government or private companies with tenure over the province’s resources, the BC government should be proactive, assuming – finally – responsibility for the effective protection of species at risk within the province. As I have argued, this will require significant changes to BC’s species at risk legislation.

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    [-] Krista

    I would like to see serious consideration given to stand alone species at risk legislation. Perhaps stand alone legislation would be more effective while also creating greater certainty and consistency for project proponents, landowners/mangers and decision makers. I believe that the natural resource economy can adapt and may realize benefits from a change in the policy framework.

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    [-] Tanis

    What are your thoughts on how to improve the current provincial policy and legislative framework for protection of species at risk?
    o I appreciate the wording “regardless of where they are found”. Protection of rare species on private lands is in great need of enhancement.
    o “Support(ing) a prosperous natural resource economy and ensur(ing) an even playing field across all sectors” does not belong as a primary part of the legislative framework of legislation intended to protect Species At Risk. By the time a species is at risk, there is already very little room for concession for these species’ survival. The economy should not prevent the protection of a Species At Risk.

    Are you aware of successful initiatives that governments in other jurisdictions have used to support the protection of species at risk?
    o Maintaining large areas of undisturbed habitat and maintaining connectivity corridors between habitat patches is the best way to protect species, and a well-functioning ecosystem.
    o Phasing out fossil fuels in exchange for green, renewable resources is a cutting-edge way that other countries are helping to minimize environmental stress on their local species. Climate change induced migration, population explosion (pine beetle), and ocean acidification related to fossil fuel combustion are already major stresses for species in BC.

    Do you have any other thoughts on how we can achieve a balance between protecting species at risk and supporting a vibrant natural resource economy?
    o Place critical habitat protection and connectivity, as well as clean air, water, and soil as the foremost priorities, without concession to natural resource development. Our agriculture, the water, the forests, the fish, the game, and our tourism dollars cannot be prosperous without clean air, water, and soil. Without natural habitat and a clean environment being top priority, there can be no conservation balance, or equitability across all natural resource sectors. However, I must stress again that economic considerations should not be allowed in the legislation to prevent protection of Species At Risk.
    o Climate change is another major threat to the biodiversity that sustains most of our natural resource economies. Supporting renewable energy and minimizing use of fossil fuels will have a huge impact on supporting our rare species and most of our natural resource economies, and goes hand-in-hand with the protection of habitat, and clean air, water, and soil.

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    [-] Juliet

    Enable to BC Wildlife Act to protect species at risk.

    Provide clear leadership to local governments on expectations and requirements to protect species at risk.

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    [-] Alex

    Expecting an at-risk species to recover or thrive, without offering the habitat they require, is like thinking that humans should be able to “go forth and multiply” without a home, a social safety net, and a suitable job. Yet BC has no laws for mandatory habitat protection for at-risk species.

    It’s not realistic to think we can protect at-risk species while at the same time exploiting more and more of the province in the name of supporting a “vibrant natural resource economy” which does little more than send unfinished raw materials to other countries for their enjoyment of the much more profitable manufacturing and related value-added industries. Along with much more comprehensive provincial at-risk species legislation, we must diversify our economy, so we’re not so dependent on exploiting our apparent endless natural resources — with all the habitat loss that entails.

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    [-] Bevan

    I think that the province would benefit from a stand-alone species at risk act. The current strategy of having species at risk values being addressed as sections and clauses in a variety of legislation leads to inconsistent application across different natural resource sectors, and impedes management based around modern ecological principles. The reliance on the wildlife act place management focus on different vertebrate species, and does not facilitate management of rare plants, invertebrates, or ecological communities. The American Species at Risk act is an example of legislation that has had positive conservation outcomes by mandating the protection and conservation of species at risk. I believe that the wealth of natural resources in BC makes concurrent management of species at risk and resource development possible. Management of species at risk does not need to preclude economic development; however it does frequently require extra management that may increase the expense of natural resource development. There is no incentive for private companies to voluntarily undertake these types of management activities as it places them at a competitive disadvantage in the market. If these management activities that are necessary to protect species at risk are mandated by legislation, this extra cost is applied to all companies eliminating any competitive disadvantage between companies operating in British Columbia. This extra cost could then be accounted for in planning of future developments and economically viable projects can proceed.

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    [-] Paula

    What is of utmost importance for species at risk is the protection of habitat.
    In BC, 30 % of species at risk are found in areas of native grasslands, such as the Thompson-Nicola and Okanagan valleys. The native grasslands of BC are at great risk. These are fragile ecologies and need to be protected. They should be no-go zones for industrial development, such as mining.
    Protect spadefoot toads, burrowing owls, badgers, mariposa lilies, sharp-tialed grouse by protecting their habitat before we have nothing left but holes in the ground, contaminated waters and air, and weeds.
    And please enact legislation to keep off-road vehicles off the fragile grasslands.

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    [-] MARION

    The current “patchwork” approach to species-protection legislation is not working as it offers no real protection: specific laws are needed as too many exceptions and loopholes currently exist. 43% of BC’s wildlife is at risk ! Let’s call things by their real name: this is a crisis that demands action. Corporate interests need to be kept in check as it is exactly this exploitative approach to the world that is so destructive of the natural environment.

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    [-] Jeff

    Considering the fact that this Government is now proposing “corporate sponsorship” of our Provincial Parks aka privatization, and what’s more, that although Park hikers and wildlife enthusiasts are required (under BC Wildlife Act & BC Parks “wildlife viewing” regulations) to give grizzly bears respectful distance and undisturbed time at salmon bearing rivers during their Fall hyperphagia period, these same Class A Provincial Parks are open to wolf and black bear hunters bouncing along with loaded weapons on their off-road vehicles. Furthermore, the fact that this Government allows ‘trophy’ killers to sit and wait at an invisible Park boundary (river) a mere 2 kilometres from a BC Parks grizzly bear viewing platform is repugnant. See previous Topic 1 comment regarding Government’s announcement for so-called “protection” of the Great Bear Rainforest.
    Absolutely support true protection for species at risk. Step one – abolish delusional, anthropocentric mindset that habitat and all other living lifeforms are economic ‘resources’.

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    [-] Susan

    Topic 2.
    I believe in BC we need a stand alone species at risk legislation. We need protection for all species, including plants and invertebrates, not just consideration for the cute photo friendly species. The environment is diverse, especially in BC, and all components of this environment are important.
    Yes, we need an economy which keeps food on the table of BC residents; perhaps eco tourism can play a bigger role in this, rather than raw resource extraction.

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    [-] Archie

    BC’s current policy on species at risk would benefit by incorporating a multi-species approach, the inclusion of socio-economic analyses as part of all decisions, the inclusion of realistic and practical tests in the decision making process, additional funding to collect inventory information and data on priority species, the establishment of minimum knowledge standards that must be met prior to any decision making (not just best available information), ongoing monitoring of the effectiveness of actions taken with regard to the species(s), as part of the decision making process including more wholistic reviews of the short term and long term impacts, and the balancing of objectives across the landscape consistent with BC’s broader societal values.

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    [-] Julie

    To achieving a better balance between protecting species at risk and supporting a vibrant natural resource economy in the forestry sector would require better forest management practices that allows for a greater inventory of older forests in BC. Forestry companies are now permitted to cut forests after 40 years if the forest is highly productive. This in turn effects many species at risk that require mature forests for habitat. We need to keep more mature forests intact for species at risk. As well there should be a halt on all old growth logging. I’d have to bet that we have a large enough land and forest base and smarts to figure out a better logging cycle that allows for resource extraction while maintaining areas of older forests.

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    [-] SCCP

    • What are your thoughts on how to improve the current provincial policy and legislative framework for protection of species at risk?
    1. Take immediate action to enact the BC Wildlife Act amendments tabled in 2004 to allow for the listing of species at risk beyond the existing four species, starting with all provincial red and blue listed species corresponding to federally listed species (Threatened, Endangered and Special Concern).
    Background: In May 2004, the B.C. Legislature enacted several amendments to the Wildlife Act to enhance the ability of the government to designate, manage and protect species that are at risk in British Columbia (Bill 51Wildlife Amendment Act, 2004). The 2004 amendments provide Cabinet with the authority to list any species or population of animal, bird, fish, plant or other species as a species at risk to ensure additional protection.
    One of the enacted amendments, Section 6 of the Wildlife Act does empower the provincial cabinet to designate a species as “endangered” if, as a result of the action of humans, it is threatened with imminent extinction throughout a significant portion of its range or to designate a species as “threatened” if it is likely to become endangered
    Since 2004 only four species have been legally designated as endangered or threatened in BC: Vancouver Island Marmot, American White Pelican, Sea Otter, and Burrowing Owl. Interestingly the pelican is not a federally listed species under SARA though it is protected as a migratory bird.
    A regulation is needed to bring these amendments into force and this regulation will include a list of species at risk that will be protected under the amended Wildlife Act as well as the option to designate a “species residence” (e.g. an individual burrow, den, nest or roost) for a species at risk.
    No such regulation has been developed to date and so the intent of the Wildlife Amendment Act has never truly come into force. BC does not have effective species at risk legislation and is not protecting species at risk until it does.
    SARA (Section 34) provides that failure by the provinces to adequately protect the listed species on land not under federal jurisdiction could lead to an order by the Governor in Council requiring them to do so. (i.e. Section 80 emergency order also known as invoking the “safety net”. Special orders to this effect have already been invoked in Saskatchewan and Quebec. Avoiding the regulatory approach (or taking a wait and see approach) in BC is not effective leadership species at risk.
    2. Provide clear, direct guidance to local governments and regional districts and by extension private landowners on expectations and requirements to fulfill responsibilities to recover species at risk and protect defined and candidate critical habitat affected by local land use activities

    • Are you aware of successful initiatives that governments in other jurisdictions have used to support the protection of species at risk?
    1. The City of Surrey has developed a streamside environmental development permit area process, biodiversity strategy and green infrastructure network that takes into account development that affects and is affected by species at risk and critical habitat.
    2. The City of Nanaimo has species at risk considerations specifically identified in their OCP
    3. The District of Saanich’s Environmental Development Permit Area bylaw specifically includes the protection of at risk species and their habitat.
    • Do you have any other thoughts on how we can achieve a balance between protecting species at risk and supporting a vibrant natural resource economy?
    Show leadership in actual commitment to achieving balance. This means making tough choices that set clear boundaries on where natural resource extraction and development can occur and standing firm on buffering and protecting the places where it must be prevented or halted. If the province is committed to employing best science, then many existing management actions need to be handled differently. Many, if not most, species are at risk due to habitat loss, leaving them vulnerable to other stressors such as disease, invasive species and predation. The science of species at risk recovery does not support using single focus actions that put investment into one course of action (e.g. predator control to save caribou or removing competitive species like Barred Owl to save remaining extant Northern Spotted Owl). These measures have some effect, but done in isolation, will not have lasting value and reflect a poor return on investment.

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    [-] Eva

    BC has a patchwork of regulations that allows too many species to fall through the cracks,
    despite being home to 75% of Canada’s bird species, 70% of freshwater fish species and 66% of
    butterfly species. BC also has more species at risk than any other province and yet is one of
    only two provinces without a specific law protecting endangered wildlife. More than 43% of
    province’s assessed species are at risk. A scientific body in BC maintains lists of species
    grouped according to risk, however action is not required by law and listing does not trigger
    legal protection. BC has 138 “red-listed” species, but only four legally listed under the
    provincial Wildlife Act (American White Pelican, Burrowing Owl, Sea Otter, Vancouver Island
    Marmot). Only three out of 191 species listed under SARA are listed as species at risk under
    the provincial Wildlife Act. There is no law specifically prohibiting harm (except prohibition
    against hunting) to species at risk. Further, BC has no laws for mandatory habitat protection
    for at risk species, which is essential for their survival and recovery. BC’s forestry laws allow
    listing of at risk wildlife, but protections are limited if they interfere with logging. BC laws do
    not require species recovery planning and implementation. Strong provincial endangered
    species legislation is required to replace the patchwork of legislation.
    Embrace the scientific discipline of Compassionate Conservation which considers animal
    welfare and ethics in conservation research, policy and practice so that broader
    considerations are made and protections for species at risk are not blanket approvals to kill
    other wildlife.

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    [-] Marjorie

    The biggest and most important is that CONSISTENT and dependable funding is legislated so that species and habitats are protected. Also reclamation projects need to be funded and included…there are old dams and polluted waterways that could be made more habitable and hospitable for human and other species…

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    [-] Betty

    Typically, environmental offenders aren’t held accountable. They’re like little kids roaring ahead looking neither right nor left, taking absolute risks, and then saying, “Oh gee, sorry,” later. And speaking of kids, as parents, we usually tell our children to clean up the stuff they already have out before adding to the mess in their room. Well in the news, it came out that there is currently a 7.7 billion price tag on the cost of cleaning up tens of thousands of government owned contaminated sites. Our laws on species-at-risk whether on public or private land need sharp teeth. We CANNOT continue forging ahead willy-nilly greedily doing what we will to the natural environment and just making a pretence of caring for the creatures no matter how large or small. I voluntarily monitor amphibians and reptiles on our property, but volunteers can only do so much without strong laws to protect species at risk–laws WITH TEETH.

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    [-] Miranda

    We need a progressive, comprehensive species at risk act, with teeth.

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    [-] isinipit

    Start controlling human population and you will help to protect SAR.

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    [-] Heather

    Protecting species at risk should take precedence over a natural resource economy. Business interests should not be allowed to impact on an endangered specie. Putting a higher priority on economic interests is often why the specie is endangered in the first place.

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    [-] Gillian

    Our present wildlife regulations do not reflect modern thinking about the natural world.
    The BC government must finally – after years of delay – proceed with strong species at risk laws, and they must not follow the lead of the federal government, who have delayed action on their duty to enact such laws, and have had to be repeatedly taken to court to move things along – as has been done with the Southern Resident BC Orca Species at Risk plan.

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    [-] George

    From the comments below, there appears to be way to much attention towards restricting resource development, rather than focusing on how resource extraction can be utilized towards enhancing habitats as part of a management regime. We need the revenues from our resources, so let us figure out ways to help the environment at the same time. It seems that clear cutting is the only way to extract timber when in reality there are various forms of extraction and extraction levels that could be used to enhance habitats at risk. It seems to me that habitats should be more important than than individual species as their population levels ebb and flow for various reasons. If we maintain the critical habitat attributes there will always be the necessary habitat to sustain new populations.
    Also we need to assess how important a particular species is. The Tiger Salamander is a red listed species in Canada, and yet it is so common south of the border, they are available in pet stores. That is not to say that we should ignore them, but we should make sure that the appropriate amount of time and effort is applied to that species compared to another that is more endangered across North America. I am sure there are a lot more species classed as “At Risk” on the Red list. Cheers George

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    [-] Bronwen

    BC has a patchwork of regulations that allows too many species to fall through the cracks,
    despite being home to 75% of Canada’s bird species, 70% of freshwater fish species and 66% of
    butterfly species. BC also has more species at risk than any other province and yet is one of
    only two provinces without a specific law protecting endangered wildlife. More than 43% of
    province’s assessed species are at risk. A scientific body in BC maintains lists of species
    grouped according to risk, however action is not required by law and listing does not trigger
    legal protection. BC has 138 “red-listed” species, but only four legally listed under the
    provincial Wildlife Act (American White Pelican, Burrowing Owl, Sea Otter, Vancouver Island
    Marmot). Only three out of 191 species listed under SARA are listed as species at risk under
    the provincial Wildlife Act. There is no law specifically prohibiting harm (except prohibition
    against hunting) to species at risk. Further, BC has no laws for mandatory habitat protection
    for at risk species, which is essential for their survival and recovery. BC’s forestry laws allow
    listing of at risk wildlife, but protections are limited if they interfere with logging. BC laws do
    not require species recovery planning and implementation. Strong provincial endangered
    species legislation is required to replace the patchwork of legislation.

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    [-] Judy

    1% maximum reduction in timber supply from WHAs is too low to actually protect endangered species. alter legislation such that the viability of the wildlife is put first. Many species eg Caribou require unfragmented habitat and 1% impact to timber wont do it.
    Make the wording in Identified Wildlife Strategies documents more concrete and measurable. Its difficult for a tenure holder to propose results in their FSPs because these IWS documents are too general.

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    [-] Terita

    Species at Risk Act is only applicable on federal land. Federal land is small in BC, can we change that? Wildlife species do not see borders, they go where they can survive and reproduce. As an environmental student with a particular interest in wildlife conservation and species-at-risk, I can see how detrimental not having a stronger legislation for protecting these species is. Industry is totally controlling this province and the conservation of species. We need a balance of economics, social and ecological. Economics can not dominate or species-at-risk will eventually become extinct.

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    [-] Islands_Trust

    We suggest that the current provincial policy and legislative framework be improved through enactment of a comprehensive BC Species at Risk Act.

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    [-] Mackenzie

    As an environmentalist in British Columbia I am not only deeply concerned with the loss of biodiversity that we face, but embarrassed and ashamed. We should not be so close to losing so many of our native species and we need to start being proactive rather than reactive. British Columbia should be a global leader in wildlife conservation as our natural landscapes draw in people from all over the world. I can’t even believe that we are still logging old growth forests and using control measures such as the wolf cull. It is a temporary, short-term fix that doesn’t actually address the root of the problem: habitat loss. As a recent university graduate I am concerned with my ability to find a job doing conservation work because sadly I feel as though the funding isn’t there. I will likely have to sell my soul and work for an oil/gas company in order to make a means of living. If research was funded I know that there are many people, myself included, willing to do the work.

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    [-] Judy

    Develop and app that lets people submit where they have seen red and blue listed species. Have an ID section and then have report function. Similar to report a weed.

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    [-] Kathleen

    Ban trophy hunting.
    Fund more research.
    Enforce environmental laws.

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    [-] Tanya

    Communicate with First Nations to obtain historical knowledge of local ecology and long-term data on species abundance and distributions.
    Err on the side of conservation rather than profits, even with the best science there is always high risk in practices that effect species due to unpredictable circumstance
    I feel we should move away from fossil fuel use and export, and instead join European nations in adopting renewable energy resources. Climate change is upon us, and it is already too late to stop at least some degree of warming from happening. Supporting the use of fossil fuels will only make this problem worse, and makes BC look ignorant to the most important issue of our time. Scientists agree, leave the oil in the ground, invest in renewable energy. Please let there be some wild things left for future generations, not a world lacking biodiversity and beauty due to our government’s unwillingness to make tough choices for the planet instead of their oil company donors.
    Kinder Morgan’s history of safe operations means nothing when there is a spill along our coast. Even with the world’s best clean up practices a spill would be catastrophic and destroy an unimaginable amount of wildlife, now and in the future do to lingering toxicity. Our region is home to many endangered species such as the resident orca, who have already been heavily affected by human pollution and carelessness. Please do not increase the risk of a spill on our coast with government greed.

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    [-] Sharon

    It is deeply concerning that of the 138 “red-listed” species in BC, only four are legally listed under the provincial Wildlife Act (American White Pelican, Burrowing Owl, Sea Otter, Vancouver Island Marmot). Only three out of 191 species listed under SARA are listed as species at risk under the provincial Wildlife Act. There is no law specifically prohibiting harm (except prohibition against hunting) to species at risk.

    The amount of development and increased tanker traffic and proposed pipelines are deeply concerning, and globally have a negative cumulative impact on wildlife and the environment they and we depend on.

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    [-] Jennifer

    BC has a patchwork of regulations that allows too many species to fall through the cracks, despite being home to 75% of Canada’s bird species, 70% of freshwater fish species and 66% of butterfly species. BC also has more species at risk than any other province and yet is one of only two provinces without a specific law protecting endangered wildlife. More than 43% of province’s assessed species are at risk. A
    scientific body in BC maintains lists of species grouped according to risk, however action is not required by law and listing does not trigger legal protection. BC has 138 “red
    listed” species, but only four legally listed under the provincial Wildlife Act (American White Pelican, Burrowing Owl, Sea Otter, Vancouver Island Marmot). Only three out of 191 species listed under SARA are listed as species at risk under the provincial Wildlife Act.
    There is no law specifically prohibiting harm (except prohibition against hunting) to species at risk. Further, BC has no laws for mandatory habitat protection for at
    risk species, which is essential for their survival and recovery. BC’s forestry laws allow
    listing of at risk wildlife, but protections are limited if they interfere with logging. BC laws do not require species recovery planning and implementation. Strong provincial endangered species legislation is required to replace the patchwork of legislation.

    Embrace the scientific discipline of Compassionate Conservation which considers animal welfare and ethics in conservation research, policy and practice so that broader
    considerations are made and protections for species at risk are not blanket approvals to kill other wildlife.

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    [-] Sue

    It seems our planet is at risk of losing many species in the next 20 years, could we not be a leader in protection and prevention? This does not need to be complicated, only a priority above other that endanger the environment, habitats and animals. Profit must become secondary to killing off species. I agree with many of the comments below. Ban ALL “Trophy” hunting… No excuse that this continues. Ban all Wolf culls. http://www.yellowstonepark.com/wolf-reintroduction-changes-ecosystem/ . Protect the orcas by rejecting the pipeline… I am a born and raised BC resident and the BC government sells our province to the world as Super Natural British Columbia – put your money where your mouth is. Can you imagine our province without orcas, grizzly bears and wolves? See, simple.

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    [-] Gillian

    The southern resident orca population is endangered and needs the BC Govt to refuse to allow the Kinder Morgan pipeline to go ahead as it will increase the amount of tanker traffic seven fold. This in turn increases noise and pollution to the waters so the Orcas find it hard to communicate with each other in the pod and hunt food. Many concerned scientists have stated they will not survive an increase in taker traffic of this size. Many local businesses rely on orcas as a draw for tourists from all over the world. We need our provincial government to show much stronger leadership rather than paying lip service to protection of endangered species and species at risk. Once they are gone they are gone for ever.

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    [-] Mila

    Many studies have shown that protecting intact ecosystems and species at risk leads to massive long-term economic benefits in the ecotourism industry. These long-term economic gains can massively outweigh the short-term benefits of natural resource extraction, and I therefore recommend that the BC government take the following actions to protect our species at risk and the ecosystems they rely on:
    1) Stop the wolf cull. The wolf cull is a bandaid solution that has not even been effective at helping raise caribou populations. A better solution would be to protect key caribou habitats by designating more wilderness areas as provincial parks and making protected areas better-connected (for example, approving the park proposal put forward by the Valhalla Wilderness Society to protect mountain caribou).
    2) Ban trophy hunting of grizzly bears. The vast majority of British Columbians are against the trophy hunt, and it needs to be stopped for ethical, environmental and economic reasons. Grizzly bear viewing as a form of ecotourism has far more long-term potential for economic gain than the trophy hunt, and is extraordinarily more ethical and just.
    3) Reject the Kinder Morgan pipeline. This pipeline infringes upon the social rights of First Nations groups and the environmental rights of coastal BC. Again, the benefits that will result from ecotourism if the coast remains oil-free will far outweigh the short-term economic benefits that the oil industry brings.
    2) Ban logging on all old-growth forests. Old growth forests have incredible ecotourism potential and we are so lucky to still have any of them that they should stop being chopped down.

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    [-] Magda

    The BCSPCA offered a response to this topic that reflects my thoughts: “Embrace the scientific discipline of Compassionate Conservation which considers animal welfare and ethics in conservation research, policy and practice so that broader considerations are made and protections for species at risk are not blanket approvals to kill other wildlife.” (For example, the wolf cull for the sake of the caribou. The real predator of the caribou is humans, who have depleted their habitat with our selfish priorities.)

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    [-] Chloe

    BC has a patchwork of regulations that allows too many species to fall through the cracks,
    despite being home to 75% of Canada’s bird species, 70% of freshwater fish species and 66% of
    butterfly species. BC also has more species at risk than any other province and yet is one of
    only two provinces without a specific law protecting endangered wildlife. More than 43% of
    province’s assessed species are at risk. A scientific body in BC maintains lists of species
    grouped according to risk, however action is not required by law and listing does not trigger
    legal protection. BC has 138 “red-listed” species, but only four legally listed under the
    provincial Wildlife Act (American White Pelican, Burrowing Owl, Sea Otter, Vancouver Island
    Marmot). Only three out of 191 species listed under SARA are listed as species at risk under
    the provincial Wildlife Act. There is no law specifically prohibiting harm (except prohibition
    against hunting) to species at risk. Further, BC has no laws for mandatory habitat protection
    for at risk species, which is essential for their survival and recovery. BC’s forestry laws allow
    listing of at risk wildlife, but protections are limited if they interfere with logging. BC laws do
    not require species recovery planning and implementation. Strong provincial endangered
    species legislation is required to replace the patchwork of legislation.
    Embrace the scientific discipline of Compassionate Conservation which considers animal
    welfare and ethics in conservation research, policy and practice so that broader
    considerations are made and protections for species at risk are not blanket approvals to kill
    other wildlife.

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    [-] John

    BC needs a stand alone Species at Risk Act that supersedes forestry, mining, oil and gas and land use legislation and policies. The mixed bags of present protections are consistently watered down or totally ignored within existing legislation and the arbitrary limits placed on protection. The framework needs to address species specifically through habitat protection and enforceable best management practices. Species protections are best managed through a landscape level framework of protected and connected areas, but species at risk must have their own legislation in order that the vagaries of existing legislation are not allowed to ignore the need for recovery actions. Actions by industry as well as recreational users that are contrary to legislated protection and practices must be prosecutable with significant penalties.

    All Forest Stewardship Plans should be required to include best management practices for species at risk and site plans should list possible species present and management actions.
    Agriculture has generally been given a free pass in regard to SAR in much of British Columbia. Range tenures should be subject to revocation when SAR are not appropriately managed for on either crown or private ranges.

    The United States Species at Risk Act has been exemplary in it ability to enforce species protections. The references to maintaining the resource economy when considering species at risk legislation is not consistent with the intent of recovery. The economic roller coaster that our resource industries ride is not going to be smoothed by sacrificing species at risk. Industry faces downturns, these species face extinction. Legislation must determine what is best for species recovery—-it is then up to industry to consider how best to adapt to the needed changes.

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    [-] Warren

    Adopt the recommendations of the COSEWIC and make them mandatory!!

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    [-] Steven

    A successful species at risk policy is dependent on preservation and expansion of natural ecosystems and allowing for their interconnection to permit the unfettered migration of animals and plants through parks and land reserves. The policy must be supported by tough and properly enforced laws and it should be guided by the principal that the health and safety of wildlife is paramount over short term economic gains.

    A hundred years ago, about 95% of the human population in North America lived on farms. Less than 5% do today. During the same period, the population has more than tripled. While the sizes of farms have probably expanded, residential and industrial use of land has been the main catalyst of urbanization. Technology and access to food globally has allowed fewer people to feed even more people. In the face of increasing automation and robotics, there is likely to be decreasing opportunities for farmers. Increasing recognition of the devastating impact of the meat industry on human health and the environment will eventually lead to its decline. Likewise, with the depleted fish stocks there will be lesser opportunities for fishermen. New types of building materials will reduce the demand for forestry products, and better sources of energy will ultimately supplant the use of polluting fossil fuels. To be part of the global new economy, British Columbians should be leading the transition away from what is really an unsustainable natural resource-based economy. An unsustainable natural resource-based economy, no matter how vibrant it might be for a short while, will ultimately collapse.

    Respect for animal welfare needs to be cultivated by public education with a consistent message from government. Government can’t say that we must save the last remaining members of a small number species, while actively supporting the exploitation of other animal species. We certainly should not be encouraging an industry for hunting animals in the wild, especially by foreign hunters. As more large animals species are hunted to extinction elsewhere, there will be increasing pressures for more pouching in B.C. This is especially tragic when magnificent creatures like bears are hunted for their gall bladders and paws because of some antiquated notion that they have medicinal or magical properties. Wildlife tourism will probably be a much more lucrative industry than the hunting industry in the future.

    We often don’t appreciate the real value of what we have lost until it gone. This is true for nature. In the Lower Mainland of British Columbia, there is almost no old growth trees left. Most people in B.C. have probably never seen such forests, but if we don’t take care, even fewer will in future generations.

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    [-] Onni

    More than 43% of the province’s assessed species are at risk. BCs patchwork regulations do not include specific laws to protect endangered wildlife. Although a scientific body in BC maintains lists of species grouped according to risk, action is not required by law and listing does not trigger legal protection. How can this be considered effective regulation? The only law specifically prohibiting harm to species at risk is a prohibition against hunting.

    BC has no laws for mandatory habitat protection for at risk species although this is essential for their survival and recovery. Where are laws banning neonics for agriculture or landscaping use to stop the disastrous decline of bee and butterfly populations?

    When BC is home to 75% of Canada’s bird species, 70% of freshwater fish species and 66% of
    butterfly species, strong provincial legislation is a must to protect precious Commons Heritage that we offer the world.

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    [-] Carol

    We require legislation that protects habitats and prevents species from becoming at risk in the first place. Also, the legislative framework must be changed so that any species that are at risk are legally protected from harm in their natural habitat. For example, protections for species at risk are limited if they interfere with logging, or oil or gas activities. I question why protection of species must be balanced with a natural resource economy. Protection of species and their habitats should be of more importance than the short terms gains from resource extraction. In the long run, protecting wildspaces can contribute more to the economy of the province and the well-being of BC residents. This could be through tourism, and development of environmentally responsible alternative energy, and development of economic activities other than natural resource activity. Not to mention the value obtained in the life sustaining activities provided by protection of ecosystems (clean water, clean air, etc.)

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    [-] Deborah

    Perhaps look to the World Wildlife Fund for their recommendations. They are well respected and bring a global perspective.

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    [-] Nikki

    I think that BC needs to create very strong provincial endangered species legislation to give the survival of species a higher priority than corporate profits.

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    [-] Des

    Have a clear, single set of provincial laws for sara species, not a mishmash of regulations and laws found here and there. BC is one of only 2 jurisdictions in Canada which have not done this! Why is our government so far behind? Protecting at risk species will not always “support a prosperous natural resource economy”; I don’t agree with this being listed as one of the principles that should be taken into account in this kind of legislation. Tourism is an economic driver; people will pay to see these species and their protected environment. Tourism dollars can offset any losses to industry that protection might cause.

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    [-] Judy

    Change FRPA so that cutting permits can be refused in red, blue listed species ranges. Also in FRPA, bring back ‘green up’ such that more connectivity happens. Bring back in FRPA ‘adequately manage and conserve’ such that timber will not trump all other values.
    Right now the balance is all on the economic side and we are having big losses of habitat and population declines. Goshawk, moose, caribou, badger, fisher, caribou all come to mind. Allow that balancing to occur and remove the ‘without unduly impacting timber supply” clause in FRPA which means that no balancing is done.

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    [-] Ann

    There are currently too many different acts and I am unsure if they work together or against each other. Simplification is needed, covering private and public lands. A vibrant natural resource economy should consider it’s impact on species at risk as more important than economic factors. If there was a Basic Income Guarantee (BIG), which is becoming necessary due to technological advances, economics loses it’s influence and destructiveness.

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    [-] Joanne

    I agree with Jody:”BC has a patchwork of regulations that allows too many species to fall through the cracks, despite being home to 75% of Canada’s bird species, 70% of freshwater fish species and 66% of butterfly species. BC also has more species at risk than any other province and yet is one of only two provinces without a specific law protecting endangered wildlife. More than 43% of province’s assessed species are at risk. A scientific body in BC maintains lists of species grouped according to risk, however action is not required by law and listing does not trigger legal protection. BC has 138 “red-listed” species, but only four legally listed under the provincial Wildlife Act (American White Pelican, Burrowing Owl, Sea Otter, Vancouver Island Marmot). Only three out of 191 species listed under SARA are listed as species at risk under the provincial Wildlife Act. There is no law specifically prohibiting harm (except prohibition against hunting) to species at risk. Further, BC has no laws for mandatory habitat protection for at risk species, which is essential for their survival and recovery. BC’s forestry laws allow listing of at risk wildlife, but protections are limited if they interfere with logging. BC laws do not require species recovery planning and implementation. Strong provincial endangered species legislation is required”. Many SAR have no legal protection because they are not designated as Identified Wildlife under FRPA. Currently, there is no protection for plant communities at risk due to a technical error in legislation. Obviously that needs to be fixed. FRPA is broken and only enables limited management of SAR – those that qualify and only to the extent that they do not unduly reduce timber supply. So on forest lands, SAR management is only undertaken in consideration of the impact of those protective measures on those resources that support the ‘vibrant and natural resource economy’. The Cumulative Effects framework only considers what is currently legal, and as such is broken. If you measure risks to values against legal objectives that were developed to protect an industry, then garbage in = garbage out. There needs to be a legislative review that identifies the gaps in terms of effective species at risk management. Pieces of FRPA are not working, many SAR affected by forest and range practises are not identified and ‘blessed’, the CE framework is not going to be effective, and the new Wildlife Act amendments missed plant communities so there is now no protection for any plant communities at risk in BC. As well, timber supply reviews that set harvest levels only reflect current practise on the landbase and do not consider habitat supply. Timber supply reviews are not land use plans and in reality are focussed on timber supply. While some attempts are being made to address this, there is still a very long way to go, and a vibrant natural resource economy (particularly in the central interior) will not occur in conjunction with honest and effective SAR management.

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    [-] Christine

    How to improve the current framework: Simplify it and make it the same for all users of Crown land. With that being said provide a suite of options so that where we may not be able to do outright conservation there are clear other actions which can be taken to mitigate impact.

    Achieving a balance: I think by providing a suite of options and being clear, up front about what we need to achieve in terms of protection we can get a lot farther to achieving a balance. I think where we run into trouble is when clients are not aware of an impediment or of a need to address a natural resource value until later on in the application process is where we get push back. On the flip side we need to recognize that not everything can always be protected the way we think it needs to be, we have to be willing to have a conversation that works for all of BC – for concerned public, for investors, for people hoping to have work.

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    [-] Jody

    BC has a patchwork of regulations that allows too many species to fall through the cracks, despite being home to 75% of Canada’s bird species, 70% of freshwater fish species and 66% of butterfly species. BC also has more species at risk than any other province and yet is one of only two provinces without a specific law protecting endangered wildlife. More than 43% of province’s assessed species are at risk. A scientific body in BC maintains lists of species grouped according to risk, however action is not required by law and listing does not trigger legal protection. BC has 138 “red-listed” species, but only four legally listed under the provincial Wildlife Act (American White Pelican, Burrowing Owl, Sea Otter, Vancouver Island Marmot). Only three out of 191 species listed under SARA are listed as species at risk under the provincial Wildlife Act. There is no law specifically prohibiting harm (except prohibition against hunting) to species at risk. Further, BC has no laws for mandatory habitat protection for at risk species, which is essential for their survival and recovery. BC’s forestry laws allow listing of at risk wildlife, but protections are limited if they interfere with logging. BC laws do not require species recovery planning and implementation. Strong provincial endangered species legislation is required to replace the patchwork of legislation.

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    [-] Lynda

    The Province needs to enact strong endangered species legislation guided by the precautionary principle. Natural resource development is a means to an end that can be achieved in ways that do not threaten species at risk or humanity’s survival. The end is general happiness in an ethical framework that values all individuals and gives them the means to actualize in a diverse and sustainable ecosystem; it is not greediness or the maximization of consumption.

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    [-] Peter

    Larger fines for damaging the environment. With the money from the fines used to fund projects to manage sensitive areas. In our are we have the Columbia Valley Local Conservation Fund, as well as the Environmental Stewardship Initiative.
    Yikes “a vibrant natural resource economy” …there lies the problem…It should be more “a sustainable natural resources ecomomy”. The sawmill in Radium is an example of “vibrant”…how long before its a “dim” sawmill and the people are out of work…again.
    I also have concerns about interest groups buying land to create private parks.

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    [-] Trevor

    You ask about how to achieve a balance between protecting species at risk and supporting a vibratnt natural resource economy. In the case of the Mountain Caribou, it’s unfortunately much too late for that. The balance has been tipped in favour of corporate interests for decades. We’ve known since the early 60s (Edwards & Ritcey) that carbiou need large tracks of oldgrowth at all forested elevations, but have favoured industry over caribou conservation every step of the way. Even the 2008 set-asides amount little more than deferrals on harvesting insofar as (1) no lowland oldgrowth forests were set aside and (2) logging is scheduled to recommence once the caribou are gone. Anybody in the know on caribou biology would understands immediately how profoundly cynical this is: R.I.P indeed! Anyhow the scales have for far too long been tipped in favour of industry. Correcting the balance can now only mean tipping them in favour of conservation. You can kill wolves and build your birthing pens until the cows come home, but without extensive oldgrowth forests at all forested elevations throughout their range, the mountain caribou is doomed disappear. A colleague and I have a paper in prep on this subject and would be pleased to share the ms if there’s any interest at your end.
    I should note that these comments apply also to various oldgrowth-dependent epiphytic lichens – they too won’t be sustained without now actively tipping the scales in their favour. In this case the paper has already been published. Let me know if you’d like a copy.

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    [-] Kathie

    I am really concerned about this topic…I always think of my grandchildren…what will be left for them…Once they are extinct, they are gone forever…Please protect all species at risk, including plants, animals and marine life…Regards Kathie

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    [-] Jenefer

    1. We should have a Provincial Endangered Species Legislation/Law for Species at Risk. Why doesn’t BC have this when we have so many endangered species. If the provincial government is serious about protection, and or improvement, should this not be a priority? I don’t see that in here? It adds to my point that we have haphazard fish and wildlife management in this province. That in 2016 with so many environmental issues we don’t even have an Endangered Species Legislation in here to hold government and industry accountable. How negligent of the Liberals.
    2. Yes I was aware of the other acts noted here, but they lack in their ability to enforce law.
    3. At this point in time 2016, the only way to create balance between protecting species at risk with a growing population, and supporting the natural resource sector is to make changes to where we get our energy from. BC and Canada need to become world leaders in clean, green energy systems, i.e., wind, tidal, solar, electric (new technology). Building new economies is the only way to protect wildlife and the earth for our future generations and wildlife. There is no other way to balance a very unbalanced, archaic, and corrupt system.

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    [-] Ron

    In respect to the third question: “Do you have any other thoughts on how we can achieve a balance between protecting species at risk and supporting a vibrant natural resource economy?” My comment is most resource industries in today’s economy undertake costly and multi-year environmental assessments for any proposed disturbance to Crown lands. There are notable exceptions, including large scale forest removal – and oil and gas extraction. It is somewhat disingenuous that small clean energy projects like wind power projects are required to undertake million dollar environmental assessments, while carbon seeking drill rigs get a free pass on environmental studies. Let’s level the playing field to protect species at risk. Industry is generally supportive of developing methods and mitigations to protect our precious species at risk. Thanks for the opportunity to comment.

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    [-] David

    If the province of BC is serious about SARA, and protection of Species at Risk, we need to protect the habitat of those species at risk to avoid wiping them out. This may mean dropping approved cut blocks and no planning of harvesting in areas that threaten the species at risk.

    This has happened to some degree in the mountain caribou habitat. Other habitat for caribou at risk north and west of mountain caribou habitat has had continued degradation.

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    [-] Judy

    We need comprehensive species-at-risk legislation that applies to all lands. It is deplorable that researchers were not even able to look for Dromedary Jumping-slugs on private lands.
    And the areas that are set aside for endangered species must be large enough to support their whole life cycle, not just their nests or breeding areas.

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    [-] Judy

    Hire more Conservation Officers to enforce existing legislation against poaching! There are only about 150 positions in the entire province right now. Kind of sparse for the square miles involved.

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    [-] Sue

    We need BC to develop a SARA that covers all of the gaps from the federal regulation. The key focus must be protecting the species, not about balancing it with the natural resource economy. That can proceed where it does not endanger species nor the environment but in key habitat areas, those should be protected for the species that rely on them for their continued existence.

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    [-] Mark

    Q1. Improve provincial policy and legistlative framework

    The BC Wildlife Act includes measures for the protection of wildlife, including the requirement for salvage of amphibians and reptiles to prevent harm, harrassment, or mortality during construction (listed under use of conveyence). This goes beyond SAR, but I raise the issue for several reasons. First, species that are not currently listed as imperilled provide many of the supporting services for species that are threatened or imperilled. However, the legislation also causes some confusion. The province has put out a BMP document for the salvage of herpetofauna to be in compliance with the legislation, but that same document suggests that salvage does not work. Hence, we are spending lots of effort moving amphibians and reptiles out of the line of construction traffic without knowing if this even does anything effective. That same document describes a BACI monitoring approach that is flawed, because the “control” sites are not true experimental controls and the onus should not be on contractors to run piecemeal “experiments” on the success or failure of the technique. The salvage process is a waste of time and money that would be better spent of better management techniques.

    The other concern is about how much information do we have on species that are not at risk? Why do we emphasize species? Can we even conserve a species? A species is a hypotheses about organisms. When we have an organism in hand we look at its features and infer its genealogical affinity by the species binomial. Of course a western toad is a western toad (Anaxyrus boreas), but more fundamentally is a western toad in a tank the same as a western toad in the woods? The extended synthesis of modern evolutionary biology tells us that organisms are acting both as ecosystem engineers and niche constructors. This means that the environment is both affected by and on the evolution of organisms. Organisms that change their environments are at the same time influenced by the environment – selection pressures change. When we alter the environment we are altering the selection context for species, so we have a difficult target when we say we are “protecting” species. The more appropriate target is the environment itself so that we can sustain processes, like migration. Migration is a process that is very threatened and it is threaded under the heading of biodiversity. What species are not currently threatened under climate change scenarios? Can we even evaluate the level of risk? Common and numerous is not a predictor of what is secure.

    Q2. Successful initiatives
    I am aware of successful initiatives, but there is an underlying problem with the economics and measure of success that I address in the next question.

    Q3. Balance between protecting SAR and vibrant natural resourse economy
    The premise of this question is a disturbing one and it has to be rejected. There is no balance between protecting the economy and protecting nature, because they are one in the same. My university course textbook for ecology was titled: “The Economy of Nature” and if you study your history you will learn that this is where the term ecology is derived from. We cannot have a vibrant natural resourse economy without effective management of the economy of nature. A large reason for recent scientific publications noting the drastic decline in global biodiversity stems from the false premise implied in this question. Our economic models have a dysfunction with the planetary economy, because governments are not using methods to evaluate the goods and services that are derived from natural systems.

    I’m an amphibian ecologist and I understand that the ecological actions of amphibians in soils creates a service that retains carbon in the soils. This is not a minor service – it is globally significant. Some scientists have suggested that the decline in amphibians is enough to explain global warming – that’s how significant this is. Yet, when governments talk about a carbon tax they are not entertaining the idea of carbon that is being lost by the fragmentation of amphibian populations. If you want to balance the protection of species at risk and supporting a vibrant natural resource economy, then start to recognize that growth in a vibrant natural resource economy is being sustained by ecosystems. Recognize that value and stop with this absurd notion that you have to balance the two. Make the value explicit and account for it, measure it, and budget for it.

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    [-] Tina

    Is there any consideration / commitment by the provincial government to work to improve/increase provincial SEAR legislation & policy on public and/or private land?

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    [-] Keith

    We should consider stand alone provincial species at risk legislation that would take precedence over other natural resource legislation. Doesn’t the fact that we are having this conversation indicate that the “balance” has been weighted in favour of exploitation rather than management of natural resources. It is time to modernize the basis for our economy.

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    [-] Tina

    Clear, comprehensive policies, implementation and enforcement processes – how to address SEAR and important habitat on private land and Crown land. Must be a pro-active policy (not just step in when needed).

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    [-] Bernadette

    BC’s protection of species at risk is currently a weak patchwork of regulations that has allowed far too many species to fall through the legislative cracks. The ineffectual BC Wildlife Act is actually derived from hunting legislation.
    BC needs a strong provincial endangered species law that replaces the inadequate system currently in use.
    Also use experts as well as just comments from individuals in environmental assessments.
    Plus remember if impact on environment is too great, people will become an endangered species if we are not already one due to climate change.

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    [-] MJ

    The background text above illustrates how convoluted and non-committal the Province’s policy, statutes, and regulations are with regard to protection and management of species at risk.

    The solution is really quite simple: pass a provincial species at risk law. A provincial Endangered Species Act …and include enforcement measures with it.

    The process would require research into the current best practices in jurisdictions throughout North America, then crafting legislation, and passing it. See Ontario and Nova Scotia for example, better still, see US Federal and State (e.g., California) examples and follow suit.

    Industry and development will adapt to the cost of doing business.

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    [-] Jennifer

    BC needs a strong, effective Endangered Species Act, that applies to all sectors/industries. It is long overdue.
    BC could provide funding for land conservation, and offer incentives to private landowners willing to protect habitat
    BC must end old-growth logging.

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    [-] Lesley

    Vibrant natural resource economy? There is only 1% old growth left on the Island. Stop the logging of Old growth. Make private lands that were inherited from the Provincial Government to plant trees and re-forest. Protect ALL endangered species today and have legislation to protect all these creatures whether on public or private land. Also respect the cycle of life, recently Island Timberlands was going to log an area that had nesting birds and said they could log around them. Wait until birds have left their nests and have healthy young!! All life matters and these birds deserve that opportunity after sometimes flying 2000=5000 miles to have their young.

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    [-] Sarah

    •BC’s protection of species at risk is currently a weak patchwork of regulations that has allowed far too many species to fall through the legislative cracks. The ineffectual BC Wildlife Act is actually derived from hunting legislation.
    •BC needs a strong provincial endangered species law that replaces the inadequate system currently in use.

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    [-] Navid

    Instead of having a weak patchwork of regulations around species at risk, why not create a strong law that is clear and unequivocal about protecting SAR?

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    [-] BCSPCA

    BC has a patchwork of regulations that allows too many species to fall through the cracks, despite being home to 75% of Canada’s bird species, 70% of freshwater fish species and 66% of butterfly species. BC also has more species at risk than any other province and yet is one of only two provinces without a specific law protecting endangered wildlife. More than 43% of province’s assessed species are at risk. A scientific body in BC maintains lists of species grouped according to risk, however action is not required by law and listing does not trigger legal protection. BC has 138 “red-listed” species, but only four legally listed under the provincial Wildlife Act (American White Pelican, Burrowing Owl, Sea Otter, Vancouver Island Marmot). Only three out of 191 species listed under SARA are listed as species at risk under the provincial Wildlife Act. There is no law specifically prohibiting harm (except prohibition against hunting) to species at risk. Further, BC has no laws for mandatory habitat protection for at risk species, which is essential for their survival and recovery. BC’s forestry laws allow listing of at risk wildlife, but protections are limited if they interfere with logging. BC laws do not require species recovery planning and implementation. Strong provincial endangered species legislation is required to replace the patchwork of legislation. Embrace the scientific discipline of Compassionate Conservation which considers animal welfare and ethics in conservation research, policy and practice so that broader considerations are made and protections for species at risk are not blanket approvals to kill other wildlife.

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    [-] Noah

    If there is a n endangered species, this should be a basis to ban resource use–such as the US model under the Endangered Species Act. BCs resource industries need to learn how to operate within limits, and not liquidate nature for short term profits.

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    [-] Kris

    I want to be able to be proud of living in BC a region where we still have an opportunity to make a difference and learn from past mistakes. Short-term profit is of no use to Canadians or the world. We need strong provincial endangered species law. We should be at the forefront, not lagging in the rear and playing catch-up. If habitat is eroded and destroyed there will be nothing left and we will be embarrassingly on the wrong side of history. The profit of a few is on no use to British Columbians. Let’s not leave this up to some of the tireless and wonderful groups who advocate for ecological balance and preservation. Let’s get the government involved in a positive way. As a private individual I don’t know what the best policies are on a micro basis but I support environmental agencies in BC who have gathered data for decades. Can we all work together on this?

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    [-] Dan

    BC needs clear and strong species at risk legislation, not a patchwork of rules with loopholes everyone. BC contains the most environmentally concerned citizens, but our legislating lags almost everywhere else in Canada.

    We don’t need to balance protecting species with a vibrant economy. This is a false trade-off. If we protect our environment we’ll grow the economy and our quality of life through recreation and tourism. Tourism is now a larger part of BC’s economy than resource extraction, and effort to protect it more than pays off economically. Corporate interests in making a short term profit at the expensive of our environment are not in BC’s best interest.

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    [-] Karl

    I want stronger protection for orcas and other species in the Salish Sea threatened by increasing traffic, especially carrying toxic cargo such as dilbit. Stop Kinder Morgan TMX.

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    [-] John

    Topic 2: Provincial protection of species at risk
    BC’s protection of species at risk is currently a weak patchwork of regulations that has allowed far too many species to fall through the legislative cracks. The ineffectual BC Wildlife Act is actually derived from hunting legislation.
    BC needs a strong provincial endangered species law that replaces the inadequate system currently in use.

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    [-] Wendy

    How can a province with the extraordinary natural resources that we take so much pride in (Super Natural British Columbia) not have its own Endangered Species legislation?

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    [-] Gregory

    In short, we need to start with a scientific study of what protections the species need for them to be sustainable. Then proceed from there as to what degree industry can be accommodated. To pick some arbitrary “balance” means that we’re both limiting industry (not good for them) while at the same time not giving the species enough protection for their populations to be sustained (useless for them). We need non-flexible, scientifically-derived minimum protections to ensure the survival of a species.

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    [-] Renee

    We need more enforcement people like forest rangers. We need more oversight of industry so as to avoid disasters like the Polley mine tailings pond burst. All logging of old growth forests must stop immediately. Stiff penalties for poachers, polluters, etc.

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    [-] Mark

    I believe that BC needs an Endangered Species Act that gives priority and coordinates responses to the protection of endangered species. In this, I believe as well that priority should be given to species protection and that economic activities should take a back seat to species protection.

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    [-] E.

    BC’s protection of species at risk is currently a weak patchwork of regulations that has allowed far too many species to fall through the legislative cracks. The ineffectual BC Wildlife Act is actually derived from hunting legislation.
    BC needs a strong provincial endangered species law that replaces the inadequate system currently in use.

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    [-] Roy

    Enact a provincial species-at-risk act and give it very broad powers over the other acts mentioned above (Wildlife Act, the Forest and Range Practices Act, the Oil and Gas Activities Act, the Land Act, the Park Act, the Ecological Reserves Act, and the Environmental Assessment Act.)

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    [-] Karl

    BC’s current system of protecting species across a bunch of legislation that is all designed for other purposes, some of which are contrary to species protection and biodiversity, is inefficient, confusing, and unlikely to be effective. This dates back to the time when biodiversity was not well understood and species protection was an afterthought. BC should enact a unified and focused species at risk law like Ontario and Quebec.

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    [-] Jennifer

    We need protection of species at risk in BC as legislation.

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    [-] Roberta

    • BC’s protection of species at risk is currently a weak patchwork of regulations that has allowed far too many species to fall through the legislative cracks. The ineffectual BC Wildlife Act is actually derived from hunting legislation.
    • BC needs a strong provincial endangered species law that replaces the inadequate system currently in use.

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    [-] Jim

    I believe the Province is doing a good job now

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    [-] Karl

    Recognize that invasive species constitute a major threat to our native flora and fauna. Take a good look at how other jurisdictions in the world have developed safeguards against such invasions and adapt them to BC (Hawaii, New Zealand, etc.). Develop policy and response mechanisms towards invasive species that mirror those we use for other natural disasters (as invasive species are a natural disaster). When prevention mechanisms fail, a response to contain an introduced species should be swift and immediate, not delayed by policy, red-tape, funding cycles or approval processes.

    In terms of improving the policy and framework for protection, build a system that incorporates or dovetails nicely with the procedures already instigated by SARA. There are a limited number of professionals in this province that can work on recovery plans and status reports, let’s maximize if not overlay completely a provincial process with this federal one. In truth, this overlay has already started, so let’s continue to build on that.

    To protect species at risk will invariably require some loss of economic gain; limits to growth and development as they effect our crown lands need to be discussed….perhaps the start of a provincial dialogue that includes identifying other metrics of societal gain and economic strength.

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    [-] Krysta

    I believe that the current patchwork of regulations are too weak and do not provide clear and effective protection to species at risk in BC. It has allowed far too many species to fall through the cracks. We need strong and clear provincial endangered species law that replaces the inadequate system currently in use.

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    [-] Steve

    I would like to see clear and simple legislation defining what is considered a species at risk (we should not have to reinvent the wheel on this). I would like to see it done in a reasonable amount of time. I would like to see it have some teeth in it so we can actually apply it and get results. I would like to see it all inclusive (not excluding special groups) and I would like to see it not crafted around what suites industry. It needs to be crafted to explicitly protect the animals and / or ecosystems it aims to protect. It should also consider the overall systems that affect a species. For example protecting a species may mean protecting its food supply and territorial ecosystems, and looking at external impacts on those key areas of dependencies. Everything is connected.

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    [-] anne

    We need more Wildlife and Conservation officers, and we need to get serious about enforcing the regulations. Stop ALL trophy hunting, tighten the restrictions on halibut to ensure the mature breeding females are protected, and close the herring fishery for two years to allow the stocks to begin to recover. Reduce the length of the prawn fishery, both commercial and recreational and increase support to Salmon Enhancement projects. Make sure any road construction doesn’t negatively impact the small, all-too-often ignored life forms like toads, etc., and stop all old growth logging.
    I guess what would be helpful would be if we all GET SERIOUS about taking better care of the world around us.
    The Vancouver Island Black Bear is genetically distinct and should be protected, not hunted to extirpation! On an Island there isn’t much “wild” land left to which they could flee, and as “civilization” and “development” expand the bears are running out of safe places.
    We also need to do more to protect the sturgeon, even catch-and-release fishing puts a strain on these ancient fish, why harass them just for some entertainment? Stop removing gravel from the rivers , there are gravel beds inland, it’s just not as cheap as hauling clean gravel out of the river…but that gravel is the spawning bed. And tighten up the regulations so that the dumping of deleterious material near water sources is illegal. We have to protect our water and keep it as clean as possible if we are to protect ourselves and all animal life.

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    [-] Micha

    We need legally enshrined protection for species at risk. Until there are actual laws protecting at risk plants and animals I don’t think industry will act to protect them!

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    [-] Paul

    A 20 year old agreement between the province and the feds is not good enough. Laws need to be enacted that are the same or MORE stringent in scope and deterents these should include , billing for costs incurred by the province should ANY extra work need to be undertaken by the province/feds. Fines should be based on GROSS revenues by the company in question remediation if called for must have an ongoing responsibilty to the company. Funds set aside for any potential remediation must be adequate for the potential size of remediation in a worst case scenario

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    [-] Helen

    The provincial and federal governments have unfortunately found themselves in a paper battle, having to meet legislated deadlines for required documents (e.g., status reports, recovery strategies) once species are listed under SARA. The bureaucracy of it has led to most time and energy being directed at fulfilling those requirements and NOT on actual positive outcomes for species at risk. The lack of charges under SARA is abysmal and should be greatly increased but there is no capacity to monitor and investigate infractions. We need to drastically increase the number of BC Parks staff and enforcement personnel (e..g., Conservation Officers) to deal with infractions of SARA and the BC Wildlife Act.

    As an aside, why use value-laden language such as “a VIBRANT natural resource economy”? Maybe it should have read “how we can achieve a balance between protecting PRECIOUS species at risk and supporting a natural resource economy”?

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    [-] Ursula

    B.C. should have a stand alone Species at Risk Act that would have precedence over all activities that would endanger an identified species. As it is currently, scattered over several ministries and with an Accord with the federal government, coordination and priorities are lost. The U.S.A. has such an act that dates back to 1973 and has been quite effective, though not without controversy. It takes a courageous government that is not on the payroll of Big Industry to take a broader view of the future of our planet.

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    [-] Margaret

    Protection of species at risk would be vastly improved if there were more people hired by M of Environment and M of FLNRO: conservation officers, people to review development proposals and RAR applications, BC Parks staff etc. The lack of staff and resources is a major weakness in the provincial system. So policy should be to provide adequate staffing for SAR protection through existing legislation.
    The sentence, “…achieving a balance between protecting species at risk and supporting a vibrant natural resource economy” reveals the bias in this consultation. SAR legislation should be about SAR goals and priorities. not balancing economic goals with SAR protection.
    Successful examples from other jurisdictions: create tax incentives breaks to preserve/create covenants for valuable SAR habitat, this includes land in the ALR.

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    [-] Dave

    Any system of protection of species or ecosystems must not be stuffed down our throats by government. It will only work through informed debate and be voluntary with incentives for participation and providing benefits. It would be particularly onerous to expect crown tenure holders to carry the burden for all society while carrying 100% of the cost. Continue to consult and don’t force it on anyone. Lead but don’t Push.

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    [-] Tracy

    I think it is hard to balance protecting species at risk and supporting a natural resource economy. At times we will have to choose one over the other and the clear choice, in my opinion, is protecting species at risk!

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    [-] Doug

    TOWARD A BETTER BALANCE:

    One phrase that appears to have fallen out of favour in the provincial government lexicon is “science-based decision making”. There is probably a general agreement that protection of species at risk and recovery efforts are a very important and laudible goal. There is also probably general agreement that resource extractive and land use activities can at times be in conflict with either the perseverance of those species currently recognized as being at risk or the prevention of adding more species to the at-risk category. Large amounts of uncertainty about the interrelationships between land and resource use and the status of at-risk species (large amounts of scientific uncertainty) will generally result in proposed management actions that cannot be confidently tied to the actual achievement of their intended goals (spatially and temporally imprecise; based on models with little predictive accuracy and little appreciation of the full set and relative influence of various predictor variables) as well as intensive debate around application of the precautionary principle.

    Thus, there remains a problem with either a perceived or real imbalance between provincial development and species at risk protection goals. In addition, the debate has gotten ugly and is not easily resolved, largely because the underlying degree of scientific uncertainty for any given issue is overly large.

    The ability to conduct relevant applied research data on at-risk species has improved immensely over the last 2+ decades, and this could substantially help to define management approaches that are far more surgical in their application, far less encumbering to various human initiatives overall, and far more effective in achieving the stated goals. The capacity to do such research in a given context and for a given Species at Risk is still very poor, since the provincial government does not appear to have made any rationale discussions about benefits and costs associated with the resourcing of studies to address important knowledge gaps, and seems to have generally moved away from science-based decision making as an important guiding principle.

    There will always be assertions that there is an imbalance. The severity of such a potential imbalance and vehemence of the polarized views, however, can be reduced by developing mechanisms for funding studies aimed at resolving key areas of scientific uncertainty.

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    [-] Doug

    IMPROVEMENTS:
    The current and evolving regimes federally, and for provinces and territories, focus on “effective habitat protection”. It has taken many decades to get to a point where a minimum level of habitat protection is embraced for at-risk species so this is something to be positively acknowledged.
    The stated goals for the policy and regulatory framework, however, remain simplistic and inadequate in the following three key areas:
    (1) Its not just about critical habitats, but also habitat fragmentation: If conceptualizations of habitat for at-risk species are cast too narrowly, they may not adequately consider key aspects of population maintenance and recovery associated with degree of habitat fragmentation versus continuity;
    (2) Species recovery, not just protection, and implications for land reclamation goals: We are missing an opportunity to restore and create new viable habitat, beyond the efforts to protect the existing extant habitat. In particular, it is entirely possible from a scientific / technical perspective to build habitat reclamation goals for at-risk species into minesite reclamation, upstream oil and gas site reclamation, forestry practices, agricultural land management, etc. While some attempts to add to critical habitat in the province have been made on an ad hoc basis, such recovery goals could be more routinely incorporated in various land reclamation regulatory frameworks. This could be seen as very positive by various industrial entities who are keenly interested in social license;
    (3) Threats to species are routinely linked to cumulative effects and watershed-scale/landscape scale change: thus reducing future threats, and mitigating against past threats require a better ability to embrace watershed/landscape scale management and cumulative effects. Thus, there is an opportunity for British Columbia to better embrace Species at Risk protection and restoration goals through alignment with current directions towards an improved Cumulative Effects Framework (CEF) and the current advancement of watershed management planning (for example, the Murray River Cumulative Effects Management Framework). In this context, advancing species at risk protection and enhancement goals will be more effective in the future to the extent that we recognize the value of “big data” and the associated improved means of driving decisions. As a concrete example, BC has become a leader in use of eDNA survey methods as a compliment to or in lieu of traditional biological survey methods for the presence and distribution of species of management interest. This allows us to more cost-effectively gather data with much better temporal and spatial resolution, and in turn to make more explicit and concrete decisions about where a land use or situation may be in conflict with protection and enhancement goals.

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    [-] Geoff

    Protection of Mountain Caribou, one of our most if not most endangered species, should be a critical priority. Problem is we continue to permit logging and access via new logging roads into the old growth forests that are the primary habitat for mountain caribou. While we deem wolves as the problem, they would not be a problem if we didn’t facilitate their access via road networks – or at least wolves would be less of a problem. We’re blessed in BC to have the only interior old growth rainforest located in the Incomappleux valley. Protecting this old growth (low value in timber) will enable mountain caribou to winter in the area. I recently read about a park proposal initiated by Valhalla Wilderness Society (and have since seen their film Primeval) that included much data including extensive Geographic Information System (GIS) mapping data for corridors, logging/timber potential, etc. It seems obvious that by establishing the Mountain Caribou Park we could help solve many problem associate with this species. It will also serve to protect the last and only remaining old growth interior rainforest and create all important wildlife corridors. Our current patchwork of parks and protected areas work as islands instead, we (they actually – most large species) need continuously connected corridors and habitat.
    I explored this area some 15 – 20 years ago, on foot. It is simply spectacular. It is remote, somewhat difficult to get to but truly a magical place. I urge everyone I know to go and explore. You won’t be disappointed.

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    [-] Jillian

    There’s a few things we need in this:
    1) The province and federal government need to be more collaborative to ensure those contravening our laws are held to account.
    2) Hire more conservation/fisheries officers to be present to enforce these laws
    3) Put tougher penalties in the Acts so that our environmental laws actually have teeth to them
    4) Encourage the public to get involved and contribute on matters like these (gathering feedback in this forum is definitely a step in the right direction!)

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    [-] James

    BC needs laws to protect species at risk and their habitats across all sectors. Government decision makers need to have appropriate authority to decide what will be listed, and where and how habitat will be protected. It needs to be transparent where these decisions deviate from what is recommended by scientists.

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    [-] Paul

    Wow BC is one of two provinces that don’t have Endangered Species Legislation BC has lots of Acts with huge wholes in them so industry can continue to do what they do without protecting the habitat of species. This Liberal government has gutted the forest of BC the old-growth forest are an endangered species because they are being targeted once they are gone nothing to fight over. National Geographic calls logging the last of the worlds primary forest which only 20% remain they call it Forest Holocaust I call it BCs Forest Holocaust its the extermination of these rare ancient forest and this government wont stop this is why we have 1900 species at risk!

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    [-] David

    1. British Columbia needs strong endangered species legislation if it is serious about protecting species at risk. The current patchwork is clearly not working given the high numbers of endangered and threatened species in BC.
    Biological diversity is essential to human health but can be adversely affected by a myriad of human activities, including habitat destruction, overexploitation, pollution, global change (e.g., ozone depletion and climate change), and the introduction of invasive species. Because of this diversity of threats, many different types of environmental laws and policies in BC contribute to protecting biodiversity, including those governing protected areas, natural resources, agriculture, environmental assessment, hunting, fishing, and pollution. However, because of widespread failures in these legal regimes, endangered species legislation is vitally important for preventing extinctions and promoting the recovery of species in decline. Laws to protect endangered species are comparable to emergency wards in hospitals, recognizing that while the emphasis ought to be on prevention, treating those in dire need is a necessary part of the system.
    The five key elements of endangered species legislation include: (1) strictly scientific criteria for listing a species or ecosystem as endangered; (2) comprehensive geographic scope including public and private lands; (3) strong legal prohibitions on killing or harming an endangered species; (4) strong legal protection for critical habitat; and (5) mandatory implementation of recovery plans.
    2. The US Endangered Species Act is working remarkably well.
    More than 30 species have recovered sufficiently to be de-listed in the US including the bald eagle, peregrine falcon, gray whale, grizzly bear, gray wolf, brown pelican, Stellar sea lion, American alligator, a snake, a flycatcher, a flying squirrel, a lizard, an orchid, and a daisy. The US Center for Biological Diversity has identified more than 20 species whose populations increased by more than 1,000 percent in recent decades. There was a 2,206% increase in nesting Atlantic green sea turtle females on Florida beaches. The California least tern enjoyed a 2,819% increase in nesting pairs. The San Miguel island fox population increased 3,830%. Numbers of the El Segundo blue butterfly increased 22,312%. Studies indicate that roughly 90% of species listed under the US Endangered Species Act are on track to meet their recovery targets by the projected deadline. Imagine other government programs—reducing poverty, rehabilitating criminals, subsidizing businesses, etc.—achieving a 90% success rate.
    3. We need to integrate environmental and economic considerations, in order to preserve and protect biodiversity. Otherwise we will suffer immense economic losses as we diminish nature’s remarkable wealth.

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    [-] Dave

    We need clear outcomes as delineated by SARA, and clear timelines with strict penalties for delays in implementation for critical habitat identification and protection.

    There have been lots of comments about how the world changes and we need to adapt our decisions about what to protect based on what we have already driven to extirpation/extinction. The same argument needs to begin to apply to industry. Having a ‘vibrant resource economy’ as one of the guiding principles of endangered species protection is a non-starter. Completely cripples the process before it even begins. Economies change, evolve, and we are at the point where continued resource extraction based on provincially dictated goals (such as forestry volume-based tenures and AAC numbers), as opposed to what can be sustained at a local/regional level will never allow us to move forward with creative solutions to continue logging, for example, while still protecting habitat for endangered species (and our clean watersheds, airsheds etc, all of which need protection these days, and which often dovetail well with habitat protection)

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    [-] Sadie

    ULTIMATELY, we need to stop acting at the last minute to protect species…ie. when they have made the list of at risk species. We need to establish large refugia NOW for large carnivores (umbrella species) to preserve FUNCTIONING AND VIBRANT ECOSYTEMS….not just single species.
    In terms of balancing species at risk with industrial interests, I am saddened that this question even appears. It is simply not right to take away species from future generations. ..for myriad reasons. SARA is not working and is a paper tiger. In addition, this short sighted approach considers prioritizing the economy above or on level with ecology and ethics; there is no business on a dead planet.

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    [-] Wendy

    The province of BC needs something stronger than a policy framework for Species-at-risk. BC needs legislation. The Wildlife Act is not effective in protecting Species-at-risk, nor is SARA.

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    [-] Lee

    You do know that you end up in court if you contravene Species at Risk regulations? What did you have in mind, bypassing the courts and going straight to jail?

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    [-] David

    To date there has been one conviction under the federal Species at Risk Act, in response to a massive poaching of abalone off the coast of Haida Gwaii. Here is some information you might be interested in:
    R. v. McNeill, McNeill, and Graff (2007), BC Supreme Court
    Poaching northern abalone
    Closed to fishing since 1990
    Listed as threatened under SARA in 2002
    Scuba diving from boat—harvested 11,000 abalone
    Stanley McNeill given a 12-month conditional sentence with six months house arrest, a five-year scuba-diving prohibition and $20,000 in fines. He also forfeited his truck, boat and equipment used during the crime, valued at $143,000.
    Daniel McNeill and Randall Graff each received four-month conditional sentences, with three months of house arrest, two-year diving bans, $10,000 fines, and 80 hours of community work involving presentations on abalone conservation. They also forfeited $4,000 worth of equipment.

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    [-] Wendy

    You rarely end up in court if you contravene SARA. There is very little legislation in place today that actually protects SAR or enables recovery.

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