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The BC government is currently accepting public input on its draft Biodiversity and Ecosystem Health Framework. The following info will help you write your personalized submission. Submissions are due by January 31st, 2024.

Send your submission in your own words to the Ministry of Water, Land and Resource Stewardship (Ministry of WLRS): biodiversity.ecosystemhealth@gov.bc.ca

Be sure to include your first and last name, home address, email, and any organization affiliation you are submitting on behalf of.

Key information

The BC government recently released a draft policy, the “Biodiversity and Ecosystem Health Framework”. If done well, it could place ecosystem integrity first to guide all land-use, forestry, and conservation policies to ensure an ecological “paradigm shift” – as called for by BC’s appointed Old-Growth Strategic Review panel’s recommendations in 2021.

To be finalized in the spring, it could result in vastly increasing the protection of BC’s most endangered ecosystems – those most impacted by industry and least included in the protected areas system, such as productive old-growth forests and lower elevation, valley bottom forests, grasslands, wetlands, and other at-risk ecosystems.

That is, a strong Biodiversity and Ecosystem Health Framework (BEHF) would up-end the status quo in conservation policy in BC that has always sought to minimize the impacts of conservation policies on resource extraction industries (in particular, to minimize the impacts of protected areas on the available timber supply for logging) and for the first time could place ecological integrity first. In turn, this will exert pressure on BC industries to operate with greater efficiency and to increase their processing operations within the province, such as fostering a modernized, value-added, second-growth forest industry.

While BC has adopted the national target to protect 30% of the land area in the province by 2030, there are currently no specific targets to ensure the protection of all of the diverse ecosystems in BC. Without legally binding “ecosystem-based targets”, protected areas will continue to emphasize the protection of ecosystems with the lowest value for logging – typically alpine, subalpine, and far northern ecosystems with low to no timber values (i.e. no trees or small trees in cold climates) – and minimize protection for the most endangered and least protected ecosystems, typically at lower elevations in southern BC where most biodiversity, species at risk, and endangered ecosystems are located, and which are most coveted for logging, development, and human settlement.

Please consider the following points to guide your written input:

We need the Biodiversity and Ecosystem Health Framework (BEHF) to result in policies and legislation that:

• Ensures ecosystem-based protection targets (ie. protected areas targets for all ecosystems) devised by science and Traditional Ecological Knowledge committees. These targets must not only be “aspirational” but legally binding. The province’s proposal to appoint a Chief Biodiversity Officer would be a major step in the right direction, especially if tasked to oversee such a scientific process.
• Ecosystem-based targets must represent the full diversity of ecosystems and ensure their long-term persistence. That is, ecosystem-based targets must be:
  • Sufficiently “fine filter” to include all ecological communities (site series) and, just as importantly, to include forest productivity distinctions (sites that tend to grow small trees vs. medium vs. large trees). Forest productivity distinctions are vital and are the greatest glaring gap in BC’s conservation and protected areas policies – and not by accident due to the dominant paradigm that seeks to minimize protection of the high and medium-productivity forests with the largest trees to benefit the timber industry.
  • Sufficiently stringent to ensure the long-term persistence of all ecosystems by employing the latest conservation biology science to ensure a low risk to each ecosystem of losing their biodiversity and ecological integrity over time.
• Ensures that ecosystem-based targets must guide both the expansion of the protected areas system (i.e. it must guide a much-needed “BC Protected Areas Strategy”, including the expenditure of the BC Nature Agreement and Conservation Financing funds), and guide the expansion of the conservation reserve network like Old-Growth Management Areas (OGMAs) and Wildlife Habitat Areas (WHAs).
• Upholds protected areas integrity, that is, ensures strong protection standards and the permanency of protected areas moving forward.
• Loopholes must be closed in conservation reserves such as Old-Growth Management Areas (OGMAs) which can be moved around under timber industry lobby pressure (i.e. to log the big trees and swap them for sites with smaller trees instead) and in Wildlife Habitat Areas (WHAs) which in many cases allow logging to continue (for example, the iconic Big Lonely Doug, Canada’s second-largest Douglas-fir, stands in an old-growth clearcut that is within a WHA). Any forthcoming, new Indigenous Protected and Conserved Area (IPCA) designation must include minimum standards that forbid commercial logging (as opposed to cutting of individual trees by First Nations for cultural purposes, such as monumental cedar for community use such as dugout canoes, longhouses, and totem poles), mining or oil and gas development within them.
• Emphasizes the establishment of provincial conservancies and other strong, legislated protected area designations, rather than primarily relying on conservation reserves that are designated via regulations (ie. not through a vote in the provincial legislature) that are more tenuous and filled with loopholes that continue to allow resource extraction or boundary shifts.
• That ensures protection targets are legally binding, with accountability and transparency on the progress towards meeting overall and ecosystem-based protection targets. Independent advisory committees of ecologists and Traditional Ecological Knowledge Holders should develop the overall ecosystem-target methodology, followed by specific targets for each ecosystem. Policy implementation committees of policy and legal experts including First Nations should develop implementation plans on how the province can reach those targets. Independent audits of how well the government meets these targets must occur and be publicly reported, and the province must develop plans to remedy any shortfalls.
• If done well, the resulting legislation and policies of the Biodiversity and Ecosystem Health Framework (BEHF) would make BC a global leader in conservation – or it could be a squandered opportunity.

Send your submission in your own words to the Ministry of Water, Land and Resource Stewardship (Ministry of WLRS) by January, 31st, 2024: biodiversity.ecosystemhealth@gov.bc.ca

Additional Resources:

See the AFA and EEA’s media release in response to the draft Biodiversity and Ecosystem Health Framework.