A true paradigm shift? Discerning the fine print of the provincial government’s draft Biodiversity and Ecosystem Health Framework 

For over a century, British Columbia’s extraction-based economic and management paradigm has fueled industrial growth, unsustainable land-use, and overharvest, while degrading and destroying vital ecosystems, species, and ecological processes that communities depend on. Now, faced with a rapidly changing climate and associated impacts –  such as reduced snowpack depth and year-round drought – British Columbia is experiencing twinned biodiversity and climate crises.

A true paradigm shift?

In late 2023, the provincial Ministry of Lands, Waters, and Resource Stewardship introduced a draft Biodiversity and Ecosystem Health Framework (‘the Framework’), which identifies a vision for conserving and managing biodiversity and ecosystem health in British Columbia. Importantly, the Framework will guide changes to existing legislation, and inform the development and implementation of new policies, laws, and strategies, with the goal of advancing the province’s commitment to implementing articles outlined in the United Nations Declaration on the Rights of Indigenous Peoples Act (UNDRIP) and the Declaration Act.  

The province states that it will work in partnership with Indigenous Nations to co-develop legislation that will give legal teeth to the Framework. However, the efficacy of the Framework legislation in changing land management will come down to the details (or lack thereof), included in the fine print of the law. Further, if the province does not adequately enforce the Framework, industry can’t be held to account and land-use practices will continue unabated. 

We break down the recently released draft  Biodiversity and Ecosystem Health Framework and identify gaps in the rigor of the Framework, and provide our recommendations for advancing a more quantitative framework that can enable true paradigm shifts.  

No quantitative objectives to guide framework and measure success

In its draft state, the Framework does not include ecological objectives to guide their vision for recovering biodiversity and restoring ecosystem health. Further, it lacks specificity, does not include quantitative metrics to determine success, and does not indicate the methodologies that will be used to achieve its stated commitments.

Recommendations

1. We recommend that the Framework include ecological and species recovery objectives, such as: protecting and restoring habitat (e.g.,  measured in km² or m², respectively), maintaining temperature ranges in freshwater habitat¹, and increasing the number of individuals in a population. These objectives must be based on best available science and Indigenous knowledge and should trigger policies, orders, and regulations that are applied across all sectors. Objectives should be updated according to changes in climatic and ecosystem conditions (e.g., water flows, water temperature, snowpack, precipitation, etc.) on an annual basis. 

2. We also recommend that high-risk land use activities (e.g., clear-cut logging, water withdrawal for industry, mining, etc.) must be identified in watersheds with at-risk species² or threatened ecosystems. Using the above quantitative objectives and thresholds, corresponding legal triggers should be put in place to reduce and regulate such activities. 

Lack of inclusion of wild Pacific salmon recovery 

Despite the role wild Pacific salmon play as foundational species³ in British Columbia, and their ecological and cultural importance to both wildlife and people⁴, the Framework does not include wild salmon, or recognize the urgent need to stem land-use activities that degrade and destroy salmon habitat. 

Recommendations

1. We recommend that the Framework include a fundamental focus on restoring and protecting salmon habitat throughout the province. Policies scoped by the Framework that will be aimed at reforming land use activities must consider the biological needs of salmon populations in their development and implementation. Further, the Framework legislation should coordinate with provincial acts that have jurisdiction over salmon habitat quality and quantity, such as the Water Sustainability Act, and its corresponding policies and orders that can be triggered to protect salmon habitat from low stream flows. These include: Environmental Flow Needs, Critical Environmental Flow Thresholds, and Fish Population Protection Orders.  

Industry accountability and loopholes

The Framework states that  “there will continue to be areas of more intensive development to accommodate increasing demands for food, fiber, and energy, as well as areas of the landscape where there will be greater emphasis on ecosystem health, including protection of priority areas and restored or degraded ones”. 

This discrepancy indicates that there will be loopholes for industrial projects to occur in ecosystems that are deemed important to resource extraction and economic goals. Considering the provincial government has recently authorized, or signed off on, numerous large-scale industrial projects that will cause cumulative effects on at-risk species in critically important habitats, (see Trans Mountain Pipeline, Roberts Bank Terminal 2, Site C dam, or Coastal GasLink), the above language does not indicate a paradigm shift but rather support for the status quo.

Recommendation

1. There cannot be loopholes for industry to advance proposals prior to the implementation of the Framework legislation, nor should proposals be able to legally proceed in areas that have been declared as Indigenous Protected and Conserved Areas by First Nations, or in areas identified as ecosystems at very high risk, Old Growth Management Areas, or old growth identified in Timber Harvesting Land Bases, as defined in in the provincial A New Future for Old Forests: A Strategic Review of How British Columbia Manages For Old Forests within its Ancient Ecosystems report.

2. The Framework must have the legal standing and regulations in place to review and reject an industrial project proposal that will adversely affect at-risk species and ecosystems. This legislation must be coordinated with the provincial Environmental Assessment Act. Proposals that have clear, quantitative evidence and Indigenous knowledge identifying adverse impacts that will occur to ecosystems and communities must be rejected by the provincial Minister of the Environment. 

Office of Biodiversity and Ecosystem Health 

Within the Framework, the provincial government suggests that it will establish an Office of Biodiversity and Ecosystem Health within the BC Public Service that will employ officers whose main priority is to implement the Framework and ensure compliance. However, there is uncertainty regarding the extent of authority the officers will have, and whether the office will have enough capacity, expertise, experience, funding, and true collaboration with Indigenous Nations to co-deliver the Framework. 

Recommendation

1. We recommend that the Framework outlines the scope and implementation of an independent, joint scientific and Indigenous knowledge advisory body to review decisions being made by the Office of Biodiversity and Ecosystem Health. We recommend that this be similar to the Committee on the Status of Endangered Wildlife in Canada (COSEWIC), which is a scientific advisory body for the federal Species at Risk Act.

2. Enforcement needs to occur jointly with Indigenous Nations whose members could act as Land and/or Water Guardians to conduct monitoring and compliance. To ensure there is capacity within interested Indigenous communities to conduct enforcement, long-term funding for Guardian salaries must be provided by the Office of Biodiversity and Ecosystem Health.

3. The Office, in collaboration with Indigenous Nations and non-governmental environmental organizations, should conduct long-term monitoring of ecosystems and species to gather baseline data and determine trends over time.  

A clear opportunity to shift the paradigm 

The Biodiversity and Ecosystem Health Framework represents a significant opportunity for the provincial government to transition away from a land use management paradigm that has prioritized industrial development over ecosystem resilience. Drafting and implementing a Framework and corresponding legislation that has quantitative ecological objectives and policy triggers–supported by an Office with adequate capacity, authority, and enforcement – will enable British Columbia to advance a sustainable economy that limits extractive industry. The key to achieving this is including legally-binding details in the fine print of the Framework. We look forward to seeing the final version of the Framework to determine if British Columbia achieves this and makes good on their promise to implement legislation that prioritizes biodiversity and ecosystem health. 

1. For example, conducting habitat restoration and enhancement projects to provide thermal refugia for salmonids (water temperatures above 18ºC cause salmon to experience sublethal impacts, such as stress and disease risks, while temperatures above 22ºC can cause mortality).
2. As identified by the Committee on the Status of Endangered Wildlife in Canada (COSEWIC).
3. A foundation species plays a critical role in structuring an ecological community due to its sheer biomass in an ecosystem. Foundation species control biological diversity of associated species and support ecosystems from the bottom up by modulating critical ecosystem processes, such as primary production (Ellison, 2019). In the Northeast Pacific Ocean, salmon, herring, and giant kelp are examples of foundation species. https://www.cell.com/iscience/pdf/S2589-0042(19)30054-9.pdf
4. Among residents of British Columbia, 86% are worried about the future of salmon. https://psf.ca/news-media/86-bc-residents-show-high-levels-concern-about-declining-salmon-stocks/

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