Canada releases the 2030 National Biodiversity Strategy and Nature Accountability Bill –a positive step, but one that falls short
The final 2030 National Biodiversity Strategy addresses biodiversity-harming subsidies and promises an adaptive management approach, but lacks a clear plan on how it will be implemented.
In 2022, Canada and 196 other countries committed to achieving 23 targets that aim to halt and reverse biodiversity loss and protect and conserve 30% of lands and waters by 2030, as part of the global Kunming-Montreal Global Biodiversity Framework (GBF). The federal government’s homework since 2022 has been to scope and deliver a national strategy adopting the GBF that will enable the 30×30 goals to be achieved in Canada.
Enter the federal government’s 2030 National Biodiversity Strategy (‘2030 Strategy’) and the Nature Accountability Bill, a tabled act that intends to legally hold the government accountable for achieving the 2030 goals.
In early April, we analyzed the draft 2030 Strategy for gaps and opportunities for improvement, and submitted our findings to Environment and Climate Change Canada as feedback. Later that month, Raincoast joined 60 other conservation organizations in Ottawa as part of Nature on the Hill, hosted by Nature Canada, to discuss the 2030 Strategy and corresponding Nature Accountability Bill with Members of Parliament, Ministers, and Senators.
In our discussions, we provided recommendations for what a rigorous 2030 Strategy and Nature Accountability Bill could look like. These recommendations included: 1) a 2030 Strategy that upholds Indigenous Rights and supports Indigenous-led conservation efforts, 2) the 23 GBF targets enshrined in law, 3) regular and independent audits by the Commissioner of the Environment and Sustainable Development, 4) public reporting to ensure transparency, 5) a whole-of-government approach that aligns with current federal legislation and provincial biodiversity initiatives, and 6) adequate funding for the Strategy, with the onus being on polluters to pay their fair share.
By mid-June, the final version of the 2030 Strategy and introduction of an Act respecting transparency and accountability in relation to certain commitments Canada has made under the Convention on Biological Diversity (the Nature Accountability Bill) was delivered by Environment and Climate Change Canada.
The final 2030 Strategy: where did it improve?
With the delivery of the final 2030 Strategy, we examined the document to determine if the government had improved upon its draft version. We also wanted to examine the language within the Nature Accountability Bill to determine if it provides real legal teeth to the 2030 Strategy, or if it contains loopholes for the government and industry to sidestep their obligations to meet the 30×30 targets.
Within the final draft, we were encouraged to see the government commit to assessing financial incentives that are harmful to biodiversity, which include direct subsidies (i.e., project funding, tax reductions, credits, exemptions, and loans) to industries such as forestry, mining, agriculture, and fisheries. The federal government has committed to compiling an inventory of these financial incentives, with the goal of developing a framework to assess them for their impacts to biodiversity by mid-2025.
While this is encouraging, Canada has committed to eliminating subsidies that adversely affect biodiversity in international agreements before. These include the 2020 Leaders Pledge for Nature, the G7 2030 Nature Compact and now, the 2022 Global Biodiversity Framework. While creating an inventory of subsidies is a positive step, we would like to see a clear plan for the phase out, or re-direction of, these subsidies that aligns with the timeline of the 2030 biodiversity targets included in the Strategy.
The federal government also promised to advance the integration and alignment of the Strategy across federal policies, programs, and decision-making. Environment and Climate Change Canada states they will develop and implement an “Effects Management Framework to help mainstream biodiversity in regulatory decision-making” that is based on principles of adaptive management. This approach has the goal of reducing the adverse effects of land use activities, such as forestry, mining, and agriculture, on biodiversity. However, this high-level language does not make it clear how this will be done, and as such lacks any real accountability or mechanisms to ensure this ‘whole-of-government’ approach is taken.
While the final 2030 Strategy improved in some areas, it still falls notably short in others. Most importantly, the 2030 Strategy lacks a concrete Action Plan detailing how the Strategy will be implemented. As part of its commitment to the Convention on Biological Diversity, Canada has produced a Strategy for achieving the 23 targets under the Global Biodiversity Framework, but there is no accompanying plan for executing the Strategy. It also lacks quantifiable objectives for recovering biodiversity, which is critical if you are to measure the progress, or lack thereof, in meeting recovery targets.
The Nature Accountability Bill
As it stands, the biggest gap in the Nature Accountability Bill is that it does not enshrine the 23 targets of the 2030 Strategy into law and doesn’t require Canada to set national biodiversity recovery targets based on species decline in our country (i.e., it simply adopts the targets agreed upon by 196 other countries that apply globally).
While the Nature Accountability Bill requires Canada to report on the implementation of the 2030 Strategy and its progress, it lacks any rigorous accountability and transparency measures if Canada fails to meet its 2030 targets. For example, as was included in the Canadian Net-Zero Emissions Accountability Act, the Nature Accountability Bill should include the requirement for regular audits by the Commissioner of the Environment and Sustainable Development to independently evaluate the Strategy’s advancement.
Further, while the Nature Accountability Bill requires the establishment of a nature advisory committee, it is not clear whether the Minister of Environment and Climate Change has to adopt the recommendations of the committee. This structure is similar to the Committee on the Status of Endangered Species in Canada (COSEWIC), which is composed of scientists with expertise related to at-risk species. Based on the best available data, COSEWIC will make recommendations to Canada to list species under the Species at Risk Act (SARA). However, Canada is not obligated to act on these recommendations. For example, in the Fraser River watershed in British Columbia, 10 out of 16 Chinook salmon populations have been assessed as endangered by COSEWIC, yet none of them have been listed under SARA. In fact, no commercially harvested species of wild Pacific salmon has ever been listed under the Species at Risk Act, despite alarming population trends across British Columbia.
The opportunity is now: COP16 in October
In October, the countries that signed onto the Kunming-Montreal Global Biodiversity Framework in 2022 will gather in Cali, Columbia for the Conference of the Parties 16 to report on their progress in advancing their respective 2030 National Biodiversity Strategies. By tabling the Nature Accountability Act, Canada is demonstrating progress in advancing a National Biodiversity Strategy and accountability legislation, however, there is more to do. In order to achieve 23 biodiversity and land and water protection targets in 6.5 years, now is the time to enshrine the 2030 targets into law and develop additional Canada-specific targets that are reflective of the ecosystem degradation, habitat loss, and species decline occurring in this country.
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