January 31, 2024

Commercial Bear Viewing Association submission on DRAFT Biodiversity and Ecosystem Health Framework

The Commercial Bear Viewing Association (CBVA) applauds the BC government for taking this very important step in recognizing the importance of biodiversity and our ecosystems in BC. The Framework is an important step forward to ensure a vibrant and thriving future for ecosystems and wildlife. The province’s proposal to appoint a Chief Biodiversity Officer will be a significant step in the right direction. However, there are threats that require immediate action. The CBVA proposes the following to ensure success.

• Stop industrial activity in land use designations that currently offer limited protections to biodiversity, such as Wildlife Habitat Areas and Old Growth Management Areas.

• Adapt interim measures while the framework is completed, and the law is developed.

• Appoint the Biodiversity Officer/Chief Ecologist while the framework is being completed and law is being developed.
  • Ensure the office and officer have authority equal to or greater than the Chief Forester
  • Both the Chief Forester and Biodiversity Officer should report to the cabinet for oversight, not a single minister.

• Remove the phrase “a just transition that considers the economic reconciliation for existing projects or activities that may adversely affect ecosystem health and biodiversity.”
  • This clause feels more like a way for the industry to ignore the framework, similar to “without unduly reducing timber supply” that forestry used to “get around,” empowering the 11 values of FRPA.

• Species at Risk is a vital component of this framework and must have a new overarching law to provide a standard level of protection for species at risk and ecosystems across all sectors.

If done right, this Framework could set British Columbia as a global leader in conserving and protecting species and their habitats. The Framework should become the leading law to which all other Natural Resource Acts are obligated. Mining, forestry, oil and gas, and tourism (all natural resource sectors) should be held to this new framework’s standards. Protection with the green economy in mind (example, incentivize regenerative and responsible businesses)