Resource Works’ Comments on the Draft BC Biodiversity and Ecosystem Health Framework

The following report was submitted to the Government of British Columbia regarding the Draft BC Biodiversity and Ecosystem Health Framework 



Resource Works’ Comments on the Draft BC Biodiversity and Ecosystem Health Framework 

As an independent advocate for a balanced approach to natural resource development, Resource Works is grateful to be able to comment on the Draft BC Biodiversity and Ecosystem Health Framework

On the plus side, it is clear that the report attempts to articulate a visionary and comprehensive approach towards ecosystem health and biodiversity management. It recognizes the complexity of this endeavour and outlines a strategic framework for success. Key to this approach are the establishment of supportive laws, policies, and practices; the provision of tools and support for effective work; inclusive and valued decision-making processes; societal understanding of the changes and their importance; adherence to UNDRIP standards; an approach to change that does not disproportionately impact certain sectors or communities; and a harmonized vision of land use, stewardship, and governance between First Nations and the Province. 

Moreover, the report aims to achieve healthy ecosystems, advance reconciliation, foster effective stewardship, and ensure resilient communities and economies. It emphasizes the interconnectedness of land, water, and people, advocating for respectful relationships, community empowerment, and sustainable, inclusive economies. The guiding principles focus on shared responsibility, respectful relationships, sustainability, interconnectedness, community-based decision-making, and multi-generational equity. 

This report's intent is praiseworthy as it seeks to create a sustainable and equitable framework for environmental stewardship, recognizing the critical role of diverse communities, particularly Indigenous peoples, in conserving biodiversity and ecosystem health. Its holistic and forward-thinking approach exemplifies a progressive path towards ecological resilience and societal well-being. 

Those features are the grounding for what is clearly meant to be a policy overhaul, and this is where we have concerns. Unfortunately, the Draft Framework, in its current form, is far from balanced. At 14 pages long, and full of buzzwords like “transformative change” and “working together”, the Draft Framework purports to provide a strategic framework upon which to build new forest policy yet it actually says little of any detail or substance, instead appearing to rest on the aspirations.

In particular, Resource Works is concerned that Draft Framework’s sharp policy shift towards more onerous conservation requirements could have a devastating economic impact on the province. The following comments outline Resource Works’ concerns and offer suggestions for improvement. 

A Change of Direction from the Old Growth Strategic Review? 

The Draft BC Diversity and Ecosystem Framework follows several other BC government publications in recent years. In particular, the strategic review A New Future for Old Forests (released in 2020) made 14 recommendations. The first five of these described necessary conditions for change: 

  1. Indigenous involvement 
  2. Prioritize ecosystem health 
  3. Adopt a 3-zone management framework 
  4. Strengthen governance 
  5. Better public information 

The Draft BC Biodiversity and Ecosystem Health Framework document states its primary goal as being to address item number two: prioritizing ecosystem health. While A New Future for Old Forests considers prioritizing ecosystem health to just one of many steps towards achieving the sustainable management of forest biodiversity, the Draft Framework document frames the prioritization of ecosystem health as an end in itself, with its own necessary preconditions, actions, and outcomes. In doing so, it diverges from A New Future in several different ways: 

1. The Framework’s heavy emphasis on ecosystem-based management (EBM) as the primary approach to achieving ecosystem health contradicts A New Future’s recommendation that BC adopt a 3-zone management framework. 

EBM is a land management philosophy in which industrial disturbance regimes (i.e., logging) are designed to mimic natural disturbances, both in pattern (i.e. large disturbances or small ones) and in temporal scale (how often is the landscape disturbed?). While A New Future mentioned EBM, it did not promote it as an across-the-board method for ensuring biodiversity and ecosystem health. Instead, A New Future suggested that BC’s lands be divided into three zones: protected (i.e., parkland), consistent (designed to mimic natural disturbance, like EBM), and converted (managed to emphasize timber production). 

As A New Future mentions, EMB has much higher conservation requirements than conventional forest management and is currently only done in three places in the province: Haida Gwaii, Clayoquot Sound, and the Great Bear Rainforest. To adopt such standards province-wide would result in dramatically lower harvest levels, with severe economic consequences. 

2. The Draft Framework re-defines key scientific and management concepts.

While the Ecosystem Health and Biodiversity Framework uses many of the same term constructs as the A New Future for Old Forests, it defines some of them differently. For example:


The changes are subtle, but important. For example, while A New Future defines “effective management” in process terms, the Framework defines “effective” as “well-perceived by the public.” Further, while A New Future defines conservation roughly as “maintaining biodiversity… in the face of human development (i.e., while using resources)”, the Draft Framework refers to it as “protection, care, management, and maintenance” of biodiversity – a definition that does not include resource use. 

3. While A New Future carefully considers economic implications, the Framework glosses over them. 

A New Future for Old Forests frequently mentions socio-economic considerations. For example, under the transition planning section, we see the following text: 

“Conduct a realistic assessment of economic diversification opportunities and options, including the time required to realize them, and the probability of success (could be value added manufacturing of wood products, botanical forest products, tourism, and commercial recreation, etc.). Ensure they are viable options — not just ideas.” 

Compare this with the action proposed to achieve economic resiliency in the Draft Framework: 

“Create pathways (including fostering innovation, skills, and training) to achieve environmental, social, and economic benefits for all, this includes supporting sustainable and stable natural resource sectors that continue to be a source of good jobs and economic security for communities and creating new opportunities and benefits which accelerates diverse streams of revenues.” 

The last paragraph does not adequately acknowledge or address what drives economic value, jobs, economic activity or vibrant communities in our province. It sounds like wishful thinking to us. 

In sum, the Draft BC Ecosystem Health and Biodiversity Framework does more than simply proclaim that ecosystem health should be the overarching management value in BC’s forests. It appears to be trying to “shift the needle” on forest policy from one that balances biodiversity with socio-economic values, to one that primarily manages biodiversity and expects economic conditions to take care of themselves. 

A Need for Greater Transparency 

The Draft Framework promises to bring about transformative change by “adopting an open and transparent process through evaluation, reporting, continuous collective learning, and adaptive management.” Indeed, “openness and transparency” is listed as the “third pillar” supporting the Framework’s foundation of upholding the requirements set out in BC’s Declaration on the Rights of Indigenous Peoples Act (DRIPA). 

In Resource Works’ opinion, the process of creating the Framework itself was considerably less transparent. Unlike A New Future for Old Forests, which clearly stated how many respondents participated and how the consultations were carried out, the authorship, consultation process, and participation rate of the Draft Framework are murky. 

In his investigative research piece “How eco-advocates worked B.C. politics, Resource Works’ CEO, Stewart Muir, highlighted how members of the Environmental Non-Governmental Organization (ENGO) community were chosen for the committee that recommended which old growth land would be set aside from logging. Given the sharp turn the Draft BC Biodiversity and Ecosystem Health Framework takes toward resource protectionism (and away from the more balanced approach advocated by A New Future for Old Forests), one might wonder if the same dynamics were at play during the creation of the Draft Framework

It would certainly appear possible. When the Tripartite Framework Agreement on Nature Conservation was released to the public, campaigner Charlotte Dawe of the Wilderness Committee told reporters from City News, 

“… we need to change [so that] industrial projects are held to a higher standard. [The Tripartite Framework] agreement does not talk about that. There might be something coming in the next couple of weeks here.” 

The Draft Framework was indeed released a short time later. This suggests that the ENGO community was not only consulted, but also that they had a hand in writing the policy. 

While Resource Works does not have a problem with the government consulting conservation organizations, we would prefer to see an open, transparent process with balanced participation. The Draft BC Biodiversity and Ecosystem Health Framework still has a way to go in this regard. 

We are also unclear on what, exactly, is the problem to be solved. Is there some pressing problem we are trying to solve? This is not very clearly stated, and that being the case some will wonder whether there is particular benefit to the recommended actions at this time. By way of example, the forest industry is facing profound uncertainty, with lack of access to trees, closures, and a disturbingly large number of forest manufacturing facilities idled in recent years.

Since 2017, there have been 28 sawmills closed indefinitely or permanently as well as shift reductions; and five indefinite or permanent pulp and paper closures. Nor have we seen any attempt in the draft to analyse the impact of the seemingly imminent Land Act Amendment, which in itself has raised inquiries about its impact on stewardship and economic access. Hence, this is neither the time nor the setting for further constraining policies that are vague in their particular intent. 

Let’s Take a More Balanced Approach 

The Draft BC Biodiversity and Ecosystem Health states that “strong, stable, and prosperous communities and economies rely on healthy ecosystems.” Resource Works agrees with this statement. Ecosystem health is an issue for all residents, due to the fact that the richest biodiversity is found in the river bottoms and estuaries that are most favoured by flora, fauna and homo sapiens alike. Yet, in the past decade, public discussion on biodiversity and land use in British Columbia and Canada has been limited.

The debate over development, including housing, transportation, forestry, mining, energy, agriculture, and water use, is intensifying, with concerns about whether current conservation efforts are sufficient. We think British Columbia, with over half of its land protected and 29% under moderate to strong protection, is doing remarkably well. It ranks 15th globally for protected areas, an achievement that, while significant and deserving of celebration, is often overlooked.

The province's commitment to establishing a variety of protected areas is commendable, yet there's a need for ongoing discussions about balancing conservation and development. 

Strong, stable, and prosperous communities throughout much of BC, including Indigenous peoples, also rely on a strong natural resource sector. Sharp curbs to well-regulated economic uses of land will cause these communities to suffer. Therefore, Resource Works urges the Province of BC to take a second look at the Draft Framework and consider where it can reflect a more balanced approach. If this would be improved by active engagement with our organization (something that did not occur during consultations for the framework), we stand ready to contribute our energies. 

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