The BC Wildlife Federation represents hunters, anglers and recreational shooters of over 100 member clubs throughout British Columbia. Membership concerns regarding regulation and policy are taken up to the government. The following are reports, correspondence, briefs and other related materials that are submitted to government by the Federation's Director of Strategic Initiatives or other representatives of BCWF.
Recommendations on the BC Cumulative Effects Framework
Submitted on behalf of the Fraser Basin Council and British Columbia Wildlife Federation
June 27, 2016
This briefing note summarizes recommendations for submission to the Province
of BC regarding the BC Cumulative Effects Framework (CEF). It is based on a
review of literature as well as observations, insights and lessons learned from
attending meetings and workshops on cumulative effects, discussions with
practitioners from across the province of BC and a review of the phase 2
engagement documents available at:
Recommendations are provided on the following aspects of the CEF:
1. Engagement and Advisory Processes
2. Selection of Values and Objectives
3. Evaluation, Oversight and Reporting
5. Other Comments
1. Engagement and Advisory Processes
• Ensure early and ongoing government-to-government engagement and
collaboration with First Nations.
• Ensure open and ongoing engagement with stakeholders and practitioners
throughout policy development and implementation, as well as the review
and refinement of values, objectives, policies and procedures over time.
• Clearly define opportunities for engagement in Cumulative Effects
Assessment (CEA) review and identification of management responses.
• Establish scientific and public advisory bodies to act as permanent and
ongoing sources for external engagement and review. This recommendation
would benefit the CEF in many ways, including:
• Facilitating input from a variety of technical experts, professionals and
practitioners, along with public, private and nonprofit stakeholders
regarding values, objectives, indicators, cause-effect relationships,
benchmarks, triggers, management responses, etc.
• Supporting continual improvement to keep pace with evolving scientific
knowledge, emerging analytical tools, changing issues and impacts, as
well as evolving values and objectives.
2. Selection of Values and Objectives
• Consider a wide range of values that relate to environmental, social,
economic, and cultural dimensions of sustainability.
• Use a consultative and collaborative process to inform the selection of values
and objectives that is inclusive of First Nations governments, other
communities, and a variety of public, private and nonprofit stakeholders.
• The selection of values, objectives and indicators should be iterative and
• Ensure provincial initiatives that identify and assess values (e.g., Forest and
Range Evaluation Program, Multiple Resource Value Assessments, etc.) are
aligned and coordinated for consistency with CE values. This will help to
improve the alignment of values across different initiatives and policies over
• Draw upon values and objectives that are expressed through existing
government-to-government agreements and other initiatives to support the
identification of values of First Nations and others.
• In addition to integrating values and objectives from existing plans, there is a
need to develop a process for reviewing, adding or revising values and
objectives over time. Past plans such as LRMPs, water use plans, watershed
plans, forest stewardship plans, and others can help collate the mix of
community and societal values and objectives. However, it must be
recognized that for much of BC, existing land use plans are substantially out
of date and gaps exist. Ideally these plans would be updated, or at the very
least, the values and objectives articulated in those plans should be
reviewed, confirmed, or corrected before using these values and objectives
as the basis of CE assessment and management in modern times. Much has
changed in terms of the natural resource sector pressures on the landscape;
the organizational structure and capacity of government; the evolving title,
rights and roles of First Nations; the evolving values and objectives of
society, and even the climate itself. Therefore, there is a need to review –
and potentially add or revise – values and objectives in the near term and
include provisions to continue to do so over time.
• It is key to have measurable indicators to provide early warning signals, as
well as thresholds and targets to trigger appropriate management responses
to mitigate the identified risks.
• In Part 1: Policy for Cumulative Effects Assessment within section 5.3 “The
following are primary criteria for the selection of CEF values:
• b. The value can be spatially identified and mapped.
• c. There is data available to support assessment of the value.”
• There is recognition that one cannot manage things that are not measured
or mapped. However, a lack of data should not prevent the expression of
legitimate and significant values. In some cases the lack of data could
fundamentally bias the CEF (both assessment and management aspects)
by excluding key values of importance. It would be far preferable to
develop the means to measure important values, than to disregard
important values simply because historically, the relevant data has not
3. Evaluation, Oversight and Reporting
• In addition to issuing the various assessment and management reports as
outlined in the CEF, it is recommend to add a function to evaluate and report
on the effectiveness of CE assessment and management including the
accuracy of assessment, the improvement of data over time, the suitability of
management thresholds and triggers, the effectiveness of terms and
conditions of permits and approvals (e.g. management responses, mitigation,
offsets, etc.) as well as long-term achievement and maintenance of values
• Establish a third party, science-based body to oversee monitoring, audits and
investigations to ensure effective implementation of the CEF as well as
continual improvement. A Natural Resource Practices Board (NRPB) is one
model that could be established to provide this function. A NRPB could be
based on the Forest Practices Board, but with an extended mandate to
include all natural resource sectors. A NRPB would be well suited to provide
3rd party oversight on the CEF.
• Ensure that adequate resources are dedicated to staffing, training, and
capacity building to support effective CEF development and implementation.
• Ensure that adequate resources are dedicated to improving data and
information to fill gaps, monitor trends, improve provincial coverage, etc.
Good information is fundamental to a technically sound CE assessment and
management process and the need to adequately resource improved
information cannot be over-emphasized. In many cases, we do not currently
have adequate data to accurately assess and effectively manage cumulative
effects. In addition, there is a need to improve the accuracy of risk functions,
understanding of cause-effect relations, modeling of future scenarios and
projected effects, etc.
• In the short term, a couple of key data gaps that need to be addressed relate
to good baseline information (i.e. the conditions of values prior to significant
resource development) as well as the influence of a changing climate on
future conditions of identified values.
5. Other Comments
• One of the benefits expressed from the Cumulative Effects Framework is that
proponents will know expectations “up front”. In addition to understanding the
expectations of statutory decision-makers, there is also a need for
proponents to consider the expectations of several other parties, including
First Nations, along with community and stakeholder interests. This can be
expressed within the values and objectives if these values and objectives are
developed in collaboration with these entities.
• In regards to First Nations, there are numerous treaties, legal decisions, and
existing government-to-government agreements that may provide helpful
guidance in expressing the values and objectives of First Nations. Additional
thought is required to enhance existing engagement processes with First
Nations and to clarify how the values and objectives of other communities
and stakeholders can be integrated.
• In Part 1: Policy for Cumulative Effects Assessment and Part 2: Policy for
Cumulative Effects Management within the section on “Key Roles and
Responsibilities” it is recommended to add the following:
• 3rd party oversight and audit function such as a Natural Resource
• Formal government-to-government processes with First Nations
• Formal advisory processes for local governments, and other public,
private and nonprofit stakeholders.
• In Part 1: Policy for Cumulative Effects Assessment within Appendix A: Initial
List of CEF Values, it is recommended to add the following:
• Environmental flows as a specific, critical aspect of the broad value
“Water Quantity and Quality”. This should consider both the volume and
timing of flows throughout the year to ensure healthy ecosystem
• Wetlands as a value in addition to riparian within the broad value of
Click the link HERE to download the file
BCWF Position on Resource Development Projects - April 22nd, 2014
The BC Wildlife Federation recognizes that economic development provides the wealth required to maintain the economic, social and environmental well being of the province and that these requirements need to be balanced.
The B.C. Wildlife Federation's priorities are:
To maintain opportunities for hunting, fishing and outdoor recreation, and
To maintain the sustainability of natural resources that sustains fish, wildlife and their habitats.
In considering resource development projects, BCWF will provide advice on the best approach to avoid, mitigate or offset the impacts of resource development on fish wildlife and their habitats. BCWF believes meaningful consultation related to resource development decisions should be consistent, focused, efficient and cost effective and the costs of avoiding impacts, mitigation and offsets should be borne by the proponent.
The B.C. Wildlife Federation recognizes that there are valued fish and wildlife elements that are fundamental to the sustainability of the resources and is opposed to resource development in areas if the impacts cannot be avoided.
Where approaches to address these concerns exist, BCWF will work with proponents and regulatory agencies to identify and minimize the impacts.
Where approaches to address resources development do not adequately exist, BCWF will advocate for legislation, regulation or agreements to address our concerns including but not limited to a Natural Resources Practices Board, a Provincial Compensation Policy and Emergency Response Capacity required to address environmental spills from mining, energy or transportation sectors.
The B.C. Wildlife Federation believes that a proactive planning process at a landscape level for resources development should be implemented to minimize the impacts on the sustainability of natural resources (i.e. transportation or energy corridors) particularly related to cumulative effects on aquatic and terrestrial resources.
B.C. Wildlife Federation Board of Directors
April 9, 2014
Letter to Greg McLelland, Shaw Media re: Cancellation of Hunting Shows in 2013
BCWF wrote a letter to Greg McLelland of Shaw Media, stating out disappointment in their decision to remove all hunting shows from their 2013 line-up.
Letter to Greg McLelland, Shaw Media re: Cancellation of Hunting Shows in 2013 (September 2012)
Rural Caucus Meetings March 29 and March 30, 2012
Bill Bosch, BCWF President, Jesse Zeman, Director and Al Martin, Director of Strategic Initiatives, met with the NDP and Liberal Rural Caucus to outline the aims of our organization and the major issues we see in a presentation titled “Fish and Wildlife Matters”.
Rural Caucus Meeting Report (June 2012)
"Fish and Wildlife Matters" Presentation- Mar. 29 | "Fish and Wildlife Matters" Presentation- Mar. 30
Letter to Deputy Minister Doug Konkin, MFLNRO, re: SSCP Review Concerns (Skeena Region)
BCWF wrote a letter to Deputy Minister Doug Konkin outlining some concerns that stemmed from a letter that was sent to the Provincial Angling Advisory Team (PAAT) by Vicki Marshall, PAAT Acting Chair.
Letter to Deputy Minister Doug Konkin | Letter from Vicki Marshall to Provincial Angling Advisory Team (June 2012)
Letter to Minister Keith Ashfield, Minister of Fisheries and Oceans, re: Changes to the Habitat Provisions in the Federal Fisheries Act
BCWF has written a letter to Minister Keith Ashfield, Minister of Fisheries and Oceans, outlining several concerns about the changes to the habitat provisions in the federal Fisheries Act through Bill C-38, the proposed Budget Implementation Act.
Letter to Minister Keith Ashfield re: Changes to Federal Fisheries Act (May 2012)
Letter to Minister Steve Thomson, Minister of Forests, Lands and Natural Resource Operations, re: Commitment to Ensure Chief Forester in Place
Region 7A has written a letter to Minister Steve Thomson in response to Minister Thomson's address at the BCWF Annual General Meeting & Convention.
Letter to Minister Steve Thomson (May 2012)
Letter to Minister Steve Thomson, Minister of Forests, Lands and Natural Resource Operations, re: Forest and Range Practices Act (FRPA) Regime
Letter to Minister Steve Thomson re: FRPA Regime (April 2012)
Collective Letter to Premier Christy Clark Re: Collaborative Management Agreement (CMA) for Wildlife
BC Wildlife Federation, Guides Outfitters Association of BC, and the BC Trappers Association have collectively written a letter to Premier Clark regarding their concerns with the Collaborative Management Agreement (CMA) for wildlife with Treaty 8 First Nations.
Letter to Premier Christy Clark Re: Wildlife Collaborative Management Agreement (March 2012)
Letter to Rt. Honourable Stephen Harper Re: Proposed Changes to the Habitat Provisions in the Federal Fisheries Act
BCWF has written a letter to Prime Minister Stephen Harper in response to a recent news release issued by Otto Langer, 2009 BCWF Conservationist of the Year winner. The news release revealed that Langer received a leaked document, which contains proposed changes to the habitat provisions of the Fisheries Act. This story is published in various media.
Letter to Prime Minister Stephen Harper Re: Proposed Changes to Habitat Provisions in Federal Fisheries Act (March 2012)
Letter to Premier Christy Clark Re: Living Rivers Trust Fund
BCWF has written a letter to Premier Christy Clark to ask for the government's continued investment in the Living Rivers Trust Fund for the next five years. This investment would be timely in light of the Living Water Smart, anticipated changes in the Water Act, and the need to respond to the results of the Cohen Commission.
Letter to Clark Re: Living Rivers Trust Fund (February 2012)
Letter to Rt. Honourable Stephen Harper Re: Fisheries Stock Assessment Programs
BCWF has written a letter to the Prime Minister, urging his government to refrain from cutting costs to the survey catch program of prawns and other species in the Pacific Region. If Fisheries and Oceans Canada (DFO) cannot determine the status of prawn stocks after the commercial fishery closes, the DFO may cancel or put overly precautionary limitations for all harvest groups.
Letter to Harper Re: Fisheries Stock Assessment Programs (December 2011)
Letter to Honourable Steve Thomson Re: Provincial Voices on Wildlife Management
BC Wildlife Federation, Guide Outfitters Association of British Columbia, and BC Trappers Association have jointly submitted a letter to Hon. Steve Thomson, Minister of Forests, Lands and Natural Resource Operations (MFLNRO), with their response to the Ministry collecting input from individuals, and independent, single interest groups. This is a departure from the past, where government funnelled individual and local viewpoints back through the respected voice for the sector.
Letter to Hon. Steve Thomson, Minister of MFLNRO, RE: Provincial Voices on Wildlife Management (November 2011)
Position Paper on BC Hydro Fish and Wildlife Compensation Program
BCWF has written a position paper re: Changes to BC Hydro's Fish and Wildlife Compensation Program due to recent staff layoffs.
BCWF Position Paper- Reconnect the Compensation Program with their Purpose (November 2011)
Presentation to the Standing Committee on Finance
This brief summarizes ten recommendations to the Standing Committee on Finance and includes recommendations such as increased funding for fish and wildlife inventories and management, building capacity for engagement of First Nations, e-licensing.
Brief to the Standing Committee on Finance (October 2011)
Ministry of Forest, Land and Natural Resource Operations (MNRO) Review
A brief was submitted to MLA Randy Hawes, Parliamentary Secretary for Natural Resource Operations Review, regarding BCWF's view of the ministry that was newly formed prior to the dissolution of the Campbell government.
Submission to MLA Randy Hawes re: MNRO Review (July 2011)