Canada and British Columbia caribou (central group): protection study summary of comments

The public comment period for the Canada-BC Southern Mountain Caribou (Central Group) Protection Study was open from February 24 to March 26, 2017. 

The following is a summary of the comments received:

Many submissions expressed appreciation for the opportunity to comment, and recognized BC and Canada for the collaborative approach.

Some comments indicated that information was missing from the Study or that additional analysis was needed.

Some comments expressed concern at the lack of interpretation of the information, or that information was included that was not relevant to the formation of the federal Minister’s opinion on protection, or that the Study was not consistent with the draft Policy on Critical Habitat Protection on Non-federal Lands.

Public (>1100)

• There were two email campaigns calling for an end to the culling of wolves and other wildlife. Close to 1100 submissions were received from these two campaigns.
• Twenty one submissions were received from individuals that are strongly focused on ending the wolf / wildlife cull, some of which included elements of the two email campaigns.
• Nine additional submissions were received from individuals. These included strong support for habitat protection including reductions in industrial and recreational activities, support for an ecosystem based approach, and an end to predator control. One respondent questioned the presentation of maps and numbers, seeking to clarify whether some areas were double-counted, and looking for a further explanation of matrix habitat. Another noted that climate change effects should be discussed more extensively. One respondent asked if a similar Protection Study is planned for Boreal Caribou.

Industry (8)

Several industry associations or stakeholders submitted comments. 

The common message was that greater clarity on the next steps is needed to provide certainty for industry and to protect jobs and the economy in British Columbia, and concern about the economic implications of additional habitat protection.  Other comments included:

• the province should lead on the management of caribou;
• greater alignment between federal and provincial definitions of habitat should be achieved, and habitat protection should be prioritized according to its value to caribou;
• range plans should be developed to guide recovery of caribou and economic activities on the landscape;
• authorizations for activities should be considered with respect to whether they achieve the pre-conditions set out in s.73 of SARA;
• a risk-based approach to habitat protection is required, and is not adequately discussed in the protection study, including with respect to conservation measures such as certification standards, professional reliance models, research, restoration efforts, and offsets;
• Project proponents subject to CEAA 2012 are unfairly expected to account for the cumulative effects on species at risk of other activities not regulated under that Act;
• the Area Based Analysis required by the Oil and Gas Commission (OGC), Caribou Mitigation and Monitoring Plans required by the OGC and as part of environmental assessment processes, and other regulatory mechanisms that protect other environmental values, including caribou and their habitat, were not given adequate consideration in the study;
• industry contributions to caribou recovery, including habitat restoration efforts, were not adequately recognized in the study;
• the impacts of climate change require more research and more discussion in the study;
• the study conflates recreation and tourism;
• non-habitat measures should be an immediate priority;
• the assessment of the provincial regulatory regime was incomplete to render a determination of which areas are not effectively protected; and
• an ecosystem-based stewardship approach by federal, provincial, First Nation, and industry partners would produce better conservation outcomes than unilaterally imposing a federal protection order.

ENGOs (7)

Several environmental non-governmental organizations also submitted comments.

Key messages were that:

• the study was fact-based and thorough, but fails to interpret or assess the facts;
• BC should emphasize habitat protection and restoration over predator management and maternal penning;
• existing levels of habitat disturbance are indicative of a lack of effective protection;
• there is a need for total surface disturbance limits and an access plan to ensure effective restoration;
• socio-economic considerations should not trump recovery of listed species;
• federal cabinet decisions should use rigorous socio economic information supported by data;
• wolf and wildlife killing is unethical, has impacts on ecosystem function, and may not significantly impact caribou recovery;
• climate change impacts were not adequately considered;
• the study suggests but does not state that BC lacks legislation to protect SMC; in the view of the submitters, existing legislation outside of parks is inadequate in substance and scale;
• BC needs overarching legislation to protect critical habitat; and
• the Minister of ECCC should recommend a protection order for the critical habitat of SMC, or the federal government should work with BC to address gaps in effective protection and consider interim protection measures such as conservation agreements (one submission).

Indigenous Peoples

No comments were received from Indigenous Peoples during the public comment period.  One community provided comments on a draft version of a summary of the Protection Study. No substantive changes were made between the draft reviewed by this community and the posted version of the document. The overarching comment was to indicate that, based on the information in the Study, the federal Minister must recommend an order to protect the critical habitat of the Southern Mountain Caribou on provincial lands within the three LPUs that make up the Central Group. Other key comments included that the Study should:

• distinguish more clearly between information relevant to the federal Minister and that of relevance to Governor in Council, and what information gaps remain;
• note that BC has no law requiring commitment to SARA compliance and has made no other such commitment;
• better define terms such as “protection” and “effective protection” to provide value to inform the Minister’s recommendation;
• include information about the percentage of disturbance in high elevation ranges, address threats according to habitat type, and address imminent threats in high elevation ranges.

Specific detailed comments were also provided by the community on various sections of the Study summary.

Corrections to the Protection Study:

As a result of comments received, factual corrections to the Protection Study have been made. The changes made can be found here. The final version of the Protection Study is available here.