To: Hon. Nathan Cullen, Minister of Water, Land, and Resource Stewardship, British Columbia, Canada From: Thor Henrich, retired teacher and naturalist; Victoria Secular Humanist Association.

January 15, 2023

Re: Critique of The Framework (‘Draft B.C. Biodiversity and Ecosystem Health Framework’)

This letter critiques the ‘Draft B.C. Biodiversity and Ecosystem Health Framework’, arguing that it prioritizes economic growth over ecological integrity. The letter points out false premises in the Framework, such as the assumption of unlimited growth on a finite planet, and highlights ominous omissions such as the need for water stewardship, the urgent reduction of carbon emissions in the province, and the immediate protection of old-growth forest and endangered and keystone species. The letter also raises concerns about the Framework's failure to address past environmental damage, its impact on First Nations, and its insufficient conservation measures.

In summary, the critique in this letter deems the Framework inadequate for the task of urgently protecting BC’s climate (as part of the global climate), its natural biodiversity and its few remaining intact ecosystems.

This letter therefore calls for a scientifically-grounded approach to urgently address the many well-documented environmental and climate change issues in British Columbia.

It also calls for additional time – until March 29th , 2024 instead of January 31st – to allow for more responses from individuals, conservation organizations and other civil society groups.

The Framework was written in response to Recommendation 2 of the Old Growth Strategic Review: “Declare the conservation and management of ecosystem health and biodiversity of British Columbia’s forests as an overarching priority and enact legislation that legally establishes this priority for all sectors.”

In response to Recommendation 2, the Framework is presented as addressing the loss of biodiversity and ecosystem health in British Columbia. Its stated Purpose is to: “provide strategic direction that sets the course for changes in legislation and current practices that aligns the Province’s commitment to UNDRIP” (the United Nations Declaration on the Rights of Indigenous Peoples) “with specific goals that are intended to maintain and enhance biodiversity and ecological integrity, communities and economies for generations to come”. It is an attempt to address these issues with substantial, transformative new policies, laws, schemes of use and management.

However, the Victoria Secular Humanist Association is highly sceptical about these measures. In reality, they will not conserve and protect what remains of natural, self-sustaining ecosystems, but instead will continue and increase the extraction and exploitation of provincial resources, wherever they are, as the primary driver for provincial growth and wealth. An examination of the Framework reveals several flaws in logic, and in critical and rational thinking, and the prioritizing of economic ideology over ecological integrity. The Framework has fatal flaws, which we describe under the following headings: False Premises, and Ominous Omissions.

If this flawed Framework does become the basis for new laws, regulations, policies and programs, and the foundation for the way we relate to our environment, the province will experience tragic consequences which will destroy the biodiversity and ecology of British Columbia as we know it.

This critique suggests that the Framework is inoperative and needs to be abandoned at the earliest moment. A new Framework with a scientific basis, one not motivated by politics, ideology or the resource extraction economy, is desperately needed and necessary at this critical time.

Brief historical background of resource exploitation in BC

The first European explorers and exploiters in British Columbia began with a lucrative trade in furs (beaver, mink, sea otter) and, later, metals (gold, silver, copper), fish (salmon, herring), forests (fir, pine, cedar, hemlock) and fossil fuels (coal, petroleum, methane), displacing First Nations (‘Guns, Germs, and Steel’). Colonial extractive systems have continued unabated to the present. Small towns and villages, once islands in the wilderness, have become (in just a few decades) rapidly-growing cities surrounding shrinking natural areas. Past and present governments have not been kind to the environment. ‘Use’ and ‘management’ continue as central themes. More pipelines, dam-building (Site C) and breaches (Mount Polley), clearcut logging, fracking and mining operations, etc., have run roughshod over natural landscapes in which indigenous peoples have lived for thousands of years. One hundred and fifty years of colonialism have left much of British Columbia in a degraded state. The Framework makes no reference to deleterious/destructive activities, past and present, or why they must to come to an end.

The following are some of the reasons why the Framework will not succeed in implementing the BC Government’s stated commitment: “To prioritize the conservation and management of ecosystem health and biodiversity, including the conservation and recovery of species at risk....”

False Premises:

The most important of these false premises is the paradigm of unlimited growth on a finite planet. As Donnell Meadows (Club of Rome) wrote in The Limits to Growth (1972), the global system of nature in which we all live cannot support the present rates of economic growth. She accurately forecast that the scenario of ‘business as usual’ would lead to serious ecological crises by the early 21st century. Yet the Framework assumes that BC’s environment can continue to support economic growth in perpetuity.

A second false premise is that there is still a lot of time to fix things before a true emergency intervenes. The recent COP28 is a perfect example of procrastination. After more than thirty years of denial, the petrostates have finally admitted the obvious scientific fact that anthropogenic global heating is caused by combustion of fossil fuels. Bypassing the Paris Agreement of 2015, COP28 agreed to ’transition’ (not 'phase down' or 'phase out’) the use of fossil fuels for energy by ‘mid-century’ (2050), but to continue indefinitely the manufacture of thousands of petrochemicals of which many are highly toxic, not only to humans, but also to species and whole ecosystems. Rising levels of atmospheric carbon dioxide and methane have resulted in record high temperatures in 2023, a year of record global temperatures, the highest in an estimated 125 thousand years, with drought, wildfires, flooding, on massive scales. In Canada all 10 provinces and 3 territories had major burns, losses of infrastructure and wildlife, at a cost of billions of dollars, with fully 5% of the country burnt up in wildfires, mostly in forests. There has been no accounting of the effects on the flora and fauna in BC after these tragic events.

Lytton, British Columbia recorded the highest-ever temperature in Canada of 49.6 C on June 29, 2021, then burned to the ground, displacing an entire community. We no longer have the luxury to wait while various planning committees come up with more ways to accommodate more extractive activities on BC lands. The Framework as outlined will take decades to implement, time we just don’t have any longer. We are in an emergency polycrisis now.

Ominous Omissions: 1. Too Little Protection

On November 3rd, 2023, the governments of Canada, British Columbia and BC First Nations signed an agreement to protect 30% of lands in BC by 2030. The 30 x 30 goal must be reached within the next six years, yet there is no mention of this urgent and critical goal in the Framework.

At present, only 15.5% of lands in BC are protected, mainly as parks and ecological reserves, leaving 84.5% unprotected. BC Parks have been subjected to heavy human impacts, from recreation, camping, hiking, trails and roadways, wood gathering, pollution and wastes, etc., so they are far from 'pristine’. A strong argument can be made that BC, as the province richest in biodiversity, is an ecological hot spot, and should therefore have at least 50% (ref: EO Wilson) of nature set aside as the actual target for conservation and preservation. BC was the first province to promote the idea of Ecological Reserves, in 1971, whereby areas especially rich in biodiversity and/or landscape features would be left inviolate, with no trails, recreational or resource uses permitted, in perpetuity, and as essential benchmarks for future reference to identify any changes over time. It was initially suggested that at least 1% of the province be set aside for this purpose. Yet to date only 0.17% of BC has been set aside, in 148 Ecological Reserves, with under-funding and inattention towards care and conservation over the 50+ year history of the program. Does the Framework recognize that reserving less than 0.17% of BC’s biodiversity and ecosystem in a pristine state and leaving 99.83% open for future economic developments is no solution?

2. Too Little Public Consultation

The Framework was developed in consultation with First Nations, local governments, interest groups and industry, but it was sprung upon the wider public without its consultation or input, a serious omission, and the public has had only until January 31st to respond to this important document. We suggest that in fairness, and due to the size and scope of the Framework, that March 29th, 2024 would be a more reasonable deadline for submissions.

3. BC’s Fossil Fuel Emissions

To avoid the worst of predicted outcomes, global carbon emissions must be cut in half by 2030, and reduced to zero by 2050. This requires an annual reduction rate of 7%, yet, to date, no country has achieved a reduction rate of more than 1.5%. British Columbia is in the business of producing all three carbon-emitting fossil fuels (coal, petroleum, and methane), which all contribute to increased levels of carbon dioxide and methane, and to the global warming caused by humans. But the Framework makes no mention of alternative sources of energy or of how BC will mitigate the deleterious effects of burning fossil fuels while at the same time protecting biodiversity and ecosystems.

4. Protecting Individual Species

Thousands of species of plants, animals, fungi and microbiota make up the dynamic natural ecosystems in BC and its unique biodiversity, yet the Framework contains only one statement concerning individual species. A small table on page 5 describes a Shift from “Individual Species" to "Continue to advance holistic multi-species/ecosystems and threats-based approach*”, below which is this interesting statement (our underlining): * “While managing for vulnerable individual species may always be needed, shifting to a multi-species/ecosystems focused approach can result in greater benefits across multiple species and reduce overall costs and effort on single species management.” This statement seems to demonstrate one of the real intents of the Framework – to reduce the funds that are needed to save vulnerable individual species. It ignores any scientific rationale about why certain native species and their complex interactions in the natural environment need conservation, protection, and care.

The Framework has no stated plans for individual species, such as the marbled murrelet, an at-risk marine bird, under federal and provincial protection, and which makes its nests, lays its eggs, and raises its young in the canopies of old growth forests, in sites which are still being clear-cut logged, despite being supposedly ‘deferred'. Caribou herds are still shrinking as road construction for mining access continues through their lands. The shooting of wolves that use these roads is not working to protect caribou. As well, there is no stated understanding that lichens are an essential dietary source for many ungulates such as caribou, moose, elk, bison, deer, as well as several smaller rodents. Hummingbirds use lichens and spider webs to make their tiny nests in trees, yet there is no statement recognizing them or the more than 2,000 lichen species living in intact natural forests. There is no mention of the essential roles of mycorrhyzal fungi/tree root nutrient exchanges as essential for the biodiversity and health of forest ecosystems. The Province played its hand when it suggested that the 2017 Provincial ban on trophy hunting of grizzly bears should be modified so that individual communities would be able to make that decision on the basis of economic benefits.

5. Stewardship of Water

Water stewardship is part of the mandate of the Minister of Water, Land, and Resource Stewardship, yet there is barely any mention of this valuable and essential-for-life molecule. Glaciers and snow ice packs grow in winter and normally slowly melt in summer, supplying lowland rivers and streams for breeding salmon, water for forest ecosystems and their inhabitants, recharging aquifers and wells, and human uses in agriculture and other industries.

The record temperatures, drought, and drying of rivers and stunted growth of vegetation last summer resulted in young fish dying in overheated shrinking pools of rivers and streams, and thirsty and hungry bears and cougars coming into human habitations, resulting in their being shot or relocated to other areas similarly impacted by poor conditions for life in the forest. The impacts of human fouling waterways, streams, lakes, bays, and ocean waters with pollution from industry, from microplastics and thousands of petroleum-based toxic chemicals need attention as worthy and essential goals in the Framework.

Climate change is resulting in more unpredictable variations in precipitation, from drought to flooding, a significant impact on the resilience and ecological limits of species found in the various ecosystems. Life on land ecosystems interacts with life in marine ecosystems in dynamic and interlocking ways. The Framework needs to explain the importance of the water cycle for both natural and human survival, and its approach to ensuring the continuing availability of clean water in an era of global heating and increased droughts.

6. Benchmarks Ignored

The Framework’s Key Terms do not define such words as ‘species’ or ‘ecology’, which are at the heart of conservation strategies. Also missing is any discussion of the differences past and present of intact versus degraded/destroyed ecosystems. For example there is no mention of the difference between an old-growth forest with thousands of different species performing various roles of autotrophs (plants, algae, lichens), heterotrophs (animals, mycorrhizal fungi), and decomposers (fungi, microbial invertebrates, bacteria and viruses) versus a 'managed forest’ of a single species of conifer, that under present conditions of clear-cutting, will not be allowed to regenerate into an old-growth forest. 150 years of human impacts (trapping, mining, logging, over-fishing, soil degradation, pollution, fossil fuel extractions) have left much of the province in a damaged state. The Framework needs to explain that we are not starting with a ‘fresh slate’, that benchmarks generally start with each new human generation (with narrowing perspectives), and that we need to develop benchmarks based on scientific data gathered from intact ecosystems such as found in ecological reserves (ERs), and not from ideological belief systems. Such data need to be based as closely as possible on the natural state of each intact ecosystem.

The Framework needs to also explain how and why we need to stop destroying what little remains of intact nature in BC.

7. Funding Costs

Given the size and scope to achieve the goals and aims of the Framework, the funding proposed so far is totally inadequate. The $500 million from the federal government, over the life of the Framework, to match commitments from the Government of British Columbia, plus $104 million from the 2 Billion Trees program towards restoration of species-at-risk habitat, wildfire mitigation and recovery, and watershed health is sorely lacking for the task at hand. How all this can be accomplished in the next six years, if at all, with the proposed funding, is suggestive of magical thinking. There is not one statement in the Framework which specifically addresses the costs involved to conserve and protect old-growth forest ecosystems and their biodiversity, which would now come under the rules of “adaptive management”.

8. Impacts of Resource Extraction Growth

Minister Cullen, in addition to his role as steward of land and water, is also responsible for stewardship of resources, yet resources are given only passing mention in the Framework, despite very large increases in exports. Energy products made up a remarkable 37% of BC’s export goods in 2022, compared to 17% in 2015. Metallurgic anthracite coal is BC’s largest export, combined with natural gas and petroleum: $23.89 billion in 2022, compared with $5.19 billion in pre-Covid 2015. Exports of other resources have also grown significantly, as the following statistics indicate, showing BC’s export income in year 2022, compared with 2015 (in parentheses). Wood products $11.11 B ($8.41 B). Pulp/paper products $4.44 B ($4.37 B). Metallic minerals $6.26 B ($4.43 B). Chemicals $1.43 B ($1.09 B). Plastics and plastic products $1.00 B ($0.43 B). And so on, with total merchandise exports of $64.46 billion dollars in 2022 compared with $35.50 billion dollars in 2015. Three-quarters of these exports go to the US (53.0%), China (16.6%), and Japan (10.2%), with lesser amounts to South Korea (5.1%), India (1.8%), Taiwan (1.6%), and other countries.

Many of these exports are toxic, for example plastics, chemicals and the impurities in coal. Or they contribute to increasing levels of human-caused CO2 in the atmosphere. But their impacts on human health and climate change are not mentioned in the Framework. And the document completely ignores the dangerous and deleterious effects of resource extractions and exports on biodiversity and ecosystem health. The massive increase of these BC exports over the short period of eight years is certain to enlarge BC’s ecological footprint several times over, hastening the date of ecological collapse.

9. Impossible Timelines

To achieve the goals by 2030, as stated in the 30 x 30 Agreement, any plans which support biodiversity and (natural) ecosystems may clash with extractive industries such as clear-cut logging, mining and fracking, the building of damaging infrastructure, etc. How will the Framework operate to achieve consensus by 2030, if there is such an impasse?

10. “Adaptive Management”

The Framework abandons the actual preservation and conservation of species and natural ecosystems presently being negatively impacted by commodification, resource extraction, destruction, pollution, and extirpation/extinction. The BC Conservation Data Centre (CDC) lists the biota (flora, fauna, fungi) of BC, and the conservation status of species which are at risk, red and blue listed, of special concern, endangered or threatened. The Framework is mute concerning how and when the data from the CDC will be used, if ever. In place of existing policies, rules, and laws concerning individual species, communities of species, and natural ecosystems, the Framework has substituted the vague terms of ‘adaptive management’, ‘use’, and ‘collaboration', which suggests that the Province would abandon actual Biodiversity and Ecosystem Health in favour of 'Business-as-Usual, Accelerated’.

11. Old-Growth Logging Deferrals

The Framework is mute on the subject of deferrals - “a system meant to prevent irreversible biodiversity loss as long-term protection plans were to be developed, provided First Nations agreed with government proposals” (Nov. 21, 2021). There are several instances of clear-cut logging which are still occurring in old-growth forests designated for deferral. The Framework has no information on how deferrals will stop the ongoing clear-cut logging in old-growth forests, or on what will happen if and after deferrals come to an end.

12. The Rights of Nature

To be effective, the Framework must have legal teeth. Attempts to use legal arguments to conserve species, natural communities, and ecosystems in BC have so far failed (see D. R. Boyd, The Rights of Nature: A legal Revolution that could save the World (2017); P. W. Taylor, Respect for Nature: A Theory of Environmental Ethics (1986). The author of this critique has published a paper titled Can using 'Rights of Nature' Protect BC’s Old Growth Forests? (2022), noting that the Rights of Nature are used to protect species, natural communities and ecosystems in several jurisdictions around the world.

If the British Columbia Government is serious about its commitment to conservation, protection, and care for BC’s Biodiversity and (natural) Ecosystem Health, it must enshrine the Rights of Nature to Exist, so that Nature can exist untrammelled, and in as close to natural biological and physical conditions as possible. Just as democracy enshrines the rights of its citizens, it should also enshrine the Rights of Nature.

Conclusions:

To be effective and accepted as a new norm, a Framework must be seen as a legitimate way forward, taking into account the many variables under the wise overview of government while making sure that the overarching priority – “the conservation and management of ecosystem health and biodiversity” – is now understood to be essential for maintaining life in British Columbia, as part of this evolving planet.

It is imperative that the BC Government appropriately fund, properly account for, and take responsibility to ensure that the Framework will bring an end to ‘business-as-usual', and save all remaining natural areas, such as old-growth forests. Downloading costs and risks onto local communities can lead to unforeseen problems and new issues. We must also realize that we can’t continue to grow without limit, that there are cogent reasons to save, care for, and protect what is left of intact nature, not the least of which is the mitigation of climate change, and we must bring the current exploitative economic agenda to a quick end.

British Columbia, if it is to survive as a healthy democracy, must prioritize biodiversity and natural ecosystems over resource extraction, by protecting all its species, especially those presently at risk, and by educating the public about the need to protect biodiversity at all levels.

This is a moral and ethical imperative which requires our humility, respect, and awe for the natural world.

Thor Henrich. Victoria Secular Humanist Association

Thor Henrich is a retired teacher of many topics in the biological sciences. He taught for 50 years at the secondary, prison, college and university levels, and holds degrees in Zoology (Bachelors, UC Berkeley; Masters in Zoology, with thesis, University of South Dakota.) Thor is a long-time member of the Victoria Secular Humanist Association (VSHA) and its Eco-Humanism Committee.

Endorsed by the Victoria Secular Humanist Association (VSHA). VSHA is a home for the secular community and recognizes that the environmental crisis, specifically climate change, is a major existential threat to humanity as part of the natural world.