Salmon Beyond Borders’ Suggestions for British Columbia's Environmental Assessment Public Engagement Survey
Salmon Beyond Borders’ Suggestions for
British Columbia's Environmental Assessment Public Engagement Survey
*to download this document as a PDF, click here.
This survey is 30 questions long and takes approximately 30 minutes to complete. Our hope is that by providing some suggestions, we can help guide your answers to reflect the need for rigorous environmental assessments in shared transboundary watersheds.
If you have ample time, please also see the attached briefing packet from West Coast Environmental Law prior to tackling the survey.
Additionally, if you want to let BC know how you feel about this form of public engagement, let them know, take the survey here!
Questions 1-7 are predominantly focused on who you are and what your background is.
The rest of the questions from the survey can be found below, with our suggestions listed in bold.
8. Please indicate how much you agree with the following statement:There are project categories that should be added to the Reviewable Projects Regulation.
9. Please share with us what project category(s) should be added to the RPR
*Only answer this question if the following conditions are met: Answer was 'Strongly agree' or 'Agree' at question '8 [q008]' (Please indicate how much you agree with the following statement: There are project categories that should be added to the Reviewable Projects Regulation. )
10. Please share with us why the project category(s) should be added to the RPR
11. Please indicate how much you agree with the following:
The Reviewable Projects Regulation includes some project categories that should be removed from the Regulation
*When SBB did the survey, it jumped from Question 11 to Question 14, skipping 12-13.
14. Please indicate how much you agree with the following:
Project Design thresholds are an important factor to determine if a project is likely to cause adverse effects, and therefore trigger an environmental assessment.
15. Please indicate how much you agree with the following:
Project design thresholds are enough information to determine if a project is likely to cause adverse effects, and therefor trigger an environmental assessment
16. Do you have any feedback on the proposed changes to the Project Design Thresholds outlined in the Intentions Paper on pages 13-20 (https://www2.gov.bc.ca/assets/download/FDD409EE186245879E6190531713074D#)
1) Restore the “original” thresholds (i.e. those enacted in 1995 under the first Environmental Assessment Act) for mineral mines and coal mines, namely 25,000 tonnes/year of mineral ore for mineral mines and 100,000 tonnes/year production of coal.
2) Calculate production thresholds based on what is extracted from the environment, not what the proponent intends to sell.
3) BC must provide the data necessary to evaluate whether the proposed new threshold for placer mines would actually result in assessment of any placer mines. Ultimately, the threshold must ensure that placer mines with potentially significant impacts undergo assessment.
4) Abandon the proposal to exempt oil and gas proponents from assessments for extracting deep groundwater and disposing of contaminated water in deep wells.
5) Include a class assessment of mobile thermal treatment of drilling mud, rather than exempting it from assessment.
17. Please tell us how much you agree with the following:
Effects Thresholds are an important factor to determine if a project is likely to cause adverse effects, and therefore trigger an environmental assessment.
18. Are there Effects Thresholds other than linear disturbance, area land disturbance, green house gas emissions, or overlap with prescribed protected areas that could be used to determine the potential adverse impacts of a project, based solely on the project design or features of a project? The criteria must be able to be determined without a lot of testing or data collection.
19. Do you have any feedback on the Effects thresholds outlined on page 21 of the Intentions paper
1) GHG threshold at 50,000 tonnes/year; our fallback is that, at minimum, it must be 1% of BC’s 2050 target, which would be weaker at 127,000 tonnes/year (but still a lot better than their proposal of 1% of the 2030 target, which is 382,000 tonnes/yr). Any project that exceeds 1% of BC's 2050 climate target rather than using the 2030 target. Apply this threshold to all projects of any type, not just the categories of projects already listed in the RPR.
2) Significantly lower the proposed disturbance-based threshold for prescribed projects to 75 hectares.
3) Apply the new (strengthened) impact-based thresholds to upstream development activities (oil and gas and mining).
4) Remove the provision exempting water uses approved under section 10 of the Water Sustainability Act from the assessment requirement for water withdrawals.
5) Remove the requirement to determine significant adverse effects from the threshold that would require EA for prescribed projects that overlap with a listed protected area.
20. Please indicate how much you agree with the following:
Requiring proponents to submit a notification to the EAO if the project:
a) requires a federal impact assessment, but it is not wholly on federal land are within 15% of the Project Design Threshold
or b) has a maximum annual direct employment of at least 250 people is enough to ensure the EAO can track projects that might require an environmental assessment that do not meet the requirements of the reviewable project regulation.
21. Please indicate how much you agree with the following:
For projects that have never received an Environmental Assessment (EA) Certificate (i.e., they were either initially constructed prior to the rest Environmental Assessment Act coming into force in 1995, or below the EA reviewability thresholds), the proponent should be required to notify the EAO if they intend to modify the project, where the modified project would exceed the threshold for new projects in that category.
22. Are there other notification thresholds that could help the EAO track projects that might require an environmental assessment, but do not meet the requirements of the Reviewable Projects Regulation?
23. Would you like to provide feedback on the Prescribed Protected Areas Appendix of the Reviewable Projects Regulation Intentions Paper? *
24. Please indicate how much you agree with the following:
Making environmental assessments mandatory for projects within the Prescribed Category of Projects that are proposed within a Prescribed Protected Area, is a good way to get proponents to consider how their proposed projects could interact with protected areas from the earliest stages of project design, providing an opportunity for proponents to adjust their design to avoid overlaps with prescribed areas, therefore minimizing adverse effects.
25. Are there other ways the Environmental Assessment Ofce could get proponents to consider how their proposed projects could interact with protected areas from the earliest stages of project design?
26. Do you have any feedback on the proposed Prescribed Protected Areas for inclusion in the regulation?
27. Do you have any feedback on the protected or managed areas not proposed for inclusion?
Let the British Columbia Environmental Assessment Office know what you think, take the survey here!
As I reflect on my time as Salmon Beyond Borders’ B.C. Organizer, I’m thinking back...way back...
I’m channeling 10 year old Sierra - playing her favorite computer game - The Yukon Trail. The Yukon Trail is a 1994 computer game based on The Oregon Trail series set during the Klondike Gold Rush of the late 19th century. Players travel through Seattle to Skagway and into the Yukon - to “strike it rich” along the river. I played this game in elementary school for years and it taught me what the foundation of Canada’s mining history had looked like. Those images played through my mind as I considered what it would be like to be a gold-rush era miner - claiming a stake! How exciting. The adventure! The hardship!
Well today, the billion dollar mining industry looks quite a bit different. But rather unfortunately, the regulations that are supposed to protect the ecosystems they operate in - do not. Our mining laws in B.C. haven’t changed in 150 years - that’s right, not since the gold rush.
Considering that British Columbia’s gold rush was important in the history and settlement of European and Chinese people in western Canada, the presence of gold in what is now British Columbia is spoken of in many old legends that, in part, led to its colonization. Still to this day, most Indigenous peoples in British Columbia have never ceded or surrendered their traditional territories.
The United Nations Declaration on the Rights of Indigenous Peoples (“UNDRIP”) affirms the rights of Indigenous peoples to participate in decision making about their traditional territories, and be entitled to give free, prior and informed consent before development can occur. As we have heard commitments from Canadian lawmakers, we eagerly await their action to fully adopt “UNDRIP” and “FPIC” - which not only will apply to First Nations, but to downstream sovereign tribes as well.
Bottom line, the way mining is currently done here in B.C. does not address indigenous jurisdiction, and it will plunge this generation into ecological and financial debt. We are spending our shrinking inheritance on cleaning up the mining industry’s mess.
So what can we do about it?
Well, first off, you can let Minister Heyman and Premier Horgan know that they need to modernize B.C. mining laws. In May of 2019, nearly 30 local, provincial and national organizations from a wide range of sectors, including citizen and community groups, First Nations, academics, and social justice and environmental organizations launched the B.C. Mining Law Reform Network, dedicated to ensuring equitable mining policies in British Columbia. I was able to be part of the launch event in Victoria, as Salmon Beyond Borders is one of 30 organizations behind this great effort. Please consider joining with support for the B.C. Mining Law Reform movement and take action here.
Next, you can tell Minister Freeland that the federal government of Canada needs to push B.C. to improve its mining laws and work with the United States to ensure our shared salmon rivers remain productive for generations to come.
The shared wild salmon rivers of this region are integral to our identities and ways of life in British Columbia, a common trait we share with our neighbors in Alaska and Washington.
People need wild spaces - if only to imagine and be comforted by the fact that there are things bigger than themselves out there. Until recently, I imagined everything north of Prince George as miner’s country - a place so wild and vast that there was no way industrial mining would put these rivers on the brink. Well, after countless markets and tabling and talking to the public about B.C.’s large-scale mining in shared wild salmon rivers - it seems many other British Columbians feel the same.
Mining has played a big role in British Columbia, and it will continue. Our job as citizens of B.C. is to take responsibility for the impacts that B.C. mines have had, and will likely have on our wild salmon rivers. We need to ask ourselves questions such as: Where should mining take place? How should it be done? Who is at the decision table? Who should benefit? And what are we willing to do to protect the places we love?
While I am leaving my official role with the Salmon Beyond Borders campaign, I will not be taking my thumb off the pulse. Pressure needs to come from people throughout the province - this is our task as British Columbians- to stay informed and take action. You can do this by taking these urgent actions, signing up for our newsletter, staying connected and attending events. Staying informed is our best form of activism (and voting is a close second!) See you all at the polls this month!
With that in mind -
Meet Breanna! Breanna is Salmon Beyond Borders’ campaign coordinator. She is based in Southeast Alaska - and is your go-to person when you have questions about the campaign and our work to defend and sustain the Taku, Stikine, and Unuk transboundary rivers. Among many things, Bre will continue to plan events throughout the region and keep you all up to speed - please reach out to Breanna if you want to collaborate in the name of wild salmon!
For me - I will continue working with, and for salmon. My focus is shifting to restoration, but my heart will always be with this transboundary campaign and the people who so passionately work for these magical places.
B.C. Organizer for Salmon Beyond Borders
It has been a really busy and productive summer for the Salmon Beyond Borders campaign crew - a lot has happened since we last provided you with a full update earlier this spring!
We’ve just returned from visits to Petersburg, Wrangell, Ketchikan, Seattle, and Washington, D.C. and have some big campaign updates for you...
We are excited to share that the hard work each and every one of you has put in over the past 5 years of this campaign is working! Your voices have reached community leaders and lawmakers at every level - elevating the need for binding international protections and financial assurances for our shared transboundary salmon rivers, jobs, and way of life.
On the heels of our meetings in Washington, D.C. last week, it is now more clear than ever that the pressure from communities and lawmakers throughout the U.S.-B.C. transboundary region is driving this issue.
This NEW action will go directly to Secretary Pompeo and Minister Freeland prior to the upcoming semi-annual meetings between the Department of State and Global Affairs Canada in Ottawa.
Updates from Washington, D.C.
Add your name to the Thank You letter to all 8 senators from the 4 states bordering B.C. here!
Updates from Southeast Alaska
We’ll leave you with a recent statement from Senator Murkowski:
“Alaska is a resource state. We are blessed with abundant fish, minerals, timber, oil, gas, and wildlife. As Alaskans, we take seriously our responsibility to manage these incredible resources so that the livelihoods they support can coexist in harmony. My longstanding concern is that our neighbors in British Columbia are not meeting a similar high standard with regard to the impacts of hard rock mining on other resources and livelihoods in transboundary watersheds –especially the downstream fisheries that support tribes and coastal communities in Alaska.”
We’re all in this together.
The SBB Crew
“Our impacts on salmon have reached a critical point – it’s time to build resilience for salmon and people. Environmental change and human impacts across the Northern Hemisphere are placing salmon at risk. The International Year of the Salmon aims to bring people together to share and develop knowledge more effectively, raise awareness and take action.” - International Year of the Salmon
In one way or another, here in British Columbia and Southeast Alaska we’re all connected to our wild Pacific salmon. This year is the International Year of the Salmon, and Salmon Beyond Borders is celebrating by joining together with salmon communities across the transboundary region to celebrate all that we love about these incredible wild fish — most recently through “Night of the Salmon Folk*,” an event that brought the Victoria, B.C. salmon community together, at Patagonia’s Victoria location.
We collaborated on “Night of the Salmon Folk” with Watershed Watch Salmon Society, with additional support from Raincoast Conservation Foundation. The evening was filled with five short films, presentations from each organization, and a special talk from guest speaker Chief Ernest Alfred of the Nisga’a Nation. His work has been crucial in protecting Pacific salmon populations, and it was an honour to hear from him and have him attend the event.
The films highlighted a variety of issues facing wild salmon and the habitat they rely on. Topics ranged from fisheries policy, to habitat development, to — of course — mining policy in B.C. Wild salmon issues in British Columbia and the transboundary region are multifaceted and complex, and it was wonderful to talk with many new people on these issues, as well as to discuss ways to individually and collectively take action in our own communities. We all come from a diversity of backgrounds, but all of us present were united by our love for and connection with wild salmon.
The films shown were:
Some of you may have seen Chasing Wild, the film we presented, which is about a team that sets out to understand what is at stake as a massive wave of new mines are developed across Northwest B.C. — and what that wave could mean for wild salmon populations.
After the films there was an opportunity for attendees to mingle, sign on to actions or get involved by volunteering. We were thrilled to meet so many interesting people who were not familiar with the issues facing B.C. and Alaska’s shared, internationally important transboundary rivers, but were eager to learn more.
We asked attendees what wild salmon means to them throughout the evening, and Amelia and Luca, attendees pictured below, said “thriving orca populations and clean, healthy ecosystems!” Other responses ranged from tradition, to food, to health, and even to LIFE! Salmon are truly an important species worth defending. Thanks to everyone who enjoyed the evening with us!
Stay tuned for another Salmon Folk event in Vancouver! In the meantime, keep up with Salmon Beyond Borders’ events and actions on our community page!
*We acknowledge, with respect, our presence on unceded Coast Salish territory of the Lekwungen and WSANEC people, the original salmon folk of this region, whose relationship with this land and these salmon stretches back thousands of years.
Thanks for reading,
What is International Year of the Salmon (IYS)? IYS is a global “initiative to inform and stimulate outreach and research that aspires to establish the conditions necessary to ensure the resilience of salmon and people throughout the Northern Hemisphere.” IYS seeks to bring people together, share and develop knowledge, raise awareness and take action. Salmon Beyond Borders (SBB) is hosting a series of IYS events throughout the region - and we look forward to connecting with you about your research and potential events in your community.
The intensive five-year initiative to address the scientific and social challenges salmon and people face in an uncertain environment will begin with efforts to partner across borders to find common ground for both research and solutions. We are keen to find solutions for the impacts of the growing mining industry on the Taku, Stikine and Unuk rivers --B.C. and Alaska’s shared salmon strongholds.
Read more below about the various gatherings in which SBB has participated or co-hosted around the region in celebration of the International Year of the Salmon!
Launch of International Year of the Salmon in Vancouver, B.C.
On October 11th, the North Pacific Anadromous Fish Commission hosted officials at Jack Poole Plaza in Vancouver, B.C., while Premier John Horgan announced the International Year of the Salmon funding and research plan for the next three years (five years total). Event attendees included media and over 100 leaders in salmon conservation from Canada, the United States, Russia, Japan, and Korea, Indigenous leaders, NGOs, academia, and industry from around the Pacific Rim.
Salmon Beyond Borders attended in an effort to build new relationships and partnerships with those who want to work together on IYS-related issues and events, to support the initiative and the government's interest in rebuilding salmon stocks, and to increase the awareness for the transboundary salmon rivers in Northwest B.C. and Southeast Alaska. SBB’s short video “Salmon Is” kicked off this great event in Vancouver.
The IYS effort reaches across borders to find common ground for both research and solutions — and one of the key threats in need of a solution is B.C. mining on the Taku, Stikine and Unuk rivers. Premier Horgan spoke of the need to “put aside those differences we may have, to put aside those things that divide us, to try to find those things that unite us — to not only preserve and increase our salmon populations but to ensure they will be there for generations to come.”
His words, along with those of Chief Bob Chamberlain’s --“ to put these spoken sentiments into real action” -- left us feeling very optimistic about the future of international salmon research efforts and the ability to move beyond borders to help these at-risk species and the way of life they provide.
International Year of the Salmon Launch Reception
for Fishing Leaders and Alaska Lawmakers in Juneau, Alaska
In January 2019, Salmon Beyond Borders hosted our Juneau Launch event for International Year of the Salmon at Amalga Distillery. United Fishermen of Alaska (UFA) board members, members of the Alaska Municipal League, Alaska state legislators, leaders in the fishing community, and Senator Lisa Murkowski came together to celebrate research, and international collaboration in the name of salmon.
Local businesses were showcased at the event; sustainable wild salmon from Taku River Reds was prepared by Chef Lionel Uddipa of SALT, and specialty cocktails from Amalga Distillery were served. Mayor David Landis of Ketchikan spoke as a representative of the Alaska Municipal League (AML) Board of Directors, Sue Doherty spoke on behalf of the UFA Board of Directors, and local business owners, Tyson Fick of Taku River Reds, and Brandon Howard of Amalga Distillery, spoke on the importance of sustaining wild salmon for Southeast Alaska communities.
Sue Doherty, Executive Director of Southeast Alaska Seiners Association and UFA board member, spoke on behalf of UFA, reading a statement from UFA ED Frances Leach. She said, “We are so excited to celebrate the International Year of the Salmon, especially here in Southeast, home of the Taku, Stikine, and Unuk-Nass Rivers, which serve as economic powerhouses to Alaska communities and the Pacific Northwest as a whole. We support research in these watersheds and we join with communities and lawmakers who call for binding financial assurances and enforceable protections to defend Alaska and our billion-dollar salmon fisheries from upstream development in Canada.”
Salmon Beyond Borders campaign director Jill Weitz highlighted the recent $1.8 million Interior Appropriations bill that was signed by President Trump two weeks ago, directing funds to the United States Geological Survey (USGS) to work with state agencies and local tribes to conduct water quality monitoring on U.S.-B.C. transboundary rivers, “Research - not only has our delegation been really strong on this issue, Senator Murkowski has been, especially as it relates to advancing the needs for research in transboundary watersheds. The last few years, we’ve been working with her and her staff to get research dollars so that USGS can install stream gauges in U.S.-B.C.transboundary rivers. Just last week, the Interior Appropriations bill was signed by President Trump and that allocated $1.8 million dollars for USGS to work with state agencies and local tribes that are already doing water quality work. We are incredibly thankful for her staff, the Senator herself, and members of Congress who also supported this work.”
Senator Lisa Murkowski spoke to the successful appropriations bill and the importance of funding research and water monitoring on transboundary waters, in her address to the Alaska Legislature the following day, “We are making some headway on different levels. From the appropriations perspective, we were able to include additional money for more water monitoring gauges in the Unuk River area. That's an important part of what it is that we do. The ongoing discussions between Alaska and Canada have been important...we need to make sure that with the new administration here in Juneau, that they are continuing to work those efforts.”
Thank you to the team at Amalga Distillery who served their specialty cocktails, including their new whiskey, Taku River Reds for the wild local salmon, and SALT for preparing delicious salmon appetizers for everyone. It was a momentous evening with so many wild salmon supporters and decision makers in the room. Thank you to all who attended.
A Salmon Soiree in Victoria, B.C.
In early March, Salmon Beyond Borders, SkeenaWild Conservation Trust, and WatershedWatch Salmon Society brought together a varied collection of salmon warriors to celebrate, collaborate, and inspire one another in light of the International Year of the Salmon. Salmon Beyond Borders is committed to co-hosting events like this one that highlight the important role salmon play on the coastline from B.C. stretching all the way up to Alaska, and ensuring that a diversity of committed individuals have a chance to get involved.
By partnering with our friends at SkeenaWild Conservation Trust and Watershed Watch Salmon Society, this event truly came together with a coastline perspective, representing the Skeena Watershed, Lower Mainland/Fraser Valley and Southeast Alaska. We gathered at the Fortune Gallery in Victoria’s Chinatown.
Minister Doug Donaldson (Forests Lands and Natural Resources), NDP Party, and MLA Adam Olsen (North Saanich and Gulf Islands) gave remarks at the beginning of the evening, as did IYS Director for the North Pacific Region, Mark Saunders. The keynote speaker of the evening, a Tahltan elder, provided some thoughtful insight and context for the transboundary rivers issue. Also in attendance was MLA Sonia Frusteau, Green Party (Cowichan Valley), and Minister George Chow (State for Trade), NDP Party (Vancouver-Fraserview) .
We appreciate the wonderful donations we received for this event: wild B.C. salmon provided by Trilogy Fish Co. in Tofino, B.C., prepared by Victoria’s own Songhess Catering. We also can’t forget to mention the locally-crafted gin by Sheringham Distillery as well as gin from Juneau, Alaska’s Amalga Distillery. We had a friendly competition, with no winner decided, because all ginwas so tasty!
The evening was filled with conversation and we trust new partnerships and exciting work will develop from it!
Wild Perspectives: A Celebration of the International Year of the Salmon
in St. Helena, California
In March, Salmon Beyond Borders co-hosted a special event in St. Helena, California with Odd Fellows Lodge #167 and Cameo Cinema: "Wild Perspectives: Celebrating the International Year of the Salmon." Over 150 artists, fishermen, decision makers, salmon consumers, activists, community leaders, and concerned citizens came together in gorgeous Saint Helena, CA, to learn more about, celebrate, and commit to protecting Alaska wild salmon.
Congressional Wild Salmon Caucus co-founder and Saint Helena native, Congressman Mike Thompson, gave remarks at the start of the event. We marveled at four incredible short films focused on the wild, rugged salmon watersheds of Bristol Bay and the Southeast Alaska/Northwest British Columbia transboundary region, were inspired by Amy Gulick's words and photos from her upcoming book, The Salmon Way: An Alaska State of Mind, and learned much from Alaska wild salmon fishermen and advocates. And, finally, we downed local wines and beers from Coho Wines, Terra Valentine Wines, and others, as well as devoured Patagonia Provisions wild salmon treats and delectable dishes prepared by Culinary Institute of America chefs with the highest quality Alaska wild salmon sourced from Gypsy Fish Company and Taku River Reds.
This event was a potent reminder that wild salmon are the ultimate connectors of us all along the western Pacific Ocean, from Alaska to California. We look forward to many more gatherings like this one in honor of 2019 as the International Year of the Salmon! When it comes to protecting Alaska wild salmon, we're all in this together!
SALMON BEYOND BORDERS is a campaign driven by sport and commercial fishermen, community leaders, tourism and recreation business owners and concerned citizens, in collaboration with Tribes and First Nations, united across the Alaska/British Columbia border to defend and sustain our transboundary rivers, jobs and way of life.
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