Learn more about University of Montana and the Flathead Lake Bio Station here! 

Learn more about Flathead Lake Bio Station and the University of Montana!  

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.

• Strongly Agree

 
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. )

• Projects that have impacts outside of B.C. jurisdiction

 
10. Please share with us why the project category(s) should be added to the RPR

• Click "The adverse impacts of these project category(s) are not being sufficiently considered by the existing permitting or regulatory frameworks"​

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

• Disagree 

 
*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.

• Agree

 
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

• Disagree

 
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.

• Strongly agree

 
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.

• The thresholds that apply to mining (production-based and impact-based) should be more stringent when there are downstream impacts to other jurisdictions. 

 
19. Do you have any feedback on the Effects thresholds outlined on page 21 of the Intentions paper
(https://www2.gov.bc.ca/assets/download/FDD409EE186245879E6190531713074D)
 
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.  

• Disagree.

 
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.

• Strongly Agree.

 
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?

• The RPR should require that all notifications are promptly posted online, require notification for any modifications of existing projects that would cause the project to exceed the threshold for a new project in that category.

 
23. Would you like to provide feedback on the Prescribed Protected Areas Appendix of the Reviewable Projects Regulation Intentions Paper? *

• Yes

 
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.

• Agree

 
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?

• Require project proponents adhere to the United Nations Declaration on the Rights of Indigenous Peoples and Free, Prior, and Informed Consent, including recognition of Indigenous protected areas. (And #26 reccs)

 
26. Do you have any feedback on the proposed Prescribed Protected Areas for inclusion in the regulation?

• Provide an ability for another jurisdiction (including Indigenous nations and local government, and governments of neighbouring states) to request that the Minister recommend to Cabinet that one or more thresholds in the RPR (for project design, impacts or notification) be lowered in a region impacting that jurisdiction, in order to account for cumulative impacts, a particularly sensitive area or important habitat, with a requirement for the Minister to issue a public response to that request.

 
27. Do you have any feedback on the protected or managed areas not proposed for inclusion?

• These all must be included, especially the Mineral Tenure Act, Great Bear Rainforest Act, Water Sustainability Act, and Wildlife Act.

 
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.
​
Why?
 
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.

Cheers, 
Sierra 

B.C. Organizer for Salmon Beyond Borders