FRPA Improvement Initiative: BCBHA Comment Guide

The Province of British Columbia recently launched the Forest and Range Practices Act (FRPA) Improvement Initiative. FRPA is a key piece of legislation in the province that governs the management of B.C.'s forests and grasslands and has direct implications on wildlife habitat, water quality, biodiversity and access management.

Speak Up! Public feedback will be collected by the provincial government until July 15, 2019 at 4:00 p.m. Participate by completing the online feedback form.

To help you respond, we have made it easier than ever, by publishing the click-to-send comment letter linked here.  Additionally, detailed BCBHA’s position on the FRPA improvement questions have been provided below in bold.

CLIMATE CHANGE AND RESILIENT LANDSCAPES

Read more in the Discussion Paper Page 7

How should the Province identify opportunities and priorities for adapting forest management to a changing climate, such as mitigating the effects of beetle infestations, drought and fire?

FRPA needs to be designed so landscape level plans identify and mitigate climate change impacts but also have built-in flexibility to allow for the adjustment of plans to protect sensitive ecosystems, wildlife habitat and biodiversity under uncertain expectations.

 

FRPA should have clear regulations to protect sensitive habitat and limit factors that increase fire risk including:

  • Selective logging and habitat improvement to reduce fuels.
  • Setting scientifically based limits on road and trail density. Close and reclaim trails to improve connectivity and habitat quality and to restore sensitive ecosystems.
  • Regulate recreation activity both in the front and backcountry to improve fish and wildlife habitat, restore sensitive ecosystems, and decrease fire risk (e.g. closing designated trails with increased fire risk)
  • Regulate forestry activity to protect sensitive habitats and reduce fire risk. Enforce harvest shut down in wet season and periods of increased fire risk.
  • Implement post-fire impact assessments so that harvest plans can be adjusted to reflect the impact of fire on the landscape. Harvest plans must be adjusted and allowable cut reduced to protect sensitive habitat and areas susceptible to erosion.

 What factors should be considered in the planning of forest operations to reduce the risks of wildfire around your community?

Improve community involvement with the formation of stakeholder advisory groups that meet regularly with government officials and industry to ensure the transfer of information and effective decision making.

LANDSCAPE-LEVEL PLANNING

Read more in the Discussion Paper page 8.

A vital step in landscape-level planning is understanding what is important to the public. Based on what is important to you or your community, what information on the condition of resource values such as species-at-risk habitat do you think is necessary to support the planning process?

I support the movement to landscape level management and want to see FRPA include measurable objectives for the management of cumulative effects on the landscape from industry, forestry, recreation and development. Measureable habitat objectives and compliance should be reported regularly to the public.

In addition, FRPA needs to provide regulation for both ecosystem level changes caused by resource extraction and development and the local impacts of recreation or development (e.g. trail proliferation and localized habitat degradation)

The public should be provided long-range landscape level plans and maps (e.g. 5 year, 20 year, 50 year projections) that detail the cumulative effects of development, industry, forestry, recreation, and climate change on the landscape so that the public may comment on plans in an informed manner.

How would you like to be involved in the planning process?

Create a collaborative, public planning process including the formation of stakeholder advisory groups that meet regularly with government officials and industry to ensure the transfer of information and effective decision making.

Resource roads are a valuable asset in the province as they provide access for the forest industry, ranchers, other resource users, and the public for commercial and recreation purposes. Yet, these same road networks are costly to maintain and have potential negative impacts on wildlife, water quality and fish habitat. What values do you believe are important to consider when planning new roads, road use and maintenance, and deactivation in your area?

Prioritize wildlife conservation and habitat values when planning road and trail networks. Access management plans should be developed that include clear and enforceable road and trail densities with thresholds based on the best available science for fish and wildlife protection. Road and trail density should be monitored and density reduced through deactivation and reclamation where necessary.

Deactivation plans need to be developed at the beginning of the planning process. Deactivation of logging and access roads should be incentivized to improve industry compliance.

Maintaining and increasing roadless areas should also be prioritized to improve habitat connectivity and the protection of sensitive ecosystems and critical wildlife habitat.

 

PUBLIC TRUST

Read more in the Discussion Paper page 9.

How can the Province improve transparency and timelines of information regarding proposed operational and landscape-level objectives, plans and results?

Create a collaborative, public planning process including the formation of stakeholder advisory groups that meet regularly with government officials and industry to ensure the transfer of information and effective decision making.

What information will help inform your feedback on plans that may impact you, your community or your business (e.g., maps of cutblocks and roads planned in your area, hydrological assessments, wildlife habitat areas or recreation opportunities, etc)?

The province should provide regular reports on plans and compliance that are easily accessible on-line. Reports should focus on data driven content that presents cumulative impacts on the landscape, impacts on fish and wildlife habitat, impacts on roadless areas.

Detailed maps depicting multi-year projections should be available as part of these reports. Maps should show planned harvest, cumulative effects, critical wildlife habitat and other sensitive ecosystems, and road/trail networks and density.

 

RESOURCE VALUES AND OBJECTIVES

Read more in the Discussion Paper page 10.

What additional values should be considered in FRPA that will allow us to manage forest and range practices in a better way?

Landscape level planning and cumulative effects management will require integration between FRPA and other legislation and ministries. Management of wildlife, habitat, access, trail density, roadless areas, water quality and biodiversity need to be incorporated into landscape level planning.

FRPA should require resource extraction and development to have net-positive impact on biodiversity, water quality and critical wildlife habitat.

In addition, tools need to be developed to allow FRPA regulations to be enforced outside the province to specifically address recreation infractions by non-residents.

 

OVERSIGHT AND ACCOUNTABILITY

Read more in the Discussion Paper page 11.

In what ways should the province strengthen government oversight and industry accountability regarding forest and range activities to better address the challenges of climate change and the interests of all British Columbians?

I believe that the provincial government should be responsible for overseeing forest and range practices and protecting our landscape in the public interest. Compliance and public engagement would be improved with FRPA revised to provide clear, enforceable legislation for landscape level management.

Importantly, landscape level planning and cumulative effects management will also require integration between FRPA and other legislation and ministries. Management of wildlife, habitat, access, trail density, roadless areas, water quality and biodiversity need to be incorporated into landscape level planning.

 

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