Guidelines for Evaluating, Avoiding and Mitigating Impacts of Major Development Projects on Wildlife in British Columbia

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initiatives with regional B.C. Ministry of Environment staff.

Guidelines for Evaluating,

Avoiding and Mitigating Impacts

of Major Development Projects

on Wildlife in British Columbia

By

W.L. Harper, RPBio,

J.M. Cooper, RPBio,

K. Simpson, RPBio,

J. Hamilton, MSc,

K.A. Dunham, MA,

and D.S. Eastman, RPBio

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I. INTRODUCTION

The report is divided into five major sections. The first section describes the purpose and applications of guidelines. The second part discusses the legislative, regulatory and approval framework that makes up the provincial environmental assessment process as it relates to wildlife. Next, sources of information on provincial wildlife are described. The fourth section generally summarizes potential impacts on wildlife arising from the seven broad types of major developments. The fifth section describes generic and species-specific approaches wildlife environmental assessment. The sixth and final section presents mitigation measures for selected groups of wildlife species.

In presenting information on environmental assessment approaches and guidelines for mitigation a coarse filter – fine filter approach was used. Environmental assessment approaches that are widely applicable for a variety of wildlife species are discussed in a generic section. More species-specific approaches are presented in separate sections on individual species or groups of species. Mitigation measures were developed in a similar way, beginning with a coarse filter approach that presents generic guidelines applicable to all wildlife and all project categories. At next level, potential mitigation strategies are discussed that are specific to a project category (e.g. hydroelectric development) but are widely applicable to most wildlife species. The lowest level presents wildlife mitigation strategies that are specific to both the project category and wildlife species. Whenever appropriate, environmental assessment approaches and potential mitigation strategies are lumped together with other species or types of projects to minimize the number of separate guidelines.

The report addresses terrestrial animals (birds, mammals, reptiles, and amphibians), their habitats, as well as plants and plant communities considered at risk in British Columbia. In order to remain consistent with the jurisdictional responsibilities of the BC Wildlife Program, marine mammals (i.e. whales and seals), and fish are not addressed in this report. Grizzly Bear and Black Bear are also not addressed in this report, but are the subject of separate and similar report – British Columbia Environmental Assessment Guidelines for Grizzly Bears and Black Bears (MacHutchon 2001).

Most of the species discussed in this report are Red- or Blue-listed (i.e. threatened, endangered or vulnerable) while others are regionally significant or have characteristics that make them especially vulnerable to major developments. These guidelines are comparable to guidelines for other industries in British Columbia, such as the Identified Wildlife Management Strategy for the forest industry (Province of BC 1997, 1999), or the Guidelines for Mitigating the Impact of Commercial Backcountry Recreation (Harper and Eastman 2000, MELP 2000).

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A. PURPOSE OF DEVELOPING TECHNICAL

GUIDELINES

The purpose of the guidelines is to provide proponents with information, in a number of Ministry program areas, on how to conduct environmental assessments of projects reviewed under the BC Environmental Assessment Act (BCEAA). These guidelines can also be utilized in non-BCEAA projects with associated potential wildlife impacts. One of the key objectives of these guidelines is to provide potential project proponents with an early indication of any wildlife/wildlife habitat information requirements in the preparation of a project application.

The intent of providing guidelines is to:

• Guide proponents with potential EA projects in the development of project approval applications and project reports;

• Assist in providing provincial consistency and continuity in the ministry’s data and information requirements;

• Ensure that the requirements under the BC Environmental Assessment Act and ministry wildlife objectives are met;

• Support ministerial decision making on EA project reviews; and

• Reduce ministry staff time allocation in EA reviews.

B. CONTENT OF TECHNICAL GUIDELINES

In general the MELP EA guidelines will address:

• Information on relevant legislation, policy, and permitting requirements.

• Information requirements for baseline monitoring and methodologies for data collection and reporting.

• Identification of potential impacts.

• Identification of mitigation options.

• Reference documents.

C. APPLICATION OF GUIDELINES

The guidelines are approved by the Ministry Executive. They are intended to be flexible so that MELP staff may consider alternatives relevant to a specific project that is still consistent with the intent of the guidelines. It is also expected that as new scientific information and experience is gained that the guidelines will be modified to reflect this new information.

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II. LEGISLATIVE FRAMEWORK

A. THE BCEAA PROCESS

The BCEAA became law on June 30, 1995. It built on many years of experience with review processes that the Ministry participated in for energy, mines, and other major project proposals. The purpose of the Act is to:

1. Promote sustainability by protecting the environment and fostering a sound economy and social well-being.

2. To provide for the thorough, timely, and integrated assessment of environmental, social, cultural, heritage, and health effects of reviewable projects.

3. To prevent or mitigate adverse effects of reviewable projects.

4. To provide for an open, accountable, and neutrally administered process for the assessment.

The Act contains a considerable amount of detail on how the EA process must be carried out. Requirements are described for:

• The types and sizes of projects that must go through the review process.

• The stages of a review.

• Information that must be provided.

• Who must be involved and the methods for involvement.

• Time limits for completing certain activities.

The Environmental Assessment Office (EAO) is a neutral agency that administers

BCEAA. The EAO is not part of the Ministry of Environment, Lands and Parks. The

Guide to the British Columbia Environmental Assessment Review Process (“the Guide”), available from the Environmental Assessment Office or online a provides a complete description of the Act and the process, along with copies of the legislation and regulations.

There are also numerous other review processes for projects that are not reviewed under

BCEAA, through permitting, referrals, licencing and approvals. These other processes also require assessments, to varying degrees, and public and First Nations consultation. These guidelines may be applied in these other review processes to projects that have a potential for wildlife/wildlife habitat impacts.

A short description of the key features of the Act and the relationship to Ministry guidelines follows.

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1. PROJECT REVIEW THRESHOLDS

The Reviewable Projects Regulation lists the types and sizes of projects that must go through the EA review process. The regulation covers major new projects as well as major expansions or modifications of existing projects.

Whether a project is ‘reviewable’ or not is at times difficult to determine, as there are a number of interpretations of the regulation and associated legislation required to make a final determination. Usually the proponent approaches the EAO for a determination, or a government agency (local, provincial or federal) may be contacted and they may make the inquiry.

The EAO contacts MELP and the responsible ministry (e.g. Energy & Mines) to discuss and verify any interpretation of that agency’s legislation. For example, definitions (e.g. of a ‘stream’ under the Water Act) are often in pieces of legislation that are not the EA Act. Or industries may fall under an SIC code that is not clearly in or out of review until it’s investigated (e.g. a gelatin plant).

In some cases, the EAO seeks legal counsel on an interpretation. Once an interpretation is made, a letter goes out indicating the section of the regulation and interpretation on reviewability.

There is also a provision in Section 4 of the Act for the Minister of Environment, Lands and Parks to designate any other project as reviewable under the Act if there is expected to be significant adverse impact and it is in the public interest. Any person or agency can request a project be included in a Section 4 designation, although this section is little used. To date, there have been 18 requests to consider using Section 4 to designate a project for review under the Act. All but two of these requests were denied – Bamberton town development and addition of a fourth lane on Lions Gate Bridge (project did not proceed). The review, once designated, proceeds in the same staged fashion as all other reviewable projects.

The limited use of Section 4 reflects the government’s commitment to use the power sparingly, to avoid undermining the certainty provided by the Reviewable Projects Regulation. Under current government policy, Section 4 designation is interpreted as being in the public interest only where there are significant impact concerns that fall outside the scope of the existing regulatory regime.

Section 40 of the Act also allows for reviews of a category of projects. There has been only one review under this section to date, the Salmon Aquaculture Review.

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2. STAGES OF PROJECT REVIEW

The most fundamental characteristic of the BC process, similar to EA processes in many other jurisdictions, is a staged sequence. The process moves from an application stage (stage 1), and may move to a project report (stage 2). The Act also provides for a third stage, a public hearing, although this stage has never been invoked. Not all stages are necessarily required; a project decision can be made at the end of any of these stages.

a) PRE-APPLICATION

The original intent of the Act was that most projects would go to the second stage of review to address issues in more detail than the application would contain. Experience with the Act has resulted in more project proponents undertaking intensive

pre-application studies and consultation to attempt to complete their review in the pre-application stage. Ministry advice on studies to undertake, methods to use, and processes to follow is frequently sought at this juncture, although there is no formal process in the Act for pre-application work. The intent of the guidelines is to assist potential project proponents in an early identification of information requirements for the preparation of a project application.

b) APPLICATION REVIEW

The formal review of the application requires that a project committee be struck which may include federal, provincial, local, regional and First Nations government

representatives. The proponent’s program of consultation is assessed for whether it is adequate. A public review period is set where comments can be submitted, and project committee agencies (including First Nations) provide detailed comments on the

application. Ministry staff’s reviewing the application refers to guidelines and previous practices on EA reviews to assist them in providing their comments on the application. The proponent either addresses the comments to the satisfaction of the project committee, with subsequent approval by two Ministers (Environment, Lands and Parks and a

‘responsible’ minister) or is sent the next stage of review or the project is rejected.

c) PROJECT REPORT SPECIFICATIONS

If the project proceeds to Stage 2, the project committee (including First Nations) provides legally binding requirements for additional information or commitments by the proponent (‘project report specifications’) that address the deficiencies noted in the project application. The guidelines should assist MELP staff in developing project report specifications for additional information requirements and/or commitments for mitigation measures and monitoring requirements. The public and the project committee review these specifications in draft form before they are finalized. The proponent then completes the remaining studies and prepares a project report.

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d) PROJECT REPORT

The project committee (including First Nations) reviews the proponents project report based on the requirements of the project report specifications. Once the project report is screened and accepted for review, it is reviewed by the Project Committee for its

adequacy in meeting the requirements of the project report specifications, and whether it resolves the issues to the satisfaction of the relevant agency on the Project Committee.

e) PUBLIC HEARING

If there remain significant outstanding issues, a public hearing may be called. The detailed process for hearings is outlined in the Act but has not been used to date.

3. TIMELINES

BCEAA sets legislated timelines for each step of the review. It places limits on the length of time to establish a project committee, and how long the project committee has to consider the project before a recommendation is to be made. It also sets the length of public comment periods. The minimum and maximum time limits for each legislated stage for project committee review and decision-making (note: proponents do not have time limits) are as follows:

Stage 1: 3.5 – 5.5 months

Stage 2: Project Report Specifications: 1.5 to 2.5 months Project Report Review: 6 to 8 months

Stage 3: 6 to 12 months

4. CONSULTATION

BCEAA sets out requirements for the information distribution or consultation by the proponent, for preparation of the application.

5. LINKS TO OTHER PROCESSES

The EA review is at a strategic level, that is, the emphasis is always on what is really a significant issue, i.e. identifying and determining if impacts have been addressed and/or are mitigable. Significant is taken to mean that:

• There are no other processes for approval that could provide suitable assessment of this issue (e.g. post-certification approvals do not exist).

• There are concerns from other levels of government or multi-agency concerns about this issue.

• The issue reflects a high degree of public concern.

Detailed project design and plans are dealt with, on the whole, during the permitting process and are not addressed during the EA project review. BCEAA projects are reviewed on a conceptual level, not the detailed level of review normally expected in

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permitting, the exception being where concurrent permitting is requested in the EA review. The existing policy and land use plan regime, such as LRMPs, guide the EA review.

B. FEDERAL LEGISLATION

1. CEAA REVIEW

The purposes of this federal Act are:

• To ensure that the environmental effects of projects receive careful consideration before responsible authorities take actions in connection with them;

• To encourage responsible authorities to take actions that promote sustainable development and thereby achieve or maintain a healthy environment and a healthy economy;

• To ensure that responsible authorities carry out their responsibilities in a coordinated manner with a view to eliminating unnecessary duplication in the environmental assessment process;

• To ensure that projects that are to be carried out on federal lands do not cause significant adverse environmental effects outside the jurisdictions in which the projects are carried out; and

• To ensure that there be an opportunity for public participation in the environmental assessment process.

The Canadian process is also a staged review process. A CEAA review is triggered when the federal government is a proponent, or for other projects where there is a regulatory approval required from the federal government (Law List), federal financial support or federal interest in the land where the project is situated. There are some projects that require a review under CEAA because they are listed under a regulation (Comprehensive Study List) that requires a major assessment, called a comprehensive study. A mediation or a review panel can also be invoked.

Most assessments are done at what is called a screening level. Every level of assessment (screening, comprehensive study, mediation or review panel) requires that effects be assessed, including cumulative effects, potential accidents and malfunctions, and alternatives to the project. The definition of effects to be assessed includes socio-economic conditions, physical and cultural heritage, the current use of lands and

resources for traditional purposes by aboriginal persons, or effects on any structure, site or thing that is of historical, archaeological, paleontological or architectural significance. The federal and BC government have a Harmonization Agreement, to coordinate their reviews where both at BCEAA review and a CEAA review are triggered. In that case, the BC review process is used, which is designed to meet both federal and provincial

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requirements. The federal government, in these cases, delegates its EA process

responsibilities, but not its decision-making. What this means is that the approval by the federal ‘responsible’ minister is still required in addition to the two provincial ministers approval under BCEAA.

Further information on the CEAA is available from the Canadian Environmental

Assessment Offi

2. PROPOSED SPECIES AT RISK ACT (SARA)

In October 1996, wildlife ministers from across the country agreed in principle to the Accord for the Protection of Species at Risk. This Accord, of which British Columbia is signatory, outlines commitments on behalf of provincial, territorial and federal

governments, to designate species at risk, protect their habitats and develop recovery plans. The federal Minister of Environment reintroduced the Species at Risk Act (SARA) to the House of Commons on February 2, 2001. SARA fulfills part of the Government of Canada's responsibility under the Accord. The proposed Species at Risk Act covers nationally listed endangered and threatened species, and species of special concern, as determined by the Committee on the Status of Endangered Wildlife in Canada

(COSEWI

SARA will prohibit the killing, harming, harassing, capturing or taking of species officially listed as threatened, endangered or extirpated, and the destruction of their residences. There will also be a mandatory requirement for developing recovery plans for endangered or threatened species, and management plans for species of special concern. The two-part recovery plan consists of 1) a recovery strategy (goals and objectives), and 2) one or more actions plans to designed to achieve recovery objectives. Among other things, recovery strategies and action plans will identify the critical habitat of threatened or endangered species that needs protection.

There are already a number of recovery activities under way in Canada under the

Recovery of Nationally Endangered Wildlife (RENEW) program launched in 1988, and these will be incorporated into the SARA recovery process. RENEW initiatives active in British Columbia in 2001 include recovery planning for the Vancouver Island Marmot, Wood Bison, Burrowing Owl, Marbled Murrelet, Northern Spotted Owl, Peregrine Falcon, Northern Leopard Frog, Oregon Spotted Frog, and the South Okanagan Ecosystem.

Under SARA, conservation actions by landowners and land users to protect critical habitat of species at risk will be encouraged and funded through the Habitat Stewardship Program. Under this program, non-federal agencies, organizations, businesses,

communities or individuals are eligible to receive funding. Activities that are eligible for funding under the program focus on stewardship initiatives for the recovery of species at

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risk and the prevention of biodiversity loss on private lands, provincial crown lands, Aboriginal lands and in aquatic and marine areas.

When not protected by the provinces or territories, the federal Minister will have the authority to recommend to the Governor-in-Council an order to prohibit the destruction of any designated critical habitat of a threatened or endangered species on non-federal land. SARA will enable compensation to be paid to individuals, organizations, Aboriginal peoples, or businesses for losses suffered as a result of any extraordinary or unfair impact when it is necessary to prohibit destruction of critical habitat. A public registry,

maintained by the Canadian Wildlife Service, will be established under SARA as the

main source of information related to the proposed Act

C. MELP and BCEAA

MELP is a key agency on the project committee. The term ‘key’ is used to indicate that sign-off on the recommendations is informally considered to be a necessary condition of approval, although this isn’t specified in the Act.

The Ministry’s active participation is recognized as needed to:

• Bring valuable environmental information to the table.

• Ensure that the ministry’s mandate is fulfilled in the development of a major project.

• Achieve the ministry’s goals and objectives.

MELP’s EA unit provides Ministry representation (‘the project review manager’) on project committees. There is only one ‘active’ member for the Ministry on the project committee (this is similar to several other ministry’s approach) - and this member coordinates and presents all ministry input to the project committee. The Ministry typically also provides a number of technical advisors on each EA review. Members of the technical review team have duties ranging from reviewing or coordinating technical reviews of the application and project report to attending public meetings and project committee meetings.

1. COORDINATION WITH FEDERAL AGENCIES

Federal agencies, when there is a CEAA trigger, may provide similar comments to

provincial agencies on the same matters. Generally, there is a good degree of cooperation between provincial and federal departments in presenting comments and how the

common issues should be resolved. Ministry guidelines are useful in discussions with federal agencies, as the guidelines provide a basis for resolving common issues about study methodologies and mitigation measures.

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2. PROJECT APPROVAL CERTIFICATE CONDITIONS AND

COMPLIANCE REVIEW

A Project Approval Certificate is subject to specific measures or steps outlined in the conditions of the certificate, which are legally binding. Proponents must abide by the certificate conditions in order to maintain the certificate. Conditions may relate to preconstruction activities, construction, operation, modification, dismantling or abandonment of the facilities constructed. The mitigation measures outlined in these guidelines should assist the ministry in determining appropriate conditions for the Project Approval Certificate for different project types.

During the final stages of the BCEAA review, a Compliance Review Tracking Document is prepared under the auspices of the EAO. This document lists all certificate conditions and those proponent commitments identified in the recommendations report and other correspondence agreed upon by relevant government agencies and the proponent. The conditions listed in the tracking document will be those which the EAO will require verification of compliance.

MELP will undertake a compliance review of certificate conditions and proponent commitments which fall under the ministry’s mandate and which have been agreed upon at the certification stage. The scope of compliance review will be contingent on the ministry’s environmental risk assessment of the project. Compliance review activities will be initiated upon project start-up and continue until the ministry is satisfied that all conditions are considered to have been met. The ministry’s compliance information will be utilized by the EAO in the conduct of their EA compliance review, which will

typically be initiated at the completion of construction.

3. PERMITTING

Reviewable projects must obtain both EA approval (Project Approval Certificate) as well as any necessary statutory approvals, permits and licenses from individual regulatory agencies. During the EA review, the EAO’s responsibility is to ensure that information and consultation requirements for necessary permit approvals are identified during the EA review, to the greatest extent possible. Key information on required permits is prepared during the EA review and regulatory agencies are expected to provide permitting information within the EA process.

No statutory approvals, permits and licenses can be issued until the issuance of the Project Approval Certificate. Statutory approvals, permits and licenses are not subject to the EA compliance review and are the responsibility of the individual regulatory agency to track.

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Separate consultation is required for the EA review process and for permit issuance. However, for concurrent reviews, the public may be notified of applications through advertisements or other notification measures that are a routine part of the regulatory procedures for processing specific permits.

There may be an overlap between the conditions in the PAC and the conditions within the statutory approvals, permits and licenses.

4. CONCURRENT REVIEWS

Proponents have the option to request that the EA review be conducted concurrently with the review of applications for other statutory approvals, i.e. water licenses. BCEAA

establishes a specific process for concurrent reviews. Optional concurrent reviews can result in timelier permit issuance where the proponent’s plans are sufficiently well

developed. However, proponents are encouraged to contact permitting agencies to clarify information requirements and the level of detailed required before requesting a concurrent review.

A request for concurrent reviews can be made anytime after the acceptance of an application for review but no later than the date of submission of the project report. Requests for concurrent reviews and the supporting documentation are placed on the EAO Project Registry. Within 70 days after the conclusion of the project report review period (or earlier if the concurrent review is completed) the regulatory authorities must inform the project committee and the proponent that, following certification, the specific permits requested:

• Will be issued within 30 days of certification;

• Will be refused; or

• The decision will be postponed with written reasons for the postponement. An indication of when a decision will be forthcoming will be provided.

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III. PROVINCIAL LEGISLATION

The purpose of this section is to discuss the various provincial environmental statutes administered by or in part by MELP that are directly relevant to the assessment of project impacts on terrestrial wildlife and its habitat. Relevant environmental statutes are

discussed and a list of regulatory permits, licenses and approvals issued by MELP under those enactments follows.

Readers requiring additional information should refer to the appropriate statute in full text for complete requirements under that statute.

A. BC WILDLIFE ACT

The primary legislation directly affecting species protection in the province is the BC

Wildlife Act R.S. 1996, c.488. The Act guides the management of wildlife in British Columbia to maintain the diversity and abundance of native species and habitats

throughout the province, to provide a variety of opportunities for the use and enjoyment of wildlife, and to reach a balance between meeting the needs of wildlife and the needs of people. The Act vests ownership of all wildlife in the province with the provincial

Crown.

The Wildlife Act grants the Minister of Environment, Land and Parks broad powers to manage and protect wildlife, including the power to:

• Designate land as a wildlife management area (WMA), pursuant to sec. 4;

• Designate land in a WMA as a critical wildlife area if required as habitat for an endangered or threatened species, pursuant to sec. 5;

• Designate species as endangered or threatened, pursuant to sec. 6; and

• Bring an action for damages against a person who destroys or damages wildlife habitat, pursuant to sec. 8.

Wildlife species are protected under the Wildlife Act primarily through the enforcement of offences including:

• Damaging wildlife habitat in a WMA, pursuant to sec. 7;

• Damaging beaver or muskrat houses, dens or dams, pursuant to sec. 9;

• Hunting, killing or wounding a threatened or endangered species, pursuant to sec. 26(1); and

• Possessing, taking, injuring, molesting or destroying a bird or its nest, pursuant to sec. 34.

The Act establishes procedures for issuing licences for hunting, firearm possession and angling within the province. Certain provisions place limits on how hunting, trapping,

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guiding and angling can be conducted (e.g., sec. 30). The Act provides the Lieutenant Governor in Council (Cabinet) the authority to make regulations to limit hunting for any particular wildlife species.

The Wildlife Act Permit Regulation provides for the exercise of specific activities under the Wildlife Act, or an exemption from the requirement to comply with certain

regulations. Two basic types of permits may be granted – an authorization permit and an exemption permit. Examples of activities requiring authorization under these permits are noted in Table 1. The appropriate regional office normally issues permits. Most permits apply for limited periods of time, usually not more than five years.

Table 1. Examples of activities requiring authorization under permits issued under the Wildlife Act Permit Regulation1

An authorization permit is required to engage in any of the following selected activities.

An exemption permit is required to engage in any of the following selected activities.

• Capturing, possessing or importing live wildlife

• Possessing dead wildlife or wildlife parts

• Transporting or exporting wildlife or parts

• Rehabilitating injured wildlife

• Trapping, hunting or killing wildlife for any of the following reasons: population control, scientific research, crop

protection, public safety, or ceremonial, educational or humane purposes

• Hunting big game with a non-resident of British Columbia

• Possessing or distributing game meat for sustenance

• Destroying particular types of bird nests or eggs

• Destroying beaver dams or muskrat dens

• Discharging firearms in a no-shooting or restricted area, from a vehicle or

powerboat

• Operating a vehicle in an area that is closed under the Wildlife Act

The Wildlife Branch of the Ministry of Environment, Lands and Parks prepares lists of endangered, vulnerable and management species – respectively, the Red, Blue and Yellow Lists – to help prioritize conservation activities and assist in wildlife

management. The British Columbia Conservation Data Centre (CDC) of the Resource Inventory Branch tracks the global and provincial rarity ranks (respectively, the status of the species throughout its entire range and the species’ status in British Columbia), and provincial list status (i.e., Red List, Blue List, Yellow List) of wildlife species. The CDC also tracks vascular plant species, selected non-vascular plant groups, plant communities,

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invertebrates and fish, which are included as required on Red and Blue Lists of endangered and vulnerable species.

When the Wildlife Branch adds wildlife species to the Red List, it becomes a candidate for legal designation as an endangered species under sec. 6 of the Wildlife Act. Only four species are designated currently under the provincial Act – the Vancouver Island Marmot, the Sea Otter, the Burrowing Owl and the American White Pelican2

B. BC PARK ACT

. These species were all designated in 1980. The other provincial enactment with application to endangered species, though to a limited extent, is the Forest Practices Code of British Columbia Act.

Terrestrial plant species are not included in the definition of ‘species’ used in the Wildlife Act, and therefore are not protected under the Act. Also, terrestrial plant species cannot be designated as endangered or threatened under the Act (sec. 6). Recently, the provincial government was provided the power to designate fish, aquatic invertebrates and aquatic plants as endangered and threatened species pursuant to the BC Fish Protection Act.

The Wildlife Branch of MELP has a limited mandate over the land base upon which wildlife resources depend. For example, MELP has direct jurisdiction over wildlife habitat only: on land acquired by MELP for wildlife protection under sec. 3 of the

Wildlife Act (often with other agencies such as the federal Canadian Wildlife Service, a municipality or a non-governmental organization); wildlife management areas designated under sec. 4 of the Wildlife Act; or in ecological reserves designated under sec. 2 and 3 of the BC Ecological Reserve Act. Protection of critical wildlife habitat under sec. 5(1) of the Wildlife Act has been established only once, for the Vancouver Island marmot. Most of the wildlife habitat in the province is administered by other government agencies such as the Ministry of Forests.

MELP administers a number of programs and initiatives within the province that include some form of wildlife or wildlife habitat protection relevant to the purpose of these guidelines. The Protected Areas Strategy is MELP’s primary tool for conserving wildlife habitat. One of the Strategy’s goals is to preserve a target amount of 12 per cent of the area of each of British Columbia’s 14 biogeoclimatic zones.

The Park Act R.S. 1996, c.344 is the primary legal mechanism used by the provincial government to establish protected areas. However, typically parks are neither chosen on the basis of their importance as habitat for species at risk, nor are protection of habitat the primary management consideration in many provincial parks.

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The Committee on the Status of Endangered Wildlife in Canada (COSEWIC) lists nationally endangered species, including species that occur in British Columbia such as the Spotted Owl, the Anatum Peregrine Falcon and the Leatherback Turtle.

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The Park Act is subject to the BCEAA, but most projects or actions occurring in provincial parks will not meet the criteria that define renewable projects under that act.

C. BC ECOLOGICAL RESERVE ACT

Protected areas can be legally designed in British Columbia under the Ecological Reserve Act R.S. 1996, c. 103. Reserves are found in all of the province’s 14 biogeoclimatic zones. Terrestrial wildlife protected in reserves includes seabird colonies, eagles, falcons and sandhill cranes. Reserves have been established for important and threatened plant and tree species such as wildflower stands, stands of Douglas fir, Ponderosa pine, Engelmann spruce, Garry oaks and Arbutus.

The Ecological Reserve Act is subject to the BCEAA, but most projects or actions

occurring in provincial ecological reserves will not meet the criteria that define renewable projects under that act.

BC Environment does not issue regulatory permits, licences or approvals under this act.

D. BC FISH PROTECTION ACT

The Fish Protection Act S.B.C. 1997, c.21 focuses on four major objectives: ensuring sufficient water for fish; protecting and restoring fish habitat; improving riparian protection and enhancement; and providing for stronger local government decision-making in environmental planning. A key provision of the Act includes the prohibition on new dams on specific provincially significant rivers (defined in the Act as ‘protected rivers’) (sec. 4). Also, the Act prohibits the introduction of debris (defined as (a) clay, silt, sand rock or similar material, or (b) any material, natural or otherwise, from construction or demolition) that causes harm to fish or fish habitat, or the diversion and use of water or the operation of works authorized under the BC Water Act.

The Fish Protection Act provides the provincial government the power to designate fish, aquatic invertebrates and aquatic plants as endangered and threatened species.

The new Streamside Protection Regulation under the Act incorporates consideration of potential impacts on fish and fish habitat in water allocation decisions or approvals for changes in or about a stream (Part 7, Water Regulation of the Water Act). The regulation applies only to new or redeveloped industrial, commercial and residential developments that take place beside urban streams that have the potential for fish habitat. It does not apply to agriculture, mining, hydroelectric facilities or forestry activities. The initiative provides a pro-active, planning approach providing preventive measures before impacts to fish and fish habitat occur. The legislation compliments the federal Fisheries Act,

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under which the Department of Fisheries and Oceans can prosecute only after fish habitat has been damaged. The regulation compliments and strengthens existing legislation to ensure adequate protection of water quality and production of natural riparian areas for wildlife habitat.

MELP does not issue regulatory permits, licences or approvals under this act.

E. FOREST PRACTICES CODE

The Forest Practices Code of British Columbia R.S. 1996, c.158 (Code) was brought into effect to improve forest practices in B.C, including the prevention of detrimental

environmental impacts from logging. It contains some provisions addressing provincial endangered species, wildlife and biodiversity. For example, provisions enable wildlife habitat areas to be established for Identified Wildlife (defined in the Code as species or plant communities requiring special forest practices to be applied where forest activities are planned). Other mechanisms to manage Identified Wildlife under the Code are general wildlife measures and higher level plan recommendations.

The Identified Wildlife Management Strategy is a component of the Code. Its goal is to preserve elements of biodiversity that are not addressed in other parts of the Code such as threatened and endangered species and plant communities. The Operational Planning Regulations under the Code use the provincial Red and Blue Lists in the development of the Identified Wildlife Species List. The strategy details the procedures and management practices that are mandatory for Identified Wildlife under the Code. Compliance to the strategy is the responsibility of the Conservation Officers of MELP and the Compliance and Enforcement Branch of the Ministry of Forests.

In general, the Code is limited in scope in addressing wildlife and wildlife habitat in several ways. Firstly, it applies only to Crown land. Secondly, it related only to forestry activities. Potential impacts to wildlife or wildlife diversity from activities unrelated to forestry, including hydroelectricity, urban development, and agriculture are not covered under the Code. Thirdly, provisions implemented under the Code are subject to an overall ceiling of 6 per cent impact on the current rate of cut. In addition, there are impact

ceilings for specific provisions. For example, 1 per cent (of the 6 per cent) is allocated for Identified Wildlife provisions.

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F. PERMITS, LICENCES AND APPROVALS

NORMALLY REQUIRED

The following list identifies the regulatory permits, licences and approvals issued by MELP under the Wildlife Act, the Park Act and the Ecological Reserves Act that are normally required for reviewable projects. The statutory requirements included in the list are applicable directly or indirectly to terrestrial wildlife and/or wildlife habitat. Each requirement may be applicable to any category of reviewable project – industrial, mine, energy, water management, waste disposal, aquaculture and food processing,

transportation, tourism and recreation – depending on the characteristics of the specific project. The type of authorization required (permit, licence or approval), effecting provision, agency responsible for issuing the authorization, description of permit, and information requirements are identified.

The list is not inclusive for all projects. For example, non-statutory impact mitigation / compensation requirements and referrals are not included.

1. AUTHORIZATIONS PURSUANT TO THE WILDLIFE ACT

a. Alter or Damage a Wildlife Management Area

Permit Title: Permit to Alter or Damage a Wildlife Management Area Statutory Reference: s. 7 of the Wildlife Act

Issuing Agency: Habitat Protection Section, Regional Office, MELP

Description of Permit and Information Requirements: The regional manager may issue a permit to authorize a person to alter, destroy or damage habitat or deposit a substance, manufactured product or by-product on land or in water, that is deleterious to wildlife or wildlife habitat in a wildlife management area. Permits may include special conditions. An application for a permit can be filed usually at the regional office – Fish, Wildlife and Habitat Protection, or MELP Victoria office, if applicable.

b. Disturb a Muskrat or Beaver House, Den or Dam

Permit Title: Exemption Permit to Disturb a Muskrat or Beaver House, Den or Dam

Statutory Reference: s. 9 of the Wildlife Act and Wildlife Act Permit Regulation Issuing Agency: Habitat Protection Section, Regional Office, MELP

Description of Permit and Information Requirements: The regional manager may issue a permit to authorize a person to disturb, molest or destroy (i) a muskrat house or den, except on diked land, or (ii) a beaver house or den or beaver dam, except if the action is

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taken to provide irrigation or drainage for the protection of property. Permits may include special conditions.

An application for a permit can be filed usually at the regional office – Fish, Wildlife and Habitat Protection, or MELP Victoria office, if applicable. The regional office may be able to provide guidance with regard to contacting registered trappers to undertake

relocation or removal of muskrats or beavers, and the associated process requirements (an authorization permit issued under the Wildlife Act Permit Regulation to capture and transport wildlife may be required).

c. Possess or Import Live Wildlife or Eggs

Permit Title: Authorization Permit to Possess or Import Live Wildlife or Eggs Statutory Reference: s. 21(1), Wildlife Act and Wildlife Act Permit Regulation

Issuing Agency: Habitat Protection Section, Regional Office, MELP

Description of Permit and Information Requirements: The regional manager may issue a permit to authorize a person to possess or import into British Columbia live wildlife or the egg of a wildlife species.

An application for a permit can be filed usually at the regional office – Fish, Wildlife and Habitat Protection, or MELP Victoria office, if applicable. Conditions of this permit may be included in the Project Certificate issued under the Environmental Assessment Act.

Example of activities requiring an authorization permit for the purpose of possessing or importing live wildlife are the use (i.e., pack animals) or display (i.e., petting zoo) of animals for recreational activities at a resort.

d. Capture Live Wildlife

Permit Title: Authorization Permit to Capture Live Wildlife

Statutory Reference: sec. 29, Wildlife Act and Wildlife Act Permit Regulation Issuing Agency: Habitat Protection Section, Regional Office, MELP

Description of Permit and Information Requirements: The regional manager may issue a permit with whatever conditions, may authorize a person to capture live wildlife (sec. 29,

Wildlife Act), or hunt, trap or kill wildlife during the open or closed season for scientific purposes (Wildlife Act Permit Regulation).

An application for a permit can be filed usually at the regional office – Fish, Wildlife and Habitat Protection, or MELP Victoria office, if applicable. Conditions of this permit may be included in the Project Certificate issued under the BCEAA.

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Examples of activities requiring a Capture Permit are capturing of a specific species for radio-telemetry studies or removal.

e. Disturb a Bird or its Nest

Permit Title: An Exemption Permit to Disturb a Bird or its Nest

Statutory Reference: s. 34 of the Wildlife Act and Wildlife Act Permit Regulation Issuing Agency: Habitat Protection Section, Regional Office, MELP

Description of Permit and Information Requirements: The regional manager may issue a permit to authorize a person to possess, take, injure, molest or destroy (a) a bird or its nest, (b) the nest of an eagle, peregrine falcon, gyrfalcon, osprey, heron or burrowing owl, or (3) the nest of a bird not referred to in paragraph (b) when the nest is occupied by a bird or its egg. Permits may include special conditions.

An application for a permit can be filed usually at the regional office – Fish, Wildlife and Habitat Protection, or MELP Victoria office, if applicable.

2. AUTHORIZATIONS PURSUANT TO THE PARK ACT

a. Park Use / Resource Use

Permit Title: Park Use Permit / Resource Use Licence Statutory Reference: s. 20(1), Park Act

Issuing Agency: Parks [and Ecological Reserves] District Office, MELP Description of Permit and Information Requirements: The Minister of Environment, Lands and Parks may issue a park use permit or a resource use licence authorizing, on the terms and conditions specified, a person or persons to do any one or more things for which, under the Act, a permit or licence is required.

The person to whom the permit is issued must make a written application. The

application must be accompanied by an undertaking in writing, executed by the person to whom the permit is issued, to pay to the government certain costs and permit fees. A restoration deposit may also be required.

Activities requiring a Park Use Permit are any that use, occupy, or cause development, exploitation or extraction of a natural resource on or in a park. Activities requiring a Resource Use Licence are any that occupy, use, or cause development, exploitation or extraction of a natural resource on or in a recreation area.

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IV. SOURCES FOR INFORMATION ON

TERRESTRIAL RESOURCES

This section describes sources for information on provincial wildlife and their habitats. The Ministry of Environment, Lands and Parks will make its wildlife inventory and habitat information available to applicants for their use in preparing applications and management plans. However, some information on especially sensitive species at risk may only be released on a need-to-know basis under specific circumstances (e.g. nest sites of Peregrine Falcons). Other provincial ministries, agencies or ministries of the Government of Canada, universities, non-governmental conservation organizations, or private individuals may also be sources of important information.

A. RARE AND ENDANGERED SPECIES AND PLANT

COMMUNITIES

General information on the distribution, status, biology and conservation needs of rare and endangered wildlife resources (Red- and Blue-listed species) are available from a large variety of sources. A good starting point is Rare Amphibians, Reptiles and Mammals of British Columbia (Cannings et al. 1999), Rare Birds of British Columbia

(Fraser et al. 1999), Rare Vascular Plants of British Columbia (Douglas et al. 1998), and

Biodiversity in British Columbia (Harding and McCullum 1994).

For more specific information, the British Columbia Conservation Data Centre (CDC) provides a centralized data source on the location of Red- and Blue-listed animal and plant species, and plant communities. The CDC has collected information from museums, herbaria, universities, published and unpublished reports, theses, scientists, natural history groups, and the ongoing work of its own staff and contractors. Location and status

information of rare and endangered species and plant communities is available to anyone making a written request. In most cases this information can be made available within one week. The CDC can be contacted as follows:

Mail: BC Conservation Data Centre Resources Inventory Branch

Min. of Environment, Lands and Parks PO Box 9344, Stn Prov Gov’t

VICTORIA BC V8W 9M1

By Location/Courier:

Second Floor, 2975 Jutland Road VICTORIA BC V8T 5J9

By Phone/Computer:

Tel: (250) 356-0928 – toll free through Enquiry BC Fax: (250) 387-2733

Email: Website:

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B. SPECIES OF MANAGEMENT CONCERN

General information on wildlife in British Columbia is available through a number handbooks and texts published by the Royal British Columbia Museum, including The Amphibians of British Columbia (Green and Campbell 1984), The Reptiles of British Columbia (Gregory and Campbell 1984), The Birds of British Columbia (Campbell et al.

1990a, 1990b, 1997, 2001), The Bats of British Columbia (Nagorsen and Brigham 1993),

Opossums, Shrews and Moles of British Columbia (Nagorsen 1996), and Hoofed Mammals of British Columbia (Shackleton 1999).

The BC Wildlife Branch in Victoria has various publication series with information on wildlife species and their conservation in British Columbia. More specific information on the distribution, status, biology and conservation needs of regionally significant and other wildlife species can best be located through discussions with wildlife and habitat

protection biologists located in regional MELP offices (Table 2). For some Red and Blue-listed species, location information is classified as sensitive and is only available on a need to know basis from the Regional Endangered Species Specialist located in these regional offices (Table 2).

Recovery and Management Plans for sensitive wildlife may have been developed and implemented in MELP regions by regional MELP staff. These documents will usually provide critical information for environmental assessments and must be consulted. A list of current Recovery and Management Plans is provided below.

*********(NOTE: LISTS TO BE PROVIDED BY REGIONAL REVEWERS FOR EACH REGION)*********

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Table 2. List of regional offices of the Ministry of Environment, Lands and Parks.

Region 1 - Vancouver Island

2080-A Labieux Road NANAIMO BC V9T 6J9 Tel: (250) 751-3100 Fax: (250) 751-3103

Region 2 – Lower Mainland

2nd Floor, 10470 – 152 Street SURREY BC V3R 0Y3 Tel: (604) 582-5200 Fax: (604) 930-7119

Region 3 – Southern Interior

1259 Dalhousie Street KAMLOOPS BC V2C 5Z5 Tel: (250) 371-6200 Fax: (250) 828-4000 Region 4 – Kootenay #401 – 333 Victoria Street NELSON BC V1L 4K3 Tel: (250) 354-6333 Fax: (250) 354-6332 Region 5 – Cariboo

Ste. 400 – 640 Borland Street WILLIAMS LAKE BC V2G 4T1 Tel: (250) 398-4530

Fax: (250) 398-4214

Region 6 – Skeena

Bag 5000, 3726 Alfred Avenue SMITHERS BC V0J 2N0 Tel: (250) 847-7303 Fax: (250) 847-7728 Region 7 – Omineca/Peace 3rd Floor, 1011 – 4th Avenue PRINCE GEORGE BC V2L 3H9 Tel: (250 565-6135 Fax: (250) 565-6629

C. ECOSYSTEM AND WILDLIFE HABITAT MAPPING

Maps of terrestrial ecosystems and wildlife habitat interpretations are available for much of the province at various scales ranging from 1:5000 to 1:250,000. Terrestrial ecosystem mapping are typically called TEM maps, and are based mainly on vegetation and soils. Over 10 million ha have been mapped and are available on the Venus database. Predictive ecosystem mapping (PEM) is a new mapping tool and is available for selected areas, and is useful for larger-scale analysis. Wildlife habitat mapping (WHR) is available for many areas, often with good information on relative quality of habitat polygons for wildlife habitat. A Sensitive Ecosystems Inventory (SEI) has mapped rare or fragile habitats mainly in urban or rural areas that are threatened by ongoing development. Regional offices of Ministry of Environment, Lands and Parks will be aware of ecosystem and habitat maps available for particular areas of interest (Table 2). As well, the Wildlife Inventory Section of the Resources Inventory Branch may have additional wildlife habitat mapping available for certain areas of the province.

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Wildlife Inventory Section

Ministry of Environment, Lands and Parks PO Box 9344, Stn Prov Gov’t

VICTORIA BC V8W 9M1 Fax: (250) 387-2733

D. WILDLIFE SPECIES INVENTORY (SPI)

Provincially funded wildlife inventories now are required to submit inventory data to the SPI database. Hundreds of projects are currently included in the database. Data are collected using Resource Inventory Committee inventory standards

Inventory Branch.

Wildlife Inventory Section

Website: http://www.env.gov.bc.ca/wld/spi

E. HARVEST DATA

Harvest data from registered trappers and hunters may be available for most areas of the province. These data will provide evidence of presence and, possibly, relative densities for areas that are regularly trapped or hunted. Data are available from the Wildlife Branch, Victoria, BC.

Biometrics Section

Website: http://www.env.gov.bc.ca/wld/

F. MINISTRY OF FORESTS

The Ministry of Forests is a key source of information on wildlife that depend on forested ecosystems, especially for those species that depend on old-growth forests or wilderness areas, or are potentially impacted by timber harvest. Wildlife Biologists within the Research Branch of Ministry of Forests, both in Victoria and in Regional offices, and MELP Forest Ecosystem Specialists located in Regional MOF offices are good resources to use during an EA project review.

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Research Branch Ministry of Forests 712 Yates Street Victoria, BC Tel: 250 387-6721

G. WILDLIFE ACCIDENT REPORTING SYSTEM (WARS)

The WARS database of the Ministry of Transportation and Highways (MOTH) provides data on wildlife, mainly large mammals, which are killed by collision with vehicles on British Columbia highways. Data are useful for identifying hotspots for collisions, and indirectly, identifying such features as ungulate migration corridors or areas with high quality habitat and relatively abundant wildlife populations. Databases are available from MOTH, Victoria.

Environmental Services Section Engineering Branch

Ministry of Transportation and Highways 940 Blanshard Street

Victoria, BC

H. GOVERNMENT OF CANADA

The Canadian Wildlife Service (CWS) is an agency of Environment Canada that

implements a multitude of wildlife and wildlife habitat-related projects. CWS has several publication series that disseminate information on wildlife. Most projects deal with conservation of breeding or wintering populations of birds or mammals, or sensitive or rare wildlife habitat or plant communities. Databases may be available to proponents upon request.

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CWS works with the provinces in determining the status of rare wildlife through the Committee on Endangered Species in Canada (COSEWIC). COSEWIC reports exist for many wildlife species that occur in British Columbia and should be consulted

for a few species that are most threatene

CWS in Delta for technical reports and databases.

Canadian Wildlife Service 5421 Robertson Road, RR#1 Delta, BC. V4K 3N2

Tel: 604 940-4710 Fax: 604 946-8359

I. UNIVERSITIES

Major universities and colleges in British Columbia sponsor studies of wildlife and wildlife habitat that may have databases available to proponents. Many of these studies are linked to provincial funds from Forest Renewal BC. Proponents should contact the appropriate science departments at the University of British Columbia, Vancouver; Simon Fraser University, Burnaby; University of Northern British Columbia, Prince George; and University of Victoria, Victoria; plus regional colleges in areas near the proposed project.

J. NON-GOVERNMENTAL ORGANIZATIONS (NGO)

British Columbia has numerous wildlife-related NGOs that may have very useful databases or reports on wildlife, or wildlife habitat. Some of these include The Nature Trust, Ducks Unlimited Canada, BC Conservation Foundation, BC Nest Records Scheme and The Wild Bird Trust, BC Waterfowl Society, BC Federation of Naturalists and their local naturalist clubs, Sierra Club of Canada, Valhalla Wilderness Society, and others. Proponents should consult with regional MELP staff to discuss which organizations might have useful information.

K. PRIVATE INDIVIDUALS

Most regions of the province have several local people who have expert local knowledge about wildlife resources. These people are usually associated with local hunting and fishing clubs, or naturalist groups, and are usually well known in local communities. Proponents should consult with regional MELP staff to short-list for interview known private individuals with special knowledge.

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V. POTENTIAL WILDLIFE IMPACTS: A

GENERAL PERSPECTIVE

Major development projects potentially have significant negative impacts on wildlife or wildlife habitat. These impacts may be related to a wide range of factors including the size or footprint of the development, temporal and spatial extent of the construction phase, direct or indirect impacts from operations or maintenance, general increased human activity levels, increased access for humans to wildlife habitat, longevity of the project, and other factors. Potential negative impacts include a wide range of direct or indirect effects that may occur over the short, medium or long term. The importance of these potential impacts depends largely on the species involved, the scale and type of project that is being proposed, and the location of the project.

The types of projects that will trigger BC’s EA process are discussed in earlier sections of this report. This chapter provides an overview of the potential impacts on wildlife or wildlife habitat that may occur as a result of major development projects. The discussion is general in nature, and is not intended to be a comprehensive discussion of all potential impacts. We have discussed major developments in groups that seem to have similar impact potential for wildlife or wildlife habitat. These groups differ somewhat from those listed as project categories for EA reviewable projects, and do not include all project types, in Appendix 2 of the Guide to the British Columbia Environmental Assessment Process (Province of British Columbia 2001)

A. LINEAR DEVELOPMENTS

1. HIGHWAYS, RAILWAYS AND ROADS

Construction of highways, railways and roads can negatively impact wildlife through direct habitat loss, fragmentation of habitats, invasion of exotic species, introduction of new additive sources of mortality, disruption of movement patterns, and increased human disturbance (Jackson and Griffin 1998, Findlay and Bourdages 2000, van der Grift and Kuijsters 1998). Even relatively small roads have the potential to cause significant impacts. Some species of small mammals are reluctant to cross small roads (Swihart and Slade 1984), and if traffic volumes are high, even secondary roads can result in

substantial levels of direct mortality for reptiles and amphibians (Jackson and Griffin 1998). Blasting during road building can disturb and damage bird embryos in nests that are within the area influenced by the blasting shockwave. New roads may create new access in remote areas and additional mortality due to hunting, trapping, poaching, and recreation (MacArthur et al. 1982, Findlay and Bourdages 2000, Trombulak and Frissell

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2000). Besides the impacts associated with increased human disturbance on new roads, increasing access through road development can also increase the risk of predation for ungulate species. For example, woodland caribou in northeastern Alberta that are close to linear corridors are at a higher risk of depredation by wolves (James and Stuart-Smith 2000).

Larger roads and high-speed highways pose an even greater threat to wildlife populations since they affect a greater variety of species, the higher speeds and traffic volumes result in more animal-vehicle collisions, and larger volumes of traffic mean higher levels of public access and the wildlife problems associated with it. As individual animals are killed, or denied access to important habitats, local populations can fail. Reduced wildlife diversity in wetlands (Findlay and Houlahan 1997), lower densities of frogs (Fahrig et al.

1995) and rattlesnakes (Rudolph 1998) have been attributed to increased traffic intensity and road density. Since populations of some species decline gradually after road

construction, and local extinctions occur sometime later, the full effects of road construction on wetland biodiversity can go undetected for decades for some species (Findlay and Bourdages 2000).

a) DIRECT MORTALITY FROM COLLISIONS

The occurrence rate of animal-vehicle collisions is primarily a function of three factors, density of animals, traffic volume, and traffic speed. The faster design speeds of modern roads and highways, coupled with increases in traffic volumes, means there will continue to be an increase in the frequency and severity of animal-vehicle collisions unless

mitigation measures are implemented. In the United States, animal-vehicle collisions increased by 69% over a 6 year period ending in 1991 (Hughes et al. 1996).

Besides the effect on animal populations, automobile collisions with large animals can cause considerable vehicle damage, human injury, and even the occasional death. In British Columbia, between 5 and 10% of large animal-vehicle collisions resulted in hospital treatments for vehicle occupants (Economic Planning Group 1986). Fatalities to vehicle occupants resulting from collisions with wildlife are not common, but they do occur regularly. In the United States the fatality rate is approximately 0.1 percent of collisions (Hughes et al. 1996), but given the large number of accidents each year, this adds up to 120 people killed annually (Romin and Bissonette 1996).

Collisions with larger animals are more dangerous than collisions with smaller animals. Since elk and moose are three and four times heavier than mule deer, respectively, collisions with these larger ungulates cause more property damage and injuries to vehicle occupants than collisions with deer. Reported vehicle repair costs from ICBC in the 1980s were twice as high for collisions with moose compared to collisions with deer (Economic Planning Group of Canada 1986). Not only do the larger ungulates present more mass in an automobile accident, but also the increased height of these animals

Guidelines for Evaluating, Avoiding and Mitigating Impacts of Major Development Projects on Wildlife in British Columbia

initiatives with regional B.C. Ministry of Environment staff.