In 2019, Canada's Fisheries Act was amended to incorporate new requirements and opportunities to protect fish habitat, including an overarching obligation for Fisheries and Oceans Canada (DFO) to consider cumulative effects in both regulatory development and decision-making. As DFO continues to develop regulations and policies to implement these new requirements, the department invited feedback on its Position Statement on the Consideration of Cumulative Effects on Fish and Fish Habitat in Support of Decision-Making under the Fisheries Act (the “Position Statement”) prepared by the Fish and Fish Habitat Protection Program (FFHPP).
This submission outlines West Coast Environmental Law's comments on the Position Statement, and some recommendations for improving protection for fish and fish habitat from cumulative effects.
For more information on this topic, please see our related report, How Crown laws and policy normalize cumulative harm to salmon watersheds in BC: A case study.