In part 1 and part 2 of this series, we discussed how Critical Habitat definitions are flawed, how Species at Risk Act (SARA) permits can be used to allow Critical Habitat destruction, and how a lack of enforcement of existing rules all contribute to a steady decline in available Critical Habitat for threatened Alberta trout species. The continued loss of habitat, and resultant decline of populations, clearly demonstrate that the intent of SARA — to ensure the survival and recovery of these species — is not being met.  

One reason for this is that implementing the required protections for meaningful enforcement of SARA would be expensive for industry, and particularly for forestry companies working in areas where Critical Habitat is found.  

For example, forestry operations often involve the building of new access roads into relatively undisturbed areas where remaining native trout populations survive, and harvest plans often overlap with Critical Habitat. Full implementation of Critical Habitat protections would make it significantly more difficult for logging to take place in these areas — and, in certain cases, perhaps even prohibit it.  

Part of the strategy that the forestry industry uses to avoid costly impacts on their operations, or potential prohibitions, is to lobby the federal government, particularly the Department of Fisheries and Oceans Canada (DFO). The Alberta Forest Products Association (AFPA), Alberta’s logging industry association, aggressively lobbies on fisheries issues, including the implementation of the Species at Risk Act.  

In fact, the AFPA’s lobbying program stated purpose on fisheries is “Advocating for implementation of the Species at Risk Act that recognizes the value of forestry on the land base and balances conservation goals and socioeconomic impacts.” 

But the reason that native trout species have reached a point at which they require protection under SARA is precisely because of the lack of balance between these goals – environmental concerns have constantly and continuously been considered secondary. To now call for balance between “conservation goals and socioeconomic impacts” when these species are at risk of extirpation, is to miss the point of the Species at Risk Act entirely.  

Since October 2020 (up to January 2024), AFPA has met with Federal government officials 83 times; 42 (51%) of those meetings have included the topic “Fisheries” and 35 of those meetings were with DFO. Over that time, meetings included 40 different DFO staff, ranging from deputy ministers to fish habitat biologists. While it is normal for an industry association to lobby government on behalf of its members, it is striking how such a large proportion of the AFPA lobbying effort is focused on fisheries and Species at Risk Act topics. What’s more, the number of meetings the AFPA has requested, and received, with the DFO has notably increased over the past three years (Figure 1).

The intent of SARA is to protect and recover at-risk species, in large part through preventing the destruction of Critical Habitat. While there are many different activities on the landscape that have an impact on trout, Critical Habitat destruction that results directly from logging operations is an especially impactful one — and one that is within the forestry industry’s power to address.  

To better understand these lobbying efforts, we recently obtained documents from the DFO through a freedom of information request. In the next post we’ll be exploring the content of these releases in detail and explaining why they matter for native trout conservation.