May 10, 2022
Att: Honourable Minister of Environment and Climate Change Canada, Steven Guilbeault
Dear Minister Guilbeault
I am writing to you with regard to the Migratory Birds Convention Act which is administered and enforced by Environment & Climate Change Canada. Under the act it is illegal to destroy, harass or disturb any of the migratory species of birds, or their nests, eggs, and offspring.
With that in mind, I wish to call your attention to a very recently released study conducted in the Wabanaki-Acadian forests of the Canadian Maritime provinces: “Forest degradation drives widespread avian habitat and population declines” (Nature Ecology & Evolution 2022), by Matthew G. Betts et al. (*see attached .pdf file). Making use of decades of carefully amassed bird atlas records collected in Nova Scotia and New Brunswick, Betts and other researchers were able to show the co-relation between the increasing loss of “mature mixed forest” and the steady decline in populations of a number of bird species which depend on that habitat for survival.
None of the above is actually new, or a great surprise, to those of us who spend time studying or watching birds. We’ve all known that there are fewer and fewer birds of certain species being seen, especially now that so much forest harvesting is done using large scale equipment which, working day and often at night, can take down huge swaths of forest. These machines and operators have no way of seeing or avoiding nesting birds, so “collateral destruction” is unavoidable. Many of us have tried to address this matter at a provincial level, but our concerns have been dismissed as unfounded. However it was good to see our observations finally vindicated and quantified in the Betts et al. peer-reviewed study.
Now, the big question for many of us is, what happens next? Is someone going to do anything about this deplorable situation? While the Migratory Birds Convention Act *should* have protected bird populations, unfortunately, it hasn’t actually helped much at all. Through a very large loophole, the act allows “incidental take” of birds by industry. Making use of this loophole, industry has been able to do an end run around the MBCA regulations for many years. Obviously, the serious declines which have taken place in bird populations are the end result.
Surely, given what we now know, this just can’t continue. We have reached a point in time when we cannot let industry go on killing birds and their young like some avian equivalent of “by-catch” similar to the destructive practices of the factory mega-trawlers of the industrial fishery. To allow this to continue unabated, flies in the face of anything that can be considered even remotely ethical. How can we, as a responsible nation, allow this to continue without taking preventive action? There are ways to significantly reduce the losses, but we need to act now — not soon — not later – but now.
Last week, I wrote an op-ed which was published in the Chronicle Herald (Halifax – May 7). I have attached a scan of the piece. I hope that it can provide more background on the situation here in Nova Scotia. I would also like to direct your attention to a commentary on the Betts et al. study, which was just written for NB Media Co-op, by wildlife biologist and president of Nature Nova Scotia, Bob Bancroft. He has succinctly summarized the thrust of the study. I don’t have a digital copy of the file on the article, but here is a link to it: https://nbmediacoop.org/2022/05/09/forest-degradation-drives-losses-of-bird-habitat-and-population/
I hope that, under your leadership, the ECCC will find a way to initiate meaningful enforcement of the MBCA and demand critically required change to prevent what will otherwise inevitably lead to even greater and more devastating species losses. Please take action.