Spatializing oil and gas subsidies in endangered caribou habitat: Identifying political‐economic drivers of defaunation

Reforming environmentally harmful subsidies is an international priority under the UN Convention on Biological Diversity. Research that links industrial subsidies to negative ecological impacts, however, is limited. This paper contributes to the emerging agenda of global “subsidy accountability” research by linking oil and gas subsidies to the decline of endangered caribou herds in British Columbia, Canada. While existing research concretely attributes the decline of caribou herds to industrial activity, including oil and gas development, we suggest there is a need to identify the political‐economic structures which drive ongoing industrial development in caribou habitat, including public subsidies. We use government data to map oil and gas wells in critical caribou habitat and determine how many are run by operators receiving provincial fossil fuel “royalty credits”. Ultimately, we find that 1678, or 54%, of oil and gas wells located within critical caribou habitat are run by companies that have received benefits from one or both of BC's largest royalty credit programs. This paper points to the need for further analysis of subsidies as indirect drivers of biodiversity loss on a global scale, as well as increased emphasis on political‐economic drivers in conservation research. It also highlights the obstacles to implementing appropriate conservation solutions in political‐economic contexts dominated by resource extraction.


| INTRODUCTION
Reforming environmentally harmful industry subsidies is an international priority under the UN Convention on Biological Diversity's (CBD) Aichi Target 3 (Convention on Biological Diversity, 2020a).Yet the CBD's 2020 Global Biodiversity Outlook concludes the target has failed, noting that "few countries have taken steps even to identify incentives that harm biodiversity," much less reform them (Convention on Biological Diversity, 2020b, italics ours).Despite the public nature of subsidies, which are defined as financial contributions from a government that confer a benefit (World Trade Organization, 2022), many states do not release transparent and disaggregated data on specific subsidization regimes, creating a challenge for those wishing to understand their impacts (Organization for Economic Cooperation and Development, 2005; Organization for Economic Cooperation and Development, 2020).i Even where data is available, it's challenging to characterize the connection between subsidies, the activities they incentivize, and the ecological outcomes that follow, making direct causation, especially to phenomena such as defaunation, difficult to attribute.
In response to this challenge, we take an explicitly spatial approach to understand how subsidies incentivize activities harmful to biodiversity, placing an emphasis on where they go and what they do in a material sense.Through the process of spatialization, we trace the downstream distribution of subsidy regimes across specific landscapes, as well as connect and identify the local impacts of their implementation.Specifically, we link oil and gas subsidies to the decline of endangered caribou herds in British Columbia, Canada, a research task that is timely in both global and provincial registers.In doing so we contribute to Dempsey et al.'s (2020) call for "subsidies accountability," an interdisciplinary research agenda that seeks to assess both the ecological and political-economic implications of state subsidy regimes.
We also demonstrate how spatialization itself can be used as a key method to characterize the material impacts of government incentives upon particular landscapes, communities, and species.When data can be acquired, this method has already shown promise in shedding light on the impacts of subsidies.Skerritt and Sumaila (2021) recently examined the spatial distribution of global fisheries subsidies, with the goal of understanding where the impacts of the top-10 highest subsidizing countries can be found within the ocean.Their findings-that the majority of these harmful fisheries subsidies "are likely to be impacting the waters of other nations, rather than their domestic waters" (Skerritt & Sumaila, 2021)-demonstrates the importance of following the uneven material impacts of financial flows.Likewise, Allan et al.'s (2020) study on coal mining in British Columbia identified the distribution of subsidies flowing to recently-approved mines within endangered caribou habitat.This study found that the economic benefits (e.g., local jobs and tax revenue) expected by the public for supporting new mines with major negative impacts on endangered caribou herds were far less than projected at the time of approval (Allan et al., 2020).These findings highlight the analytical value of identifying the spatial distribution of impacts-both environmental and economic-of subsidy regimes in ecologically sensitive areas.Still, spatialization of subsidy regimes remains an underexplored method for understanding how and where subsidies incentivize environmentally-harmful activities.
Toward this end, our case study centers on the relationship between oil and gas subsidies and endangered caribou herds in British Columbia.British Columbia is the second-largest provider of provincial oil and gas subsidies in Canada; in Fiscal Year 20/21, the British Columbia Government subsidized the oil and gas sector to the tune of at least CAD 765 million (International Institute for Sustainable Development, 2022), with outstanding fee reductions for this industry standing at CAD 3.2 billion (Office of the Comptroller General, 2021).The province primarily subsidizes oil and gas development through royalty credit programs, which benefit these industries by giving companies a discount on the fees (royalties) that they pay for the right to extract and sell the province's nonrenewable natural resources (International Institute for Sustainable Development, 2019).By lowering the royalties that are paid on the province's nonrenewable resources, these royalty credit programs also make the initial risk-return ratio for oil and gas companies more favorable for investors; this effectively uses public funds to "de-risk" (i.e., incentivize) further private investment in oil and gas expansion (Erikson et al., 2020).These subsidies were initially introduced in 2003 "under pressure from the Canadian Association of Petroleum Producers [CAPP]" (Park, 2003) to increase investment, exploration, and development of BC's Montney Formation (where oil and gas are found); the then-CAPP president celebrated them for "allowing companies to 'pursue resources that would otherwise have been left untouched'" (Ibid).This is to say that British Columbia's royalty credit regimes are explicitly designed, as per the provincial government, to encourage oil and gas development "beyond what would occur otherwise" (Ministry of Natural Gas Development, 2018aDevelopment, , 2018b)).
This subsidy regime, therefore, has had a significant impact on the expansion of oil and gas development in British Columbia and is necessary context for understanding caribou declines in British Columbia today.While other research has already addressed the impacts of oil and gas drilling on caribou populations, we further this work by asking how these subsidies expand the overall footprint of oil and gas in the habitat that caribou need to sustain themselves.To do so, we examine the distribution of British Columbia's subsidy regime within federally-designated critical caribou habitat in the Northeastern part of the province, where caribou declines are closely tied to the expansion of industrial development, including oil and gas infrastructure.Specifically, we determine the extent to which provincial oil and gas royalty credit programs are subsidizing this type of industrial disturbance in areas that the government has deemed necessary for caribou survival.
This public spending on the oil and gas sector comes at the same time as the government of British Columbia is increasing public spending on intensive caribou conservation programs (Environment and Climate Change Canada, 2020a), such as wolf culling, maternal penning, and moose stabilization which aim to stabilize caribou populations yet cannot address the underlying driver of caribou decline: industrial disturbance (McNay et al., 2021).First Nations in British Columbia, specifically West Moberly First Nations (WMFN), Saulteau First Nations, and Fort Nelson First Nation (FNFN) have been closely involved in efforts to protect caribou herds, which form a critical source of cultural sustenance, crucial to these Nations' economies, cultures, knowledge systems, and kin relations (Fort Nelson First Nation & Liard Basin Monitoring Initiative, 2019;Government of British Columbia, 2020;Muir & Booth, 2012).Under Treaty 8, signed in 1899, these Nations retain a legal right to hunt caribou on their lands in perpetuity.As a result of caribou declines, West Moberly First Nations have brought legal challenges against the provincial government for authorizing activities driving caribou toward extirpation (Muir & Booth, 2012;see West Moberly First Nations vs. British Columbia, 2010).
There is this significant pressure on the government of British Columbia to stop caribou decline, yet the province has not yet taken comprehensive action to ensure the population's survival.Caribou researchers and even government scientists maintain that comprehensive habitat protection, and a reduction in the current pace of both industrialization and extraction in critical habitat areas, is the only way to prevent caribou extirpation in British Columbia (Bridger, 2019;Environment Canada, 2012;Environment Canada, 2014;Environment and Climate Change Canada, 2020b).Despite this, our findings ultimately show that there is significant state-subsidized oil and gas development happening in federally-designated critical caribou habitat, pointing to the need to further address subsidies as indirect drivers of extinction.These findings suggest that one straightforward measure to reduce this expansion would be to end the subsidization of industrial activities which degrade caribou habitat, at least within defined habitat boundaries.They also highlight the substantial obstacles to implementing effective conservation solutions in political-economic contexts dominated by resource extraction.As such, we argue that developing conservation interventions that address underlying drivers of defaunation requires an understanding of economic mechanisms that promote harmful industrial activity in the first place.

| The impacts of oil and gas on British Columbia's endangered Woodland Caribou
Woodland Caribou populations in Canada are undergoing steep population declines (Fryxell et al., 2020;Hervieux et al., 2013;Nagy-Reis et al., 2021).Despite being listed as a "priority species" under Canada's Species at Risk Act (SARA) since 2002, their numbers have continued to plummet (Festa-Bianchet et al., 2011;Fryxell et al., 2020).These declines are especially significant in Western Canada, including the province of British Columbia (Wittmer et al., 2005), where there have been seven herd extirpations in the past 20 years (BC Caribou Recovery Program, 2021); overall, woodland caribou in the province are estimated to have dropped from 40,000 to just 15,000 in the past century (BC Caribou Recovery Program, 2020).Most of these losses have occurred in the Southern Mountain and Boreal subpopulations, which are both classified as threatened under SARA (Environment Canada, 2012;Environment Canada, 2014).Though intensive and isolated recovery strategies, such as First-Nations-led maternal penning operations, have led to marginal improvement among select herds (Lamb et al., 2022;McNay et al., 2021) recent research paints a bleak picture for the possibility of self-sustaining caribou herds without the development of national and provincial legislation that can effectively halt industrial development in caribou habitat areas and protect said areas from future exploration (Hebblewhite, 2017;Nagy-Reis et al., 2021;Palm et al., 2020;Shackelford et al., 2018).
There is widespread consensus in the scientific literature that these caribou declines are driven by industrial land-use change resulting in habitat loss and alteration (Lochhead et al., 2022;Shackelford et al., 2018;Wittmer et al., 2007).Industries such as forestry, coal, and oil & gas fragment existing habitat.Through this fragmentation, they facilitate proximate drivers of decline, the most significant of which is increased predation by wolves (Ehlers et al., 2016).By altering habitat composition, industrial development reduces forest cover, creates artificial lines of sight, and increases the amount of primary prey animals and thus the actual number of wolves in an area (Ehlers et al., 2016;Mumma et al., 2018;Wittmer et al., 2005).
The relationship between forestry and caribou declines is typically emphasized in the literature (see Lochhead et al., 2022;Nagy-Reis et al., 2021;Wittmer et al., 2007), yet it is increasingly clear that oil and gas development within British Columbia is also a major cause of caribou mortality, primarily because the "linear features" required to develop oil and gas resources facilitate increased wolf predation on herds (McKay et al., 2021).The most significant of these features are seismic lines: 1.5-5.5 m wide cuts (Dabros et al., 2018) made in existing vegetation to allow for "geographical exploration to indicate the location and characteristics of subsurface formations," that can extend for multiple kilometers through forest landscape (BC Oil & Gas Commission, 2013).Wolves use seismic lines as lines of sight to hunt caribou, and these lines facilitate quicker movement or scouting over a larger piece of land (Dickie et al., 2017), and increase wolf density in a particular area (Dickie et al., 2022).Cutting seismic lines and other linear features creates an "early successional" environment that generates favorable forage for moose and elk, and therefore drives up the primary prey source for wolves and other predators, a process known as "apparent competition" (Anderson et al., 2018).Seismic lines and other linear features associated with oil and gas development, such as access roads and trails, also increase opportunities for wolf encounters with caribou (Mumma et al., 2018;Whittington et al., 2011).
These linear features impact caribou populations long after the time a well site is active.McKay et al. (2021) emphasize that the risks of proximity to seismic lines and pipelines are significant enough that "restoration of anthropogenic linear disturbance features should be an immediate priority for caribou recovery in central mountain caribou ranges."Even old well sites that have been officially reclaimed often remain "in an arrested successional state," (Lupardus et al., 2019), and woodland caribou are known to avoid well sites even after human activity has ceased (MacNearney et al., 2021).Active well sites, however, are still likely to have the highest impact, as this avoidance behavior increases "relative to the degree of activity at the nearest wellsite" and can push caribou out of more desirable zones and into unfamiliar areas more vulnerable to predators or hazards (MacNearney et al., 2021).Additionally, direct impacts on habitat are not the only consequence of continued oil & gas development: growing evidence demonstrates that climate change will decrease old-growth coniferous forest cover that caribou rely on for protection and food sources (Barber et al., 2018;St-Laurent et al., 2022).The continued extraction of British Columbia's fossil fuel reserves is a threat to caribou at the scale of individual wells, but also in a more generalized sense because it contributes directly to climate-induced habitat alteration.
There is robust evidence that continued oil and gas development in caribou habitat has a significant negative impact on the survival of endangered caribou populations in British Columbia (Stewart et al., 2020), but there have been few actions taken to protect caribou habitat from this disturbance.The 2002 Species at Risk Act (SARA) codified Canada's commitment to preventing extirpation and extinction; under this act, the Federal Government has identified "critical habitat" for two of the most threatened woodland caribou subpopulations: Southern Woodland Caribou and Boreal Caribou (Environment Canada, 2012;Environment Canada, 2014).Critical habitat is defined by the federal government as "the habitat that is necessary for the survival or recovery of a listed wildlife species and that is identified as the species' critical habitat in the recovery strategy or in an action plan for the species" (Environment and Climate Change Canada, 2016).This habitat is the most significant for caribou recovery, but it is important to note that caribou habitat extends (and is nominally protected) beyond these ranges.However, the federal government has yet to enforce any restrictions within critical caribou habitat on nonfederal land (Palm et al., 2020; also see Bird & Hodges, 2017).ii In the absence of federal enforcement, and due to BC's lack of provincial endangered species legislation (Palm et al., 2020), there is little comprehensive policy recourse for protecting this critical habitat.
Some of the only provincial mechanisms to protect caribou habitat are found in the BC Oil and Gas Commission operating guidelines for developers.Yet the oil and gas industry has continuously violated provincial-level interim operating protocols designed to minimize damage to areas essential to caribou survival (Parfitt, 2018).This is significant given that these guidelines are the only legislative mechanisms available to address oil and gas habitat alteration at the time of development.All other current efforts to address boreal and southern mountain caribou declines, such as predator removal, maternal penning, and even seismic line restoration, are designed to address the proximate impacts on caribou after initial oil and gas development occurs.Nagy-Reis et al. (2021) suggest that efforts to manage proximate drivers will need to be in place until habitat ranges can once again support caribou without intervention.Whether or not habitat ranges will ever be able to support caribou again is "highly dependent on the direction and pace of ongoing habitat change, which in turn may be affected by policy instruments and recovery actions" (2021).As they exist currently, there are no "policy instruments" that directly challenge or effectively mitigate extraction-driven habitat change in BC, leaving the future of the critical habitat areas in our analysis deeply uncertain.
A primary reason for why critical habitat areas for caribou are so difficult to protect is because they directly overlap with high densities of extractive industries such as forestry and oil and gas (Fortin et al., 2020;Palm et al., 2020).Over one-third of the world's oil reserves are located in Western Canada's Boreal forest (Hebblewhite, 2017).This presents a fundamental tension between BC's economic mandate for continued extraction and the protection of critical caribou habitat.While the state is clearly attempting to manage the fallout of resource extraction for caribou, to what extent is it undercutting these efforts by actively subsidizing industrial development in the first place?In the following section, we present our methods for identifying the continued state support of the oil and gas industry in relation to protections, or lack thereof, for critical caribou habitat in British Columbia.

| METHODS
To determine the extent to which oil and gas activity operators in critical caribou habitat within BC are subsidized by provincial royalty credit programs we split our methods into three main steps: (1) identifying the number of active oil and gas wells within both Boreal and Southern Mountain subpopulation critical habitat, (2) determining the operator of each well or group of wells, and (3) using royalty credit data to determine which operators were receiving credits, and in some cases assessing how much each operator received during a specific time period.Following these three steps we were able to determine how many wells within critical caribou habitat in BC were operated by companies receiving significant royalty credits.
In step 1, we accessed the public "Well Surface Hole Location" dataset from BC Oil and Gas Commission, which includes the coordinate points of all wells within the province.In order to keep our analysis to the wells most likely to have ongoing or proposed activity, we excluded any wells that did not have a predetermined range of "activity codes" to indicate active or recently active status.iii After implementing our exclusions, we layered our resulting "Active Well" dataset over two critical habitat shapefiles accessed via Environment and Climate Change Canada.In our analysis, we chose to use the critical habitat boundaries for both the Boreal and Southern Mountain Caribou sub-populations, in BC, as both are listed under the Species at Risk Act.After layering the "Active Well" set on top of the critical habitat polygons, we were able to determine how many active wells fell within both habitat boundaries.After generating this list of wells, we used the metadata provided in the dataset to find out the primary operator of each well located within critical caribou habitat.
In step 2, we determined which of the aforementioned well operators were receiving provincial royalty credits.First, we evaluated BC's array of royalty credit programs available to the oil and gas industry and decided to base our analysis on the three largest: The Deep Well Royalty Program (DWC), the Infrastructure Royalty Credit Program (IRCP), and the Clean Infrastructure Royalty Credit Program (CIRCP) (see Table 1).These specific royalty credits are but three out of a handful of different royaltyrelated credits and programs that the government of British Columbia uses to encourage oil and gas exploration and development (Ministry of Natural Gas Development, 2022).These royalty programs exist in addition to other types of subsidies provided by the province (International Institute for Sustainable Development, 2019), as well as subsidies and public finance provided by the federal government of Canada that further lower the cost of business for these companies (International Institute for Sustainable Development, 2020).Disaggregated information on BC's royalty credit programs, or subsidy amounts listed by a single company as opposed to the total amount the government spends in aggregate, is not publicly accessible.To obtain the necessary datasets for our analysis we submitted a request under the Freedom of Information Act for disaggregated credit data by operators on the Deep Well Credit Program and the IRCP and CIRCP iv from fiscal years 2019 to 2020.v The province ultimately provided us with the requested data for the IRCP/CIRCP programs.However, they rejected our request for disaggregated data for the DWC pursuant to a statute that allows them to refuse data requests that may be "harmful to economic interests of the province".vi Using BC's publicly accessible database of existing information release packages we were able to locate a previously requested document that contained sufficient information on the Deep Well Credit recipients to complete our analysis.vii  All of the royalty credit data we received was disaggregated by oil and gas "operators" (i.e., the company owning the well).To complete step 3, and link the information on the three royalty credit programs to the information on relevant wells, we added three different fields to the well/operator dataset: "IRCP/CIRCP eligible," "IRCP/CIRCP Amount," and "Deep Well Eligible."Once these fields were created we were able to fill in the appropriate royalty credit information for each well based on its operator.Then, we were able to simultaneously identify the specific locations of these wells within critical caribou habitat along with whether or not the operator had received IRCP/CIRCP or DWC in fiscal years 2019 and 2020.Because of the nature of the data on royalty credits, we were not able to determine which specific wells qualified companies for which royalty credit payments.However, because royalty credits flow to the overall well operator (rather than to the balance sheets of a particular well), we use these well sites as a proxy to spatialize the footprint of companies whose expansion is being underwritten by provincial subsidies.After adding the royalty credit fields, we were able to summarize the wells included in our original "Well Surface Hole" dataset based on their royalty credit attributes to determine how many of the wells within BC's critical caribou habitat were operated by companies that received one or both forms of royalty credit programs included in our analysis.

| RESULTS
In the first part of our analysis, we found 3114 active viii wells within the boundaries of federally defined critical caribou habitat in BC: 2720 within boreal caribou habitat (see Figure 1) and 394 within southern mountain caribou habitat.After attaching our disaggregated royalty data, we found that 1678 of these wells, or 54%, are run by operators that have received royalty credits from the IRCP/CIRCP and or DWRCP during fiscal years 2019 and 2020.There is extensive overlap between the two programs, meaning that most operators receive credits from both programs as opposed to one or the other.Significantly, 925 of the wells run by companies receiving DWRCP (see Figure 2), and 977 run by those receiving IRCP/CIRCP were authorized after the implementation of the federal Species at Risk Act in December of 2002, which also established critical habitat ranges for boreal and southern mountain populations a year later in 2003.(Environment Canada, 2014;Environment and Climate Change Canada, 2018).

| DISCUSSION
Over the past two decades, the province has permitted and subsidized the expansion of oil and gas development in established and federally recognized critical habitat ranges.These results demonstrate that the three main oil and gas royalty credit programs in BC are supporting continued oil and gas development within the bounds of both Boreal and Southern Mountain critical caribou habitat.Over half of all active wells within critical caribou habitat are run by companies that have received some form of support from these royalty credit programs within the past 3 years, even despite a Federal declaration in 2018 that the Southern Mountain subpopulation was facing an "imminent threat" to its survival (Collard & Dempsey, 2022;Environment and Climate Change Canada, 2018).While the extent to which these credits are directed toward a reduction in costs for the specific wells in these habitats is impossible to quantify with available data, both the Deep Well Credit and IRCP/CIRCP support an overall reduction in operating costs for companies that operate wells in critical caribou habitat and beyond.Thus, the province is neither sanctioning nor withholding credits from companies that operate in these areas, but instead incentivizing continued oil and gas expansion in this habitat that, according to the provincial government's own rationale (Ministry of Natural Gas Development, 2018a, 2018b), would otherwise not occur.
F I G U R E 1 Active wells in Southern Mountain and Boreal subpopulation critical habitat.
To understand their full significance, these results must be viewed in the context of previous commitments to caribou conservation made by the provincial government.From 2018 to 2021 the BC government spent over CAD 27 million dollars (Simmons, 2021) on caribou recovery projects.In contrast, the data we received shows that in just 2 years the provincial government distributed nearly CAD 26 million dollars in credits via the IRCP and CIRCP alone to oil and gas companies operating within critical caribou habitat.With these funds, the province is de-risking industrial activity in critical areas and making current and future extraction more economically viable.These findings are also significant in the face of provincial legal obligations to First Nations under Treaty 8, an 1899 agreement that protects First Nations' traditional hunting rights for food and cultural sustenance on Treaty Lands.Many caribou herds, which are central in material, cultural, and spiritual senses to a number of First Nations in Northeast BC, are not robust enough to sustain an annual hunt (Environment Canada, 2012;Environment Canada, 2014).West Moberly and Saulteau Nations voluntarily implemented a hunting moratorium for their nearby herds in the 1970s, meaning they have been unable to engage in a hunt for almost 50 years (Muir & Booth, 2012).Muir and Booth conclude that in the case of coal extraction-driven caribou declines on the West Moberly First Nations territory, a "disproportionate share of environmental burdens was therefore placed onto the shoulders of the [Nation] while the interests of the government and the mining industry were protected," making this issue "a clear case of intentional environmental injustice on the part of the British Columbia government" (Muir & Booth, 2012).
As a result, First Nations such as the West Moberly have taken the BC government to court over caribou decline (West Moberly vs.British Columbia, 2010).In 2021, a related case brought by the Blueberry River First Nations ultimately led the BC Supreme Court to conclude that the provincial government breached its obligations under Treaty 8 (Yahey v. British Columbia, 2021).Unique to this case was the court's finding that the BC government failed to mitigate industrial disturbance by not adequately assessing the "cumulative effects" of industrial development on species decline (Yahey v. British Columbia, 2021).This term refers to the aggregate impact of individual landscape changes when concentrated in certain locations.For example, while British Columbia has, on average, 60% intact forest landscape, Blueberry River First Nations' traditional territory now has only 14% intact forest landscape (Yahey v. British Columbia, 2021).Over the past decades, the territory has been heavily impacted by forestry, oil and gas, agriculture, mining, and hydroelectric development, and the court case acknowledged the role that the provincial subsidy regime had in incentivizing industrial activity beyond what would otherwise occur in this area.Ultimately, the final ruling stated that: "the evidence shows that the Province has not only been remiss in addressing cumulative effects and the impacts of development on treaty rights, but that it has been actively encouraging the aggressive development of the Blueberry Claim Area through specific royalty programs (including for marginal wells) and Jobs Plan policies" (Yahey v. British Columbia, 2021).
Despite the court's finding that BC is not upholding its Treaty obligations, the government continues to subsidize the industries that drive caribou decline within caribou habitat, and there is little indication that they plan to change this.The government's commitments to this sector are reflected in Canada's Energy Future Prediction for British Columbia, which shows a projected increase in both oil and gas production over the next two decades.BC's oil production is predicted to increase 151% between 2020 and 2040; for methane gas, there is a projected 90% increase for the same period (Canada Energy Regulator, 2022).Further, an estimated $6 billion in subsidies are currently flowing to the BC Liquified Natural (methane) Gas sector alone (Furstenau, 2022).These staggering numbers, in the face of a climate emergency no less, should point us to the state's dual role as both promoter of economic interests and protector of natural resources, in which we see economic interests continue to trump the interests of biodiversity all the way to the brink of extinction (Collard et al., 2019).But these economic interests are not even; the entrenched power of the oil and gas fossil fuel sector within political processes often results in their ability to overdetermine how the state's material commitments are upheld (Carrol, 2021).Because oil and gas resources are concentrated in Northeastern BC, we expect that these increases in production will be accompanied by the expansion of oil and gas wells (and associated linear features) in this region, which overlaps with the habitat that caribou herds need to survive.In the case of British Columbia, the state's orientation toward intensified extraction of oil and gas resources in Northeastern BC is incompatible with addressing the drivers of defaunation.
An understanding of this dynamic is integral for conservation practice, and points to the need for further incorporation of broader political-economic conditions into conservation planning and advocacy.By this we mean advocating for measures that address underlying drivers, such as the state's allowance of, and material support for, oil and gas development at the expense of critical caribou habitat.Robust habitat protections and reclamations must be on the table; making this a possibility requires an understanding of the political economy that drives resource extraction in these areas in the first place.

| CONCLUSION
There is little doubt that unregulated industry and resource-oriented subsidies are fueling habitat degradation and species decline (Organization for Economic Cooperation and Development, 2020).The CBD's Kunming-Montreal Global Biodiversity Framework, to which the Government of Canada is a party, recently renewed its commitment to subsidy reform through Target 18.The target affirms the need to further identify and reform specific upstream financial mechanisms -such as damaging industrial subsidies, due to their ongoing role in exacerbating extinction crises.While oil and gas subsidies have received substantial attention for their simultaneous impacts upon greenhouse gas emissions, environmentally harmful subsidies are also prevalent in forestry, agriculture, aquaculture, transport, water, and construction (Organization for Economic Cooperation and Development, 2020).Each of these groups of subsidies necessitates focused and location-specific attention in order to understand which types of incentivization are most environmentally destructive, as well as how subsidies could be reformed to incentivize positive social and ecological outcomes.But, in order to do such an analysis, disaggregated data on subsidy flows must be publicly available such that researchers can understand their socio-ecological implications.In many cases, more research is not needed in order to classify subsidies as environmentally harmful, but rather to understand who benefits from activities that run counter to collective priorities, and who bears the risks.Given that these benefits are allotted by governments, citizens are deserving of data about where public funds are flowing and how such funds may be undermining efforts to prevent environmental degradation.Conservation practitioners have a potential role in demanding this transparency from governments, as these underlying drivers of defaunation and biodiversity loss pose direct threats to meeting environmental commitments and objectives.
In May of 2022, the government of British Columbia undertook a comprehensive review of its royalty credit framework and announced that by 2024 the province would phase out both subsidy programs analyzed in this study, as well as a number of smaller well-related royalty credits.This development came in the wake of significant public pressure to review oil and gas subsidies for their economic and environmental implications, as well as an Independent Assessment for the government, which concluded that "There is no apparent market failure that currently justifies the continuation of these [The IRCP and DWC] credits" (Olewiler & Winter, 2021).As the largest royalty credits for oil and gas, this move signified a substantial shift in policy.
The province, however, opted to replace the existing system with an alternative royalty credit framework (Ministry of Energy, Mines, and Low Carbon Innovation, 2022) which includes an industry-favored (Simmons, 2022) capital recovery mechanism for oil and gas expansion.Instead of allocating adjusted sums of royalty credits to qualifying wells as the DWC or IRCP did, the new royalty framework charges a flat 5% royalty fee until "the capital spent on drillings and completions is recovered."(Government of British Columbia, 2023) The royalty fee is then adjusted on a case-by-case basis to a price-sensitive rate between 5% and 40% with an emphasis on maintaining "a return of 50% of profits after production costs are accounted for" (Government of British Columbia, 2020).Although this new system arguably deals with smaller overall sums of royalty credit allowances, it still actively incentivizes the construction of new wells by guaranteeing a return on upstart costs, thereby making oil and gas drilling continuously investable.This system was put in place despite the fact that the majority of respondents to a province-wide survey on subsidy reform (R.A Malatest & Associates Ltd., 2022) indicated that they favored a flat system with no capital recovery mechanism.This new system will continue to de-risk investment in new oil and gas projects in Northeastern BC.
These new reforms are inadequate from an environmental perspective.Caribou decline was not cited as a concern for the government when redesigning these subsidy programs.In the British Columbia government's 2020 Performance Measures report on oil and gas royalty credit programs, there was no mention of caribou, or of any ecological impacts, when considering the consequences of incentivizing further oil and gas development (Ministry of Energy Mines & Low Carbon Innovation, 2020).While there are currently no provincial or federal regulations prohibiting well development in the critical habitat areas discussed in this paper, subsidies lower upfront operating costs for oil and gas operators and thereby accelerate new capital investment into drilling projects.The removal of all royalty credits would not equal the cessation of drilling entirely in critical caribou habitat, but would likely significantly slow the pace of planned or early-stage projects, and result in fewer wells overall (Olewiler & Winter, 2021).In order to fulfill its stated commitments to caribou recovery, British Columbia must ensure (and transparently report) that subsidies, such as the new capital recovery framework are not lowering costs for operators within critical caribou habitat.Ongoing efforts to re-establish caribou populations and habitat will be needed for decades to come, and must not be undercut by further industrial expansion, especially as incentivized via the use of public funds.All data used in this analysis are accessible online.The "Well Surface Hole" dataset and the metadata for Well Activity Codes can be found at via the BC Energy Regulator Data Centre.Information used in our analysis pertaining to the IRCP & CIRCP is contained within the BC Open Information database.Information pertaining to the DWC is also located in this database.Spatial data on Boreal and Southern Mountain subpopulation critical habitat can be accessed via Environment and Climate Change Canada.

ENDNOTES
i The Organization for Economic Cooperation and Development (2005) notes that "In most cases, new environmental measures are subject to a 'regulatory impact assessment' while, in many countries, existing subsidy programs are not subject to an 'environmental impact assessment.'"ii Federal land in this case specifically means areas such as parks, and not other land designations such as Crown lands.
iii To do this, we only included wells that had a "well activity code" of "ACT," "COMP," "DRIL," "GAST," "CASE," "PRES," or "PSPD" as of March 2021.The well activity code metadata is linked in our data resources.iv In the provided data, the government combined the IRCP and CIRCP programs.Thus, in our analysis, they are considered one program.v We use "fiscal years 2019 and 2020" to as an abbreviated way to refer to the fiscal years ending on March 31st 2020-and March 31st 2021, which cover the time period from April 1, 2019 to March 3, 2021.Our data does not include the last 28 days of the fiscal year ending on March 31, 2021.vi The Deep Well Credit is a much larger subsidy program as compared to the IRCP/CIRCP credits and had already been subject to critical attention prior to our analysis.Disaggregated data on the DWC had never been previously released, and it was therefore not unexpected that our request was denied.In comparison, IRCP data had already been released for previous years, and comprised a much smaller, and less politically contentious, amount of provincial funding.vii The difference between the information we requested and the Deep Well Credit information used in this analysis is that the requested records contained exact amounts awarded to corporations who had wells that were eligible for the credit from FY 2019-2020.Instead, we utilized a previously released dataset that listed all operators who were eligible for, and received, the credit during FY 2019-2020.We were not able to determine how much each individual company received, although we do know the total number in aggregate as outlined in Table 1.Credits for a "Tier 1" well under the deep well credit program can range from $440,000 to $2,800,100 per well drilled.(Ministry of Natural Gas Development, 2021).viii "Active" here is defined as all of the wells listed with the qualifying well codes included in analysis.

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I G U R E 2 Active wells in Southern Mountain and Boreal subpopulation critical habitat displayed by Deep Well Credit eligibility.
Royalty credit programs used in analysis.The IRCP "encourages new capital investment in oil and[methane] gas infrastructure beyond what would occur otherwise…this deduction can be as much as 50% of the cost of building roads or pipelines that are approved under the program."(Ministry of Natural Gas Development, 2018a).
T A B L E 1 a As of the last BC budget, there is also a $3.2 billion outstanding balance of Deep Well Royalty Credits that will reduce future royalty payments to the Province until 2026 (Office of the Comptroller General, 2021).