Using Conservation Covenants to Preserve Private Land in British Columbia

DAVID LOUKIDELIS
Barrister & Solicitor

edited by

ANN HILLYER
Barrister & Solicitor
Staff Counsel
West Coast Environmental Law Research Foundation

1992

West Coast Environmental Law Research Foundation
Vancouver, Canada
Original Printed on Recycled Paper


[Note: The amendments to statutes recommended in this paper have since been adopted by the B.C. Legislature. See Leaving a Living Legacy: Using Conservation Covenants in British Columbia.]


Contents

Executive summary

Preface

Acknowledgements

Chapter 1. Introduction

Chapter 2. Conservation Covenants: A Necessary Tool

Chapter 3. Existing Law Of Covenants And Easements

Chapter 4. The Experience Elsewhere

Chapter 5. Recommendations For Law Reform In British Columbia

Chapter 6. Conservation Covenants And Taxation

Chapter 7. Conclusion

Appendix A. Summary Of Recommendations

Appendix B. Glossary Of Terms

Appendix C. The Existing Law On Covenants And Easements

Bibliography



EXECUTIVE SUMMARY

Land use issues have long occupied a central role in environmental disputes in British Columbia. How land and its resources are managed and whether land will be subject to any human impact at all are questions that frequently generate heated public debate. Increasingly, citizens and conservation organizations are interested in the preservation or conservation of land for a variety of ecological reasons, including

This report recommends that the Province of British Columbia enact legislation permitting the use of conservation covenants for the voluntary protection and preservation of private land in British Columbia. One of the most important features of this tool is that it would be possible for a landowner to grant a conservation covenant to a private conservation organization.

While a variety of tools are available to protect land, there is a growing need in British Columbia to expand the initiatives available to private parties for the protection of private land. In the United States and elsewhere, the conservation easement has enjoyed wide success as a private land protection measure. The conservation covenant recommended in this report is similar to the U.S. conservation easement. It is a tool that is flexible, requires a minimum of government resources, and could take advantage of the expertise of local and regional conservation organizations in land protection.

This report examines and makes recommendations on key issues that need to be addressed in the conservation covenant legislation. A summary of some of the main recommendations is set out below.

There are serious constraints on the ability of government to preserve land in British Columbia. The focus on larger areas and the need for public financial restraint together hamper government's ability to preserve anything other than British Columbia's publicly owned land base. Given the limits to what government can do itself to protect all of the natural areas in British Columbia that warrant protection, there is a pressing need for private methods of protecting land as well. One of the most promising tools for the private protection of land is the conservation covenant. The government of British Columbia should act quickly to make this tool available.



PREFACE

The West Coast Environmental Law Research Foundation (WCELRF) is a non-profit, charitable society devoted to legal research and education aimed at protection of the environment and promotion of public participation in environmental decision-making. It operates in conjunction with the West Coast Environmental Law Association (WCELA), which provides legal services to concerned members of the public for the same two purposes.

This report has been prompted by a growing awareness among conservation groups and landowners in British Columbia that there are serious limits to what government can do to preserve the environment. This report urges law reform in British Columbia to enable the voluntary preservation of privately owned land through a new statutory tool called a conservation covenant, that may be granted to private conservation organizations. There are various methods currently available to protect private land in British Columbia. However, experience elsewhere illustrates that a tool similar to the conservation covenant recommmended in this report would be a valuable addition to the existing tools.

The views expressed in this report are those of the author alone.

Readers are reminded that this report is educational and does not constitute legal advice. Readers concerned about specific land preservation issues in a particular situation are urged to seek legal advice from a lawyer.

David Loukidelis

Vancouver, July 1992



ACKNOWLEDGEMENTS

The author is indebted to the staff at the West Coast Environmental Law Research Foundation , particularly: Ann Hillyer, William J. Andrews and Murray Mollard for their cogent comments and editing; and Catherine Ludgate, Denice Regnier and Morgan Ashbridge for production and desktop publishing. I would also like to give special thanks to Rick O'Neill and Judith White for their excellent photographs.

The study was funded by the Real Estate Foundation of British Columbia. Special thanks are owed to Tim Pringle, Executive Director of the Real Estate Foundation, for encouragement and direction. I am also pleased to acknowledge that the Law Foundation of the British Columbia provides core funding for the West Coast Environmental Law Research Foundation.

Many individuals helped in the preparation of the this study. I would like to thank the following people with whom we consulted in the course of our research: Alan Andison, Ministry of Environment, Lands and Parks; Marc Denhez; Bo Fodchuk, Russell & DuMoulin; Ray Halladay, Ministry of Environment, Lands and Parks; Bill Huot, Ministry of Tourism and Ministry Responsible for Culture; Lindsay Jones, Nature Trust; Randy Klarenbach, Lawson, Lundell, Lawson & McIntosh; Art Martell, Canadian Wildlife Service; Professor Sandra McCallum, University of Victoria; Rick Paige, Ministry of Environment, Lands and Parks; Tom Slater, Ducks Unlimited; Gerry Townsend, Canadian Wildlife Service; Wes Umphrey, Ministry of Environment, Lands and Parks; and Bill Wareham, Ducks Unlimited.

The views expressed are those of the author and the West Coast Environmental Law Research Foundation . Any errors or omissions are, of course, solely the responsibility of the author.



CHAPTER 1
INTRODUCTION

Concern about the natural environment has increased dramatically in recent years. Many of the most pressing environmental issues in British Columbia are land use issues involving questions about allocation and management of land and resources. [[Footnote: (1) -- 1. For a discussion about a number of the environmental issues connected to land use issues, see British Columbia Round Table on the Environment and the Economy, Sustainable Land and Water Use (Victoria: British Columbia Round Table on the Environment and the Economy, 1991).]] There often is intense -- and sometimes acrimonious -- struggle over how land and resources are to be used, if at all. Many parties involved in land use struggles look to one level of government or another for resolution of the conflict. However, in many cases there are limits to what government can do to solve these problems. Therefore, private measures to preserve private land in British Columbia are becoming increasingly important.

This report examines the conservation covenant, a tool that offers maximum flexibility in the use of land while ensuring protection for defined purposes. This report also identifies key areas of law reform aimed at making this tool available to private conservation organizations, thereby creating new opportunities for the voluntary preservation of private land in British Columbia.

1.1 Limits on Government Action

There are serious constraints on the ability of government to preserve land in British Columbia. First, land use planning and protection mechanisms usually operate on a large scale. [[Footnote: (2) -- 2. This is not universally the case. For example, many ecological reserves in British Columbia protect relatively small areas.]] Traditional preservation tools, such as parks, apply to relatively large areas; they encompass valleys, forests or watersheds. Opportunities to protect smaller parcels of land, especially privately-held land, are frequently overlooked.

The second important limit on what government can do is financial. Despite broad public support for land preservation, the financial resources of government available for that purpose are increasingly limited. Moreover, land values in all areas of the province are climbing. For those reasons, government is often unable to purchase privately owned parcels of land for conservation purposes. Publicly funded preservation initiatives are therefore likely to continue to focus on Crown land. Privately held parcels of land are less likely to be preserved even if they are environmentally significant.

The focus on larger areas and the need for public financial restraint together hamper government's ability to preserve anything other than British Columbia's publicly owned land base. This has led many people to pursue private initiatives in land preservation to complement government action. [[Footnote: (3) -- 3. An example of the growing recognition that traditional conservation tools must be supplemented by private sector conservation tools is found in the opinion piece by D. Anderson, "More Than Mountaintops" The Vancouver Sun (21 December 1991) B5, where the author argues that there is a need for "an increase in the use of private sector legal tools for environmental protection." ]]

1.2 Private Purchase of Land

Private purchase of private land for conservation purposes is a major option. However, the cost of land in British Columbia presents an increasingly serious obstacle to private land preservation through outright acquisition. Land values are an obstacle not only to government intervention, but also seriously limit the ability of private conservation organizations to acquire land for conservation purposes.

Cost is not the only reason private conservation organizations are interested in alternatives to land purchases. Some landowners have no interest in selling their land, in spite of possible tax benefits. For example, a farmer may wish to ensure that her land will continue to be used for agricultural purposes forever. Sale or donation of the land to a private conservation group may not provide sufficient assurance to the farmer that the use of the land will remain unchanged. In other cases, the landowner's desire to retain control may make outright disposition unworkable.

In addition to the purchase of land by a conservation organization, there are other legal tools available in British Columbia that offer opportunities for land preservation by private methods. There are two types of tools, statutory and non-statutory, and they include the following:

1.3 The U.S. Conservation Easement

For reasons similar to those discussed above, methods of protecting land, other than through outright purchase, have become popular in the United States. Experience in the United States and elsewhere has shown that one of the most useful tools is what is referred to in the United States as a conservation easement, [[Footnote: (4) -- 4. In this report the term conservation covenant is used to refer to a registrable interest in land created for the purpose of preserving or conserving the land or some feature of the land. This interest is similar to that referred to as a conservation easement in the United States. While some authors draw a distinction between conservation covenants and conservation easements, in this report the terms are used interchangeably to refer to the same type of interest in land.

End of Footnote]] z which can be held by private organizations. It is one of the most popular tools used by land trusts [[Footnote: (5) -- 5. Many United States land preservation groups refer to themselves as land trusts, many of which are not-for-profit corporations. The term land trust is not a technical legal term. It arises from the fact that a land trust holds land, or interests in land, for the public purpose of preservation. Although land trusts may be formed and used in British Columbia, examination of various practical and legal issues related to land trusts is beyond the scope of this report. End of Footnote]] z and other conservation groups in the United States. A similar method of land preservation is not available in British Columbia to private groups.

Other tools used by private conservation groups in the United States are already available in British Columbia. A detailed discussion of those tools is beyond the scope of this report. However, some require a brief discussion largely to underscore the need for law reform in British Columbia to permit the use of conservation covenants held by private groups.

1.4 Tools Available in British Columbia

The land preservation tools currently available for the protection of private land in British Columbia are both statutory [[Footnote: (6) -- 6. In addition to the statutory instruments discussed in the text, there are other statutory powers which may be useful in the preservation of private land. For example, a local government may co-operate in the designation of privately owned land as an environmentally sensitive area under the development permit area provisions of Part 29 of the Municipal Act, R.S.B.C. 1979, c. 290 [the "Municipal Act"].]] and non-statutory.

1.4.1 Statutory Tools

If a landowner wishes to involve government in land preservation, the Land Title Act [[Footnote: (7) -- 7. R.S.B.C. 1979, c. 219 [the "Land Title Act"].]] offers two useful tools.

First, section 215 of that Act permits a landowner to enter into an agreement with the government, by way of a covenant registered on title to the land, to restrict the use of the land in question, including what can or cannot be built on it. The agreement can also require the landowner to do something positive on the land, such as undertake a program of works preserving wetlands.

Recent amendments to the Land Title Act allow a covenant of this kind to be granted for environmental purposes. The new provision, section 215(1.1)(e), permits a covenant to be registered for the purpose of protecting, preserving, conserving or keeping land in its natural state according to the terms of the covenant. While a section 215 covenant is enforceable against successors in title and does not need to benefit adjacent land, it can only be granted in favour of a provincial or local government body. It cannot be granted in favour of a private party. This seriously limits its application for the protection of private land.

In this report, the covenant permitted under section 215(1.1)(e) of the Land Title Act is referred to as a " section 215 environmental covenant" to distinguish it from the new land preservation tool recommended in this report, referred to as a "conservation covenant". The latter could be held by a private organization, the former cannot.

Second, under section 214 of the Land Title Act it is possible for a landowner to give the provincial or a local government a statutory right of way over land. [[Footnote: (8) -- 8. Section 214 of the Land Title Act also allows a statutory right of way to be granted to anyone designated by the Minister of Lands, Parks and Housing -- as the section now reads -- as qualified to receive such rights of way. This could be very useful for conservation groups, if the government were willing to make the necessary designations under section 214.]] This permits the government to use specified parts of the land for purposes necessary to a government undertaking. Some local governments have used this power to secure rural and urban trails.

Another existing statutory tool, similar to a covenant granted under section 215 of the Land Title Act, is the heritage conservation covenant or easement under sections 13 and 27 of the Heritage Conservation Act. [[Footnote: (9) -- 9. R.S.B.C. 1979, c. 165 [the "Heritage Conservation Act"]. ]] That Act allows a landowner to grant a covenant or easement in favour of the Province, the British Columbia Heritage Trust or a local government for the purpose of protecting or conserving a heritage object or heritage site. A heritage site is defined in section 1 of the Heritage Conservation Act as "land, including land covered by water" which has "historic, architectural, archaeological, palaeontological or scenic significance to the Province or a municipality."

It is clear from the language of the Heritage Conservation Act that land can have heritage significance apart from the structures located on the land. A heritage covenant or easement could be used, for example, to preserve a landscape of scenic or historic significance.

Further, unlike section 215 of the Land Title Act, the Heritage Conservation Act expressly contemplates assignment of interests created under it. Section 27(3) of that Act provides that a heritage easement or covenant may be "assigned ... to any person and shall continue to run with the land and may be enforced ... by and in the name of that person." The assignability of such interests offers considerable flexibility. For instance, it would be possible for a local government to act as a facilitator by accepting a covenant or easement and then assigning it to a private conservation organization. However, one significant restriction on the use of heritage covenants or easements is the limited list of heritage purposes for which they can be created. For example, there will be many cases where wildlife habitat which merits preservation is neither scenically nor historically significant to the Province or a local government.

1.4.2 Non-Statutory Tools

There are four main non-statutory preservation techniques available in British Columbia to landowners and private conservation groups or governments, in addition to the option of purchasing the land outright.

First, a landowner may grant a long term lease of land to a conservation group for 99 years or longer. The lease could include a base-line ecological inventory of the land, using written descriptions, data, graphs, photographs and maps, and detailed conditions for the use of the land by the conservation group. Breach of the conditions, such as use of the land for prohibited purposes, might entitle the landowner or his or her heirs to terminate the lease. This would give the landowner ongoing control over land use while giving the conservation group some security of tenure. [[Footnote: (10) -- 10. There may be tax consequences which would limit the utility of this technique.]]

Second, a variation of the long term lease is a "lease-back". In this case a landowner transfers title to the land to a conservation group. As part of the deal the conservation group leases the land back to the owner on a long term lease, subject to conditions designed to ensure preservation of the land or particular aspects of it. Breach of the lease could entitle the conservation group to terminate the lease and take possession of the land.

Third, a landowner could transfer title to the land to a conservation group, but reserve a life interest in the land. This allows the landowner to remain on the land for life undisturbed. However, the landowner has the assurance that the conservation group will assume control of the land upon the landowner's death, without further legal action.

A fourth tool currently available involves carving up property rights and transferring a specific right to a conservation group. One such property right is known as a profit a prendre, a right which entitles its holder to enter the land and carry away or harvest a specified part or produce of the land. For example, if a landowner wished to preserve old growth forest on his or her land, the landowner could grant a conservation organization a profit a prendre entitling the organization to enter the land and cut trees growing on it. By granting such a right to a conservation group, the landowner would prevent future owners of the land from harvesting the trees, since that right has been given away. The profit a prendre itself -- or perhaps a collateral agreement in some cases -- would place conditions on the use of the profit a prendre. If it was the landowner's intention to preserve the old growth forest on the land, the conditions would prohibit cutting old growth trees.

Profits a prendre also can be given with respect to the land's soil, water, and other commonly exploited components. [[Footnote: (11) -- 11. See A.H. Oosterhoff & W.B. Rayner, 2d ed., Anger & Honsberger: Law of Real Property (Aurora, Ontario: Canada Law Book, 1985) at 973-977 ["Anger & Honsberger"]. In British Columbia, the Mineral Tenure Act, R.S.B.C. 1979, c. 263.3 removes the power of almost all landowners in the province over minerals on their land. There are exceptions, such as where the original Crown grant included minerals of certain kinds (which varies from case to case).]]

1.5 Need for Law Reform

While the tools discussed above -- and other statutory and non-statutory tools -- are currently available for preserving private land in British Columbia, each has limits to its application. For example, one serious drawback to using the available statutory tools is that each involves a level of government, thus limiting private conservation organization initiatives.

Experience in the United States suggests that what is referred to in this report as a conservation covenant is the most flexible and widely used private land preservation tool in the various states. Even though in British Columbia it is possible to grant a covenant for conservation purposes under section 215 of the Land Title Act, the section 215 environmental covenant, it must be held by a government body. Law reform is needed in British Columbia to allow private organizations to hold conservation covenants.

1.6 Land Title System in British Columbia

It is necessary to discuss briefly the land title system in British Columbia, since the legal effectiveness of conservation covenants -- and the legal tools just outlined -- depends on that regime. The following discussion, intended for the general reader, deals only with those aspects of the British Columbia land title system relevant to this report.

The law conceives of land, which is also known as real property or realty, as a bundle of individual property rights which can be divided into component property rights. A landowner can transfer some or all of these rights to another person, a conservation group or a government. For instance, a landowner can lease land or grant a profit a prendre by carving out specific rights from the overall bundle of property rights and transferring them to someone else.

In earlier times there was no system for keeping track of who had done what with that bundle of property rights. This had serious drawbacks, since it was difficult for anyone dealing with a landowner, such as a prospective purchaser or lender, to know if the landowner really owned all the rights to the land. A basic legal rule is that a purchaser cannot acquire any legal rights which were not the seller's to give. So purchasers were always nervous that someone would claim to have acquired an interest in the land from a previous owner.

The problems resulting from this state of affairs led to legislation in various jurisdictions creating systems for registration of all dealings with land. The current land title system in British Columbia, which is established by the Land Title Act, provides certainty as to dealings with land. Subject to certain exceptions, [[Footnote: (12) -- 12. Such as the limits set out in section 23 of the Land Title Act regarding municipal taxes.]] the present statutory regime is designed to ensure that anyone who wishes to purchase land can search the title records kept by the Land Title Office and be certain of what they are getting.

This certainty has been achieved by providing in the Land Title Act that every owner registered in the Land Title Office has a good and marketable title to the land he or she is shown as owning. [[Footnote: (13) -- 13. Land Title Act, s. 23.]] Therefore, if Jane Doe is registered in the Land Title Office as the owner of certain land, that normally settles the matter. Subject to some rarely encountered exceptions, [[Footnote: (14) -- 14. Such as the right of a person to show fraud in which the registered owner has participated. See Land Title Act, s. 23(1)(j). End of Footnote]] z her registration under the Land Title Act as owner of the land assures everyone that she is the owner of the land.

The system also records lesser interests in land, such as the rights of mortgagees or holders of easements. [[Footnote: (15) -- 15. It should be noted that section 26 of the Land Title Act provides that only the fee simple interest is indefeasible; lesser interests such as easements -- or conservation covenants -- are open to challenges to their validity. Although beyond the scope of this report, some consideration should be given to whether conservation covenants should also be indefeasible and immune from challenge.]] For example, if Jane Doe has mortgaged her land, registration of the mortgage in the Land Title Office gives everyone notice of the mortgage company's rights under the mortgage. Everyone who deals with the land -- for example, a second mortgagee -- is subject to the first mortgagee's rights. If anyone buys the land from Jane Doe and the two mortgages are not discharged, the purchaser becomes bound by them.

This has important implications in the land preservation context. If it were possible to register a conservation covenant of the type recommended by this report against title to Jane Doe's land, anyone who later bought the land from Jane Doe, or who was later registered as the holder of a mortgage of the land, would be bound by the covenant and would be required to observe it. Anyone who acquired an interest in the land after the covenant had been registered would be deemed by the Land Title Act to have had notice of the obligation and therefore would be bound by it. [[Footnote: (16) -- 16. As always in the law, there are important exceptions to this, some of which are discussed in this report in connection with conservation covenants.]]

Despite some important exceptions to this system, if law reform in British Columbia proceeds as recommended in this report, conservation covenants could very effectively bind parties who later deal with the land. This ability to affect people who later deal with the land would make conservation covenants an effective tool for the voluntary preservation of private land.

1.7 Organization of this Report

The remainder of this report is organized as follows:


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