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First
we would like to say that we have been involved in the feedback process
initiated by SEHAB and agree with the comments they have forwarded to you. We
would also like to comment specifically on the first two principles mentioned in
the Wild Salmon Policy document. 1)
The first
principle is stated to be protection of the resource yet Fisheries and Oceans
has consistently failed to provide adequate resources for habitat protection and
enforcement. Everyone knows that
you just wait until after 2)
The
second principle mentions an open and consultative process.
Our experience with DFO has been that consultations are not sought
regularly and when they are sought they are often token. We
recall a meeting in We
all know that since then protection has become even more pitiful than it was.
This has continued despite further letters from our group and from SEHAB
requesting improvement in protection and pointing out how significant this issue
is to volunteer groups. It is
difficult to remain motivated when you see that DFO is not doing their part.
The
education programs that were already in place in 2000 have continued but there
has not been a significant effort to expand these programs they way that they
need to be expanded to improve environmental awareness.
It
is difficult to see the 2000 “consultation” as being anything more than
token. A
policy is, after all, only a policy. The
real measure of DFO is whether they are accomplishing what needs to be
accomplished “on the ground”. One
hesitates to think of how many thousands of hours have been spent drafting the
Wild Salmon Policy when a small fraction of those hours and resources could be
allocated to providing more field personnel who could actually improve the
enforcement and education issues
that are important to the community. Doug
McFee Director,
Comments on the Wild Salmon Policy Salmon Enhancement and Habitat Advisory Board February 2005 www.sehab.org Chair George Farrell hssk@qcislands.net 1 Strategy 1- Standardized Monitoring of Wild Salmon Status 1. What advice do you have about the delineation of CU’s and the protection of genetic diversity? The creation or delineation of Conservation Units (CU’s) does nothing to protect or recognize the need to maintain biodiversity within watersheds. Maintaining genetic diversity is not the same as maintaining biodiversity or the role of salmon in watershed functioning. The WSP does not recognize this difference clearly. Safeguarding genetic diversity in a large CU may: • Ignore the role of salmon in watershed functioning and biodiversity, and; • Enable decision-makers to focus on specific salmon populations and habitat areas at the expense of other populations and habitats in the CU. Salmon provide many ecosystem benefits, beyond their economic value and genetic diversity. They include: • Marine-derived nutrients to freshwater and terrestrial ecosystems; • Protein in the form of eggs, fry, smolts and adults to over 317 keystone species, including eagles, bears and other higher level predators, and; • Stream substrate enhancement by removing fine sediment during spawning. Delineating genetic diversity requires DNA testing. Does DFO Pacific Region have the financial and professional resources to accomplish comprehensive DNA testing? Does DFO have the resources to delineate CU’s on the basis of genetic information? Separate and unique populations have not been well documented in BC. There are also traits based on genetic differences (genotypes) versus those based on external appearance and learned behaviour (phenotypes), with the latter contributing to diversity but indistinguishable genetically. Currently, the only means of delineating these distinct populations may be through years of observation. CU’s must be a manageable size and be determined based on these distinct individual populations. The CU size will likely vary, and even a watershed may be too large a scale for protecting genetic diversity. Sub-basins and/or sub-areas can be managed effectively and may prove to be the largest unit in which a diverse population or populations can be delineated.1 The WSP delineates a small number of large CU’s for fisheries management decisions, as opposed to the current large number of management areas. This decision may be a direct result of the low quantity and quality of annual data for habitat, stock and spawning inventories and assessments available. Information-gathering resources have been strained for years and there do not appear to be any new funding initiatives. While CU’s may be a legitimate management tool, 1 For example, in the Tsolum River, coho in headwater tributaries (e.g., Pup Creek and Joshua Creek) appear to be separate and unique populations. No matter the number of coho observed entering the Tsolum system, Pup and Joshua Creek have nearly identical numbers of coho spawners year after year. It appears that Pup Creek and Joshua Creek coho are born, reared and return to these tiny creeks.
The Salmon Enhancement and Habitat Advisory Board contact www.sehab.org Advocate for the Volunteer Community Committed to Ensuring a Healthy Salmonid Resource. February 17, 2005 The Honourable Geoff Regan Minister of Fisheries and Oceans and Wild Salmon Policy Consultations Policy and Economic Analysis Branch Fisheries and Oceans Canada 200-401 Burrard St. Vancouver, BC V6C 3S4 Dear Minister Regan, RE: Public Consultation on the Wild Salmon Policy The Salmon Enhancement and Habitat Advisory Board (SEHAB) provides a liaison between Fisheries and Oceans Canada (DFO) and communities and volunteers engaged in salmon restoration, stream monitoring and habitat work in urban and rural British Columbia. We understand and appreciate the links between healthy stocks, sound harvesting practices, good land use practices, monitoring and enforcement, and the need for cooperation among the various stakeholders in government, industry, First Nations and community. Some of our members and their fellow volunteers’ projects predate the Salmonid Enhancement Program (SEP) (late 1970s). SEP and the Streamkeepers Program (1994) have effectively linked communities with the salmon resource and associated decision-making processes; this community can now provide valuable information on habitat health and fish populations at a time when the Department needs a partner to help complete these important tasks. SEHAB understands that the Wild Salmon Policy (WSP) represents a considerable change in policy regarding sustainability of wild salmon stocks, and that "A key consideration of the policy is to find the appropriate balance among social, economic and biological benefits and risks, in order to make the right decisions." (Press release Dec. 17, 2004, Minister Regan). SEHAB has reviewed both the initial draft and the current Wild Salmon Policy (WSP) and provides the attached comments based on considerable consultation among member organizations. Our broad conclusions are, unfortunately, the same as our concerns going into the review. The protection of wild salmon through the use of the WSP will not work as long as human activity continues to degrade habitat – we need strong enforcement of habitat protection.
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