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 5 pm and you don’t have to worry about Fisheries. 

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 Vancouver in 2000 which was well attended by volunteer groups.  At this meeting DFO purported to be seeking input on future directions.  There was a widespread consensus amongst the volunteer groups that the priorities were increased protection and more education especially in the schools.

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, Salmon River Enhancement Society

Comments on the Wild Salmon Policy Salmon Enhancement and Habitat Advisory Board

February 2005 www.sehab.org Chair George Farrell hssk@qcislands.net

1

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.

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,

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.