OldBlackDog
Well-Known Member
Nothing More to Lose
The following is my last ditch attempt to get the feds to pay a bit of attention to what they are doing to a resource whose value they have ignored consistently for as long as any of us have been sounding the alarm. What are the chances? The email has been sent and receipt acknowledged.
Dear Ministers McKenna and Wilkinson:
As you know, we are at the deadline for public comment with respect to the potential listing of Interior Fraser Steelhead under Canada’s Species At Risk Act. The processes leading to this final moment have been inestimably costly and time consuming. The average citizen can only scratch the surface of the mountain of material that dozens of your respective staffs would seem to expect us to keep up with.
Since the original undertakings by your own Committee on the Status of Endangered Wildlife in Canada in reviewing all available information and finalizing its recommendation for an emergency SARA listing of IFS as endangered, DFO has managed to orchestrate another full fishing season essentially unaltered from the one that saw the COSEWIC recommendation advanced. Furthermore, the combined efforts of DFO and ECCC have set the stage for enough process to see another one unfold with similarly toothless constraints.
The long awaited Recovery Potential Assessment report that was intended to provide a summary and analysis of all the “science” related to IFS and inform all those with an interest on the likelihood of ever seeing the trends in Thompson and Chilcotin steelhead abundance stabilize and reverse themselves finally arrived one week in advance of your Dec 2 deadline for comment. The flurry of activity and lobbying that has ensued in the days since has been that much more to try and keep up with. Many of the issues identified in the draft of the RPA that found its way into the hands of a select audience in mid-September consumed much time and energy of those who managed to scratch up a copy of that document and organize their thoughts in terms of a response. Then came the final report (with no authorship identified) which moved the goal posts substantially and left myself and many others wondering what purpose there is in offering comment. That said, I will make a few observations for the record.
Science is trotted out as the basis for decisions by your respective Ministries. You would have us believe everything you do revolves around good science and the precautionary principle (i.e. conservatism) prevails in its absence. More commonly, though, a lack of science deemed adequate by your staffs becomes the excuse for maintaining the status quo. For IFS the abundance has been driven so low by harvest fisheries focused on co-migrating salmon stocks for so long there are not enough of those steelhead left to be able to provide anywhere near the confidence in any numbers the best of the best stock assessment science of the moment can come up with. Think about this Minister Wilkinson. Your staff has been 100% complicit in allowing the commercial fishing sector to operate in the absence of any compliance with steelhead related conditions of license and catch reporting since steelhead stock assessment efforts began in earnest with the advent of the Salmonid Enhancement Program more than forty years ago. You can confirm that in mere moments by glancing at the DFO records of how many steelhead have been reported caught (and released, of course) by seiners and gill netters in any of the approach waters to the Fraser River or by gill netters in the lower Fraser itself in the past decade or any longer period you might wish to review. Then tell me how many commercial fishers have ever been charged for failure to comply with any of the rules. Meanwhile the status quo has prevailed and the IFS numbers have continued their downward trend. How do you prescribe science based management actions when the leftovers of decades of these practices and behaviour amounted to four steelhead at your Albion test fishery in 2017 and six in 2018? How do you counter the chronic position of the commercial sector they aren’t and never have been part of the problem when they repeatedly trot out your own catch records that indicate they rarely, if ever, catch any? No data is consistently interpreted as no problem.
Where is the precautionary principle with respect to IFS? If any significant salmon stock in the Fraser system had dwindled to 150 spawners (Thompson this past spring) red lights would flash. Fisheries would be shut down immediately. There would be no debate about rolling window closures, re-configuring gill nets and their deployment, pretending to hold some level of control over a long list of First Nations communities each with its own spectrum of fisheries (conventional fishing with gill nets and seines, FSC fisheries, economic opportunity fisheries, etc.). Conservation would be the object of the moment. Why not IFS?
The history of salmon abundance in this province is replete with examples of over harvest by commercial fishers. Season lengths, number of days fished and gear restrictions have been adjusted constantly in an ongoing game of defence to match the latest, greatest offence by commercial fishing fleets but stocks continued to decline. All of that was abundantly clear long before pinniped populations in the Fraser River approaches began to grow, before there were enhanced pink and chum salmon influencing the productive capacity of the central north Pacific and Gulf of Alaska and before anyone had ever heard of El Nino, La Nina and “the blob”. But, what does the RPA focus on today? Almost everything but the harvest related declines that predated them. Why haven’t we learned that harvest management is the primary tool to address the declines? What does it take? How much more “science” will it take to support doing the obvious?
The other aspect of the RPA that is terribly inadequately addressed is the First Nations fishing impacts. Everyone understands the constitutionally protected priorities of conservation, FN fisheries and then commercial and recreational fishers but what has happened to that first priority of conservation? We’re down to 150 Thompson system spawners in 2018. Chilcotin has all but fallen off the radar entirely and those other four stocks in the same IFS grouping (Nahatlatch, Stein, Bridge and Seton) don’t even warrant an honourable mention. If that isn’t enough to be labelled a conservation crisis, what is? How can any fisheries, especially set and drift net fisheries for enhanced chum salmon (primarily for their roe) that were hardly a component of FN fisheries historically be conducted right on top of the last remnants of passing IFS? When will our FN communities of the lower and middle Fraser walk their talk about responsible resource stewardship. When will they co-operate rather than compete for fish along the migration corridor for IFS and so many other stocks and species on a similar downward trend? When will our governments force that to happen rather than constantly indulging in consultative processes that have done nothing but take us further along the path of no return?
Minister Wilkinson, your staff don’t even monitor steelhead harvest by FN fishers. Your own records reveal a grand total of one steelhead harvested during the return period of IFS this late summer and fall for the entire area from Tsawwassen to Sawmill Creek. Your Director General tells me there are observers out on the water monitoring all FN fishing openings and at every FN fishery landing station. Multiple contacts with extensive on the water experience this year instruct me that is pure nonsense. The catch records would confirm that. How do such realities factor in to the RPA? How can the best stock assessment and computer modelling experts available not recognize and incorporate such realities in their outputs?
I leave you with one final observation. The least impactful fishery of all, the recreational fishery, is strictly forbidden wherever and whenever IFS may be encountered. Who recognizes the consequences of that? The commercial sector descended on politicians immediately following the first hint of a SARA listing of IFS, complaining bitterly about the potential economic consequences. It isn’t potential consequences for the recreational fishery. The economic impacts have already arrived. Perhaps a visit to Spences Bridge would help you appreciate what that looks like. Perhaps some intransigent commercial fishery spokespersons could accompany you. Why should the least impactful sector pay so disproportionately for conservation?
Ministers, this is all happening on your watch. You can be remembered for being conservation advocates and sustaining fish or for sustaining fisheries that are certain to lead IFS over the brink with many other stocks of salmon following the precedent you set. The choice is yours.
R.S. Hooton
Nanaimo, BC
The following is my last ditch attempt to get the feds to pay a bit of attention to what they are doing to a resource whose value they have ignored consistently for as long as any of us have been sounding the alarm. What are the chances? The email has been sent and receipt acknowledged.
Dear Ministers McKenna and Wilkinson:
As you know, we are at the deadline for public comment with respect to the potential listing of Interior Fraser Steelhead under Canada’s Species At Risk Act. The processes leading to this final moment have been inestimably costly and time consuming. The average citizen can only scratch the surface of the mountain of material that dozens of your respective staffs would seem to expect us to keep up with.
Since the original undertakings by your own Committee on the Status of Endangered Wildlife in Canada in reviewing all available information and finalizing its recommendation for an emergency SARA listing of IFS as endangered, DFO has managed to orchestrate another full fishing season essentially unaltered from the one that saw the COSEWIC recommendation advanced. Furthermore, the combined efforts of DFO and ECCC have set the stage for enough process to see another one unfold with similarly toothless constraints.
The long awaited Recovery Potential Assessment report that was intended to provide a summary and analysis of all the “science” related to IFS and inform all those with an interest on the likelihood of ever seeing the trends in Thompson and Chilcotin steelhead abundance stabilize and reverse themselves finally arrived one week in advance of your Dec 2 deadline for comment. The flurry of activity and lobbying that has ensued in the days since has been that much more to try and keep up with. Many of the issues identified in the draft of the RPA that found its way into the hands of a select audience in mid-September consumed much time and energy of those who managed to scratch up a copy of that document and organize their thoughts in terms of a response. Then came the final report (with no authorship identified) which moved the goal posts substantially and left myself and many others wondering what purpose there is in offering comment. That said, I will make a few observations for the record.
Science is trotted out as the basis for decisions by your respective Ministries. You would have us believe everything you do revolves around good science and the precautionary principle (i.e. conservatism) prevails in its absence. More commonly, though, a lack of science deemed adequate by your staffs becomes the excuse for maintaining the status quo. For IFS the abundance has been driven so low by harvest fisheries focused on co-migrating salmon stocks for so long there are not enough of those steelhead left to be able to provide anywhere near the confidence in any numbers the best of the best stock assessment science of the moment can come up with. Think about this Minister Wilkinson. Your staff has been 100% complicit in allowing the commercial fishing sector to operate in the absence of any compliance with steelhead related conditions of license and catch reporting since steelhead stock assessment efforts began in earnest with the advent of the Salmonid Enhancement Program more than forty years ago. You can confirm that in mere moments by glancing at the DFO records of how many steelhead have been reported caught (and released, of course) by seiners and gill netters in any of the approach waters to the Fraser River or by gill netters in the lower Fraser itself in the past decade or any longer period you might wish to review. Then tell me how many commercial fishers have ever been charged for failure to comply with any of the rules. Meanwhile the status quo has prevailed and the IFS numbers have continued their downward trend. How do you prescribe science based management actions when the leftovers of decades of these practices and behaviour amounted to four steelhead at your Albion test fishery in 2017 and six in 2018? How do you counter the chronic position of the commercial sector they aren’t and never have been part of the problem when they repeatedly trot out your own catch records that indicate they rarely, if ever, catch any? No data is consistently interpreted as no problem.
Where is the precautionary principle with respect to IFS? If any significant salmon stock in the Fraser system had dwindled to 150 spawners (Thompson this past spring) red lights would flash. Fisheries would be shut down immediately. There would be no debate about rolling window closures, re-configuring gill nets and their deployment, pretending to hold some level of control over a long list of First Nations communities each with its own spectrum of fisheries (conventional fishing with gill nets and seines, FSC fisheries, economic opportunity fisheries, etc.). Conservation would be the object of the moment. Why not IFS?
The history of salmon abundance in this province is replete with examples of over harvest by commercial fishers. Season lengths, number of days fished and gear restrictions have been adjusted constantly in an ongoing game of defence to match the latest, greatest offence by commercial fishing fleets but stocks continued to decline. All of that was abundantly clear long before pinniped populations in the Fraser River approaches began to grow, before there were enhanced pink and chum salmon influencing the productive capacity of the central north Pacific and Gulf of Alaska and before anyone had ever heard of El Nino, La Nina and “the blob”. But, what does the RPA focus on today? Almost everything but the harvest related declines that predated them. Why haven’t we learned that harvest management is the primary tool to address the declines? What does it take? How much more “science” will it take to support doing the obvious?
The other aspect of the RPA that is terribly inadequately addressed is the First Nations fishing impacts. Everyone understands the constitutionally protected priorities of conservation, FN fisheries and then commercial and recreational fishers but what has happened to that first priority of conservation? We’re down to 150 Thompson system spawners in 2018. Chilcotin has all but fallen off the radar entirely and those other four stocks in the same IFS grouping (Nahatlatch, Stein, Bridge and Seton) don’t even warrant an honourable mention. If that isn’t enough to be labelled a conservation crisis, what is? How can any fisheries, especially set and drift net fisheries for enhanced chum salmon (primarily for their roe) that were hardly a component of FN fisheries historically be conducted right on top of the last remnants of passing IFS? When will our FN communities of the lower and middle Fraser walk their talk about responsible resource stewardship. When will they co-operate rather than compete for fish along the migration corridor for IFS and so many other stocks and species on a similar downward trend? When will our governments force that to happen rather than constantly indulging in consultative processes that have done nothing but take us further along the path of no return?
Minister Wilkinson, your staff don’t even monitor steelhead harvest by FN fishers. Your own records reveal a grand total of one steelhead harvested during the return period of IFS this late summer and fall for the entire area from Tsawwassen to Sawmill Creek. Your Director General tells me there are observers out on the water monitoring all FN fishing openings and at every FN fishery landing station. Multiple contacts with extensive on the water experience this year instruct me that is pure nonsense. The catch records would confirm that. How do such realities factor in to the RPA? How can the best stock assessment and computer modelling experts available not recognize and incorporate such realities in their outputs?
I leave you with one final observation. The least impactful fishery of all, the recreational fishery, is strictly forbidden wherever and whenever IFS may be encountered. Who recognizes the consequences of that? The commercial sector descended on politicians immediately following the first hint of a SARA listing of IFS, complaining bitterly about the potential economic consequences. It isn’t potential consequences for the recreational fishery. The economic impacts have already arrived. Perhaps a visit to Spences Bridge would help you appreciate what that looks like. Perhaps some intransigent commercial fishery spokespersons could accompany you. Why should the least impactful sector pay so disproportionately for conservation?
Ministers, this is all happening on your watch. You can be remembered for being conservation advocates and sustaining fish or for sustaining fisheries that are certain to lead IFS over the brink with many other stocks of salmon following the precedent you set. The choice is yours.
R.S. Hooton
Nanaimo, BC
