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[Buckeye]

Here is the official letter that went out from the SFAB on their opposition
to listing Interior Fraser Coho for those who have not seen it.

Sport Fishing Advisory Board.
Pacific Region, D.F.O.,
c/o 127, South Thulin St., Campbell River, British Columbia, V9W 2J8.
Tel / Fax: (250) 286–1456.

Trevor Swerdfager
Director General, Canadian Wildlife Service,
Environment Canada,
351,St. Joseph Boulevard,
Gatineau,
Quebec
K1A 0H3.                                                                        trevor.swerdfager@ec.gc.ca.

December 19th, 2005.

Dear Sir,

This letter is in response to the proposal to list Interior Fraser coho as endangered under the Species At Risk Act as described in the Canada Gazette (Part 1, Vol. 139, No. 50 — December 10, 2005). The Sport Fishing Advisory Board (SFAB) is the community based advisory and consultation process between the Pacific regional recreational fishery and Fisheries and Oceans Canada (DFO). Because the recreational fishery is the avenue by which most citizens access the common property fisheries resource of this country, in effect the SFAB speaks for the Canadian public in matters of this kind; formed in 1964, the SFAB is thought to be the longest running consultation process between any fishery anywhere in Canada and DFO.

The SFAB wishes to express its grave concern regarding the process to develop the recommendation and consequently does not support the proposal to list Interior Fraser coho salmon as endangered for reasons described below. The Board requests that your office seriously consider not continuing with this listing as described in the Canada Gazette.

Science

The SFAB is troubled by what might be termed the “politics” of the COSEWIC /SARA process. Several years ago SFAB representatives were startled to learn from Dr. Mart Gross that the Fisheries Committee of COSEWIC had not
recommended an endangered listing for Interior Fraser coho but rather was evenly split between recommending categorizing these fish as either of special concern or
threatened. Ignoring this advice by the specialists, the main COSEWIC decided to categorize these fish as endangered because the committee lacked faith that the federal government had sufficient resolve (pre-SARA) to deal with the systemic issues afflicting Interior Fraser coho. The SFAB thinks it vitally important that your office consider this fact when deciding whether to list these fish as endangered.

Additionally, the SFAB is concerned that the federal government is proposing to list as endangered a stock of anadromous fish that has been returning in numbers varying between 20,000 and 45,000 animals in recent years, while earlier this year it decided not to list two other proposed stocks (Sakinaw and Cultus Lake sockeye), returns for which in the same period have ranged between 3 and several hundred fish. The SFAB questions how the Interior Fraser coho population that is described in the Canada Gazette as one which since 2000 “the population has started to recover, such that escapement levels are well above minimum viable population levels” can be properly categorized as “endangered”. In fact, in the recently released “2006 Salmon Outlook” DFO described Interior coho stocks as “low” with a ranking of 2 out of a possible 4.

Consultation

Consultation with the public regarding this listing proposal was seriously flawed. While the government of Canada claims that “Public consultation is an essential part of the regulatory and decision-making process” and the Canada Gazette states that “DFO undertook consultation throughout British Columbia” to secure information on Interior Fraser coho, you should know that this is simply not true. For example on Vancouver Island, the tidal waters all around which the Canada Gazette accurately notes is the marine area where Interior Fraser coho are predominantly found, there were exactly two (Nanaimo and Port Hardy) two hour public open houses in the fall 2005 round of consultations at which SARA was but one of several important topics listed for discussion.

We acknowledge that there was a two-day, multi-stakeholder forum requiring pre-registration in Nanaimo this fall but attendance required a commitment by participants of significant travel and living expenses and once again the time was spread amongst numerous other important topics. At a similar two-day meeting in Vancouver discussion of SARA was expressly excluded from the agenda and there was no opportunity for the public at all in the interior of the province, right in the home range of these fish of concern.   

Most importantly, DFO did not consult with the recreational fishery through the SFAB as a whole even though the Board represents this stakeholder group, one that will suffer the largest socio-economic impacts of a listing and despite the fact that this is what the Board was developed for by the government of Canada. We regard this as a significant oversight and reflects a number of serious flaws in the consultation process.

As a further illustration, although not yet SARA listed in 2004/5 the SFAB was advised that DFO would be developing a Recovery Strategy for Interior Fraser coho and the Board was allowed to have one representative (Bob Otway) as a participant. While highly knowledgeable about the freshwater habitat of these fish, Mr. Otway was candid about his relative lack of experience regarding Interior Fraser coho in the other areas they inhabit during their life cycle and expressed considerable frustration about the inability of securing additional recreational fishery input to the draft Recovery Strategy. This is where the broad SFAB process should have been fully engaged by DFO.

Fish management and costs associated with a SARA listing

The SFAB does not dispute that the Interior Fraser coho stock is less abundant than it could or should be and fully supports reasoned strategies to see this stock increase to a more optimum population level. Your office should be aware that although the recreational fishery has borne enormous negative consequences since the move to non-retention (excepting some terminal harvest opportunities for specific healthy stocks in non-mixed stock areas) of all wild coho (not just Interior Fraser) since 1998 in southern BC, it remains supportive of the non-retention approach as one part of a broad suite of measures until such time as the wild coho population of concern has recovered to the extent it can sustain some harvest.

Given that non-retention of wild coho is expected to remain a fixture in the management of almost all salmon fisheries in southern BC for the foreseeable future, the SFAB is alarmed by the forecast (Canada Gazette under “Costs”) of “losses in recreational sector revenue resulting from reduced angling opportunities could be between $41.9 million and $227 million” over the next ten years. Because of the existing wild coho non-retention regulation, this implies that there will be time and area specific closures of all fishing in the recreational fishery as part of an Interior Fraser coho Recovery Strategy. We repeat that the federal government (DFO) has not consulted with the SFAB in regard to this.

The loss of any Interior Fraser coho due to the activities of the regional recreational fishery is limited to the accidental mortality of a very small number of fish when released. Studies have been performed on this topic and the number of mortalities, while varying with inter-annual abundance, is thought to be very low, in the order of several dozen fish annually out of a population measured in several tens of thousands. Your office should be aware that time and area fishing closures in the recreational fishery to provide additional protection for Interior Fraser coho will have large and negative socio-economic consequences entirely disproportionate to any hoped for additional conservation benefit. The SFAB notes that the decision to not list several Atlantic Cod populations was based upon the “potential unacceptable socio-economic impacts on Canadians and coastal communities of Atlantic Canada” and asks that the same consideration be applied on the Pacific coast.

In the event of a SARA listing for Interior Fraser coho, the SFAB also questions how government intends to deal with the issue of “incidental harm permits”. Given the potential distribution area of these fish, is it anticipated that every single fisherman, commercial as well as recreational, in both fresh and saltwater will have to carry such a permit? If so, is the issuance of approximately half a million such permits annually consistent with the meaning of SARA? If not, what does SARA really stand for?

Next steps

In the short term, in consideration of both the season and the flawed consultation process with the recreational fishery the SFAB requests that your office extend the time allowed for comment on the proposed listing of Interior Fraser coho for an additional 45 days beyond the current deadline. In addition we request that the appropriate DFO and Environment Canada staff be directed to attend the next main SFAB meeting (January 27/28, 2006 in Richmond, BC) to conduct meaningful consultation with representatives of the fishery most at jeopardy from this proposal.

On behalf of the Pacific regional recreational fishery, yours sincerely,



Jeremy Maynard, Chairman, SFAB.


c.c.  Hon. Stephane Dion, Minister of the Environment.
       Hon. Geoff Regan, Minister, Fisheries and Oceans Canada.
       Dr. John Davis, SARA office at DFO.
       Paul Sprout, Regional Director-General, Pacific region DFO.
       Devona Adams, Regional recreational fisheries coordinator, DFO.
       SFAB executive.

[Buckeye]

The SFAB process plays a big role in all of these events and I would
continue to urge those who read this to belong to a club or organization
that is supportive of the SFAB process.  These days memberships are
generally very cheap and some complain that they do not get anything for the
money spent.  Let me assure you again that this is absolutely false as most
clubs have members on all kinds of boards and are represented at
consultation meetings, which help you stay fishing.  It is not easy these
days and active participation is somewhat rare for most.  So at a very
minimum join a club by paying your dues so that they can show DFO that they
have your backing.