Recieved today the report from the 2009 Spring Report of the Commissioner of the Environment and Sustainable Development. I have extracted some from the report that is pertaining to the gravel removal on the Fraser River that we have been working on for some time. I think you will agree we were correct on taking this on and some politicans have not been up front in what they have been saying. Interesting it was released on the day of the election.
Project proposal. Fisheries and Oceans Canada, the Province of British Columbia, local governments, and First Nations agreed to gravel removal from the Fraser River, largely for flood and erosion management. Gravel deposits and the shifting flow of the Fraser River create bars, islands, and secondary channels between Hope and Mission, British Columbia. This area has high-quality habitat for at least 28 species of fish. The Department determined that gravel removal was harmful to fish habitat.
In 2004, the Department signed a Letter of Agreement with the Province of British Columbia to develop a five-year Gravel Removal Plan. Numerous project proponents (companies interested in removing gravel and selling it) submitted proposals to the Department. A number of ministerial authorizations have been issued and continue to be issued.
The following information provides examples of the Department’s approach to approving and monitoring these proposals and highlights some of the challenges it faces in implementing the Habitat Policy.
Flood control. Engineering and scientific studies at different sites, some commissioned by the Department, concluded there was no reduction in the flood profile after gravel removal. These studies stated that changes in the flood profile were minimal in the removal area and were local to the removal site. Thus, gravel removal would not significantly affect the potential for flooding.
Damage to sensitive habitat. Projects in areas that are sensitive habitat for both salmon and sturgeon are high risk, but adequate information on fish stocks to assess project impacts was lacking for a number of the ministerial authorizations for gravel removal. In 2006, improper construction of a causeway for accessing one gravel removal site resulted in a side channel downstream drying up, exposing salmon nests and resulting in the loss of up to 2.25 million pink salmon.
Lack of compensation plans. The ministerial authorizations did not include compensation plans. The Department believes that compensation plans are not required on the assumption that new gravel will replace gravel removed over one to three spring runoffs. We found no documentation in the project files to support this position for large gravel removals, although there is evidence to the contrary. For example, 300,000 tonnes of gravel were mined from Foster Bar in 1995, but it has not been replaced to date. The Department advises us that the requirement for habitat compensation will be reviewed as part of the renegotiation of the 2004 Letter of Agreement, using the results of post-construction monitoring studies, lessons learned from removals under the 2004 agreement, and contemporary research.
Lack of monitoring. Although proponents are required to submit monitoring plans and surveys, there were few on file. These documents specify the conditions prior to gravel removal, during removal, and after removal, as required under the terms of the 2004 Letter of Agreement.
Lack of enforcement. The Department did not take enforcement action after a proponent failed to comply with the conditions of a ministerial authorization by exceeding the volume of gravel allowed to be extracted, destroying habitat, and mining outside the approved area. We could not find documentation to support the Department’s lack of enforcement action. The Department advised us that it was short of resources at the time of the proponent’s actions and that it is considered too late to pursue charges.