Sample letter to PM
June 5, 2012
Prime Minister Stephen Harper
Office of the Prime Minister
80 Wellington Street
Ottawa, ON K1A 0A2
Dear Prime Minister Harper,
The United Fishermen and Allied Workers’ Union – CAW and the T. Buck Suzuki Environmental Foundation are strongly opposed to the changes to fish habitat protection in the federal Fisheries Act as detailed in Bill C-38.
Our two organizations have memberships based in the commercial fishing industry on the B.C. coast, an industry that employs more than 12,000 people in various fisheries and in the fish processing sector.
Although the proposed changes to the Fisheries Act habitat seem to take into account fish habitat that “supports fisheries,” we firmly believe that the suite of changes will significantly reduce current fish habitat protection and put B.C. fishery jobs in jeopardy.
Habitat alteration and disruption
The current wording in the Fisheries Act in prohibiting the “harmful alteration, disruption and destruction” of habitat acknowledges the complexity of fish habitat requirements, particularly freshwater habitat for juvenile and spawning salmon. By changing the Act to prohibit only “permanent alteration” or “destruction” of habitat ignores the extremely sensitive biological needs for salmon including: pristine spawning channels with no disruption of salmon eggs through winter months, adequate water flows at all stages in freshwater systems, no sedimentation or other water quality degradation, undisturbed rearing areas for juvenile salmon, and no impassable blockages in any part of a stream or river system through the entire migratory corridor during both in-migration for spawning adults and out-migration of juvenile salmon. Temporary alteration or disruption of any one of these habitat functions could create significant harm to an entire run of salmon to a particular stream system. Some salmon species remain in freshwater for one to two years and cannot survive with any of these habitat functions disrupted. It is essential that “harmful alteration, disruption and destruction” of habitat remains the cornerstone of Fisheries Act habitat protection.
What constitutes a “fishery”
Although some attempt has been made in Bill C-38 to specifically protect habitat for fish that are part of or support a “commercial, recreational or Aboriginal fishery,” we do not believe that this vaguely worded section will actually protect all the habitat we rely on for our livelihoods. Does this only relate to “fisheries” that are currently conducted? If so, it ignores and thereby does not protect habitat in salmon river systems that were historically fished but have been closed for some years. An example would be the Owikeeno River and tributaries feeding into Rivers Inlet that at one point twenty years ago produced millions of salmon and supported the third largest commercial salmon fishery on the B.C. coast. The salmon runs of Rivers Inlet are slowly rebuilding and could yet again become a potential fishery, but may be excluded from habitat protection provisions worded in this manner and could be seriously damaged through forestry and other impacts if the federal Fisheries Act is changed.
A second serious concern is that tying habitat protection to a “fishery” implies that the onus would be on commercial, recreational and aboriginal fish harvesters to document and prove that particular habitat is tied to a specific fishery. A Chinook salmon caught in the recreational fishery off Haida Gwaii or a pink salmon caught by the commercial fishery in northern coastal waters could have come from any number of watersheds. And although DNA testing over the years has created a general picture of the timing and location of specific spawning stocks, literally thousands of streams in B.C. have not been studied enough to make a definitive link to a fishery, given that fishing can take place a thousand kilometres from a natal spawning bed.
We have seen major cuts to Fisheries and Oceans staffing and budgets over the last 10 years making it increasingly difficult for the department to keep up its scientific research, its habitat monitoring and its enforcement capabilities. Reducing the scope of the protection of the habitat provisions of the Fisheries Act could lead to a further reduction in staffing levels to the point where the Department is no longer able to work with industries to properly plan development to safeguard habitat, an important pro-active role that the Department has played for decades. It also must be said that it has been the strong wording of the habitat provisions of the current Fisheries Act that has given the Department the clout to negotiate habitat protection at the development planning stage, and this function may be in jeopardy.
We call on the Prime Minister and the Minister of Fisheries and Oceans to immediately withdraw the fish habitat protection provisions embodied in Bill C-38 Fisheries Act amendments and consult with the B.C. commercial fishing sector, conservation groups and other stakeholders about ways to make the existing Fisheries Act habitat protection provisions work better for both habitat preservation and sustainable economic development for all sectors.
E. Irvin Figg
Executive Director, T. Buck Suzuki Environmental Foundation