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What modern safeguards should be instituted in order to ensure appropriate protections for fish and fish habitat?

Conservation and Protection of Marine Shore Spawning Forage Fishes

SCORE:
5.0
Theme:Conservation and Protection of Fish & Fish Habitat
on 11/08/2016 1478583444
Marine shore spawning forage fishes (Surf smelt, Capelin, Pacific sand lance) have a spawning habitat that is extremely finite and imperiled.  Spawni .... Read More

Marine shore spawning forage fishes (Surf smelt, Capelin, Pacific sand lance) have a spawning habitat that is extremely finite and imperiled.  Spawning beds occur along certain marine beaches. The spawning areas are very narrow and no, these fish can't spawn elsewhere, unlike herring that in BC waters can spawn on SAV (submerged aquatic vegetation) and intertidal cobbles.

In Washington State, these beaches are listed and protected as "critical wild salmon habitat".

Soft-sediment marine beaches (pebble and sand) are built by erosionary processes of the land and from water courses.  Sediments transported to marine receiving waters build up beaches.

Hardening of backshore and foreshore areas degrades and destroys these CRITICAL fish habitat.  Removing marine riparian vegetation impacts the quality of the beaches and reduces insect prey for juvenile salmonids.  Driving on beaches destroys the embryos and reduced the quality of these habitats.

 

Sea level rise threatens these critical habitats due to placement of seawalls at the high water mark, resulting in what has been termed "coastal squeeze".  Normally, over geological time beaches would retreat landward with rising sea levels.  Due to seawalls and other hard infrastructure, these beaches cannot transgress landward.  

Lands zoned to the high water mark are creating a situation where beaches cannot move back.  Critical infrastructure for cities and private shoreline property owners are all at risk due to zoning to the high water mark.  Even with regional districts and the Province of British Columbia recognizing the issue of sea level rise, why are building permits still allowing this type of development to continue?

In 10 years of working to educate the public, government and conduct spawning surveys, I have learned that protecting human security, ecosystem services and spawning beaches is possible if we setback from the high water mark, respect drift cell sediment processes and keep oil, vehicles and high impact activities (horse riding etc) off beaches.

The health of the Strait of Georgia and Puget Sound (the Salish Sea) depends on protecting, enhancing and restoring marine shore spawning habitat.  These spawning beds are not seawalls in waiting.

Under the Fisheries Act, and due to the fact that these are forage fish (so of ecological importance to CRA fisheries) and commercially/recreationally fished as well, you would think that there would have been a regulatory framework in place, similar to herring, to protect them. 

 

Timing windows of least risk for Surf smelt and Pacific sand lance do not occur on DFO's website.  

Guidance does not exist for working around these habitats.

Professional reliance is near zero.

Unlike Washington Department of Fish and Wildlife, there are no habitat biologists in DFO trained and experienced in the area of marine shoreline spawning habitat.  Considering the importance of these fishes, it is shocking that they remain virtually ignored in British Columbia.

DFO's emphasis on freshwater systems has been to the detriment of marine shore spawning forage fishes as well as to their predators.

A restored DFO should include an "enhanced" DFO or a separate entity that can meet its statutory obligations that include marine shoreline habitat (from spawning beaches to marine riparian vegetation). 

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Fish-friendly floodgates and pumps

SCORE:
5.0
Theme:Conservation and Protection of Fish & Fish Habitat
on 11/09/2016 1478651399
Fish habitat found upstream of flood control structures in British Columbia’s lower Fraser Valley is not currently being managed as fish habitat .... Read More

Fish habitat found upstream of flood control structures in British Columbia’s lower Fraser Valley is not currently being managed as fish habitat. While fish passage appears to be addressed under Section 20 of the Fisheries Act, the on-the-ground reality represents  a grey area under the law, with Fisheries and Oceans Canada having little involvement or oversight. We would like this issue addressed in the current review of Fisheries Act legislation. We also request that the federal government require flood control upgrades to be fish friendly.

Most flood protection and irrigation infrastructure was installed at a time when fish needs were not considered, and fish stocks were healthier than they are today. Since then, flood infrastructure and related land use changes have cut off or degraded thousands of kilometers of former fish habitat in the lower Fraser Valley. Re-connecting degraded waterways to the Fraser and restoring habitat that was once home to vibrant populations of salmon will provide a significant contribution to local and regional salmon recovery goals.

Infrastructure spending for flood protection in the lower mainland is being guided by an interjurisdictional initiative between the Government of Canada and many other entities. This initiative is called The Lower Mainland Flood Management Strategy and it is now assessing strategies, priorities, and options for funding and implementation. Current standards do not include considerations for fish.

Fish-friendly solutions are compatible with flood protection requirements, and fish needs must be incorporated into this process. It is critical that federal funding be tied to and supportive of salmon access through any upgraded flood gates or pumps. It is the Federal government’s responsibility to protect fish habitat and we need federal leadership to act quickly to make this happen.

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Consider the Potential Value of Restored Habitat

SCORE:
5.0
Theme:Conservation and Protection of Fish & Fish Habitat
on 10/26/2016 1477462049
Consideration should be given to the historical quality and quantity of fish habitats which have been degraded or destroyed during modern times, and .... Read More

Consideration should be given to the historical quality and quantity of fish habitats which have been degraded or destroyed during modern times, and their potential value if restored. Care should be taken to ensure that these habitats are not further compromised by proposed activities which could render these habitats unrecoverable or further impact the health of the watershed. These situations are already part of a series of cumulative impacts which have resulted in the current state of fish populations and fish habitat, in order to achieve meaningful improvements in the health of watersheds across Canada many of these areas may need to be the focus of restoration efforts, or at the very least protected from further degradation. Restoring fish habitat will ultimately benefit all Canadians through the important ecosystem services they provide. Degrading fish habitats further will ultimately cost Canadians due to the loss of these valuable services, and the need to replace them with expensive and alternatives. 

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Inclusion of Bycatch in fisheries impact assesments

SCORE:
5.0
Theme:Conservation and Protection of Fish & Fish Habitat
on 11/03/2016 1478140626
Tags:
currently for commercial and industrial fishing we do not record the amounts of bycatch and what they compoistion is and toss them back into the ocean .... Read More

currently for commercial and industrial fishing we do not record the amounts of bycatch and what they compoistion is and toss them back into the ocean regardless of how healthy they are.We assume that they are:1) minimally stressed

2) Physically unharmed

3) Alive

4) Suffer no long lasting effectsThis is a flawed ideology as we know that capture is stressful. Some species are incredibly sensitive to changes in pressure (Rockfish/Rockcod) and have seen effect on their reproductive viability. some fishing operations operate at high bycatch rates because there is currently no laws/regulations to prevent such excess due to lack of data recording. If we wish to modernize our current stock assessment systems and have a better understanding of our populations we must include this data and adjust our maximum catches to reflect the effect these events have on the animals 

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Yes to Habitat Protection- No to Freighter Anchorages

SCORE:
5.0
Theme:Conservation and Protection of Fish & Fish Habitat
on 11/16/2016 1479327785
Tags:
  The present protocol for assessment of harm to fish or fish habitat needs an overhaul, beyond simply returning it to pre-2012 but instead going ab .... Read More

 

The present protocol for assessment of harm to fish or fish habitat needs an overhaul, beyond simply returning it to pre-2012 but instead going above that to a new and more robust assessment and monitoring mandate.   The present process is simply inadequate. Proponents seeking to develop a project are permitted, encouraged even, to do a self-assessment and self-determination. This protocol completely fails to achieve any positive outcome in protecting fish or fish habitat.

One only has to look at recent proposals such as the Pacific Pilotage Authority (PPA), with Port of Vancouver (PV) plan to install 5 super tanker anchorages off the pristine coastline of NE Gabriola Island in the Strait of Georgia as an example of a failed process.

The proponents, PPA, PV were permitted to self assess, to hire their own Environmental Assessment (EA) contractor, to set the EA parameters favourable to their desired outcomes. The resulting draft of the “Environmental Overview Assessment’ (EOA) amounted to little more than a ‘literature review’ of publications mostly 5 or more years old. One publication cited was over 30 years old!  In general, the findings in the report were ‘proven’ by assertion instead of by scientific evidence. Independent scientists and others reviewing the draft EOA identified many areas where there was failure of modeling (Underwater noise, air noise), failure to adequately identify harm to fish and other marine species, under-reporting of potential harm from chronic oiling, failure to identify the hazards of bunkering, transshipping. The list goes on. Suffice to say this was a flawed procedure that did nothing to protect fish and other species. In fact, one could argue that it increased the potential for harm in that it gave the appearance of due diligence where none existed.

The proponents tasked the EOA contractor to suggest ‘mitigation’ options. The ‘option’ to reduce the high degree of harm was to suggest that 3 of the 5 anchorages only be used sparingly. This highlights another flaw in the present system, the proponents can “tick the box” on the DFO form saying they have ‘mitigation’ in place. However the proponents are apparently under no obligation to comply once they have approval (or rather lack of ‘disapproval’) to go forward with the project.

Suggested changes:

  • Change the protocols to ensure that major projects cannot go forward until all aspects of the marine environment of the proposed site have been subjected to rigorous research by DFO scientists, to accurately identify and quantify the level of harm to fish or fish habitat.
  • Establish a baseline environmental assessment of a proposed project area.
  • Stop the protocol of self-assessment and self-mitigation.
  • Acknowledge that the ‘potential for harm’ is not restricted only to the immediate footprint of the proposed project. For example, chronic oiling from tankers/freighters at anchor could cause harm or mortality within adjacent forage fish spawning sites.
  • Remove the restriction that requires a link to commercial fisheries. For example the food chain relies on forage fish for the health of many of its species. Pacific Sand Lance (PSL) is not a ‘commercial’ fishery, but the salmon fishery, particularly Chinook, rely on healthy PSL stocks for their survival. Southern (and Northern) Resident killer whales rely on healthy Chinook stocks for their survival. Humpbacks rely on PSL, as do the endangered Marbled Murrelet and others.
  • Only approve ‘mitigation’ as an option where it can be demonstrated by DFO scientists that actual prevention of harm to fish or fish habitat is possible. Set stiff restrictions in place, closely monitor, and heavily penalize those proponents who do not abide by the DFO restrictions.
  • Give DFO the legal capacity to stop any proposal that will unavoidably cause harm to fish and fish habitat.
  • Re-evaluate the ‘off set’ program.
  • Hire more DFO staff to research, and monitor.

Thank you for this opportunity to contribute to the Phase 1 Review of Fish and Fish Habitat protections section of the Fisheries Act.

 

 

 

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Rétablir les compétences en ingénierie à la Protection des Pêches

SCORE:
5.0
Theme:Conservation and Protection of Fish & Fish Habitat
on 11/16/2016 1479322755
Tags:
La division des examens réglementaires de la Protection des Pêches a la responsabilité d’examiner les projets de construction en milieux aqu .... Read More

La division des examens réglementaires de la Protection des Pêches a la responsabilité d’examiner les projets de construction en milieux aquatiques afin que ceux-ci respectent la Loi sur les Pêches. Depuis la réorganisation de 2013, cette division est composée uniquement de biologistes.

Or, la conception et la construction des projets de construction sont assumées par des ingénieurs civils en hydraulique, en hydrologie, en structure, en génie routier et en géotechnique. Avant 2013, la division comptait dans son équipe des ingénieurs qui pouvaient porter un jugement technique éclairé sur les projets. Leur expertise permettait de supporter les biologistes dans leurs examens de projet, de produire des analyses basées sur des rationnels solides et d’avoir la crédibilité d’argumenter avec les ingénieurs impliqués dans les projets. Cette expertise permettait aussi des collaborations efficaces dans la recherche de solutions réalistes et positives. Actuellement, la nature uni-disciplinaire (biologie) des équipes de la division limite l’efficacité du MPO à remplir son mandat.

La Protection des Pêches a aussi dans son mandat le développement des normes et lignes directrices ainsi que la formation des clients sur celles-ci. Pour avoir la crédibilité de produire des normes et des lignes directrices pertinentes en lien avec les pratiques d’ingénierie, le MPO doit pouvoir compter sur des ingénieurs à l’interne. Leur compétence est également requise pour former les ingénieurs de projets sur les approches et pratiques favorables à la protection des pêches.  

Pour toutes ces raisons, il serait important de recréer des postes d’ingénieurs à la Protection des Pêches.

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Fish habitat protection

SCORE:
5.0
Theme:Conservation and Protection of Fish & Fish Habitat
on 10/27/2016 1477585377
Tags:
  Need to restore and modernize the habitat management policy of 1998 with a focus on no net loss and achieving a net gain with each incremental dev .... Read More

 

Need to restore and modernize the habitat management policy of 1998 with a focus on no net loss and achieving a net gain with each incremental development proposal. Also provide guidance when it is ecologically critical to say no to a development proposal after redesign and relocate options hVe been reasonably exhausted. Train biologists to be expert witnesses and empower them with habitat inspector and guardian status to assist fishery officers with non compliance. Strengthen working relationships with provincial fisheries management biologists and foster intimate cooperation.

Web master people, please fix spelling on theme title Conversstion and replace with Conservation. 

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Improved Monitoring of PCBs and Heavy Metals

SCORE:
5.0
Theme:Monitoring Threats and Reporting-back to Canadians
on 11/15/2016 1479230060
Our oceans can be a resource for generations if protected. In order to protect our oceans Canadian's need to know what state they are in and how it i .... Read More

Our oceans can be a resource for generations if protected. In order to protect our oceans Canadian's need to know what state they are in and how it is changing. Raw environmental data must be collected and posted for all to see in order to be open and transparent and benefit from crowd sourcing of analysis. All Niskin (CTD) bottle samplings and salmon blood sampling raw data should be publicly available, and the program expanded to include significant testing for plastics, dioxins, lead, cadmium, mercury, and the anthropogenic isotopes.

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Comprehensive GIS for better assessment and decision-making

SCORE:
5.0
Theme:Conservation and Protection of Fish & Fish Habitat
on 11/24/2016 1480008014
Creating a GIS database that includes a variety of data like sensitive fish habitat, approved projects, compensation and restoration projects, to name .... Read More

Creating a GIS database that includes a variety of data like sensitive fish habitat, approved projects, compensation and restoration projects, to name a few, would greatly assist biologists with better assessing projects not just locally but at a broader scale for cumulative effects. There would be an initial investment gathering existing information, creating these datasets and collaborating with other organizations to collect data, but the benefits could be great for a variety of applications whether for project assessment, increased transparency in decision-making, or assisting in developing indicators and thresholds for aquatic habitat and watershed health.

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