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

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Research Ongoing Cumulative Impacts of Multiple Salmon Farms in Pacific Migratory Waters

SCORE:
5.0
Theme:Monitoring Threats and Reporting-back to Canadians
on 11/25/2016 1480111896
Act on Justice Cohen's concerns:  “DFO has not completed research into the effects of diseases and pathogens from salmon farms on wild Fraser .... Read More

Act on Justice Cohen's concerns: 

“DFO has not completed research into the effects of diseases and pathogens from salmon farms on wild Fraser River sockeye. Nor has DFO done any research into the cumulative effects on sockeye of having multiple salmon farms sited on their migration route. In sum, there are insufficient data (almost no data) to evaluate cause and effect relationships, and insufficient data to look for correlations between fish farm factors and measures of sockeye health such as productivity.“ Vol3 p. 24

"I accept the evidence that a devastating disease could sweep through a wild population killing large numbers of wild fish without scientists being aware of it." (Spoken in press release & in report)

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Fish Habitat Restoration

SCORE:
2.5
Theme:Conservation and Protection of Fish & Fish Habitat
on 11/25/2016 1480101507
While the Fisheries Act has programs in place for habitat protection, changes should be made with the intention of addressing the restoration of fish .... Read More

While the Fisheries Act has programs in place for habitat protection, changes should be made with the intention of addressing the restoration of fish habitat in areas that have been damaged by human impact and development. 

Restoration is not intended to return a system to a pre-altered state or fixed condition but to help restore the structure, function, and ecological processes of a system. Restoration also includes extensive environmental monitoring. Environmental monitoring requires collection of data to measure the success of a project. Data collected from monitoring programs will also aid in filling gas in DFO and public data and can assist in mapping. 

Habitat restoration is at the foundation of many land management strategies and endangered species recovery initiatives and should be considered further in the Fisheries Act. 

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Restore Protections for all Native Fish Species

SCORE:
4.1
Theme:Conservation and Protection of Fish & Fish Habitat
on 11/25/2016 1480099124
Non-CRA fisheries (commercial, recreational, or aboriginal) currently lack adequate protection despite being critical components of their ecosystems; .... Read More

Non-CRA fisheries (commercial, recreational, or aboriginal) currently lack adequate protection despite being critical components of their ecosystems; the result is weakened protections for the important habitats that support these and other species.

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Offsetting and Habitat Banking

SCORE:
5.0
Theme:Conservation and Protection of Fish & Fish Habitat
on 11/25/2016 1480098286
While offsetting is meant as a last resort if an impact cannot be prevented or mitigated, in some cases, it is inevitable. Currently, offsetting is do .... Read More

While offsetting is meant as a last resort if an impact cannot be prevented or mitigated, in some cases, it is inevitable. Currently, offsetting is done on a project-by-project basis with an effort to complete the offset near the area of impact. DFO needs to explore more fully the concept of habitat banking. Major restoration works could be completed in areas that have been heavily impacted in the past if offsetting from multiple projects could be applied to fewer large projects.

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Enforcement: Ticketable Offences and Funding for Provincial Agencies

SCORE:
5.0
Theme:Compliance and Enforcement
on 11/25/2016 1480098180
Enforcement of the Fisheries Act has been downloaded to provinces as there are very few federal enforcement officers. If provinces are expected to enf .... Read More

Enforcement of the Fisheries Act has been downloaded to provinces as there are very few federal enforcement officers. If provinces are expected to enforce the Act, they should be provided funding and training to do so. Other enforcement options may also exist such as through ticketable offences.

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Restore DFO Capacity

SCORE:
4.6
Theme:Compliance and Enforcement
on 11/25/2016 1480098060
DFO currently lacks the capacity to effectively monitor and protect habitat and enforce the Act. While there may be advantages to centralization, the .... Read More

DFO currently lacks the capacity to effectively monitor and protect habitat and enforce the Act. While there may be advantages to centralization, the capacity for staff with local knowledge is severely limited.

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Setting limits for cumulative effects, watershed-level management

SCORE:
4.5
Theme:Conservation and Protection of Fish & Fish Habitat
on 11/25/2016 1480095119
Managing cumulative effects requires that limits be set on allowable habitat change or fish population loss. Setting those limits is both a a technica .... Read More

Managing cumulative effects requires that limits be set on allowable habitat change or fish population loss. Setting those limits is both a a technical and a political exercise. It needs to be done in an open and public process, and involve multiple jurisdictions. The new Fisheries Act must provide for such a process.

To illustrate the issues, consider Ripley et al. (2005) http://www.nrcresearchpress.com/doi/abs/10.1139/f05-150#.WDdOcHdk8UE, their Figure 2. Probability of bull trout occurrence in a watershed declines with ANY tree harvest or road development. There is no threshold of development in watersheds below which bull trout are completely safe in the presence of logging or roads, so there is no objective limit you can use for managing logging.

The allowable amount of logging & road development, and the allowable loss of bull trout, will depend on a scientifically-determined range of probabilities of persistence of bull trout in the face of logging, from which an acceptable, politically-determined level of  logging is selected. Also, note that this has to be determined at the watershed level, showing that there will have to be cooperative management involving different legal jurisdictions.

Some exercise like this would need to be done for each species in a watershed, or by evaluating the probability of persistence of entire fish communities. The new Fisheries Act needs to be written in a way that accommodates processes like this.

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Gabriolans Against Freighter Anchorages Recommendations

SCORE:
4.2
Theme:Conservation and Protection of Fish & Fish Habitat
on 11/25/2016 1480086749
Tags: Science 
  Background: On June 27, 2016 – after the current review of the Fisheries Act was announced- the Department of Fisheries and Oceans (DFO) Fis .... Read More

 

Background: On June 27, 2016 – after the current review of the Fisheries Act was announced- the Department of Fisheries and Oceans (DFO) Fisheries Protection Program issued a decision that a proposal by commercial shipping interests including the Chamber of Shipping of BC and the Port of Vancouver, spearheaded by the Pacific Pilotage Authority, to establish anchorages for 5 super freighters off the pristine coastline of NE Gabriola Island in the Strait of Georgia (the “project”), required neither a DFO review nor an authorization under the Fisheries Act

A formal request on March 30, 2016, that consideration of the project be postponed pending completion of the Fisheries Act review, went unanswered.

The DFO decision regarding the anchorages project has far-reaching consequences and is of a precedent-setting nature.  It should be cause for alarm.  Based on this decision, any number of other large-scale commercial anchorages could be established anywhere and at any time in our coastal waters, without any independent review or study, and without any understanding of the potential adverse effects resulting from repeated scouring of the seabed, turbulence, underwater and in-air noise, obstructions and other activities associated with commercial anchorages, and without any knowledge of the valuable resources that may be lost

  • The project will directly impact an area of marine habitat that is more than twice the size of Vancouver’s Stanley Park.  This represents only the actual footprint of the proposed anchorages area.  If adjacent intertidal areas that could be impacted by bilge and ballast discharges and chronic oiling are included, the area is much, much larger;
  • According to a very limited environmental overview assessment submitted by the project proponent “The proposed anchorages will degrade or destroy a large area of soft-bottom substrate, making it uninhabitable for the operational duration of the anchorage. Without a permanent mooring system, anchors will be repeatedly dropped within the anchorage, and chains will continue to create scour areas and turbidity plumes.”   
  • The anchorages may be used by any type of commercial ship, for any duration, for the foreseeable future, making the aforementioned degradation and destruction functionally permanent
  • While using the proposed anchorages ships may load and unload cargoes including thermal coal, and engage in refuelling operations and ship repairs, all without any further environmental assessment.

Although the proposed project area is scientifically understudied, its resource value is recognized by independent scientists, expert in their fields.  See full statements of Dr. Richard Beamish and Dr. D. Furnell: http://www.gabriolaanchorrage.org/the-latest/2016/9/6/scientist-statements-in-support-of-request-for-reconsideration-of-dfo-decision

 The following are extracts of their statements:

The area off the Strait of Georgia side of Gabriola Island is productive rearing habitat for a number of species including important commercial and recreational fishes. In particular, rockfish and lingcod are common and both are species that have been overfished and now are being rebuilt. This area, Area 17-10, is an important part of the rebuilding effort. These species depend on specific bottom features as well as an abundance of prey. It is essential that any human intervention into this ecosystem does not alter the habitat in a way that significantly changes the productivity and the capacity of the habitat to provide prey and protect adult and juvenile rockfish and lingcod. ….The area is also a common fishing area for Chinook salmon. Most likely this is because of the abundant prey which in turn depend on the plankton production. Chinook salmon have been declining in abundance since the mid-1980s. … Small changes in food for the juvenile Chinook can have major impacts on their subsequent survival. It is known that the area off the east side of Gabriola Island is an important rearing area for the young Chinook salmon and it is necessary to understand how any intervention into this ecosystem will affect the food for juvenile chinook salmon.”  Dr. Richard Beamish

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The main conclusion I reach, after reviewing the information presented by [consultant], is that we actually have relatively little knowledge of the marine environment in the anchorage area or the effects of the project on the species that occur there. This lack of information is compounded by the meager literature on the effects of anchorages on the marine environment.”

“Pacific sand lance are a forage fish critical to the diet of many predatory species such as chinook and coho salmon, both of which occur in relative abundance in the anchorage area. Sand lance are also important components of marine bird diets. Although the [EOA] concludes that no suitable sand lance burying or spawning habitat exists in the anchorage area, that conclusion is based on Robinson et al. (2013) which is a habitat suitability model that has not been evaluated by direct observation and validated. … Numerous Gabriola fishers have reported finding sand lance in the stomachs of chinook and coho salmon taken in the immediate area of the anchorages and the Gabriola Stream Keepers have photographs of dead sand lance washed ashore on Sandwell Beach, at the northwest end of the anchorage area. Stream Keepers also report observations of schooling sand lance in the waters of adjacent Lock Bay …. Given the local observations of washed up, dead sand lance, live schooling sand lance and their presence in locally caught salmon, it cannot be concluded there would be no loss of sand lance habitat or direct mortality from anchor scour.”

The anchorage area is located on one of the most important recreational spot prawn fisheries in the southern Gulf Islands for individuals from Nanaimo to Ladysmith. The area also supports a significant commercial spot prawn fishery. The extent to which First Nations harvest prawns in the area is unknown. … [The EOA author] does not consider the effect of anchor scour to be significant on motile benthic invertebrates and does not report any observations of spot prawns in their ROV survey. This absence of spot prawns in the ROV data is in direct contradiction to observations in local recreational and commercial fisheries. Detritivorous organisms require an undisturbed benthic surface on which to feed. It is obvious, direct anchor scour would eliminate that foraging area; however, sedimentation from turbidity would cause a much farther distribution of disturbance than scour alone, burying food resources”  Dr. D. Furnell.

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The scope of the environmental overview assessment (EOA) for the project was limited by the project proponents.  It is evident from the following statements of the proponents’ consultant that no studies were undertaken to estimate the presence or the abundance of various species in the project area, or how the project will affect food sources for important species and species at risk:

  • Quantitative assessment of the Anchorage area was largely absent within this high-level EOA”. (12.0 Summary and Conclusions)
  • “[EOA Consultant] recognizes that there is a lack of specific, quantitative information. There is potential that expert advice or quantitative information, should it become available, would change the effects characterization and significance determination(s)”. (12.0 Summary and Conclusions)
  • Further, the lack of First Nations/Public consultation leaves potential for significant effects to occur within social components, including those assessed within the EOA. (i.e.) Noise, light and fisheries. (12.0 Summary and Conclusions)
  • No site specific fish surveys were conducted at the proposed Gabriola anchorages.”(Appendix D)
  • Baseline conditions at the proposed anchorages were inferred from the published literature and a one-time limited survey [of less than 1/1000th of the project area, over a few hours on a single day] using a remotely operated vehicle (ROV) outfitted with a recording device.” (Appendix D) “The ROV survey provided a cursory view of a limited area approximately 1 square meter immediately in front of the camera long the transect lines.” (Appendix D)

Other problematic aspects of the process surrounding this project are articulated in submissions titled (See “Yes to Habitat Protection – No to Freighter Anchorages” and “A Case Study on the Legacy of the FA Changes”).

While it is not clear on what basis DFO Fisheries Protection Program reached its decision that the project requires neither a review, nor an authorization under the Fisheries Act, the decision refers to a predetermined List of Projects not requiring DFO review.  The project is not comparable in nature, spatial or temporal extent to any of the projects on that list.  Our request for an explanation and reconsideration of the decision has been met with silence.  This, in itself, is problematic.  All decisions that affect public resources should be transparent and the legislative provisions, administrative guidelines and policies on which they are based, clearly articulated.  

It should be also noted that more than 5,000 people have signed a petition asking for this proposal to be stopped because of concerns over adverse environmental effects.

Recommendations:

  1. Withdraw the DFO decision that the proposal to create a commercial anchorages area off the NE coast of Gabriola Island BC requires neither a review nor an authorization under the Fisheries Act. The decision has far-reaching consequences that require thorough, comprehensive consideration.  A reliable scientific baseline of the proposed project area must first be completed including fish surveys, bottom fauna and sediment sampling, and underwater noise measurement, and a rigorous, sound and credible assessment undertaken of the risks and potential impacts of the project on fish, fish habitat, and species at risk. 
  2. End the practice of relying on proponents to determine whether or not his/her project will cause Serious Harm; hire more DFO scientists to review proponents’ project assessments on a routine basis for most projects; limit use of the Professional Reliance Model to non-commercial projects;
  3. Require site-specific, quantitative baseline data for development proposals.  Reliable baseline data are essential for effective monitoring and evaluation of proposed mitigation measures;
  4. Evaluate mitigation measures proposed by project proponents or imposed by DFO to ensure that they will actually prevent harm to fish or fish habitat; mitigation measures must be enforceable, closely monitored and any failure to abide by them or implement them should be heavily penalized;
  5. Restore habitat protection for all native fish, not just those that are part of or are deemed to support an established fishery.  All fishes are part of Canada’s biodiversity legacy and those that do not necessarily support anthropogenic fisheries should not be ignored.
  6. Return to the habitat protection model (HADD); “No person shall carry on any work, undertaking or activity that results in the harmful alteration, disruption or destruction of fish habitat.” 
  7. Re-evaluate the ‘off set’ program; restore the policy goals of “Net Gain” and “No Net Loss” of habitat.
  8. Create a public registry of applications (with accompanying documentation), decisions and authorizations.  Require that legal and policy grounds for decisions and authorizations be disclosed.  These should all be public documents, and available in an easily searchable database.
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Effects of Shipping on Fish and Fish Habitat

SCORE:
5.0
Theme:Conservation and Protection of Fish & Fish Habitat
on 11/25/2016 1480053792
The Effects of Ships and Shipping practices on Fish and Fish Habitat. Fisheries and Oceans Canada has a lot of catching up to do. For many years, DFO .... Read More

The Effects of Ships and Shipping practices on Fish and Fish Habitat.

Fisheries and Oceans Canada has a lot of catching up to do. For many years, DFO has been hampered in executing it’s mandate to protect fish and fish habitat because of the past changes in the Fisheries Act and also because of reduced staffing and reduced funding for research and monitoring.

 The Fish and Fish Habitat protection review by Fisheries and Oceans is a hopeful sign that things are about to change for the better.

 New findings in research on responses of fish to ships and ship movements need to be seriously considered.

 For example, new research has been published reporting methods to analyze video recordings of fish in their natural habitat. The object of the research was to assess conditions where fish in their natural habitat were affected by ship presence. While the authors indicate that more research is needed, their initial findings indicate that fish in their natural habitat are adversely affected by shipping in 2 different scenarios. The first observed effect was a response to ship noise from a moving ship. The second recorded effect was that fish are also affected by the mere presence of a stationary ship in the area of their natural habitat. Further research needs to be done to explore this effect, but even at this stage, it is a game changer. The new findings substantially impact the assessment guidelines that address ‘harm to fish and fish habitat’. Proponents of development projects or anchorage proposals for large freighters will need to face this issue.

 When you consider the number of large tankers and freighters currently in our waters and add to that the threat of those numbers increasing, research such as this will be critical to better assess the impact of large ships and shipping on fish and fish habitat.

 Recommendations:

  • Expand the criteria for fish and habitat protection to all fish and marine species. Recognize that the marine ecosystem is an interconnected web that relies on the health of all species.
  • Remove present Section 35 prohibition where “serious harm to fish” is narrowly defined in part as: “the death of fish or the permanent alteration to, or destruction of, fish habitat……”,
  • Reinstate the former Section 35 HADD prohibition: “No person shall carry out any work, undertaking or activity that results in harmful alteration, disruption or destruction of fish habitat.”
  • Change the criteria for DFO assessment. Any major development proposal should now require a DFO independent assessment.
  • Support an increased infusion of financial support to research. Re-commit to important research that has suffered in recent years from lack of funds and from the “post-2012” narrow focus on the commercial fishery. Two such fields of study are forage fish, and Resident Killer Whales. There are others.
  • Support financially and practically an infrastructure where the senior scientists can mentor the new young scientists.
  • Re-engage in active research about the impacts of ship noise.
  • Initiate new research on the impact of stationary large ships on marine life.

 Thank you for this opportunity to provide comments on fish and fish habitat protections in the Fisheries Act.

 

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