The Wild Salmon Policy - why salmon and wildlife can’t wait any longer
What is the Wild Salmon Policy and why does it matter?
The Policy for Conservation of Wild Pacific Salmon (WSP) represents, according to the Government of Canada, “Fisheries and Oceans Canada's commitment to maintain healthy and diverse populations of salmon that will support sustainable fisheries now, and meet the needs of future generations. WSP places conservation of salmon and their habitat as the first priority for resource management."
The WSP has an ambitious and worthy goal to “restore and maintain healthy and diverse salmon populations and their habitats for the benefit and enjoyment of the people of Canada in perpetuity” and, at the time it was released in 2005, contained innovative policies that provided a lot of hope for the future of our ecologically, culturally and economically important Pacific salmon.
In the years following, it became apparent that few steps had been taken to implement the innovative policies it contained, as reviewed by the 2011 Gardner Pinfold Review and the 2012 Commission of Inquiry into the Decline of Sockeye Salmon in the Fraser River, also known as the Cohen Commission. The Cohen Commission recommended that the government create a formal implementation plan to ensure the delivery of the bold ideas presented by the WSP.
Fast forward to 2015, when the change of federal government propelled Fisheries and Oceans Canada (DFO) to create the recommended implementation plan. The draft 2018-2022 Wild Salmon Policy Implementation Plan describes the concrete activities that will be taken by DFO in order to act on the WSP, with frank recognition of the necessary contributions of Indigenous people, communities, watershed groups and other organizations.
Salmon are critically important to our ecosystems, our economy, and to both settler and Indigenous communities and culture. Evidence of this is prolific in our coastal communities, but as a recently published 19 year study from UVic and Raincoast shows, the ecological footprint of salmon actually spreads throughout the province, over 1000km from the coast, thanks to the large roaming habitat of the grizzly bear.
What does the draft Implementation Plan promise?The Implementation Plan first describes the state of Pacific salmon and the history of the WSP as well as that of salmon management in Canada. It outlines the timeline of events over the next five years, promising annual progress reviews and a evaluative review at the end of the five year period, and describes how the principles of the WSP will be implemented and in what ways the progress will be measured as it fulfils its goals.
So what’s the problem?Though the draft Implementation Plan is a promising document, we are past the need for drafting and discussing an implementation plan for a policy that everyone’s been waiting to be implemented for almost 18 years. Quite simply, the policies set forth in the WSP need to be implemented before it’s too late.
Wild salmon are facing numerous threats. Salmon populations are in desperate decline, subspecies such as the Steelhead are on the brink of collapse, and sockeye have just been recommended by the Committee on the Status of Endangered Wildlife in Canada (COSEWIC) to be listed under the federal Species at Risk Act. Because wild salmon are an important part of the Pacific Coastal food chain, the impact of population decline on wildlife — from orcas to grizzly bears — is enormous.
An emotional topicWe attended DFO’s Implementation Plan open houses in Vancouver in both spring and autumn 2017, and with a wide array of scientists, environmentalists, commercial fishery owners, and Indigenous people in attendance, it was hardly surprising that the calm discussion escalated to the point of intervention by open house staff. People on all sides of the issue expressed frustration over the Wild Salmon Policy’s inertia and questioned the utility of a consultation on a plan, when everyone seems to agree the WSP simply needs to be enacted now.
A polite yet forceful protest demonstration by the Wild Salmon Warriors (including delegates from Cleansing Our Waters) respectfully articulated the lack of consent for the operation of open net salmon fish farms within Musgamagw Dzawada’enuxw territories, noting their occupation of fish farms that has been ongoing for over 90 days (at that time; the occupation began mid August 2017). Warrior Publications posted video footage of the demonstration.
The open house was a useful opportunity to learn more about differing views on the issues salmon are currently facing and the justifications for some of the questions we were left with upon reviewing the Implementation Plan.
Our submission on the Draft Implementation PlanOur main points of concern relating to the draft Implementation Plan are listed below. We summarized and submitted these thoughts on the Draft Wild Salmon Policy Implementation Plan in a letter to DFO.
1. The Implementation Plan must be actualized before it’s too late for it to make any positive impact on the Pacific wild salmon populations.
2. Policies without resources achieve very little. It has been identified that the existing resources are inadequate to implement the WSP, leaving doubt that it will achieve its intent. A successful implementation would need to be accompanied by an investment in the DFO’s financial and human resources. See also recommendation 6 of the Cohen Commission.
3. Related to the above, with no additional budget or resources to implement the WSP, much of the actual work of monitoring fish populations may fall to First Nations, non governmental organizations, and other stakeholders. The Implementation Plan mentions the necessity of this collaboration, but there is no indication of how this data might be evaluated and integrated, especially if it indicates conclusions that are contrary to what the DFO is finding. Moreover, if First Nations and civil society groups are to be relied upon to input data and carry out local monitoring, sufficient resources should be allocated for the work carried out by those people and groups.
4. Fisheries and Oceans Canada currently has a mandate that includes ensuring economically prosperous maritime sectors and fisheries, which extends in practice to “a responsibility to promote the sustainable use of fish resources” including open net salmon fish farming operations. Given not only the ecological but also the economic importance of wild Pacific salmon, and the stated goals and objectives of the WSP regarding restoring and maintaining genetic diversity of wild Pacific salmon and habitat and ecosystem integrity, we feel the Department and the WSP team must be explicit about their priorities and ensure a coordinated effort in restoring and managing Pacific salmon stocks.
This point has become increasingly concerning in light of a recent 2.48 million dollar government ‘investment’ in aquaculture, including open net Atlantic fish farms, and DFO’s notice of intent to amend the regulations regarding transfer of live fish, not to mention mounting scientific studies that caution against the dangers to wild salmon stocks posed by open net fish farms (for example, see here and here).
5. With the amount of department responsibility overlap apparent in the WSP and the Implementation Plan, it’s evident a structured strategy for collaboration is needed for the WSP to be successful. This may require the creation of a WSP implementation coordinator or director (as noted in the Cohen Commission Report, p.544).
6. There has been no mention of the importance of salmon to other marine and terrestrial wildlife, nor mention of considering wildlife allocation in determining harvest numbers. One would argue that exclusion of this point is unsustainable, and this must be corrected in order to effectively “manage fisheries for sustainable benefits”.
In our letter to DFO, we recommended that the WSP Implementation Plan, as set out in our Report of the Board of Inquiry recommendations, explicitly consider and account for in its allocation formula the nutritional needs of grizzly bears, due to their keystone status as a species in the predator-scavenger complex that uses and distributes marine nutrients.
Comments on the WSP Implementation PlanIf you also have comments or concerns about the WSP draft implementation plan, DFO is accepting submissions until December 15, 2017 via WildSalmonPolicy@dfo-mpo.gc.ca or through their fillable workbook, which may be found at http://www.pac.dfo-mpo.gc.ca/forms/wsp-pss/workbook-cahier-eng.aspx.
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