Thank you.
Good afternoon, everybody.
The Atlantic Salmon Federation is pleased to have this opportunity to speak to the committee today. The Atlantic Salmon Federation is dedicated to the conservation, protection, and restoration of wild Atlantic salmon. We work closely with our regional councils in Atlantic Canada and Quebec and with over 100 local watershed organizations and salmon conservation groups, which represent thousands of volunteers.
Canada's wild Atlantic salmon populations have been declining for many years, largely due to the impacts from human activities. Populations in most areas are well below historical levels, and some are listed or are in the process of being listed as threatened or endangered. Many commercial, aboriginal, and recreational fisheries have been closed, and significant social and economic benefits have been lost.
Despite this, wild Atlantic salmon are still worth about $150 million to Canada's GDP, and they generate the equivalent of 3,800 full-time jobs. These numbers of course would be much greater if populations were recovered and fisheries were reopened.
Halting the salmon's decline, recovering populations, and restoring lost fisheries will take significant resources and hard work, backed up by strong legislative and policy frameworks to address the threat from human activities. Unfortunately, at this time, we believe that the Fisheries Act and its administration are not sufficient to address some of the most important human impacts on wild salmon populations. There are several reasons for this.
First, the focus on preventing permanent alteration or destruction of fish habitat is not sufficient. Atlantic salmon have specific habitat requirements at specific points in their life cycle and at specific times of the year. Temporary alterations to key habitats at times when they are needed can have substantial and long-lasting impacts. For example, temporary disruptions to water quality, flow, or temperature at key times during the fall of the year could render important spawning habitats useless when they are needed and have significant impacts on salmon productivity for years into the future.
Despite that, such alterations to key habitat would not be considered serious harm under the current act, simply because they are not permanent. This leaves the door open for human activities to cause significant impacts on salmon productivity through temporary alterations to key habitats. We believe that legislation needs to protect key habitat at the time it is needed. It should not matter whether that alteration is temporary or permanent.
Second, the act's focus on preventing the death of fish is not sufficient. Many of the human activities that impact salmon have non-lethal effects. In other words, these are impacts that affect the long-term health and productivity of salmon populations without actually causing the death of the fish that are being impacted. Impacts from open net salmon aquaculture are a good example of this. They're only one example of this, but we will use this one.
One of the major problems with net-pen aquaculture is that farmed fish escape and interbreed with wild salmon. When those farmed fish interbreed with wild fish, the gene pool of wild populations is weakened, leading to reduced fitness in future generations and decreased abundance. All of this happens without actually causing the death of the wild fish that have been interbreeding with the farmed fish, which means that these sorts of non-lethal impacts are not considered serious harm under the Fisheries Act. We believe that legislation that does not protect fish from all of the significant ways that they are impacted by human activity will not ensure the protection, sustainability, and recovery of wild salmon and the fisheries they support.
Third, in the administration of the act, there is too much reliance on project proponents to self-assess and notify DFO regarding impacts on habitat. People undertaking potentially damaging activities are typically not qualified to understand the complexities of salmon habitat requirements or to judge when their activities may have caused serious harm. There are also disincentives for people to report harm that they may have caused, yet the self-assessment tool currently used by DFO places most of the responsibility for protecting fish habitat with the project proponents. This provides significant opportunities for projects to proceed without sufficient oversight from monitoring and enforcement.
We believe that this situation results in ongoing and cumulative habitat loss that is undocumented and unmitigated, and it makes it nearly impossible to assess future project impacts in light of previous damage. There needs to be a greater presence of DFO on site at proposed project locations to assess the potential damage prior to work being conducted, and there must be better monitoring of impacts during and after activities.
Fourth, we feel that the act grants too much discretionary power to the minister to exempt works, undertakings, activities, deleterious substances, and water bodies, and to grant authorizations to cause harm to fish or fish habitat. Currently, the minister's discretion can be exercised without sufficient guidance or processes to ensure that the impacts of those decisions are known, understood, monitored, or mitigated. There's no automatic mechanism to ensure that discretionary decisions are made with information about the full range of costs and benefits, or that the public is informed about such decisions and can participate.
Without a rigorous and transparent process to guide the application of ministerial discretion, it is difficult for the public to hold the minister accountable. There need to be meaningful safeguards to ensure that the minister does not consistently prioritize the desires of project proponents over the needs of wild fish and the people who depend on them.
In summary, we have a number of recommendations for changes to the Fisheries Act and its administration.
In the first instance, we believe that there needs to be a restoration of protections and administrative processes that were removed in 2012, including the following: restore provisions that prevent the harmful alteration, disruption, or destruction of fish habitat and remove the requirement that impacts must be permanent; reduce proponent project self-assessment and increase the capacity for government oversight and monitoring of projects and impacts; and, re-establish ministerial authorizations for causing harm to fish or fish habitat as triggers for an environmental assessment process.
In addition to restoring lost protection, there is also a need to introduce modern safeguards to address issues that have not been covered in previous versions of the act. In particular, we recommend the following: expand the definition of harm to incorporate non-lethal impacts; limit and guide ministerial and administrative discretion through the incorporation of clear and meaningful guiding principles and decision-making criteria, as well as opportunities for public education and public input; and, include provisions and processes for the designation of critical fish habitat that cannot be altered or destroyed.
Finally, we recommend that a revised act include purposes for restoring lost or depleted populations and re-establishing fisheries. A modern Fisheries Act should be aimed at more than just preventing impacts and maintaining the status quo. It should acknowledge that significant impacts have occurred to fish habitat, fish populations, and fisheries and aim to be restorative where possible.
Thank you.