Thank you, Mr. Chair.
My name is Marvin Rosenau, and I'm honoured to talk to you today. My background in fisheries work goes back 40 years locally, nationally and overseas within and outside of governments, including in academic and scientific venues as well as in management and policy and the courts. I am now an educator with the fish, wildlife and recreation program at the British Columbia Institute of Technology, and I specifically concentrate on fish and aquatic sciences.
My personal view is that the current salmon collapses that have occurred in southwestern B.C. and the Fraser River have largely been driven by impacts associated with fish farms. However, with the recent announcement of 19 farms being removed from the Discovery Islands smolt out-migration routes, along with the decommissioning of the Broughton Archipelago fish farms several years ago, the DFO is moving in the right direction. I praise Minister Jordan, this standing committee and others for making these bold moves.
Today I will focus on habitat destruction and the failure of DFO to address this issue, and that's my theme. Species and ecosystems cannot survive and thrive without properly functioning habitats, and thus I pose the following questions. Are there sufficient and appropriate rules in place in Canada to protect these salmon stocks and species in B.C. from habitat damage, for example, through Canada's Fisheries Act? Are the existing rules being implemented properly, either at the referral and approval stages for new projects where potentially deleterious impacts might occur, or where random violations might take place and fisheries officers need to initiate an investigation and the triage decision folks need to go forward with charges or directed remediation?
It's my position that, notwithstanding the recent upgrades in the Fisheries Act via Bill C-68, which was very good, in my experience over the last 30 years using the act, there is no reason to believe there hasn't been sufficiently good legislation, regulations and policy to protect fish and fish habitat. However, the implementation of these rules has sometimes been woefully inadequate. This can be due to a lack of will in the internal DFO decision-making process, sometimes due to a failure in understanding what constitutes destruction of fish habitat, and there's often a failure in regard to how to restore or mitigate damage.
Staffing capacity at DFO habitat protection in British Columbia continues to be a major issue. The loss of the Prince George DFO habitat office and some of the closures in the Quesnel, Clearwater and eastern B.C. offices exemplify this problem.
My opinion, having worked on this issue for many years, is that habitat protection is the most difficult part of fisheries management, and to do it properly always requires a lot of work and tough decisions. If they're doing their jobs properly, agency habitat decision-makers have to constantly tell developers, farmers, loggers, miners or the hydroelectric industry that no, they can't do that, and that rarely occurs.
The capitulation to proponents becomes the norm, due to pressure both within and outside of government. Roberts Bank Terminal 2 in the Fraser estuary and the Trans Mountain Pipeline expansion project are current examples of this scenario.
Habitat protection and enforcement staff and the fish and fish habitat protection program, FFHPP, decision-makers in DFO often feel personally and professionally vulnerable to criticism. They try to do the right thing: protect habitat. My observations and my own personal history is that superiors often come down hard on employees who try to take legally and scientifically defendable positions.
As an example, there has been a spectacular failure to protect large amounts of salmon habitat in recent years regarding the removal of flood-land forests in order to develop farmland in the areas between Mission and Hope on the lower Fraser River in B.C., and I think you might have some figures to see. In my opinion, many of these activities in what we refer to as the heart of the Fraser have been clear violations of the habitat provisions of the Fisheries Act. However, DFO has not charged any landowners under the act that I'm aware of, and up to a thousand hectares of prime Fraser River juvenile salmon-rearing habitat have been or will be lost because of inadequate enforcement or bad triage decision-making in the FFHPP.
DFO has failed to properly interpret the science and/or the law, and/or has simply refused to enforce its own rules in this instance, and this is just one example.
In conclusion, Canada has lots of good rules for salmon that are adequate to protect fish and habitat, but the government needs to concentrate on applying its existing powers, and not politically interfering with but supporting line staff in terms of increased capacity and the various ways I've just discussed.
Thank you very much.