Salmon Aquaculture

Heritage Aquaculture Proposed Finfish Aquaculture Facility - Downie Range

March 5, 2004

Debra Hughes, A/Finfish CEAA Biologist
Salmon Aquaculture Directorate - HEB
Fisheries & Oceans Canada
200 - 401 Burrard St
Vancouver , BC V6C 3S4

Dear Ms. Hughes:

Re: Heritage Aquaculture Proposed Finfish Aquaculture Facility - Downie Range , Bute Inlet , British Columbia ; FEAI Reference Number 27551

The Georgia Strait Alliance (GSA) is made up of organizations, businesses and individual members from around the Georgia Basin, with a common goal: to protect and restore the marine environment and promote the sustainability of Georgia Strait, its adjoining waters and communities. I am writing to convey our concerns regarding Heritage Aquaculture's application to site a finfish aquaculture facility at the Downie Range and to provide additional information.

Throughout this submission reference will be made to the federal Fisheries Act and to sections of the following additional documents that guide the responsible authority (DFO) in carrying out the environmental assessment of potential aquaculture sites. For the sake of brevity I will refer, herein, to each of these documents as shown in boldface:

  • Canadian Environmental Assessment Act : CEA Act .
  • Fisheries and Oceans Canada Interim Guide to Information Requirements for Environmental Assessment of Marine Finfish Aquaculture Projects - February 15, 2002 : Information Guide .
  • Fisheries and Oceans Canada Interim Guide to Consideration of Cumulative Environmental Effects Under CEAA Relative to Aquaculture Projects- Operational Policy Guidance - February 15, 2002 : Guide to Cumulative Effects .
  • Fisheries and Oceans Canada Interim Guide to Consideration of Effects of Environmental Change on Socio-Economic Conditions Under CEAA Relative to Aquaculture Projects- Operational Policy Guidance - January 18, 2002 : Guide to Socio-Economic Effects .
  • Fisheries and Oceans Canada Interim Guide to the Application of Section 35 of the Fisheries Act to Marine Salmonid Cage Aquaculture - February 15, 2002 : Fisheries Act Guide .
  • Fisheries and Oceans Canada Interim Guide to Application and Site Marking Requirements for Aquaculture Projects in Canada - Under the Navigable Waters Protection Act - February 15, 2002 : Site Marking Guide .
  • Fisheries and Oceans Canada Finfish Information Checklist: Information Requirements for CEAA : Finfish Checklist
  • Schedule C New Tenure Siting Criteria : Schedule C .

Reference will also be made to the following documents submitted as part of the proponent's management plans (again, for brevity sake, as shown in boldface):

  • Heritage Aquaculture (Conners Bros. Ltd.) Downie Range Relocation Application : Heritage Relocation Application
  • Heritage Aquaculture - West Coast Operations - October 31, 2000- Escape Prevention, Response and Predator Avoidance Plan : Escape Prevention Plan
  • International Underwater Surveyors (IUS) - Environmental Assessment of Heritage Aquaculture's Proposed Salmon Farm Development at Downie Range in Bute Inlet - November, 2000 : IUS EA
  • International Underwater Surveyors (IUS) - Supplemental Environmental Assessment of Proposed Finfish Operation in Downie Range , Bute Inlet Benthic Habitat Survey - February, 2003 : Supplemental IUS EA
  • Sea-Tech Environmental Service (Sea-Tech) - Stream, Habitat and Fish Reconnaissance for the proposed Downie Range Site, Bute Inlet, British Columbia - October 25, 2000: Sea-Tech Survey
  • Westmar Consultants Inc. - October, 2000 - Evaluation of Downie Range and Clipper Point Sites: Westmar Report
  • Ocean Dynamics Canada Ltd. - April 24, 2001 - Downie Range Bathymetry Report and Aquaculture System Anchoring Plans: Ocean Dynamics Report

Appendix A contains copies of all other documentation referenced in this submission.

Appendix B contains copies of all maps and images referenced in this submission.

General Observations

We would like to begin by highlighting the importance of section 2.2.2 (Biological Environment) of the Information Guide:

"For this section, a number of resources should be consulted when collecting information. These may include the underwater video survey, commercial and recreational fishers, aboriginal groups, Fishery Officers, local fishery organizations, other local residents, etc. A great deal of information concerning fishery resources is available to the public through local regional development authorities. Ensure that all information transfer is documented and attached. It is the responsibility of the proponent to demonstrate a reasonable effort to collect information. Provide details about the source of the information (contact name, agency, phone number, etc.)."

and subsection 18(2) of the Canadian Environmental Assessment Act :

"Any available information may be used in conducting the screening of a project, but where a responsible authority is of the opinion that the information available is not adequate to enable it to take a course of action pursuant to subsection 20(1), it shall ensure that any studies and information that it considers necessary for that purpose are undertaken or collected."

Review of the proponent's management plans and associated DFO communication, obtained through the CEAA Public Registry, has raised a number of questions in regard to the Downie Range application, particularly as it relates to the above cited sections of the Information Guide and the CEA Act . The issues we have identified generally stem from one of the following:

  • Numerous cases where information provided by the proponent is in direct conflict with internal DFO correspondence on the same subject.
  • What we see as a failure, to date, by the proponent to demonstrate a reasonable effort to collect information.
  • Due to the number of errors and DFO's lack of confidence in the results of the October 2000 IUS EA , the proponent submitted the Supplemental IUS EA in February 2003. Yet neither of these studies was conducted during the summer when one would expect to find maximum biodiversity and further, in both reports, IUS states that vertebrate species are not included in the richness and diversity analysis. Therefore, neither of these reports nor their subsequent analyses can be relied upon to reflect the diversity and richness of species that frequent the proposed site.
  • Conflicting and speculative data contained in the Westmar and Ocean Dynamics engineering reports, particularly as this relates to the buoyancy and anchoring of the proposed netcage system and the oceanographic conditions, winds and icing that occur in Bute Inlet.

In the following section we will demonstrate specific cases that highlight the concerns outlined above. In addition, as requested in the Information Guide , we will provide additional information and details about the source.

Specific Concerns

  1. The Comox Strathcona Regional District has denied zoning for this application.

    Schedule C siting criteria states that sites must be located : Consistent with approved local government bylaws for land use planning and zoning.

    The proposed Downie Range site lies within Electoral Area "J" of the Comox-Strathcona Regional District (CRSD) and is therefore subject to the zoning requirements of the CSRD. These requirements compel the proponent of a finfish aquaculture application to apply to the CSRD to re-zone the foreshore for finfish aquaculture purposes. The re-zoning process entails public hearings, two of which have already been held with regard to the Downie Range application. The public hearing process extended over two meetings (June 9 th and July 21 st 2001) with approximately 78 people in attendance on June 9 th and 114 in attendance on July 21 st .

    The clear majority of participants at both meetings spoke in opposition to the proposed Downie Range site for many of the same reasons that we outline in this submission. Generally speaking, those who spoke in favour of the proposed site worked for Heritage Aquaculture, while those opposed included local landowners, sports-fishing lodge owners, eco-tourism operators, sports-fishing guides, commercial fishers, and environmental organizations. In addition to the verbal submissions at the public hearing, the CSRD received a total of 788 written submissions as follows:

    Submissions received in support     184     23%
    Submissions received in opposition 603     77%
    Other submissions                             1      n/a

    Given the overwhelming and diverse opposition to the proposed Downie Range site, the CSRD did not grant Heritage Aquaculture the requisite zoning to operate a finfish aquaculture facility at the Downie Range .

    On August 27, 2001 the Comox Strathcona Regional Board adopted a resolution which stated:

    " Bute Inlet is an unsuitable location for any industrial aquaculture operation; AND THEREFORE, the Regional Board requests that all relevant agencies ensure that further study and a detailed response to the expressed public concerns take place prior to any further consideration of industrial aquaculture operations in Bute Inlet."

    Past exchanges between DFO and the CSRD in regard to other finfish aquaculture applications have demonstrated a DFO protocol requiring local zoning requirements be satisfied prior to carrying out any significant environmental assessment processes on proposed aquaculture sites. This position is understandable given that Schedule C criteria requires that the siting of aquaculture tenures be consistent with approved local government bylaws for land use planning and zoning.

    In this case, it is unclear how an authorization under section 35 of the Fisheries Act could be granted given that approval of the proposed facility would directly contravene the zoning jurisdiction of the CSRD.

    As requested in the Information Guide, contact information for the public consultation process is hereby provided:

    [Stakeholder names and phone numbers provided in original letter for consultative purposes.]

  2. Homalco First Nation does not support open netcage salmon aquaculture in Bute Inlet.

    Schedule C siting criteria states that sites must be located : Not in areas that would pre-empt important Aboriginal, commercial or recreational fisheries as determined by the province in consultation with First Nations and DFO.

    The site of the proposed aquaculture facility in Bute Inlet lies in the heart of the Homalco First Nation ("Homalco") traditional territory. We note that in two comprehensive submissions to the Major Projects Review Unit of DFO, April 3 and July 25, 2003, the Homalco have documented numerous negative impacts the proposed site would have on the traditional use of lands, fisheries and resources.

  3. Wild salmon migration routes and fisheries in Bute Inlet

    In response to information requested in section 2.2.2.3 (Biological Environment) of the Information Guide "Does the site lie within the migratory route of any fish species?" and section 2.2.3.1 (Socio-Economic Environment), i.e., "Describe any fishing activities.in the vicinity of the site that could potentially be affected..", we offer the following observations and comments regarding salmon stocks in Bute Inlet and the fisheries that depend upon them.

    Schedule C siting criteria states that sites must be located : Not in areas that would pre-empt important Aboriginal, commercial or recreational fisheries as determined by the province in consultation with First Nations and DFO.

    In section 2.3.2 of the Heritage Relocation Application the proponent states:

    "Heritage Aquaculture has initiated communications with selected aboriginal, commercial and recreational fishing stakeholders in order to obtain feedback with regards to this proposal. Any comments received by Heritage Aquaculture will be forwarded to BC Assets and Lands."

    The proponent attended open houses March 6, 7 and 8 of 2001 to obtain public feedback and we include the "Summary Public Input for Heritage Bute Inlet Fishfarm Relocations and Pilot Project", prepared by Land and Water BC (p.3-6, Appendix A.). We have been unable to locate any other public comments provided by the proponent.

    Recreational Fishing Stakeholders

    Recreational fishing stakeholders of Bute Inlet include approximately 50 independent local sports fishing guides, 12 local sports fishing lodges, a significant number of guided vessels that day-trip to the Stuart Island area out of Campbell River , and a great many cruising boaters who frequent the area either as a destination or as an important waypoint.

    The proposed Downie Range site lies on the eastern shore of Bute where the areas known as Fawn Bluff and Spring Creek meet. The proposed site is in direct line of sight as one enters Bute through the Arran Rapids and is well known to local guides for excellent chinook fishing in the spring and early summer. These fishing activities would be pre-empted by a salmon farm at the Downie Range.

    The position of recreational fishing stakeholders was clearly evident at the two public hearing held by the Comox-Strathcona Regional District as part of the re-zoning process. Many sport-fishing guides and lodge owners spoke in opposition to the application. None spoke in favour.

    In the spring of 2001, the Sport Fish Advisory Board passed the following resolution:

    "Whereas the proposed Fish Farm sites in Bute Inlet {Clipper Pt., Paradise River, Downey [sic] Range} will interfere with recreational access by occupying prime sport fishing locations and,

    Whereas the proposed sites and also most of the inlet are exposed to severe winter outflow wind conditions, likely to lead to pen damage and subsequent fish escapes.

    Be it resolved that Federal and Provincial Agencies review the appropriateness and safety of these sites prior to any further aquaculture activities in Bute Inlet."

    Recently, the Sport Fishing Institute of BC passed the following resolution:

    "The Sport Fishing Institute of BC supports the precautionary principle in fisheries management and believes that this principle requires an end to net cage salmon aquaculture unless and until the federal and provincial governments can demonstrate that this form of salmon farming can be operated in a manner that does not pose a threat to naturally reproducing salmon stocks."

    The recreational fishery in Bute Inlet is a significant and sustainable industry that relies on healthy salmon stocks, access to fishing grounds and the undeveloped natural beauty for which Bute Inlet is renowned.

    As requested in the Information Guide, contact information for recreational fishing stakeholders is hereby provided:
    [Stakeholder names and phone numbers provided in original letter for consultative purposes.]

    Commercial Salmon Fishing Stakeholders

    The Area "D" Gill-netters and the Gulf Trollers Association Area "H" represent commercial salmon fishing stakeholders in the Bute Inlet area. Commercial fishing activities in the vicinity of the proposed site that would be affected are well documented in internal DFO correspondence:

    • "Traditional salmon gillnet fisheries in the area of Bute Inlet." (p.2, Appendix A)
    • "The preferred gillnet set area is within the southernmost bay, presently designated for the farm site. Troll tacks by sport and commercial fleets favor the shoreline." (p.14, App. A)
    • "A potential conflict with prawn fishers and commercial gillnet fishers targeting chum salmon may exist and this should be addressed through appropriate Fisheries Management staff." (p.11, Appendix A)

    For reasons described above, commercial salmon fishing stakeholders do not the support the proposed aquaculture facility at the Downie Range . Area "D" Gill-netters participated in a chum salmon opening this past fall, with numerous sets being made within the proposed tenure.

    To our knowledge, neither the proponent, the province nor DFO has consulted commercial salmon fishing stakeholders to date.

    As requested in the Information Guide, contact information for commercial salmon fishing stakeholders is hereby provided:

    [Stakeholder names and phone numbers provided in original letter for consultative purposes.]

    Wild Salmon Migration Routes

    The Finfish Checklist requests "detailed supporting information" regarding the " Location of 'sensitive fish habitat' such as kelp beds, eelgrass, herring spawn areas, migratory routes, etc., that are within 1km of the farm tenure". It also states, "Information describing the size or area of habitat, depth, seasonality/frequency of use, etc., should also be provided."

    Under section 34 of the Fisheries Act , fish habitat is defined as "spawning grounds and nursery, rearing, food supply and migration areas on which fish depend directly or indirectly in order to carry out their life processes."

    We note that the proponent has provided no information addressing what we consider to be the most serious potential impacts of the proposed project: the impact on the health of the wild salmon stocks in Bute Inlet, and in particular, the impact on migrating salmon smolts of sea-lice incubated within the netcages. Without such data it is simply not possible to determine that the project would have no significant environmental impact.

    Bute Inlet is 75km in length and fed by three major river systems: the Orford River , mid-way up the inlet; and the Homathko and Southgate Rivers , which feed into the head of the inlet. These rivers, all glacially fed, have long provided spawning and rearing habitat for all five species of Pacific salmon. Glacial till in these rivers is most abundant from late summer to early fall and often results in difficulty enumerating salmon stocks due to low water clarity. Consequently, it has not been possible to compile escapement data for all salmon stocks on a consistent basis. An exception has been chum escapement; data for Orford and Southgate chum stocks follow:

    Orford Chum Escapements:
    Southgate Chum Escapements:

    2003       ~50,000 - 60,000

    2002       29,136

    2001       14,000

    2000        7,000

    1999       15,000

    1998         5,000

    1997         7,000

    1996         4,500

    1995        30,000

    1994         1,500

    1993        60,000

    2002       45,000

    2001       40,000

    2000        8,000

    1999        8,000

    1998       16,000

    1997       25,000

    1996       20,000

    1995       50,000

    1994       85,000

    1993     175,000 *

    *Escapement data prior to 2001: FishWizard
    ** Preliminary escapement data 2001-2003: DFO Stock Assessment

    Upon emerging from the gravel environment, chum fry, like pinks, promptly migrate downstream to estuarine waters and into the marine environment, not spending significant time rearing in fresh water like other salmon species (E.O. Salo, 1991, Life History of Chum Salmon, pages 252-257 in Pacific Salmon Life Histories . C. Groot and L. Margolis). Consequently, juvenile chum salmon starting their outmigration through the nearshore marine environment are smaller in size (~0.2 - 0.4 grams or 35-40mm as per Healey, M.C., 1980, The ecology of juvenile salmon in Georgia Strait , British Columbia , pages 203-205 in Salmonoid ecosystems of the North Pacific. W.J. McNeil and D.C. Himsworth), than other salmon species during outmigration, putting them at an even higher risk of mortality due to lice loading as a result of contact with Lepeophtheirus salmonis copepods incubated on salmon farms. Juvenile chum salmon outmigrating along the nearshore of Bute are observed every March and April, by Fisheries Officers carrying out herring surveys.

    According to internal DFO correspondence, " The most significant Chum spawning rivers in Area 13 flow into the inlet. [our emphasis] These rivers have supported a commercial harvest in the past and I believe will do so in the near future (p.15, Appendix A)." In fact, a commercial chum opening occurred in the fall of 2003, presumably demonstrating the confidence of DFO in the Bute chum stocks.

    DFO's on-line document, Fisheries Management Pacific Region: Fishery Overview of Coastal First Nations Fisheries in Southern BC , states in regard to Coast Salish First Nations:

    "This group consists of 23 First Nations fishing in the Strait of Georgia , Juan de Fuca Strait and Lower Mainland rivers. Passing Fraser stocks are a major component of this group's fisheries. Also important are Bute Inlet chum.. " [our emphasis]

    The northern half of Bute Inlet, from Orford River on the east side and Alpha Bluff on the west side, has been closed to sports and commercial fishing for over 20 years. The rationale for this closure is to protect migratory salmon stocks, particularly chinook (Personal comm. with Kent Spencer, Resource Manager, Central Coast Area, Fisheries and Oceans Canada, February 2004). In addition, the area of Spring Creek, immediately south of the proposed Downie Range site, has traditionally had a sport fishing closure. A fish farm at Downie Range would sit directly in the migratory corridor of salmon, juvenile or adult, attempting to enter or exit the inlet.

    The geographic nature of Bute Inlet is such that migratory salmon stocks must follow either the western or eastern shoreline as they enter or exit the inlet. Given this fact, and the salmon stocks that are known to spawn and rear in the Homathko, Southgate and Orford Rivers , it is only logical to conclude that Bute Inlet is a restricted migration route of high activity. This conclusion is supported by internal DFO correspondence:

    • "This inlet is a corridor for migrating salmon and there is a known holding area for adult chinook and chum south of Downie Range ". (p.11, Appendix A)
    • "The proposed farm site under application by Heritage Aquaculture is located within the southern portions of a 5.6 Sq.K. (square kilometer) holding back eddy utilized by migratory stocks in Bute Inlet". (p.14, Appendix A)
    • "The Salmon stocks in the area are unique to the area.It has been my observation that migrating smolts favor the shoreline as they migrate seaward." (p.15, Appendix A)

    It is important to ensure that open netcage fish farms are not sited along wild salmon migration routes, to avoid the risk of transferring parasites and diseases to wild fish (particularly juveniles, which cannot tolerate as high a level of sea lice or pathogens). This is why the Senate Standing Committee on Fisheries recommended, "grow-out sites for salmonid fish be prohibited near migratory routes as well as near rivers and streams that support wild salmon stocks" [ Aquaculture in Canada's Atlantic and Pacific Regions , Report of the Standing Senate Committee on Fisheries, June 2001].

    This has also been recognized in other jurisdictions. In 1999 the Scottish Environmental Protection Agency recommended that fish farms be located well away from entry points of smolts to the marine environment. In 2001, the Norwegian government announced its plan to declare 39 river systems and 22 fjords protected areas for wild salmon, in order to "provide specific protection against harmful encroachment on watercourses and the negative impact of fish farming to .wild salmon populations."

    Section 4.4 of the Information Guide (Examples of Potential Environmental Effects) identifies "various effects relative to components of the environment that could be affected by marine finfish aquaculture operations, as well as possible mitigation and monitoring." Table 1B of Fisheries Resources states that a potential environmental effect from the physical footprint of the cage is to "Alter migration patterns of fish" and possible mitigation is to "Avoid sites with high migration activity." [our emphasis]

    Additionally, Appendix 6 of the Fisheries Act Guide identifies unacceptable HADDs (Harmful, Alteration, Disruption or Destruction) of fish habitat or "showstoppers" for which DFO would not issue a subsection 35(2) Fisheries Act authorization. The list of considerations when determining unacceptable HADDs includes, "The presence of critical habitat such as spawning areas, restricted migration routes [our emphasis], etc. at the site, or sufficiently close to the site that the effects cannot be mitigated adequately."

    We respectfully submit that the proposed Downie Range site clearly lies in a restricted migration route of high activity that cannot be mitigated adequately, and that authorization of the project under subsection 35(2) of the Fisheries Act would result in an unacceptable HADD, as identified in Appendix 6 of the Fisheries Act Guide.

  4. Herring stocks and fisheries in Bute Inlet

    Schedule C siting criteria states that sites must be located : At least 1 km from herring spawning areas designated as having "vital", "major" or "high" importance.

    In section 2.3.1 of the Heritage Relocation Application the proponent states:

    "Available herring resource information was reviewed. No vital, major or important herring spawn areas were identified that would be affected by the proposed facility. In addition please refer to the DFO inter and sub-tidal transect report prepared by I.U.S Inc."

    For reasons outlined in the General Observations section of this submission, the IUS EA referred to above cannot be relied upon to reflect the reality of the herring stocks that frequent the holding back eddy in which the proposed site would lie. Further, the conclusion that "No vital, major or important herring spawn areas identified that would be affected by the proposed facility" is in direct conflict with internal DFO correspondence that states:

    • "Juvenile Herring utilize the entire inlet throughout the year" (p.14, Appendix A).
    • "In addition to the Herring Spawn that occurs annually in the inlet, Herring in their Larvae stage are pushed into the area as a result of the Strait of Georgia drift.The drift also carries with it euphasids in their larvae stage." (p.14, Appendix A)
    • "Proximity to herring spawn, spawn on rock face of Bute Inlet" (p.3, Appendix A)
    • "It has been my observation over the past 13 years that the natural back eddy holds migratory Herring and Salmon stocks of all species." (p.14, Appendix A)

    As requested in the Information Guide , contact information for commercial herring fishing stakeholders is hereby provided:

    [Stakeholder names and phone numbers provided in original letter for consultative purposes.]

  5. Prawn stocks and fisheries in Bute Inlet

    In section 2.3.1 of the Heritage Relocation Application the proponent states:

    "Heritage has initiated communications with the two major Prawn Fishery stakeholder organizations: BC Prawn Fishermen's Conservation Society and the Pacific Prawn Fishermen's Association. Any relative information or comments will be directed to DFO for assessment."

    The Pacific Prawn Fishermen's Association (PPFA) represents 85% of the commercial prawn fleet. The PPFA is opposed to the Downie Range site, as it would sit directly over a productive prawn fishing area. Furthermore, while Bute Inlet supports a healthy population of prawns, its steep-sided geography provides only limited shelf space where prawn sets can occur. The Downie Range is one of these few sites.

    Internal DFO memos state:

    • "The area of concern has long supported a Spot Prawn fishery. Numerous setting spots are within the area." (p.15, Appendix A)
    • "The proposed site is currently used and considered to be prime fishing area by commercial prawn trap fishers. Conflicts with the commercial prawn trap fishery are anticipated with this development." (p.1, Appendix A)
    • ".advise that the proponent or the Province of BC meet with the prawn sectoral group to see if their interests can be accommodated." (p.1, Appendix A)

    It is our understanding that, to date, the Province of BC has not met with the Prawn Sectoral Group.

    Additionally, the PPFA has not yet been contacted by the proponent or the province, despite the fact that the position of the PPFA was submitted in writing to the Comox-Strathcona Regional District at the July 21, 2001 public hearing.

    As requested in the Information Guide , contact information for commercial prawn fishing stakeholders is hereby provided:

    [Stakeholder names and phone numbers provided in original letter for consultative purposes.]

  6. Rockfish stocks in Bute Inlet

    The proponent has provided very little information concerning rockfish populations in the proposed area. As stated earlier, neither of the IUS EA or the Supplemental IUS EA includes vertebrate species in the richness and diversity analysis, and therefore cannot be relied to reflect the reality of rockfish populations that reside in the proposed area.

    According to internal DFO correspondence, ". important biological resources in the area include rockfish and lingcod." (p.11, Appendix A)

    We note that DFO's Rockfish Conservation Strategy has identified Revised Candidate Rockfish Conservation Areas (RCA's) for Implementation in 2004 , which includes two RCAs in Bute Inlet. Site number 96 encompasses the eastern shoreline of Stuart Island running from Bud Bay to Turn Back Point. This RCA is located across the inlet and on the shoreline adjacent to the proposed site. Site number 128 encompasses the entire northern half of the inlet, from Alpha Bluff and Orford River to the head of the inlet.

    We are concerned that the presence of a netcage salmon farm will lead to the deposit into the marine environment of waste feed, fish excrement, pesticides and antibiotics which will would have a significant negative impact on rockfish populations, especially in light of the sedentary nature of rockfish. This would run counter to DFO's stated Rockfish Conservation Strategy of rebuilding Pacific inshore rockfish stocks, particularly in the Strait of Georgia.

    To date, neither the proponent, the province nor DFO has consulted commercial rockfish stakeholders.

    As requested in the Information Guide, contact information for commercial rockfish stakeholders is hereby provided:

    [Stakeholder names and phone numbers provided in original letter for consultative purposes.]

  7. Degradation of fundamental wilderness characteristics that make Bute Inlet unique

    The Finfish Checklist requests a "Description of other present uses of the area surrounding the site (e.g. tourism, recreational boaters, logging etc) (details, e.g. location, operators, frequency) ". Section 2.2.3.1 (Socio-Economic Environment) asks for a description of "any.tourism operations.in the vicinity of the site that could potentially be affected'.

    As environmental awareness has grown, wilderness tourism has established itself as one of British Columbia 's most sustainable and non-consumptive industries, with an annual growth rate in excess of 9%. Over the past decade, Bute Inlet has emerged as one of the premier destinations for marine tourism on the coast of BC , as the blend of wilderness characteristics that make Bute unique are experienced by more people each year. The success of Bute Inlet as a marine tourism destination is directly related to these fundamental wilderness characteristics; conversely, degradation of these characteristics would be detrimental to those businesses that depend on their existence and to the future possibility of the development of new wilderness tourism businesses in the area.

    Considered one of the grandest fjords in the world, Bute Inlet is surrounded by rugged coastal mountains that rise to heights of nearly 10,000 feet, capped by the Homathko Icefield and numerous other glaciers in the surrounding mountain ranges. The upper reaches of the inlet comprise steep granite bluffs, numerous hanging valleys, and impressive waterfalls.

    Bute Inlet is glacially fed by 3 major river systems: the Orford, Southgate and Homathko Rivers ; the importance of these watersheds has been recognized by establishment of the Homathko River - Tatlayoko Protected Area, the Homathko Estuary Provincial Park and the Bishop River Provincial Park .

    The Homathko River - Tatlayoko Protected Area was designated through the Cariboo Chilcotin Land Use Plan in 1996 and comprises 17,575 hectares, preserving one of the few river bottom transitions across the Coast Mountains from the rainforest to the interior plateau. Unique features of the surrounding area include the spectacular Waddington Canyon on the Homathko River, extensive icefields, and the aquamarine Tatlayoko Lake.

    The Homathko Estuary Provincial Park was established in 1997 and comprises 234 hectares of upland and 216 hectares of foreshore for a total area of 450 hectares. The park is located at the head of Bute Inlet with the primary purpose of protecting the conservation values of a Pacific Coast estuary. According to the Garibaldi/Sunshine Coast District Management Direction Statement ( June 1999), the park " Protects portions of important habitats for coastal wildlife including grizzly bear, black bear, black-tailed deer, wolves, cougar, resident and anadromous salmonids, shorebirds, raptors and waterfowl."

    Bishop River Provincial Park encompasses 19,947 hectares and is located at the headwaters of the Bishop River, a primary tributary to the Southgate River.

    The emerald green runoff from these watersheds flows toward Stuart Island at the mouth of Bute, where water flowing in through Johnstone Strait mixes with it at the Arran, Yuculta and Dent Rapids. These tidal rapids surrounding Stuart Island are among the most impressive in the world. The floodtide is known to push through the Arran Rapids in excess of 18 knots, resulting in whirlpools that can be greater than 7 meters in diameter and equally deep. Boils push up unexpectedly to heights of 3 meters or more. The colour contrast between the glacial runoff and the almost black ocean water is striking; the mixing of the two in tidal rapids is unique.

    In the spring and summer months it is not unusual to witness 50 to 100 bald eagles in the Arran Rapids feeding alongside seals and stellar sea lions. Dalls Porpoises, Pacific Whitesided Dolphins and Orcas are commonly seen in the rapids and throughout the inlet. Black bears are easily spotted along the shoreline of Bute and exceptional viewing opportunities for grizzly bears are available at all the major watersheds.

    Marine tourism operators enter Bute Inlet via either the eastern shoreline of Bute or through the Arran Rapids at slack tide. The proposed fish farm site lies directly in the path of the eastern shoreline route and is in direct line of sight as one enters Bute Inlet through the Arran Rapids. Tourism operators follow the shoreline closely in order to maximize wildlife viewing opportunities.

    The proposed site would negatively impact tourism operations both because of its location (directly on the tour route), and by degrading the wilderness characteristics that draw visitors to the area. Impacts that would degrade these fundamental wilderness characteristics include:

    • the visual impact of an industrial operation,
    • generator noise,
    • constant noise of modern forced-air feeding systems,
    • movement of crew boats in and out of the area,
    • harvesting and associated activities (which carry on for months),
    • movement of mort barges and divers in and out of the area,
    • mort totes and the associated odour,
    • helicopters transporting hatchery smolts, and
    • net washing operations.

    These industrial activities are inconsistent with the fundamental characteristics upon which tourism operators in the area depend.

    In the long run, any impact in the wild salmon stocks will also have an additional negative impact on marine tourism operations, even those not connected with sports fishing, because any decline in salmon stocks leads to a decline in the presence of the wildlife which feed on salmon (including bears and killer whales, key species for marine wildlife watching operators).

    It is instructive to note the current locations of salmon farm tenures in the lower Johnstone Strait/ Discovery Island/Bute Inlet area (p.1, Appendix B). Bute Inlet is one of the few locations in this area that is free of salmon farms, further increasing its value as a marine tourism destination. The mouth of Bute Inlet is located 50km northeast of Campbell River and is easily accessible by boat or floatplane during the extended tourism season enjoyed in this area (May-October).

    Given its pristine nature, recognized ecological values, unique blend of characteristics, proximity to the marine tourism market and growing importance as a premier destination, it is clear that Bute Inlet is a valuable asset to BC's wilderness tourism industry. This value is not compatible with industrial salmon aquaculture.

    As requested in the Information Guide, contact information for tourism stakeholders is hereby provided:

    [Stakeholder names and phone numbers provided in original letter for consultative purposes.]

  8. Oceanographic conditions, winds, icing, net-cage buoyancy and anchoring.

    In response to information requested in section 2.2.1 (Aquatic Environment) and 2.2.5 (Changes to the Project Caused by the Environment) of the Information Guide we offer the following comments regarding the Ocean Dynamics Report and the Westmar Report , submitted by the proponent.

    Wind and Wave Calculations

    While the Ocean Dynamics Report states that "wind speed records, from light and weather stations such as Cape Mudge near Campbell River, do not reflect the true wind speed and direction of winds exiting Bute Inlet", the Westmar Report states that, "the wind loads on the Wavemaster cages are calculated using wind data from Campbell River, Cape Mudge and Comox." Consequently the Westmar Report calculates a maximum wind speed of 24.0 m/s from the North sector. This is less than 50 knots and far less than the northerly outflow wind speeds that are known to occur in Bute Inlet. According to internal DFO memos, the wind gauge at the Stuart Island airport "recorded a wind speed of 94 mph [75 knots] before being blown away (p.9, Appendix A)." On this basis alone one cannot rely upon the Westmar Report .

    The Ocean Dynamics Report calculates "Deep Water Significant Wave Heights for a 1 in 30 Year Condition" using formulas for offshore waters, while the Westmar Report calculates "unrefracted wind generated waves." Both of these calculations reflect conditions that would exist in open water, for a given wind speed. However, the shoreline of Bute Inlet is irregular with steep sided rock faces throughout the inlet. This results in significant wave refraction, shorter wave periods than in offshore waters and a confused sea state during wind events, most notably during high outflow northerly winds. The inappropriate nature of the offshore wave generation formulas used is clear in the Ocean Dynamics Report description of Bute: "The local geographic conditions of narrow valleys and glaciated mountains in proximity to Bute Inlet creates very localized conditions." and "high outflow northerly wind velocities can be expected across the lease." Consequently, the wave generation formulas applied in both the Westmar Report and the Ocean Dynamics Report do not reflect the oceanographic conditions that exist in Bute Inlet.

    We note that the "Deep Water Significant Wave Heights for a 1 in 30 Year Condition" calculated on section 3.5 of the Ocean Dynamics Report are denoted as being data for the Paradise River Site, which not the site under consideration.

    This may or may not explain the discrepancy between the Ocean Dynamics Report and the Westmar Report in relation to calculated fetch lengths:

    South
    SW
    West
    NW
    North

    Westmar Report
    0.8 km
    7.2
    4.0
    6.4
    0.4

    Ocean Dynamics Report
    0.5 km
    4.5
    2.2
    3.9
    4.1

    and peak wave period:

    Peak Wave Period T(sec) @ Northwest 25.0 m/s

    Westmar Report
    3.8

    Ocean Dynamics Report
    5.6

    The Westmar Report only supplies data for northwest wind speeds of 25 m/s; consequently data comparison between the two reports is limited to this wind speed and direction. The significant difference between the calculated fetch lengths and wave period demonstrates the speculative nature of these reports.

    Internal DFO memos raise the following concerns:

    • "The sensitivity of the area to high winter winds and currents are problematic and can cause site failures." (p.2, Appendix A)
    • "Severe weather patterns are known to occur in this area. The extreme weather is of particular concern as it could result in a large escape of Atlantic salmon." (p.11, Appendix A)
    • "The issue for CCG will be whether or not the facilities will remain on site. Drifting net pens would most certainly qualify as a safety concern to mariners." (p.7, Appendix A)

    Icing, Snow and Net-Cage Buoyancy

    The Westmar Report assumes a design ice thickness for the Bute Inlet area of 31mm (derived from the Ontario Highway Bridge Design Code, 1983) while the Ocean Dynamics Report estimates that the pens will submerge when covered with 4.97 inches (126 mm) of ice; in Appendix D of the Ocean Dynamics Report , Wavemaster Icing Data, we do not see any design parameters defining that 4.97 inches in any way reflects the actual level of icing that may be experienced at the site. Anecdotal information suggests that ice accumulations in excess of 12 inches (304 mm) are not uncommon during an outflow wind event. The Westmar Report concedes, "it is evident that full snow loading could submerge the Wavemaster system."

    As a contingency plan for icing the proponent states, "Nets will be sewn to the top of the net pens at the water surface level during potential episodes of extreme weather for both the Clipper and Downie Range applications. This is a preventative measure to reduce the risk of escaped fish should ice build up occur and reduce the buoyancy of the net cage systems (p.10, Appendix A)."

    This "preventative measure" is another admission that the Wavemaster system could submerge during icing events.

    Anchoring System

    According to the Westmar Report :

    "The proposed Downie Range and Clipper Point facilities are located in challenging anchoring environments. Water depths of more than 600 metres are found less than 1 km from the shoreline. This represents an average seafloor slope of 30 degrees.due to the limited information with regard to the environmental conditions on the East shoreline of Bute Inlet, a full dynamic analysis of the system was deemed inappropriate. A simplified approach was adopted."

    No documentation or calculations of this "simplified approach" are included in our copy of the Westmar Report , although this is the basis for Westmar to deem "the proposed Wavemaster system to be suitable for the aquaculture locations at Downie Range and Clipper Point."

    We note that on May 30, 2001 Sunshine Coast Engineering Ltd. confirmed to Ocean Dynamics Canada Ltd. completion of an "Anchoring System Design" for the proposed Downie Range site. An engineer's stamp accompanies this confirmation. (p.8, Appendix A)

    Appendix B of the Ocean Dynamics Report includes a Description of Engineering Analysis for Aquaculture Anchoring Systems by Sunshine Coast Engineering (1993) Ltd. for Ocean Dynamics Canada Ltd. which states:

    "We generally try to design the system so that the dead weight of the anchor system is equal to or greater than the forces exerted on them due to current and wind on the pens.

    There is little written hard data regarding the anchoring systems that are used for aquaculture. Engineering analysis of the rope, shackles and chain can be completed simply, as there is a great deal of data available. The forces on the net system are far more difficult and involve several assumptions [our emphasis]. The forces exerted on the net relate to current and wind data on the site. As well, the amount of fouling of the net (by marine growth) also affects the forces exerted on the net and thus the anchoring system. These forces and assumptions are used to arrive at a calculated force on the anchoring system. We are utilizing the drag equation to arrive at the forces exerted by currents and wind on the system."

    In our copy of the Ocean Dynamics Report we have been unable to locate any design parameters that utilize either the "drag equation" or the generated "Deep Water Significant Wave Heights" to calculate the forces exerted by current, wind, waves and icing on the proposed net-cage system.

    The Escape Prevention Plan states, "Divers will inspect subsurface anchoring equipment annually to a depth of 10 m or by other means and results of any needed repairs will be recorded. Given that offshore mooring lines extend to depths of over 600 m and are in excess of 1.2 km in length, we submit that this inspection protocol is irresponsible . There are no existing aquaculture net-cage systems in BC that are anchored in this depth of water. Further, LWBC wishes to issue a 2-year temporary permit to investigate the unproven technology of long anchor lines at the proposed Downie Range site.

    In its August 1, 2002 press release regarding the proposed Downie Range site, the BC Ministry of Sustainable Resource Management states, "The operation will also provide on-site experience and help to verify whether the recommended technology for the farm is suitable for Bute Inlet" (p.13, Appendix A, our emphasis).

    Use of this experimental technology in Bute Inlet would be in direct conflict with the recommended mitigation measures put forward in the Information Guide (described below).

    Section 4.4 of the Information Guide (Examples of Potential Environmental Effects) identifies "various effects relative to components of the environment that could be affected by marine finfish aquaculture operations, as well as possible mitigation and monitoring." Table 1H - Physical Structure of the Facility states that mitigation measures for the possible environmental effect of "Cage damage resulting in loss of fish" include that the structure be "Engineered to account for extreme site and operational conditions," and to "Use only proven technologies and equipment" [our emphasis].

    Further, section 2.5 of the Site Marking Guide states that the proponent (owner) must "ensure that a reliable and safe mooring system is in place that is capable of maintaining the works in position under all foreseeable weather and sea state conditions, and waterway characteristics " [our emphasis].

    We respectfully submit that the proposed Wavemaster net-cage array satisfies neither the recommendations in Table 1H of the Information Guide, nor the responsibilities outlined in section 2.5 of the Site Marking Guide , and that neither the Ocean Dynamic Report nor the Westmar Report can be relied upon to reflect the oceanographic conditions or the viability of the Wavemaster system in the proposed lease area.

    In Environment Canada's publication, The Wind Came All Ways (Owen S. Lange), the author quotes experienced mariners regarding Bute Inlet:

    "Bute winds are fierce, they come out like an air hose.if you hear a roar up in the mountains, you have four hours to get out of the inlet.the winds are so strong that you cannot cross the mouth of Bute during an outflow.Bute winds are very vicious, and you need to respect them."

  9. Cumulative impacts

    Section 2.2.6 (Cumulative Environmental Effects) of the Information Guide states that "thinking cumulatively" requires giving consideration to "the interactions among the environmental effects of this project, and other existing and planned future aquaculture and non-aquaculture projects and activities."

    It is our understanding that no systematic research has been conducted which would clearly identify the migration routes of Bute Inlet smolts. However, it is instructive to examine the locations of existing salmon farms in relation to possible migration routes for these smolts (p.2, Appendix B). A summary analysis reveals a total of 9 likely routes. Assuming that Bute smolts follow only one of the routes directly to Johnstone Strait or the Strait of Georgia, the minimum number of salmon farm tenures currently on each possible route, starting with the southernmost, range from one to six. The three southernmost routes (with 1, 5 and 6 existing tenures) lead to the Georgia Basin while the remaining six routes (each with 4 to 6 existing tenures) lead to Johnstone Strait. In cases where Bute smolts do not directly migrate to Johnstone Strait or the Strait of Georgia, it is very likely that they would need to pass even more salmon farm tenures than listed above.

    In terms of what cumulative effects require consideration by the responsible authority, paragraph 16(1)(a) of the CEA Act states that consideration shall include, " cumulative environmental effects that are likely to result from the project in combination with other projects or activities that have been or will be carried out".

    The Hon. John Fraser, in his role as Chairman of the Pacific Fisheries Resource Conservation Council, stated in a brief to the Senate Committee on Fisheries and Oceans on March 18, 2003:

    ". while there is no absolute proof directly linking the spread of sea lice from farmed salmon to wild salmon populations, there is a growing body of compelling evidence suggesting that this is a very real possibility. Of all the fish health issues considered in this report, sea lice from fish farms constitute the most serious and immediate risk."

    Each additional salmon farm along the migration route will increase the potential for juvenile salmon to be exposed to Lepeophtheirus salmonis copepods incubated on salmon farms. We believe that cumulative environmental impacts of an additional salmon farm located directly on the migration route of Bute smolts are likely and merit very serious consideration.

    Section 3.3 of the Guide to Cumulative Effects states that an assessment of cumulative environmental effects should include consideration of the following:

    • severity of the effects;
    • the geographic extent of such effects;
    • the duration and frequency of such effects;
    • the degree to which such effects are reversible; and
    • the fragility of the ecological area;

    Experience in other jurisdictions (Norway and Scotland), and recent experience in the Broughton Archipelago (Morton et al, Canadian Journal of Fisheries and Aquatic Science , March 2, 2004 ) suggests that the severity of effects from the cumulative impact of salmon farms may be very serious. The geographic extent of such effects would include the entire Bute Inlet ecosystem, as it is highly probable that smolts migrating out of all three Bute watersheds would need to pass by the proposed aquaculture site. The degree to which such effects are reversible is low, and in the worst-case scenario may be zero. While Pacific salmon stocks in Bute Inlet currently support a lucrative sport-fishing industry and the re-emergence of some commercial fishing, the ecological area of Bute Inlet has been subject to decades of intensive logging and salmon harvesting. The area surrounding Bute Inlet has been subject to concentrated salmon farming for over a decade; it is difficult to gauge with any certainty the carrying capacity of the area to withstand additional cumulative effects.

    Given the considerable number of salmon farms already located on the migration routes of Bute smolts, we submit that cumulative effects from a salmon farm at Downie Range clearly have the potential be significant and have a serious impact on the health of Bute Inlet salmon stocks.

  10. Socio-Economic Effects

    The Guide to Socio-Economic Effects differentiates between socio-economic effects attributable to changes in the environment ("indirect" effects) and socio-economic effects arising from the project itself ("direct" effects), and states as an example of a direct effect, "the loss of fishing privileges as a result of the issuance of the provincial aquaculture lease". The Guide to Socio-Economic Effects further states that, ".'direct' socio-economic effects (typically, positive effects) can be applied to mitigate the adverse effects resulting from the project."

    The proponent estimates six full time jobs could be created in the operation phase of the project. (p.18, Appendix A) This conclusion is either based on an earlier version of the proposal or would appear to be intentionally misleading. The proposal is for the relocation of an existing aquaculture facility and it cannot, therefore, be reasonably anticipated that the project will result in any net creation of additional employment.

    We respectfully submit that given the significant negative socio-economic effects outlined in this submission, the direct negative socio-economic effects of the proposed facility likely outweigh any direct positive socio-economic effects, and may intensify, not mitigate, the adverse effects resulting from the project.

    Furthermore, any indirect socio-economic effects, attributable to changes in the environment, can only have a negative effect on the socio-economic fabric of the local area. These indirect socio-economic effects have been detailed throughout this submission.

    Taken together, the negative direct and indirect socio-economic effects of the proposed project are considerable and it is unclear how these negative socio-economic effects could be mitigated. We respectfully request that a comprehensive assessment of these effects take place prior to any decision being made with regard to the proposed project.

Concluding Remarks

Subsection 18(2) of the CEA Act states that, " where a responsible authority is of the opinion that the information available is not adequate to enable it to take a course of action pursuant to subsection 20(1), it shall ensure that any studies and information that it considers necessary for that purpose are undertaken or collected."

Throughout this submission we have provided numerous sources for new information that is crucial for the responsible authority to undertake a well-informed course of action. Pursuant to subsection 18(2) of the CEA Act we request that DFO, as the responsible authority, ensure this information is collected.

In its role as the responsible authority required to carry out the environmental assessment of the proposed Downie Range site under the CEA Act , and pursuant to paragraph 4(d) of the CEA Act, DFO is required to "ensure that there be an opportunity for public participation in the environmental assessment process."

Section 1.7 of the Information Guide states, "The majority of aquaculture projects requiring an EA will undergo a screening, which is a systemic approach to documenting the environmental effects of the proposed project and determining the need to minimize or mitigate these effects; to modify the project plan; or to recommend further assessment through mediation or a panel review [our emphasis]".

Section 25 of the CEA Act states:

"Subject to paragraphs 20(1)(b) and (c), where at any time the responsible authority is of the opinion that

(a) a project, taking into account the implementation of any mitigation measures that the responsible authority considers appropriate, may cause significant adverse environmental effects, or

(b) public concerns warrant a reference to a mediator or a review panel,

the responsible authority may request the Minister to refer the project to a mediator or a review panel in accordance with section 29."

Given that:

  • on August 27, 2001 the Comox Strathcona Regional Board, as a result of overwhelming public concerns, adopted a resolution which stated, " Bute Inlet is an unsuitable location for any industrial aquaculture operation; AND THEREFORE, the Regional Board requests that all relevant agencies ensure that further study and a detailed response to the expressed public concerns take place prior to any further consideration of industrial aquaculture operations in Bute Inlet";
  • in two comprehensive submissions to the Major Projects Review Unit of DFO the Homalco First Nation has documented numerous negative impacts the proposed site would have on the traditional use of lands, fisheries and resources;
  • there are numerous cases where information provided by the proponent is in direct conflict with internal DFO correspondence on the same subject;
  • the proponent has provided conflicting and speculative data in regard to oceanographic conditions in Bute Inlet and the ability of the proposed experimental net-cage system to withstand all foreseeable weather and sea state conditions;
  • approval of this project would result in considerable direct negative socio-economic effects due to lost fishing privileges for several key economic industries, and the degradation of fundamental wilderness characteristics upon which the tourism industry depends;
  • approval of this project would run counter to DFO's stated Rockfish Conservation Strategy of rebuilding Pacific inshore rockfish stocks, particularly in the Strait of Georgia;
  • Bute Inlet is a restricted salmon migration route of high activity;
  • cumulative effects from a salmon farm at Downie Range clearly have the potential to be significant and have a serious impact on the health of Bute Inlet salmon stocks;
  • approval of this project would contravene Schedule C siting criteria which states that sites must be located : Not in areas that would pre-empt important Aboriginal, commercial or recreational fisheries as determined by the province in consultation with First Nations and DFO;
  • a section 35 authorization of this project under the Fisheries Act would directly contravene Schedule C siting criteria that states sites must be located : Consistent with approved local government bylaws for land use planning and zoning;

we hereby request that, DFO, as the responsible authority under the CEA Act , deny a section 35 authorization for this project, or at the very least, pursuant to section 25 of the CEA Act, refer this project to a panel review for further assessment and a comprehensive, transparent and public evaluation of concerns and potential impacts.

If you have questions regarding the details in this submission, please contact Eric Blueschke at 250-334-0095 (or by email, eric@georgiastrait.org ).

Please contact pat@georgiastrait.org for a complete hard copy of this submission including appendices

Thank you for your consideration of our concerns and we look forward to hearing from you.

Sincerely,

Laurie MacBride,
Executive Director

cc: Hon. David Anderson, MP, PC, Minister of the Environment
Hon. Geoff Regan, MP, PC, Minister of Fisheries and Oceans
Hon. Andy Mitchell, MP, PC, Minister of Indian and Northern Affairs
Peter Stoffer, MP, Member of the Parliamentary Fisheries Committee
John Reynolds, MP
John Cummins, MP
Svend Robinson, MP
Hon. George Abbot, Minister of Sustainable Resource Management
Hon. John Van Dongen, Minister of Agriculture, Food and Fisheries
Hon. Bill Barisoff, Minister of Water, Land & Air Protection
Harold Long, MLA
Joy MacPhail, MLA
Chief and Council, Homalco First Nation
Chairperson & Directors, Regional District of Comox-Strathcona
Hon. John A. Fraser, Chairman, Pacific Fisheries Resources Conservation Council
Paul MacGillivray, A/Regional Director General, Pacific Region, Fisheries and Oceans Canada
Sue Farlinger, Regional Director, Habitat Enhancement Branch, Fisheries and Oceans Canada
Allison Webb, A/Director, Sustainable Aquaculture, Fisheries and Oceans Canada
Jim Naylor, Area Officer, Navigable Waters Protection Division, Canadian Coast Guard
Adrian C. Duncan, Coordinator, Referral and Liaison, Environment Canada
Dr. Rob Butler, Pacific Wildlife Research Centre, Canadian Wildlife Service
Duncan Williams, Manager Finfish Development Program, Land and Water BC Inc.
John Bones, Director, Coast & Marine Planning, Ministry of Sustainable Resource Management
Graham Winterbottom, Coast & Marine Planning Branch, Ministry of Sustainable Resource Management
Ray Pillman, Outdoor Recreation Council of BC
Paul Kariya, Executive Director, Pacific Salmon Foundation
John Radosevic, President, United Fishermen and Allied Workers Union
Mary Mahon Jones, CEO, Council of Tourism Associations

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