The Honourable Steve Thomson,
BC Minister, Forests, Lands and Natural Resource Operations
The Honourable Gail Shea
Minister, Fisheries and Oceans Canada
Re: Proposed 2014 gravel extraction on the Fraser River and government commitments to protect endangered white sturgeon
Dear Minister Thomson and Minister Shea:
We are writing to express our concern about a proposal by the Seabird Island First Nations to extract 105,000 cubic metres of gravel from the lower Fraser River near the Seabird Island reserve this winter (Feb – Mar, 2014). We are of the opinion that if this projects proceeds, there will likely be adverse impacts to lower Fraser River white sturgeon and their spawning habitat. In light of prior commitments both levels of government have made to carefully manage this fish, we are asking that you ensure this proposed project does not proceed.
We also want to raise concerns over the lack of opportunity stakeholders have had to provide input into this proposal. The David Suzuki Foundation has been an active participant over many years in the review of in-river gravel extraction proposals. This proposal stands out for its lack of opportunities for stakeholder input, whether through being notified that the project has been proposed, challenges obtaining copies of documentation related to the proposed works and/or the inability to reach and talk to staff who may be reviewing the proposal.
Lower Fraser white sturgeon are classified as a “species at risk”
In November 2003, the Committee on the Status of Endangered Wildlife in Canada (COSEWIC) determined that all white sturgeon populations in Canada should be considered an endangered species. The lower Fraser River white sturgeon was one of those populations .
In August 2006 the federal Cabinet approved for listing under the federal Species At Risk Act the Kootenay, Nechako, Upper Columbia, and Upper Fraser river white sturgeon populations. The lower Fraser River stock was not granted similar protection because of the “potential negative socio-economic impacts” that could result from such a listing under the SARA .
However, despite forgoing SARA listing, the federal government publicly remained committed to protecting these fish stating:
“All white sturgeon populations, whether listed or not listed, will continue to be carefully managed under SARA and the Fisheries Act. ”
And committing to continued work with stakeholders:
“Government will continue to work with stakeholders to ensure that threats to the survival of this species are adequately addressed.”
Additionally, in 1995, British Columbia signed the National Accord for the Protection of Species at Risk thereby committing the Province to taking actions to identify, protect and develop recovery plans for “species at risk” in BC.
The urgency of our concern for the lower Fraser River white sturgeon has not changed with the 2012 COSEWIC re-assessment of the fish as “threatened”.
Gravel removal and impacts on white sturgeon
In-river gravel mining was one of the key threats identified by COSEWIC as negatively affecting this species in 2003 and it remains so today . In 2004, the Fraser River White Sturgeon Working group (which includes government, industry and First Nations) concluded:
“In British Columbia, white sturgeon habitat has declined in both quality and quantity .… Dredging, gravel extraction, dyking and channelization have also been common practices throughout the province, and may be especially important on the lower Fraser River” … in negatively affecting sturgeon populations. (emphasis ours)
Additionally, in 2007 the Canadian Science Advisory Secretariat in examining the recovery potential for white sturgeon on the Fraser River stated that:
“Threats to [white sturgeon] habitat include river regulation; instream activities such as dredging for gravel or sand; linear development; alterations or development of riparian, foreshore, or floodplain areas; upstream use of land and water; and effluent discharge from both point and non-point sources.” (emphasis ours)
Most troubling are population assessments conducted by the Fraser River Sturgeon Conservation Society (FRSCS) over the past decade that have shown a steady drop in the numbers of juvenile sturgeon being recruited into the lower Fraser River population . It should be noted that the timing of these declines coincides exactly with the start of large-scale gravel removals in the lower Fraser River in the mid-1990s.
Potential impacts of the proposed 2014 gravel mining project on white sturgeon
In 2013 the FRSCS conducted side scan sonar surveys in the Seabird Island area that provided clear evidence that several spawning size sturgeon could be found in areas where gravel was extracted in previous years and where gravel may be extracted in the future. They concluded that:
“Given the current concerns regarding the reduced levels of juvenile recruitment for lower Fraser sturgeon population and the potential for sturgeon spawning and rearing in the Seabird Island area, the FRSCS strongly opposes the removal of gravel from in-river locations in the Seabird Island area.”
We agree with them.
However, in January of this year, the FRSCS was advised by a provincial biologist of a proposal to extract gravel in the vicinity of one of the adult sturgeon congregations observed by the FRSCS during their 2013 spawning survey, that being Seabird Island. This is disconcerting as it strongly suggests that adult sturgeon spawning habitat may be directly impacted by this, or any future, proposed excavation.
Stakeholder consultation
The David Suzuki Foundation has worked hard over the past nine years to develop a good working relationship with Emergency Management B.C. and Fisheries and Oceans Canada on matters related to in-river gravel removal. Until recently, we were afforded the opportunity to review and comment on proposals such as this. However, in regards to this particular proposal, we’ve been mostly excluded from the project review process.
In our past discussions with the provincial and the federal governments on matters related to in-river gravel extraction we have argued for a long-term management plan for sediment removal on the lower Fraser River and in February 2013, we were assured that just such a planning process was being developed:
“All parties agree that a long term plan is preferred. As such, the detailed work on the development of a long term plan for sediment management within the Fraser River is beginning with the focus being on what areas provide the greatest benefit to the flood profile and at the same time, limit the impact to the natural environment. This plan will not only involve the Technical and Management Committee but also key stakeholders who have an interest in the Fraser River.”
We have yet to see any significant movement on the development of such a plan; instead, we are seeing concerned stakeholders now being shut out of the review process.
In addition to ensuring this proposed project does not proceed, we are hoping that you will instruct staff in your Ministry and Department to commence work with stakeholders as soon as possible to develop a comprehensive long-term management plan for in-river sediment removal for the lower Fraser River so that only projects that are scientifically sound, support the need to mitigate for flood protection purposes and ensure protection for threatened and endangered species come forward in the future.
Thank you for your consideration.
We would be happy to meet with you or your designated staff to discuss this matter further.
We look forward to your reply.
Sincerely
___________________
Jay Ritchlin
Director-General
Western Canada
David Suzuki Foundation
CC: The Honourable Suzanne Anton, B.C. Attorney General and Ministry of Justice
The Right Honourable Stephen Harper, Prime Minister of Canada
Sue Farlinger, Regional Director General, Fisheries and Oceans Canada, Pacific Region
Karl K. English, Chair, Fraser River Sturgeon Conservation Society
Carol Loski, Director, Flood Protection Program, Emergency Management BC