Dear Ministry of Forests, Lands, Natural Resource Operations and Rural Development (aka FLNRORD) :
Signals from some of your constituents tell a handful of us with an ear to the ground there has been considerable discussion between local residents of the Skeena area and your agency regarding the future allocation of angling opportunity on at least some of the internationally renowned steelhead streams you manage. Without being involved directly and not having any information disseminated from your office, those of us who do not happen to reside in the communities where these discussions are ongoing are shut out. That is not acceptable but it doesn’t dissuade me from offering some free advice anyway.
For years I have tried to convince you of steps that should and could be taken to address information deficiencies that have plagued decision makers and proliferated debates about what constitutes crowding and who is responsible for how much of that, where, when, etc. I’ll speak to that in greater detail below. The second point I find unconscionable that your staff has not pursued relates to a simple change to existing regulations that could have controlled what became a tsunami of guiding on all waters that weren’t classified in 1990. That’s now 28 years of self directed inertia that has allowed angling guides to dominate times and places where fish supplies should never have been subjected to such treatment and where resident anglers have been increasingly squeezed out of the picture.
To the subject of data that could address those prevailing myths about who and what constitutes crowding. There is a simple solution that could solve multiple problems. A mandatory permit for anyone – resident, non-resident, alien, guided or unguided – who fishes any classified water for any part of any day. Permits could be available on demand with no reservation required and no limit on the number of permits issued. The existing regulations around certain rivers being resident only opportunities on certain days could remain but residents in those situations would also be required to hold a permit. By the way, guides and assistant guides should be part of rod day quotas and permit requirements whenever they’re on the water.
The cost of a permit could easily be set at a level where enough revenue would accrue to put bona fide enforcement officers on the water in sufficient numbers and places to be a recognized deterrent to non-compliance. No “guardians” with exceedingly limited enforcement authority. I’m talking full meal deal enforcement personnel. The penalty for non-compliance would have to be substantial enough to convince transgressors it wasn’t worth it. How about several hundred dollars and/or cancellation of eligibility for future permits for a prescribed period?
A year or two of data compiled from permits would answer, once and for all, where, when and who was a “problem”. Those with an interest could review numbers and origins and start to address future allocation of opportunity on the strength of information no one could dispute. Issues like illegal guiding, bed and breakfast operations could be illuminated and dealt with effectively simply by limiting or eliminating the number of permits available to any such operation or its clients. A permit application system could follow if and when it is determined angling effort was in need of various forms of control.
The BC Parks reservation system and the BC Ferries reservation system are models that ought to be adaptable. After all, this is 2018 and technology reigns supreme. How hard would it be to set up the equivalent of a cell phone app to offer anglers all the access and flexibility needed to accomplish the desired end point?
On to my other hobby horse. The regulations governing classified waters and angling guides are included in what is known as BC Reg 125/90, The Angling and Scientific Collection Regulations. Those regs took effect in 1990 and they were developed to address the issues of the day. Those who wish to explore beyond what I say here can look up the details at:
The central item in terms of where we sit today is the flexibility of the statutory authority for issuing angling guide licenses to impose restrictions (i.e. “conditions”) on the holder of an angling guide license. Section 13 (3) of the regulation reads:
(3) If a regional manager issues an angling guide licence to an angling guide who holds angler day quota for a classified water, the regional manager may attach conditions to the angling guide licence in respect of the classified water that:
(i) the period of time during which,
(ii) the day of the week on which, and
(iii) the area in which the angling guide may guide for fish
The operative words here are underlined. Those words need to be eliminated and leave the statutory authority with the ability to place conditions on any angling guide licensee, not just those with rod day quotas and on classified waters. That simple amendment, brought to the attention of this government’s steelhead rivers managers on multiple occasions between the mid 1990s and today, has never been acted upon. The consequence has been an explosion of angling guiding on every unclassified river on which any qualified applicant wishes to ply his/her services. They can do that, unlimited, for the price of an annual angling guide license. No rod day fees, no additional fees for their clients, just an annual license that costs less than what guides charge for a single day of their services. How’s that for giving away public resources?
Over to you FLNRORD. Show us you’re in the steelhead sport fishery management game. Nineteen-ninety is a long way back in the rear view mirror. The regulations that made perfectly good sense at the time are long overdue for revision. Get out there and get the data that will facilitate intelligent option definition and decision making. Your guardian programs of years gone by were a complete failure. Please don’t try and sell the notion you’ve got reliable data already. You can’t even tell my how many assistant guides there are on any of your rivers at any point in time, nor can you retrieve appropriate data from the electronic data base you thought was going to answer every question immediately following its implementation. And, start looking seriously at how you are going to reclaim some of that unforgiveable handover of angling opportunity on all those unclassified waters long ignored. This isn’t rocket science and it doesn’t require years of consultation and the institutional inertia that goes with that. Create the tools to do the job. Get on with it while there may still be something salvageable. Do it for the other regions of the province also in need of a mechanism for controlling things like guides fishing out of jet boats forbidden to the rest of us. We’re waiting and watching.