Beyond COSEWIC

 

On Feb 13, 2018 the Committee on the Status of Endangered Wildlife In Canada (COSEWIC) announced its recommendation stemming from the emergency review of the status of Interior Fraser Steelhead. We’ve known that was coming for several weeks and we’ve been reasonably confident the obvious would prevail. It did. Thompson and Chilcotin steelhead have been assessed as endangered (i.e. they face imminent threat of extirpation) and recommended for listing as such under Canada’s Species At Risk Act (SARA).

 

People need to appreciate who this recommendation is coming from. The members of COSEWIC are not some ad hoc group of unknown technicians. They are the equivalent of the gold standard among scientists in this country and they operate under the law of the land. The Canadian public can have the utmost confidence its conservation interests are well served by COSEWIC.

 

On surface the COSEWIC recommendation is the tool that will dramatically alter the course of the primary, controllable force responsible for the endangered status – the commercial and First Nations fisheries operating along the steelhead migration routes approaching the Fraser River and within the river itself. Lest anyone be under illusions here, the COSEWIC/SARA process needs to be examined more closely.

 

Let me begin with two quotes taken directly from SARA documents:

 

  1. …..the government of Canada is committed to conserving biological diversity and to the principle that, if there are threats of serious or irreversible damage to a wildlife species, cost-effective measures to prevent the loss or reduction of the species should not be postponed for lack of full scientific certainty.
  2. This is in keeping with the Supreme Court’s articulation of the precautionary principle: “Where there are threats of serious or irreversible damage, lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental regulation.”

 

On with a critical review of what we are looking at in months and years ahead. What I refer to in the material that follows comes directly from a presentation given by the Regional Manager of the Department of Fisheries and Oceans (DFO), Species At Risk Program, at the “Forum on Conservation and Harvest Planning for Fraser Salmon” in Richmond on Jan 23, 2018. Such a recent summary by someone so close to the process was a perfect source to illustrate what a COSEWIC recommendation means. For those concerned I am unfairly treating or misrepresenting the material presented, I invite you to review the full presentation.

http://frafs.ca/sites/default/files2/SARA%20Listing%20-%20Fraser%20Salmon%20Forum%202018-01-23_0.pdf

 

Here are the highlights and milestones as they pertain to the Interior Fraser Steelhead (lets just refer to them as Thompson steelhead).

 

  1. The COSEWIC recommendation for an emergency listing as “endangered” now rests with Canada’s Minister of Environment and Climate Change. The law says the Minister has 90 days to decide if there is an imminent threat and, if so, make a recommendation to the federal Cabinet to confirm the endangered listing under SARA……….but the Minister must consult with DFO and form an opinion based on that consultation, as well as the COSEWIC assessment.
  2. If those Thompson fish survive that process and do get listed, there will be a further assessment conducted by COSEWIC to either confirm its listing or to remove it from the list. That takes one year.
  3. If the endangered listing is upheld, automatic prohibitions apply (i.e. killing, harming, harassing, capturing of Thompson steelhead would be forbidden) but not before a recovery strategy and action plan is developed and critical habitat defined. The latter is habitat necessary for survival and recovery of the species.
  4. If the endangered listing is not confirmed, the consequences are essentially what we have in place today. In other words, write those Thompson steelhead off.
  5. The listing process “must be informed by the best available information.” That entails development of a consultation plan that incorporates existing advisory processes, governance processes, consultation planning and communications. (Starting to sound familiar?)
  6. The anticipated timelines described by our DFO Manager in that Jan 23 presentation is where we start to understand what those Thompson fish face. To begin with, Thompson steelhead were included in her presentation but not in the context of any timetable. We can figure some of that out, though, by referencing other stocks of salmon recently classed as endangered. Those 8 Fraser sockeye stocks that were recently added to the list will not be the subject of that obligatory Federal Cabinet decision until 2022. The pathway to that point calls for recovery potential assessment, proposed management scenarios, socio-economic analysis, consultation on listing approach and, finally, a listing recommendation. If Thompson steelhead are not even included on the DFO timeline chart yet I think it reasonable to assume it wouldn’t be until at least 2022 that we would see the endangered listing that would kick in those items described in #3 above. Then there would be that additional time involved in those requirements.

 

All things considered, there can be no mistaking that Thompson steelhead are not going to receive treatment substantially different over the next several years than they have in the past four or five. Extirpation would seem to be unavoidable if due process is followed. How else can any reasonably informed person interpret the circumstances described herein?

 

No doubt there will those who defend process as the only game in town. To that I’ll add some further advice that originates from an article published in the Canadian Journal of Fisheries and Aquatic Sciences (probably the most respected journal of fisheries science in the western world). (Missing the safety net: evidence for inconsistent and insufficient management of at-risk marine fishes in Canada Jamie Marie McDevitt-Irwin, Susanna Drake Fuller, Catharine Grant, and Julia Kathleen Baum Can. J. Fish. Aquat. Sci. 72: 1–13 (2015)).

Here is the quote from that paper that tells us what we need to know:

“Overall, at-risk marine fishes typically spend 3.25 years under consideration for SARA, during which time they receive no additional protection. Endangered and Threatened marine fishes (i.e., those most at risk) face the greatest bias and receive the least protection; their SARA decisions are typically delayed, with almost 5 years usually passing between their COSEWIC (Committee on the Status of Endangered Wildlife in Canada) assessment and listing decision; most (70.6%) are then denied listing, after which the Fisheries Act provides few of the SARA-required measures. For SARA-listed marine fishes, recovery strategies are usually late and to date no action plans have been produced. Marine fish conservation is hindered by SARA’s slow pace, incomplete recovery measures, and inadequate implementation of the Fisheries Act.”

The other points of note in this paper were the authors’ condemnation of Integrated Fisheries Management Planning (IFMP) processes and the Marine Stewardship Council (MSC) certification process whereby fisheries like the Fraser chum fishery are green stamped as “sustainable”. The authors state plainly that MSC in particular has a responsibility to ensure certified fisheries are not endangering species at risk. Remember, in the context of Thompson steelhead, the province is a major player in the MSC game through its Ministry of Agriculture (fish processor licensing agency and seafood marketing agency) interface with DFO as the provincial voice of steelhead. You can get a sense of what that is all about by reading my post of Jan 22 (Against All Odds – The Future of Thompson Steelhead in the Balance).

Where to from here? If we allow the COSEWIC and SARA agenda to be followed as it is best understood today we deserve what we get. Here’s some alternatives to think about.

  1. IFMPs and SFAB forums are useless from a steelhead perspective. If anyone can offer evidence of steelhead ever being accommodated in any significant way through either one of those DFO forums, provide your comments here. The people I know who have made a significant effort to assess the efficacy of these consultative processes share my view enough is enough. Its time to abandon the addiction of process and send a strong signal to the convening agency.
  2. Demand your elected provincial and federal government representatives pay attention to Thompson steelhead. In terms of steelhead in British Columbia, they represent the canary in the coal mine. Remind our politicians at every opportunity these fish face extinction on their watch. Forget the usual polite letters that rarely, if ever, receive a response that obligates the sender to actually do something. Demand face to face sessions and attend them armed with penetrating questions. Demand answers.
  3. Use social media at every opportunity to drive the message home. Thompson steelhead are an iconic internationally revered treasure that represent an important component of the lifestyle and social fabric of this country. We will not stand idle and witness them relegated to photo albums. The fact that there was an emergency assessment conducted by COSEWIC was, in no small part, the result of noise coming from deeply concerned lay persons. If there is one thing our elected representatives pay attention to it is criticism directed at them though mainstream and social media. The more, the merrier.
  4. Invest in lawyers instead of process. There are measures afoot to engage legal experts to test DFO’s legal obligations under SARA. The principle actors involve a coalition of the four main steelhead advocacy groups in BC plus two other conservation focused organizations with extensive experience in the political arena. Watch for more from them in days ahead.

 

Comments 26

  • Well put Bob

  • Bob

    I agree with your analysis. This is the process leading to any SARA listing. As you can see, getting the initial COSEWIC listing is the easy part. Now it gets difficult as it enters the bowels of government process.

    Darn. I can’t post the slide here. I will PM it to you

  • Heaven help us! We are in the hands of bureaucrats.

  • I looked at some old notes this morning and realized that it is twenty-three years ago that the then provincial biologist in charge of Thomson steelhead offered the opinion to me and others present that, “they will be gone in ten years.” (This a fine man and solid scientist). What then can we do about such wretched impotence? Nearly a quarter century gone, and still we blunder on. This is as Bob astutely suggests, time for a monumental shift in protecting what we value most.

  • Canada’s timidity about endangered species protection has always been driven by politics and greed. There has been the provincial inclination to favour industry and related jobs in the resource sectors. On the federal side, the factors include catering to the powerful marine fishery interests, deep seated bureaucratic flaws and, more lately the increasing DFO role in arbitrating and catering to First Nations Fisheries. We need a model that breaks away from these patterns, or at least one that, in dire need, allows an overriding authority or regime. On the Fraser, as mentioned by others in this forum, there must be a total closure of all fishing during the Chilcotin and Thompson River steelhead migrations windows for, say, five to ten years. The question is, how to make this happen and quickly?

    • If anyone thinks government(s) will do the obvious, they’re not paying attention. The only way there will be any serious reduction in net harvest of T & C steelhead is if a much broader public than we have ever witnessed before rises up and demands it. It doesn’t go unnoticed that in all the COSEWIC outputs and all the background documents I have been able to get my hands on, the only fisheries mentioned are those prosecuted by licensed seiners and gill netters. The First Nations fisheries, which are a much greater problem and growing at an alarming rate are deliberately excluded. That is entirely in keeping with the government position on virtually everything to do with FNs in this country today. In far off Ottawa, who really cares about west coast fish, especially that bothersome species that essentially belongs to the province anyway? When the FN nets are in the water under an “economic opportunity” label (which means harvesting chum to belly rob for the Asian market) next October maybe we should be thinking about blockading the Port Mann Bridge to make a point?

  • Well I must still have my old firebrand headband somewhere, but,seriously we live in an era of mass extinction while the public fiddles with Facebook. I am a long-time B.C. naturalist. Even that group seems indifferent to species loss. Are we all becoming numb by the immensity? While I would join a protest, I think it better to fight on varied fronts and perhaps even some novel ones. I had earlier suggested little known legal avenues. That Swiss army knife of remedies may still have a useful tool. More urgently, I have another notion. In the past decade, there have been startling advices in fish cryopreservation technology and in ideas about de- extinction. Doubt me? Start reading. Begin with “Generation of Functional Eggs and Sperm from Cryopreserved Whole Testes (rainbow trout). (PNAS journal 2013 January 14 PMC3562789) Yes, it says producing eggs from frozen sperm. Preserving fish eggs has in the past proved difficult, but there are advances there as well. Much of the recent work is in Japan. Maybe there is an opportunity for urgent collaboration between BC university researchers and their Japanese counterparts? There might be good publicity from this. I have made an overture to the Dean of sciences at TRU here in Kamloops and while that worthy (an acquaintance) is impressed, the idea seems to have little traction in the biology department. Anyone know a billionaire Japanese sports angler who might bankroll an urgent initiative? Can we help preserve this genetic treasure laid down over ages in the Chilton and in the storied reaches of the mighty Thompson?

  • Correction. I misspoke in stating they produced eggs from frozen sperm. More accurately, and astonishingly if I read the abstract properly, is that the researchers succeeded in producing functional egg from juvenile female triploid salmon into which they introduced cellular material. Stuff derived from the testes of rainbow trout. (Note that this is experimental and at the time, the eggs were not hatched -maybe could not be. The work may have advanced since.) The trout testes had been frozen in a deep freeze and for as long as nearly two years. No cryogenic preservation was involved. The material found its way into the gonads of the female salmon, where by some process production of eggs was stimulated in the surrogate fish. The eggs represented the genetic heritage of the introduced rainbow trout material. Think on it. Male Interior steelhead could be taken next October – perhaps stream-side as incidental catch from the deplorable chum beach seines, the testes removed and frozen soon after in a normal household deep freezer. This whitish, slippery treasure could then be used a hatchery facility to inoculate young salmon, who when mature could have their eggs expressed and fertilized by previously frozen milt – also extracted from Thompson steelhead. The result, if it all works in practice, could be young steelhead with the full genetic inheritance of wild stock. Mind boggling, and a sort of hail Mary pass into the future.

  • Bob Do you mean, to participate in an approved catch of steelhead to obtain and freeze the buck’s testes or to donate one of your own (If it’s your own, you perhaps misunderstood the donor part.) It all sounds fantastic but this is serious science, though I can barely grasp some of the paper’s more obtuse parts (I should have paid more attention in my biology classes). I could post the link but I don’t think you can do that on these kinds of pages. Let me know; in any event the report was published in 2013.

    • If we get to the stage where the people we invest in to manage our fisheries advance this sort of madness as a solution, I’ll be looking for a tall building.

  • Further information on the 2013 research paper, “Generation of Functional Eggs and Sperm from Cryopreserved Whole Testes.” Authors Seungi Lee, Yoshiko Wasaki, Shinya Shikino and Goro Yoshizaki. Department of Marine Bioscience, Tokyo University of Marine Science and Technology, Tokyo. Please do not confuse this paper with a later paper (2015) “Production of Viable Trout Offspring Derived from Frozen Whole Fish.’, these and other startling papers by these eminent and imaginative researchers (Contact as to the first paper for those having background or interest, and with appropriate professional courtesy, is

  • Obviously the email link would not fly, but with the aforementioned provisos, try goro at kaiyodai dot ac. dot jp. And here apologies to two of the authors names misspelled in my previous post (my 76 year old eyes weary from too much screen time) Seungki Lee and Shinya Shikina.

  • Perhaps the fish geneticists could weigh in on this to determine the validity of the claim, but if memory serves, there is a Steelhead living gene bank alive and well and far removed from any Ocean borne pathogens. These steelhead could become donor brood stock and/or provide eggs and sperm for seeding barren streams or those about to become so. These living gene repositories carry the vital spark of wildness their West coast forebears passed down to them. They thrive in such numbers that taking sufficient brood will not diminish their numbers. When the time comes, as it already has for so many streams, to utilize donor stock for rebuilding runs of steelhead, then we may well find our saviours thriving in the Great Lakes.

  • It may be madness, but it the genie is escaping the bottle and as Leonard Cohen said It is the future – with lots of dark implications. I am not advocating, but revealing and thinking there might be a glimmer of hope in these ideas. The application and intent is everything. Of course if such technology ever come about on our waters it would be pure desperation and madness indeed if the needed changes in management did not also happen. Should we count on the public to rise up and be outraged by the loss of steelhead – no matter how some of us treasure them – that’s not going to happen. Having caught, in my little lifetime adventures, just two Thompson steelhead and both epic, I would want to see them survive after all is desolation and utter ruin in this mad society we have created.

    • Your suggestion is precisely the sort of thing the status quo advocates for the steelhead interception picture will grab onto Frank. There is no technofix here and we’re in dangerous territory thinking there is hope somewhere down that road. Unless there is an immediate and major reduction in harvest of returning Thompson and Chilcotin (wild) adults these fish are on a path to extirpation. The only debate is how long that will take. Perhaps you don’t have a full appreciation of how the commercial and First Nations fishery advocates (i.e. DFO) think and operate but any evidence of support from the recreational fishing community for a fish culture based “solution” can only come back to obstruct the case for harvest reduction.

  • Well, am I to feel properly chastised for sharing an idea? I am not in any ideological camp. As you well know since I began to participate in this forum I have supported shutting down all fishing that could impact returning interior steelheads and proposed lines of attack against the federal government. It seems here that one gets stroked for falling into line and saying the right things while getting roundly cautioned for saying what is not palatable. What I am suggesting is only a last resort in the event Thompson steelhead are finally facing extinction. I am not suggesting hatcheries as a solution. Some might at least read the abstract at the start of the research paper I mentioned. I did not know there are taboo topics. Furthermore, I do not easily accept a muzzle. if that is what is intended, I will be more comfortable not participating.

    • Easy Frank. No muzzle intended. Tell the world all about the technofix to avoid extirpation but please don’t ask me to endorse it as any solution to the fisheries management ills of the moment. Remember, there are 8 Fraser sockeye stocks, upper Fraser chinook and upper Fraser coho facing circumstances similar to what the Thompson and Chilcotin steelhead are. The list is growing at an alarming rate. Are we going to save all them the same way?

  • I, for one, am glad a dedicated nucleus of steelhead champions have taken on the task of affixing a legal remedy to the current IFS situation. That action will, I hope, have spill-over benefits for all West coast steelhead stocks.
    As to the statement in a previous post that a general uprising of agitated citizens will not happen; I agree. As example; the closure to angling on nineteen streams on Vancouver Island as an attempt to give the steelhead a break from being caught so stocks could rebuild. At its initiation, I was a strong advocate for such action. I had good company at the time, as The Steelhead Society of BC, too, after much debate, supported the closures. The collective thought amongst the backers of the plan was; there would be such an intense rant and roar, a rebellion really, from fishermen, that the MoE overseers would have to take all necessary action to set things right.
    Neither of those things happened. The spark of explosive rebellion fizzled before it got started and still barely smolders today. The turn around in steelhead numbers failed and an accelerated decline persists. The closures were an act born from exasperation. One from which we may never recover.
    This time around, litigation may prove the most useful tool for ensuring the hoped for outcome. Suitable lawyers do not come cheap. Even those retained on a pro bono basis require some funding and supplemental costs can mount rapidly. The question is; will present day steelhead champions open their wallets wide enough to see this thing through to a successful outcome?

    • So true Rory. We sing to the church choir but no one else hears. Case in point – when the COSEWIC decision was announced I immediately sent it to the environmental reporters at the Globe and Mail, the Vancouver Sun, the Tyee and Desmog. I added a covering note indicating there was much more to the COSEWIC and SARA process than meets the eye and they might want to do a bit of investigation and report on that. No takers, although the Sun at least tweeted the COSEWIC press release. When you add it all up, steelhead are not even close to being on the political radar so the media is not about to pick up anything we might like to get to a broader public. You’re right, though, we can still try and hold government’s feet to the fire in court. Justice maybe but, sadly, we may not get any fishing out of it.

      • I hear you Bob, about trying to get some attention from the media. I, too, sent out an enticing “press release” right after our meeting with the Environmental Law Centre folks in Victoria. My list of first round recipients for this Op/Ed, Letter to the Editor type piece included: The Globe & Mail, Vancouver Province, Victoria Times Colonist, Seattle Post Intelligencer, Terrace Standard newspapers and to Dr. David Suzuki’s office, amongst others. The title line read; “New Tool Needed for BC Steelhead Survival.”
        As suggested by an old hand in the newspaper publishing business, included was all contact information and a couple of pertinent steelhead related credentials… just so they would not get the impression I was some off-the-wall crank. All to no avail.
        This might lead one to believe, that, for all the frenzy of emotional dynamism generated amongst ourselves over steelhead issues, the fever is not contagious. Next step?

        • Noise! Occupy DFO offices, blockade the Port Mann Bridge when the nets are fishing right under it. Film the FN fisheries and put that out over the public airwaves. Shame everyone who is part of the problem. If we lived south of the 49th there would have been a small army of lawyers on this stuff years ago.

  • Advice taken and no endorsement for radical ideas asked of you Bob. Keep up the good fight. It happens that I am about to leave for down under for a month, so I can reflect on larger questions. Ultimately, as I said earlier, this is a question of the public trust. The crown is a trustee of the resources belonging to us all – for now and for the future. I believe that the government of Canada has a duty to protect steelhead in coastal waters, in the interior river they traverse and in their natal streams. At its core, this means protecting races of steelhead against extirpation by all means available and also by exercising great prudence in DFO decisions that impact on returning steelhead.

  • Case in point: the first mention of the recent IFS situation by a Black Press organization despite being fed numerous documents by myself and others.

    https://www.ashcroftcachecreekjournal.com/news/thompson-chilcotin-steelhead-trout-in-danger-of-extinction/?utm_source=dlvr.it&utm_medium=twitter

    • A good article except that it doesn’t draw the obvious distinction between the interior indigenous communities and those of the lower Fraser. The latter are the issue, not the commercial fishery as is commonly believed. It is entirely commendable that the upriver people have foregone steelhead harvest locally to conserve what remains. Now, how about if they compel their downstream neighbours to forego chum roe harvesting that is now the single greatest factor influencing how many steelhead make it back to the Thompson (and Chilcotin)?

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