Decisions not to add the Steelhead Trout populations to the List of Wildlife Species at Risk

Official title: Statement setting out the reasons for the decisions not to add the Steelhead Trout Chilcotin River population and the Steelhead Trout Thompson River population to the List of Wildlife Species at Risk

Polycentric factors considered

In deciding not to add the Steelhead Trout (Oncorhynchus mykiss) Chilcotin River population and the Steelhead Trout (Oncorhynchus mykiss) Thompson River population (Chilcotin and Thompson River Steelhead) to the List of Wildlife Species at Risk set out in Schedule 1 to the Species at Risk Act (SARA), the Government of Canada considered a range of factors in order to make a decision that results in the greatest overall benefits to current and future generations of Canadians and the conservation of these wildlife species.

Considerations included the following:

• the emergency assessment and recommendation made by the Committee on the Status of Endangered Wildlife in Canada (COSEWIC), the peer-reviewed Recovery Potential Assessment and other available information regarding the status of and threats to the wildlife species
• the current and ongoing shared management and conservation of Chilcotin and Thompson River Steelhead between the Government of Canada and the Province of British Columbia
• the anticipated conservation outcomes of implementing protection through listing these wildlife species versus the anticipated outcomes of not listing them and continuing to manage their conservation under existing federal and provincial legislation. This includes consideration of actions that have been taken, are being taken and will be taken for the conservation of Chilcotin and Thompson River Steelhead
• a cost-benefit analysis of the potential impacts of listing these wildlife species
• the results of consultations undertaken with the public, the Province of British Columbia, appropriate Indigenous groups and organizations and other persons and organizations, as the competent minister considered appropriate

Science advice

Chilcotin and Thompson River Steelhead are facing threats associated with the following: fishing-related mortality, changes in marine and freshwater environments, including habitat loss and degradation, and biological limiting factors such as predation (e.g. by seals and sea lions) and competition.^{Footnote 1}, ^{Footnote 2} In its emergency assessment, COSEWIC classified both wildlife species as endangered and made a recommendation to the Minister of the Environment that they be listed as such under SARA.

Science advice, based on population modelling conducted as part of the peer-reviewed Recovery Potential Assessment led by the Department of Fisheries and Oceans, clearly indicates that an increase in productivity (i.e., increasing the number of surviving progeny per spawner or natural survival rate) is required for the recovery of Chilcotin and Thompson River Steelhead. While reducing fishing-related mortality has the potential to lessen rates of decline and contribute to population growth, the indication is that reducing mortality is not enough on its own and that, without increasing the productivity of the populations, the likelihood of recovery remains low. Proactive measures must be taken not only to reduce fishing-related mortality but also to provide for habitat conditions that will promote natural survival, including halting further habitat degradation and promoting restoration of lost habitat. Taking actions to promote productivity will require collaborative action between the Government of Canada, the Province of British Columbia and other partners.

Steelhead management and conservation

The management and conservation of Chilcotin and Thompson River Steelhead are areas of shared responsibility between the Government of Canada and the Province of British Columbia. In the absence of listing under SARA, Chilcotin and Thompson River Steelhead will continue to be managed for conservation under the Fisheries Act and its regulations, including the Fishery (General) Regulations and the British Columbia Sport Fishing Regulations, 1996. The Province of British Columbia also has legislative mechanisms available under applicable provincial legislation (e.g. the Water Sustainability Act, SBC 2014, c. 15). The Department of Fisheries and Oceans will continue to implement management measures to reduce mortality of Chilcotin and Thompson River Steelhead from bycatch in marine and freshwater Pacific salmon fisheries. Proposed management actions will be developed annually through the process established in the Department of Fisheries and Oceans’ integrated fisheries management plan (PDF - 7.96 MB) for Southern Pacific salmon and will take economic impacts into account. It is anticipated that the Province of British Columbia would continue to implement management measures related to habitat degradation and management measures for freshwater recreational fisheries, including instituting closures for the conservation of these wildlife species in non-tidal waters in keeping with the conservation objectives outlined in the Provincial Framework for Steelhead Management in British Columbia (PDF - 420 KB).

Conservation outcomes

The Government of Canada has determined that the application of the prohibitions that would follow the listing of Chilcotin and Thompson River Steelhead would not provide for the best conservation outcome for these wildlife species. As the protections would be prohibition based, they would not lead to proactive measures being taken in a timely manner that would promote increases in these wildlife species’ productivity. The Government of Canada is therefore advancing the development and implementation of a conservation plan for these wildlife species on an emergency basis, in collaboration and partnership with the Province of British Columbia, Indigenous groups and others. The conservation plan will contain measures to:

1. reduce mortality and increase survival of returning spawners
2. improve productivity in freshwater through habitat protection and remediation
3. implement effective governance
4. increase science and monitoring

Immediate measures will be taken to reduce fishing-related mortality, remove significant barriers to migration and reduce ongoing habitat destruction. Additional measures will be taken over the longer term to remediate degraded habitat. Options will be explored to address the causes of natural mortality (e.g. predation) and to augment wild populations through hatchery production.

Socio-economic considerations

Listing Chilcotin and Thompson River Steelhead as endangered under SARA would result in significant and immediate negative socio-economic impacts on Canadians due to the application of the general prohibitions. The incremental costs associated with listing were estimated to range from $190,300,000 to $254,000,000 (present value) over a 20 year period, or $17,900,000 to $24,000,000 per year in impacts on harvesters, recreational anglers, Indigenous groups, the seafood industry and the recreational services industry. The loss in profits to the commercial salmon fisheries, Indigenous commercial fisheries and seafood processing was estimated to be $90,700,000 over 20 years. The loss in profits to the recreational services sector (lodges, charters and guides) was estimated to be $16,200,000 over the same period. In addition, as a consequence of the prohibitions, anglers were anticipated to experience a loss in consumer surplus that reflects a loss in the benefits that anglers obtain from the activity that goes beyond the market value of the expenditures that they incur. The losses in consumer surplus to anglers were estimated to be $66,300,000 to $123,200,000 over 20 years, with the majority of the consumer surplus loss being borne by tidal recreational anglers. Indigenous groups would also be affected due to loss of harvest for food consumption, and for cultural and ceremonial purposes.  If a foregone harvest for food purposes is compared to the cost of replacing this food source, the value is estimated to be in the range of approximately $17,100,000 to $23,900,000 over 20 years, which represents a conservative estimate.  Although not quantifiable in economic metrics, it is acknowledged that there is value associated with salmon to Indigenous groups for cultural and ceremonial purposes.

Consultations

Consultations on the potential emergency listing of Chilcotin and Thompson River Steelhead were conducted from October 1 to December 2, 2018, following a period of early engagement from February 13 to September 30, 2018. Consultations with Indigenous groups included the participation of First Nations in the Chilcotin, Thompson and Fraser River watersheds and on the South Coast (including Vancouver Island and the Sunshine Coast). Key stakeholders consulted included environmental groups, commercial harvesters, recreational harvesters and the Province of British Columbia.

Feedback received from consultations was mixed. The concerns that were expressed related to the emergency listing timeline and consultations, current conservation measures, expected fishery impacts and the uncertainty of benefits if listed. Environmental organizations and Indigenous groups located in the interior and in the headwater areas of the Chilcotin and Thompson Rivers were generally supportive of listing. Indigenous groups located along the Fraser River mainstem and in South Coast communities and commercial salmon fishing representatives were generally opposed, while recreational fishing representatives were divided. The Province of British Columbia has not provided an official position on listing; they have, however, indicated concerns with the expected impacts associated with listing.

Two of the three Indigenous groups that are party to a relevant treaty were opposed to listing, while the third indicated concerns with the fisheries implications of listing (e.g., impacts on Treaty fishing rights, First Nations businesses that rely on the recreational salmon fishery and commercial salmon fishers), but did not provide a clear position. Many other First Nations and Indigenous organizations did not provide a position on listing itself but cited potential infringement of Aboriginal rights and inadequate science information and consultation.

During consultations, expressions of the cultural significance of Chilcotin and Thompson River Steelhead were received from several First Nations. Submissions expressed that Indigenous Peoples place intrinsic value on Steelhead Trout as part of a holistic view of the environment. Specifically, Chilcotin and Thompson River Steelhead are important as a seasonal source of food, in supporting the development and maintenance of skills in the manufacture and use of fishing technology and harvesting techniques and in traditional stories and a spiritual belief system about reciprocity and accountability between humans and the environment. References were also made to the cultural significance of salmon fisheries that affect Chilcotin and Thompson River Steelhead. These spoke to a First Nation’s ability to exercise their Aboriginal right to fish, food value for harvesters, food security for communities, cultural ceremonies, Indigenous knowledge and the transmission of fishing and fish processing skills from one generation to the next.