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B.C.W il dlif e F ed eratio n June 28, 2006
The Hon. Barry Permer
Minister of Environment
P.O. Box 9047 Stn Prov Gov't
Room 112, Parliament Buildings
Victoria, BC V8W 982
3c !rliDrlFE FLDEiAT oN B.C.Wllctnle recl
Unit 101 - 3060 Norland Ave.,
Bumaby, BC V5B 3,46
Phone 604 291 9990 Fax 604291.9933
To11 Free in BC 1 888 881 BCWF (2293)
[email protected] www.bcwf.bc.ca
Re: Steelhead Stream Classification Policv Via Fax: 250-387-1356
(ORIGINAL FOLLOWING BY MAIL)
The BCWF continues to have a major concern with your Ministry of Environment draft
policy entitled "Steelhead Stream Classification - Policy and Procedure" (SSCP).
Specifically, page 4,8. Management of Designated Steelhead Sfteams states that:
o "The Ministry will manage designated provincial steelhead steams as follows:
o "Wild" Steelhead Streams\
And further:
"Angling regulations are to be enacted that prohibit retentions of wild
steelhead to conserve wild {ish, provide higher catch rates and simpliff
management."
It is our view that consultation by your MoE officials about this proposed policy has been
inadequate. We have repeatedly asked for and offered necessary changes but, to our best
knowledge, your ministry continues to provide the unchanged original proposal. There
has been no redraft and certainly no follow-up consultation despite groups such as ours
providing input and moderate recommendations for change, as requested. This creates the
unfavorable optic ofyour ministry enacting policy regardless oflogical stakeholder
sentiments.
The policy ofthe BCWF is to support a retention fishery for all species where a
biological surplus exists. This position was clearly stated in our original response to the
draft SSCP in 2004. Our members are particularly concemed about MoE's intent to wdte
this reasonable "retention" position out ofthe final policy altogether. Premier Campbell
made a commitment that management of our environment, fish and wildlife would be the
best in the world, bar none, but this cannot be achieved if the draft SCPP is imposed in its
current flawed form.
The present policy provides an implied motivation to enumerate stocks. A blanket change
to province-wide non-retention, such as currently proposed, would eliminate the need for
mariagers across the province to monitor steelhead stocks and the already sparse data
would become even sparser. Since there is no provision to write this retention-ifabundance
policy back into the regulations for when stocks improve, the effect of
"simplified management" becomes unmistakably clear, namely a permanent loss of the
retention right of residents.
The members of the BCWF have always demonstrated a clear and continued commitment
to conservation in our proud history, and the membership continues to support extensive
fisheries management and harvest restrictions where the conservation ofany species of
fish is a concem. However, the BCWF does not believe that the best management of a
species occurs with the use of irreversible blanket policies, and we see no scientific or
logical motivation to eliminate the opportunity to harvest wild steelhead ifa biological
surpius exists.
The BC provincial steelhead management policy is progressively excluding resident
anglers from participating in the recreational fishery sector.
Bait bans, high license fees, fly-only fishing, prohibiting harvest, and outright closures
are all examples ofpolicies which discourage residents from participating in steelhead
angling. This is diametrically opposed to MoE's own service plan obj ective to increase
the number of anglers in the provrnce.
Further, angling is a fundamental part of our lifestyle in British Columbia. This is
especially true in rural communities where the opportunity for the angler/gatherer to keep
a fish and share that natual food with the family at the dinner table is an historic and
integral part of the social fabric. This encouragement ofnatual food harvesting by
residents, in a sustainable way, is a centerpiece of MoE's wildlife management regime.
Why can't the same approach be included in the Steelhead Stream Classification Policy?
In our view, the proposed blanket policy of maaaging steelhead so that no wild fish can
be harvested will set a dangerous precedent that carries broad implications for future
angling ofall fish species. Our membership strongly opposes this proposed regulation
change and we reiterate our great displeasure that your ministry has ignored our
recommendations on this matter.
The Federation cannot supporthe proposed policy implementation for 2007 as written
and feels that it is imperative that "The ability to retain a wild steelhead where a
biological surplus exists" be included in the provisions ofthe policy.
We look forward to discussing this matter in person at your earliest convenience.
Yorus in Conservation.
Wilf Pfleiderer
President
