With concerns regarding Northern Pipeline planing....

Dear Madam Premier,

In reference to the proliferation of pipeline proposals that could be located in the Morice River watershed, the Burnie River pass, the Kitimat Valley or alternatively through the Skeena River corridor, through the Nass River watershed and along or over many tributaries of the two major river systems, as well as the planning of new electrical transmission lines to service the liquefied natural gas (LNG) plants.
The Northern Branch of the Steelhead Society of British Columbia is alarmed and shocked that neither our Provincial or Federal Government have made any effort to understand or even acknowledge the importance of the river watersheds (the pipelines will traverse), their fish, wildlife and substantial, associated economic and intrinsic social values that these historical, natural watershed resources have provided for First Nations, British Columbians and for visitors from around the world.

The Morice River is home to the largest population of chinook salmon in the Skeena drainage and one of the most extensive in BC, the largest race of summer steelhead in BC, a huge population of pink salmon along with substantial numbers of other species which spawn and rear in its waters. It is one of the most prolific and important recreational river fisheries in British Columbia.

The Skeena River is the mother river to all of those populations plus the myriad of other runs, races, species and populations that are indigenous or migrate to and from other tributary rivers and streams.
The Nass River Watershed is the third largest salmon producer in the Province, with major and unique populations of steelhead including all of the other species that are found in the Skeena river system.
There has been no comprehensive, government initiated integrated resource planning process that includes the input from the public or apparently from First Nations as has been suggested by those involved in the "Idle No More movement". The Environmental Assessment process which is initiated by a proponent does not address many of the issues we are talking about. In other words there has been no easy way for the public or average First Nation person to be able to talk with either Government about the importance of these river systems, there fish and other values before critical decisions have reached a point of finality.

The emphasis by both levels of government for economic development has been very one sided. The lack of concern for other interests is distressing and disquieting. Both governments have gone so far as to silence their scientists and managers. The remaining few professional and technical staff in the Ministry of Forests, Lands and Natural Resource Operations (MFLNRO), Fish, Wildlife and Habitat sections and similarly with a now much smaller Federal Department of Fisheries and Oceans (DFO) can now only carry out the most essential responsibilities. Their budgets have been slashed and in some instances have been entirely eliminated, preventing both government agencies from carrying out meaningful stock and habitat assessment, research and studies to address the importance and value of the fish species that both Governments are responsible to protect and to manage.

Those mandated to carry out environmental assessment are taxed with interpreting meagre and or often no data that is realistic, meaningful or quantifiable. There for it is impossible for them to make fair and responsible, stand alone decisions, based upon solid and substantive science. What has and continues to unfold is reprehensible and must be challenged. If our watersheds are going to be shredded and their fisheries and associated values squandered than all of our citizens must know what the consequences are going to be.

The construction and operation of as many as six pipelines will have an enormous impact upon the spectacular scenery of our region which seems to no longer matter or to be a serious consideration.
The history and connections to this very special part of our province is being ignored and pushed aside for hasty, panic and corporation driven, gigantic industrial development, sadly so similar to that which has taken place worldwide for generations with so many very unhappy and disastrous consequences.
It is the responsibility of senior Governments, not corporations to undertake the initial integrated resource planning for large industrial projects and activities in terms of where project works can or should be located and how they and existing economies and resource values can co-exist.

Rather shockingly Shell Canada is moving into the assessment stage for its huge 48" diameter natural gas pipeline. In comparison, this proposed pipeline will have a diameter that is almost five times the size of the existing 10" dia.PNG pipeline which at one time provided enough natural gas for three pulp mills, a methanol plant, the Rio-Tinto Alcan smelter as well as for residential consumption and all of the
other commercial and industrial users in Kitimat, Prince Rupert and Terrace with extra natural gas to spare.

This very large company has said on many occasions to those of us who live in the North West that they would consult broadly and not leave a stick or stone left unturned. We guess their giant phone conversation during "the autumn 2012" was in their mind their idea of carrying out sufficient due diligence.

What is unfolding in front of our eyes is the largest combined group of industrial projects in the history of British Columbia. One would assume that such a mammoth industrial development plan would trigger an apolitical community/provincial dialogue so that all concerned could learn and understand the consequences of what is being proposed. There should be discussion over "where or if" LNG plants and energy corridors should be located in a particular area? If there is community, regional and provincial consensus for LNG plants and corridors to be established than consideration of location options should be discussed. Upon determination where the corridor(s) are going to be located than a discussion over how many pipelines should be allowed in a corridor, either deciding in favor of a number of smaller pipelines or possibly "one" or two larger pipelines in an effort to minimize the environmental footprint?

It should be the rule that natural gas is provided to all British Columbians in communities located along or close to a new pipeline, such as to the Hazeltons and Kitwanga where natural gas is not now available.
There are other issues such as the petrochemical industry concerns over the declining availability of natural gas derivatives such as ethane as well as price implications over the export of gas. One of the larger corporations in the business is so concerned over the large scale export of natural gas, it has commented in a roundabout way over the rational, or if we can use the word "threat" to the domestic supply of natural gas and the availability of the by-products from it. There is little doubt that this is a very complicated subject that our organization may not clearly understand but at the same time is of the opinion that a clearing of the air and open discussion is very important for the industry as well for all Canadians.
Fracking or hydraulic fracturing of geological formations to allow the escape of natural gas and replace it with water is a huge and controversial subject that cannot be ignored. The implications from such a divisive way of extracting natural gas needs a full public airing.

There must be a dialogue over carbon dioxide emissions from LNG production, creating electrical power from natural gas and from the extraction of natural gas. It is crucial to determine if there is a contrasting set of BC Government principals and policies over the development of giant LNG plants, while on the other hand attempting to control and reduce green house gas emissions in BC.
What are the consequences for the future of British Columbia, with the extraordinary, never before contemplated amount of electrical energy that will have to be used and produced for a single form of industrial development, creating LNG at four or more proposed conversion facilities. As an example of
the magnitude of these projects, it is our understanding that one large LNG plant could consume all of the electrical energy the proposed "Site C" Peace River Hydro Development could produce.

A public dialogue must happen with British Columbians in a frank, open and thorough way, with no political or ideological baggage to confuse or distort the discussion. This is not intended to be an election issue, but a responsibility for all the political parties to support, including the governing party. No one party or government has the mandate to decide on such a gigantic policy shift and set a new direction with so many unknown implications without discussing the transformation with its citizens.

Sadly the discussion to date has been content to push the process and ignore, bury and hide the issues moving British Columbia in a totally wrong direction which could all be reversed if the implementation of the process were carried out in an open and democratic way, along with appropriate planning and information to minimize and manage the risk. If that kind of process were implemented the projects could provide most of the benefits that have been envisioned while preserving much of the wild fisheries and the other values our organization and most British Columbians do not want to see disappear.

Should the current policy decision and direction be continued, there will be repercussions that will be impossible for our province to reverse or extricate itself from, we better get it right or the magic and mystique of North West BC will be traded off for industrial development that could last for 20,30, 40 years but certainly not for perpetuity. The damage could go beyond what future British Columbians could ever have imagined and be ashamed to be living with.

Madam Premier think "clearly and carefully", this is not a simple land use decision but a gigantic provincial policy direction shift that will reverberate for generations to come.

Yours sincerely
Jim Culp Chairman Energy Committee
Northern Branch of the Steelhead Society of BC



Comments on the Coastal GasLink Pipeline Project

The Canadian Environmental Assessment Agency has determined that a federal environmental assessment is required for the proposed Coastal GasLink Pipeline Project in British Columbia and has invited Public comment. Attached is the SSBC submission.

Letter RE: Canada-China Foreign Investment Promotion and Protection Agreement (FIPA)

Dear Prime Minister Harper,


The Steelhead Society of BC is a British Columbia-based grassroots organization who advocate for the conservation, protection, and health of all wild salmonids and wild rivers in British Columbia. Considered to be one of the most important conservation organizations in North America, the Steelhead Society consists of 400 members from across Canada, including current and former Ministry of Environment staff, fisheries biologists, scientists, analysts and anglers in our membership.

Our members' support, as well as private donations and monies raised through fundraising campaigns, funds advocacy actions and awareness in the public spectrum, and acts to encourage positive change in government and private enterprise.

It has come to our attention that in approximately one week from now, your government will institute a 31-year binding treaty, better known as the Canada-China Foreign Investment Promotion and Protection Agreement, without a single debate or vote. The fact that you plan to advance this agreement with your own volition, without any parliamentary review or oversight is Orwellian.

Entering into this agreement will effectively pave the way for China’s oil giants to buy out Canada’s natural resource companies. Entering into this agreement purports only to protect the rights for foreign nations to benefit off of Canada’s national resources. As you know, FIPA will give China’s companies the legal grounds to sue Canadian governments – federal, provincial or municipal, in secret tribunals outside of Canada, if such governments block the profits of any Chinese companies, in any way. Preventing the Northern Gateway pipeline from being built, would give China, under this agreement, grounds to sue the Province and/or the Federal government.

Canada has already spent hundreds of millions on penalties from lawsuits launched under the North American Free Trade Agreement, and it would be a dire waste to spend even a penny more of taxpayer money on such lawsuits when you can stop the FIPA dead in its tracks, right now. Evidently, drafting up legally-binding rights and obligations in favor of foreign investment in Canada’s natural resources is not in the interest of Canadians nor British Columbians. Moreover, it is irrational for one man to be able to unilaterally lock our country into such an extreme deal for such a long period of time, risking potentially billions of dollars of taxpayer money over the 31-year life of the agreement.


We the SSBC strongly believe that us Canadians have the right to have a say in such a deal that will shape a good portion of our lives, and urge you not to sign the FIPA on November 1st, or at the bare minimum, open up the FIPA to the adequate discussion and debate it deserves from the Canadian public.



Brian Braidwood, President of Steelhead Society of BC

Letter RE: Seymour River Hatchery application to Western Economic Diversification Canada (WEDC)

To Whom It May Concern,

The Steelhead Society of BC is a British Columbia-based grassroots organization who advocate for the conservation, protection, and health of all wild salmonids and wild rivers in British Columbia. Considered one of the most important conservation organizations in North America, the Steelhead Society consists of 400 members from across Canada, including current and former Ministry of Environment staff, fisheries biologists, scientists, analysts and anglers in our membership.

We are writing this letter in support of the Seymour Salmonid Society, which operates an important salmonid enhancement facility and educational programs in North Vancouver. Although the Steelhead Society of BC are advocates for wild salmon and steelhead and their associated habitats, we recognize that without the continued efforts of the Seymour Salmonid Society, there would be far fewer – if any – returning steelhead in the Seymour River, due to upstream habitat loss from the Seymour Falls dam, serious urban encroachment form urban development, near total loss of historic intertidal rearing areas due to heavy industrial and Port development, and pollution and predation in the area.

In addition to the important salmonid enhancement activities carried out by hatchery staff, we support the Society’s educational programs:
 -  Several schools take part in the Gently Down the Seymour field trip each fall, which is a great opportunity for children to learn about forest ecology, aquatic invertebrates, and fish habitat right in the remarkable Seymour watershed. This hands-on experience teaches them how important forest and habitat are to the health and survival of BC’s wild salmon.
 - The Salmonids in the Classroom program is another valuable educational initiative, as it provides schools with fertilized salmon eggs for their classrooms, giving students the opportunity to witness salmon eggs hatching.


The Seymour Salmonid Society is important not only to steelhead in the Seymour River, but to the well being of wild fish in BC overall, for it teaches children to respect the fishery resource through their education and awareness programs. However, in order to continue the enhancement activities and educational programs at the Seymour Hatchery, the aging facility and leaking roof must first be addressed. Thus, we are happy to advance our support in the Seymour Salmonid Society’s application to Western Economic Diversification Canada (WEDC) for funds under the Community Infrastructure Improvement Fund (CIIF). It is our understanding that the monies received will be used to replace the existing hatchery and educational center roof, which is in dire need of repair.

The Steelhead Society supports the Seymour Salmonid Society in their activities, and would recommend that you support them also, through providing funding for their much-needed hatchery improvements so that they can continue to serve the community.

Brian Braidwood, President of Steelhead Society of British Columbia

Letter re: BC Angler/Conservation Groups Opposed to Ominous Bill C-38

Dear Prime Minister, Minister Oliver, Minister Ashfield and Mr. McCauly:

The extensive and far reaching proposed changes to both the Fisheries Act and the Canadian Environmental Assessment Act (CEAA) weakens the original intent and very essence of both acts to protect Canada’s environment and its indigenous fish and aquatic species. As separate and distinct organizations we are aligned in our condemnation of your government’s action for taking such a disrespectful and alarming position that reverses the fundamental mandate that you, our Federal Government, is responsible for upholding. Further, by not including all Canadians in a dialogue over these proposed extreme changes to the two acts is an affront to Canadian democracy, the common good and unity of our nation.


Astonishingly, it appears that government will be consulting a choice few regarding the new wording of the two Acts. What of the 1000 scientists who have recently expressed alarm and dismay over the many programs that are going to be, or have been, cut and that are so crucial to Canada’s environment? Are those scientists to be consulted? Their concern appears to be over programs such as the special Ontario Lakes study which is a world-leader in the information and breadth of science on water quality. As well, the closing of the high Arctic Science lab by your government at the end of April--which provided critical CO2 data and other air quality monitoring information--is impossible to understand when climate change appears imminent and the greatest threat to human life and the survival of natural world.

Further, the dismantling of the Round Table of the Environment, a body intended to provide advice and sober second thought to the federal government based on wisdom and common sense from a cross section of people and disciplines, makes little sense. We are also dismayed that Federal opposition parties have not been able to reasonably represent the interests of all Canadians when having to digest and debate the impossible list of hidden bills and changes incorporated into the Omnibus 2012 Budget bill in such an unreasonable time frame. This is an affront to Canada’s democratic process.

The proposed changes to the CEAA and the Fisheries Act ignores the views of the majority of Canadians and clearly puts the economic interests front and center in decision-making. Unfortunately, the environment and wild things cannot be put into uncompromising situations and be able to come out on top or for that matter to be able to survive.
That very disturbing word mitigation--so often misused and abused--implies that in some magical way our country can have both resource extraction and wild, natural places and species, when it is widely known that such is impossible. Development, harvesting and extraction always impact the natural world. Only thoughtful and careful planning and public involvement can truly minimize that impact and, in a very few cases, may be able to mitigate the change and damage by artificial or technological means.

As a government you only have to look at the Lower Mainland and the Fraser Valley of British Columbia and see the effect of development and human activity upon the rivers, tributary streams and aquatic areas that drain into the Fraser River. The majority of the damage to this system took place before the Fisheries Act was amended in the 1970’s. Rivers were dammed, streams diverted and altered, wetlands were drained, spawning gravel removed for industry, agriculture and community expansion, pollution took place and water was diverted for domestic water supply. It is fair to say that 60 % or more of the original fishery and aquatic production for the region has disappeared, likely forever.

With a stroke of a pen the changes being proposed by your government will reverse the protection and management of fish and their habitat that was so difficult to attain, back to that bygone era when so much of the damage took place.
The Minister of Fisheries has often talked about conflict between fish in farm drainage ditchs and the conflict with agriculture production. This is a common issue in the Fraser Valley where fish have often been the losers. The Minister has not been clear or honest in his assessment and discussion with Canadians and he should be aware that most often the water flow in such situations are from a stream that has been diverted and or channelized because it interferes with a farm operation. Unfortunately those streams are often home for indigenous fish species and aquatic life.


The amendments to the CEAA will create unnecessary animosity and division between Canadians. What is required is a national discussion over how we manage Canada’s economy and its natural resources. Such a discussion will take time and good will by all levels of government and all Canadians. Contrary to your government’s view, it’s in the long-term best interest of our country to take this extra time to get it right.
The decisions regarding where and when pipelines should be built and energy projects and production decided upon should evolve from a national energy strategy and a policy established through a “Royal Commission on Energy” because the implications are so important. A half-baked, narrow focused energy policy emanating from the four western Provinces and the self interest of the natural resources industry will only further divide Canadians and national unity. Such an approach is unacceptable. Our Federal Government is responsible for mediating and setting a direction that is thoughtful and creates an atmosphere in which Canadians can work together for the common good.
Ramming legislation through should not be a mantra of government. Rather, the aim should be to make the wisest management and development decisions for both the short and long term best interests of our country and its natural and wild creatures.

Yours truly,

Brian Braidwood, President of Steelhead Society of BC

Greg Gordon, President(acting) of BC Federation of Fly Fishers



Letter to Joint Review Panel Re:Enbridge Northern Gateway Project

The following is the SSBC written submission to the Joint Review Panel regarding the proposed Enbridge Northern Gateway Project.


Aug. 25th Update:

We noticed some of the references in the letter are now invalid. Please note references #1 and #8 should point to http://ercb.ca/reports/r2007-A.pdf and #3 should point to http://msdssearch.dow.com/PublishedLiteratureDOWCOM/dh_07cf/0901b803807cfd99.pdf?filepath=productsafety/pdfs/noreg/233-00833.pdf&fromPage=GetDoc . The #3 pdf has also been uploaded below for your convenience.