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.

Minister Ashfield responds to SSBC letter to Prime Minister Harper regarding proposed changed to the Fisheries Act

Keith Ashfield, Minister of Fisheries and Oceans, took time to respond to our letter we sent to Prime Minister Harper in March of this year regarding changes to the fisheries act.  Below are some highlights and the reply, in its entirety, is attached at the bottom of the page.


Dear Mr. Braidwood,

As you may be aware, on April 26, 2012, Bill C-38, the Jobs, Growth and Long-term Prosperity Act, was tabled in the House of Commons. Amendments to the Fisheries Act were included in Bill C-38. the proposed amendments are intended to support a shift from managing impacts to all fish habitats to managing threats to fisheries by: focusing the regulartory regime on managing threats to the sustainability and ongoing productivity of Canada's commercial, recreational and Aboriginal fisheries; provider clarity, certainty and consistency of regulatory requirements through the use of standards and regulations; and enabling enhanced partnerships to ensure agencies and organizations that are best placed to provide fisheries protection services to Canadians.


-Aligning the Fisheris Act with the Environmental Enforcement Act (increased fines and penalties for offences)

-Improving the enforceability of conditions to Ministerial authorizations

-Providing for the designation of ecologically significant areas for fish

-Increasing inspector powers to provide them with additional authorities


For updates on the proposed amendents to the Fisheries Act, please see http://www.dfo-mpo.gc.ca


Yours Sincerly

Keith Ashfield