Letter to the Environmental Assessment office regarding the Garibaldi project

July 17, 2009

Submitted by electronic mail

Graeme McLaren, Projects Assessment Director

Environmental Assessment Office

PO Box 9426, Stn Prov Govt.

Victoria, B.C. V8W 9V1

Re Proposed Garibaldi at Squamish Project (2006)

Dear Sir

The following is the submission of the Steelhead Society of British Columbia regarding this matter.

We urge the Environmental Assessment Office to not issue a certificate to the project proponent because the project, as currently described, will almost certainly have significant and permanent impacts on steelhead habitat in Brohm Creek.

Brohm Creek is a uniquely productive steelhead stream because of unusually high levels of naturally occurring phosphorous, and is therefore capable of producing 3 to 5 times as many steelhead as other streams of similar size. It is the major steelhead spawning tributary of the Cheakamus River, which in turn is the most important spawning tributary of the Squamish River.

The uniquely productive water chemistry in Brohm Creek also makes the stream exceptionally fragile and susceptible to pollution impacts.

The Garibaldi Project threatens Brohm in at least three ways:

o Removal of water resulting in lower stream flows and changes to Brohm’s hydrograph;
o Changes in water chemistry; and
o Physical changes to aquatic and riparian fish habitat.

Development in headwater areas has the highest opportunity to influence the overall aquatic ecosystem supported by the drainage. Headwater habitat largely defines the water quality and chemical composition of the stream water. Headwater health also plays an important role in food and nutrient contribution and debris flow. Whatever changes occur in the headwater areas can be expected to affect the entire watercourse downstream and all its inhabitants. There are too many examples involving poor forest practices that make this point very clear considering the damage done to many small streams over a very short period of time as a result of logging in headwater areas.

This proposed development is positioned over the entire headwaters of Brohm Creek. There will be road, trails, golf course fairways, ski hill runs all crossing Brohm Creek over and over again. Essentially, the headwaters of this creek will become semi-urbanized overnight. While the project EA states that the development will only result in approximately 6% impervious surface, there are still likely to be impacts such as:

* Altered hydrograph due to stormwater contributions;
* Elevated nutrient levels and changes to water chemistry as a result of golf course fertilizer and runoff water;
* Elevated temperatures as a result of insolation occurring in exposed channels and pond discharge and runoff from water surface (i.e., roads)
* Elevated sediment loads as a result of development and operation. A casual attitude to erosion and sediment control during the development phase alone could render Brohm Creek sterile for many years, if not permanently. We did not see this issue addressed anywhere. High sediment loads over a prolonged period of time are insidious. Even with the best ESC management, there will still be sedimentation impacts and considering the massive scope of the proposed development, likely a lot of sedimentation will occur.

Brohm Creek is too small, too sensitive and much too valuable to use as a domestic water supply for this project. The Steelhead Society has concerns that the methodology used by the proponent to determine water supply was inappropriate in this case. We assert that the outstanding issues regarding surface water withdrawal should not be deferred to a post- Environmental Assessment Certificate stage as these issues are difficult and potentially without remedy. In addition, the domestic water requirements of the development may be significantly underestimated.

It has been noted that there is only one Brohm Creek and that there is a conservation concern for steelhead in this watershed and elsewhere in southern BC. On the other hand there is no shortage of golf courses or ski hills in the Squamish area. Why would we take the chance that this development could irreparably damage the function of this extremely important stream?

Discharge of treated sewage into the Cheakamus River is proposed. Accidents happen. All we need is another spill in the Cheakamus. The EA document did not address the potential for accidental releases of deleterious substances.

We recommend that the proponent modify the development proposal as follows:

1. Find an alternative source of water so no water is directly or indirectly removed from Brohm Creek;
2. Reduce the amount of impervious surface in the headwater development, and take additional steps to minimize headwater development impacts on Brohm’s hydrograph and water chemistry; and
3. Delete the proposed golf course development from the lower Brohm valley.

We further recommend designation of the lower Brohm watershed downstream of Brohm Lake as a park or other protected area in order to preserve these unique steelhead values in perpetuity.

Please publish this submission on your website.

All of which is respectfully submitted,

Poul Bech, Ralf Kroning and Trevor Welton


Steelhead Society of BC

Letter to the Hon. Barry Penner Minister MOE - November 23 2009

November 23, 2009
Letter to the Hon. Barry Penner Minister MOE re. budget and staffing.
Jim Culp Chair Northern Branch Steelhead Society of BC
November 19, 2009
To - Hon. Barry Penner Minister
Ministry of Environment
Parliament Buildings
Victoria B.C.
Fax 250-387-1356

From - Jim Culp Chairperson
Northern Branch of the Steelhead Society of BC
5321 Mountain Vista Drive
Terrace BC V8G4X4

Dear Mr. Penner, In reference to the brief our organization presented on October 22, 2009 to the Select Standing Committee on Finances and Government Services on the “Budget for the Ministry of Environment Fisheries and Habitat Stewardship Sections.

In our brief we outlined a number of very serious concerns to do with the proposed budget for the Fisheries and Habitat Sections for 2009/10 and for a number of years into the future. These two MOE Sections have become skeleton operations that are no longer capable of managing the majority of British Columbia’s fresh water fisheries and their essential habitats. It is unacceptable that your Government is prepared to downsize these two Stewardship Sections even further when there is so much at stake. The Provincial Government has a fiduciary responsibility to manage and to protect the freshwater fishery resource of British Columbia at an acceptable level of competence. That competence can not be easily measured, but one way or another will be judged by the citizens of this province.

In our presentation we have made some suggestions on how budgets and staff can be increased even during these difficult times. Unfortunately a mistake that we made in our presentation is that we did not include the impact of the proposed HST upon the introduction of a dedicated special tax to raise revenue for fish and fish habitat management.

We are proposing an alternative. It is now our understanding that not only will the proposed HST be applied to all goods (fishing tackle) and services but it also will be applied to angling licenses and special angling fees. Because British Columbian’s would never embrace another new tax regardless of how important it may be it is our view that all the revenue from the sale of licenses and special fees + the HST should go towards the management of the freshwater fishery and its habitat. And further that all of the HST revenue from the sale of fishing tackle should be dedicated or channeled into the management of the freshwater fishery and its habitat.

On “CBC Almanac” November 18, Don Peterson from the Freshwater Fisheries Society of BC discussed a just completed study which showed that British Columbia’s freshwater recreational fishery generates more than $500 million annually. That money goes back into the BC economy and Government coffers and employs many people. With that kind of revenue being generated our request for more funding and staff for fisheries and habitat management is justified and the responsible thing for your government to do.

We look forward to a sympathetic response to our ideas and proposals. In the interests of the freshwater fishery our Northern Branch of the S.S. would be more than happy to sit down with you or a representative from your Ministry to explore the options that we have proposed. Your Government needs to move us from the dilemma that has compounded since the mid-nineties to a stable and productive freshwater management regime that can be counted on to do the job that British Columbians expect and are entitled too.
Yours sincerely
Jim Culp Chairperson
Robin Austin MLA Skeena
Rob Flemming MLA Victoria - Swan Lake, Critic for Environment
John Les Chair for the Select Standing Committee on Finances and Government Services
Doug Donaldson Deputy Chair S.S. Committee Finances and Government Services MLA Bulkley - Stikine
Jason Tonelli President of the Steelhead Society of BC

February, 2004 Letter to the Minister of WLAP - Thompson River Recovery Plan

Letter to the Minister of WLAP - Thompson River Recovery Plan
Tyler Kushnir

Honourable Bill Barasoff,
Minister of WLAP

The Thompson River Steelhead is a world famous icon of British Columbia. People come from around the world to challenge these magnificent fish. That this symbol of BC sport fishing is in grave danger is beyond question. This past November your Ministry was about to take the unprecedented step of a total closure of fishing on the Thompson River. This was due to the predictions that only 800 fish were expected to return. Historically the Thompson is thought to have supported some 10,000 spawners. Only intense political pressure and a few late arriving fish kept the closure from being implemented.

The Steelhead Society of BC is very concerned with the future of Thompson River steelhead. The problems of the Thompson are varied and difficult to deal with: from rearing habitat issues in the Nicola and Deadman Valleys, to commercial and native interception in the Fraser - not to mention the apparent apathy of the DFO to steelhead.

Furthermore, ocean survival issues complicate the situation. To this end the SSBC wants to see the creation and implementation of a full-scale recovery plan for Thompson River steelhead.

The Provincial Government needs to take the lead in this process. The Thompson and its steelhead bring worldwide fame to British Columbia. The failure to take decisive action at this time could mean the end of one of British Columbia’s great symbols. We need to act now.

Yours sincerely,

Tyler Kushnir
Director Steelhead Society of British Columbia.

Cc. Honourable Gordon Campbell, Premier

February, 2004 Coquitlam River Mudslide - The Coquitlam Now Newspaper

Coquitlam River Mudslide - The Coquitlam Now Newspaper
Poul Bech

Thank you for your coverage of the January 19th mud slide near the Coquitlam River.

I went up and looked at the slide area on Saturday morning. What a mess! The Coquitlam River remained muddy downstream of the gravel pits.

Community groups and individuals, notably the Port Coquitlam and District Hunting and Fishing Club, have been fighting to protect the Coquitlam River from gravel mining impacts since at least the 1960's. It’s amazing that small populations of wild steelhead and salmon still cling to survival after decades of abuse. And yet the gravel companies seem willing to do little more than the minimum required by regulation.

It’s time for the gravel companies to step up to the plate and take some real responsibility for the river that flows through their gravel pits and our community.

Yours truly,

Poul Bech
Steelhead Society of B.C.

January, 2004 Thompson Steelhead/Water licenses

Ms. Joyce Murray

Minister of Water, Land and Air Protection Province of British Columbia

(by e-mail)

Dear Minister Murray

Re: Thompson River Steelhead

The Steelhead Society of B.C. is extremely concerned about the continuing population decline of Thompson River steelhead. The world-famous Thompson River steelhead catch-and-release sport fishery was on the verge of closure this fall due to the lowest predicted escapement in 25 years of records, much to the dismay of both anglers and the local communities that depend on them.

As I’m sure you are aware, one of the most critical issues facing Thompson steelhead is insufficient summer stream flows in the Nicola, Coldwater, Deadman and Bonaparte River systems. Until these issues are resolved, the Steelhead Society supports a moratorium on issuing any new water licenses on these important rearing tributaries. Such a moratorium would also benefit endangered Thompson River coho salmon stocks.

In September, 2003, the Pacific Fisheries Resource Conservation Council published a report titled "Conflicts Between People and Fish for Water: Two British Columbia Salmon and Steelhead Rearing Streams in Need of Flows" (the full text of the report is available at www.fish.bc.ca).

The report made several recommendations specific to the Nicola/Coldwater systems at page 56. In their news release (click here to read news release), the PFRCC summarized these recommendations as follows:

"1. The establishment of a moratorium on water licensing for diversion or extraction.

2. A review and update of the Nicola Basin Strategic Plan, now 20 years old.

3. The development of a hydrological budgeting process, throughout the watershed, in order to allocate water to fish and agriculture in a fair, transparent and legal manner.

4. The launching of a license-compliance and beneficial-use audit of existing water licenses and water use in the basin.

5. The updating of the flow-release regime that is part of the Nicola Lake dam-operation plan to protect fish and meet appropriate water requirements.

6. The exploration of opportunities to buy back water licenses for fish and ecosystem values similar to initiatives undertaken in parts of the western United States."

The Steelhead Society asks if the provincial government supports these recommendations, and if so, what steps have been taken to implement them.

The Steelhead Society was distressed to learn that the provincial regional fisheries management section in Kamloops was very recently cut from a total of four positions to three positions. Ironically, one of the major duties of the lost fisheries biologist position was resolving water use issues. In our view, particularly given the critical state of Thompson steelhead populations, provincial fisheries management capability was inadequate even prior to this recent cut. We urge you to provide sufficient additional funds in order to meet what we is considered a crisis situation for Thompson steelhead, and also to reinstate the cut position.

We look forward to your response.

Yours truly,

Poul Bech


Steelhead Society of British Columbia

cc Premier Gordon Campbell

Joy Macphail, MLA

Dave Chutter, MLA

David Anderson, MP

BC Federation of Fly Fishers

BC Federation of Drift Fishers

BC Wildlife Federation

Kingfisher Rod & Gun Club

Pacific Fisheries Resource Conservation Council

Pacific Salmon Foundation

The Osprey, c/o FFF Steelhead Committee

Watershed Watch

Wild Salmon Center

Wild Steelhead Coalition

Mark Angelo

Jim Ryan, Spences Bridge

Laurie Kingston, Spences Bridge

January, 2004 Letter to the WLAP Regarding Riparian Zones on Salmon Streams

January, 2004 Letter to the WLAP Regarding Riparian Zones on Salmon Streams


To Minister of Water Land and Air Protection

On behalf of the members and directors of Steelhead Society of BC (SSBC), I would like to express my concern over the provincial government’s lack of commitment to fish habitat preservation. In the face of forceful pressure from the development community and related stakeholders, it appears the Ministry of Water Land and Air Protection (MWLAP) is revamping the Streamside Protection Regulation (SPR) contained in the Fish Protection Act, and relaxing riparian setback requirements.

SSBC is aware that after much urging, most municipalities in the Lower Fraser area are currently assessing riparian setbacks based on the SPR, with a few utilizing the older DFO/MELP “Land Development Guidelines for Aquatic Habitat”, leave strip recommendations. DFO has currently embraced the more prescriptive SPR setbacks with the realization that riparian habitat, particularly in urban areas, is rapidly dwindling as are the fish populations which utilize it. SSBC understands that MWLAP is proposing to change the current SPR to a new results based, site specific riparian assessment methodology, which may provide limited riparian protection (5-12m) for small streams and disconnect the regulatory agencies from the assessment process.

Small streams are where a majority of coho, cutthroat and steelhead, BC’s most threatened salmonids, spawn as mature adults and rear as juveniles. The trees, shrubs and forbs contained within the riparian corridor are extremely important for buffering the effects of residential, commercial and industrial land use. Furthermore, riparian vegetation plays a critical role in water quality, water quantity, channel morphology, food and nutrient contribution, instream complexity and overall stream ecosystem health. Best science (See below for example references) has shown us that small streams, with a functional riparian corridor of 15-30m, are more healthy and stable and provided a much higher index of productivity in terms of macro-invertebrates and fish population numbers.

The SSBC is committed to steelhead and salmon habitat preservation. As angler’s we are intimately aware of the local and global pressures affecting the health of our anadromous fish species. Many of us have experienced a favorite fishery which has suffered until poor returns force angling closures. This reoccurring theme in British Columbia is what the SSBC is determined to fight. I implore you, the Minister of Water, Land and Air Protection, to stand up and use the precautionary approach for riparian setback assessment. Let us err on the side of caution and not be persuaded by economic, developmental pressures. After all, with the protection of fish habitat, are we not in turn taking steps to ensure this highly economically valuable resource is perpetuated?


Scott Baker-McGarva

Steelhead Society of British Columbia President


1- John Millar et al. 1997. “Establishing Fisheries Management and Reserve Zones in Settlement Areas of Coastal British Columbia”.

2- Leavitt, Jennifer. 1998. “The Function of Riparian Buffers in Urban Watersheds”.

3- Knutson, K.L., and V.L. Naef. 1997. “Management Recommendations for Washington’s Priority Habitats: Riparian”.