June 30, 2011
Ms. Sue Farlinger
Regional Director General
Fisheries and Oceans Canada
Suite 200 – 401 Burrard Street
Vancouver, B.C. V6C 3S4
(by email and Royal Mail)
Dear Ms. Farlinger,
Re: May 10/11 Shimkus letter to Farlinger reference 176204 (attached)
In reference to the letter above, the Steelhead Society of BC (SSBC or Society) appreciates that, in
accordance with the Marine Stewardship Council (MSC) certification process, the Province of B.C.
and your department appears to be examining ways of further reducing or eliminating incidental
interception of Fraser and Skeena bound steelhead in non selective market fisheries.
The Society also appreciates the efforts your department has undertaken in the past to minimize the
impact of commercial fisheries upon steelhead populations through time and area closures and other
initiatives.
Given the perilous status of fall-run Fraser River steelhead stocks, however, the SSBC remains vitally
concerned that such measures may not be adequate. Therefore, the Society is in agreement with
the province that additional restrictions are warranted on commercial fisheries that may have an
impact upon commingling steelhead stocks. Further, in the SSBC’s opinion, such restrictions must be
undertaken irrespective of the MSC process and on a much broader scale to adequately protect other
vulnerable fish stocks like Dean River steelhead.
The SSBC is also in agreement with the province about the use of selective live harvesting in those
salmon fisheries where incidental interception of steelhead stocks is problematic. Through the more
pragmatic and timely implementation of selective live harvesting methodologies, market opportunity is
maintained, upstream economic activity is maximized, while identifiable non-target fish stocks, such as
steelhead, are preserved.
The Society also shares the concerns of the province regarding the notion that gillnets, through the
use of the “short net, short set” practise, can be truly effective as a selective live-harvest methodology
given the poor survival rates of gill net released fish, the current paucity of effective enforcement and
monitoring and the likelihood of diminishing resources towards that end in the future.
You may be aware that the Society has long been an advocate of selective live-harvest in Pacific salmon
fisheries. To that end, in 1995, the SSBC published the booklet “Going backward to go forward: why
selective live harvesting is vital to the survival of Pacific salmon” (an e-version can be found at http:/
/issuu.com/going-backward/docs/going_backward). This document, and the harvest methodologies
described therein, remains relevant today, perhaps more so, as some steelhead stocks appear to
dwindle towards extirpation.
As was the case in 1995, once again, the Society maintains that the implementation of selective live
harvest methodologies in the Pacific salmon fishery are necessary not only to preserve Fraser and
Skeena steelhead to meet MSC certification requirements but, additionally, wherever the interception
of weak fish stocks is problematic.
Lastly, the SSBC is in agreement with the Province of B.C. that the time to act is now and that, given the
inconsistencies of accurate catch reporting in all salmon fisheries, current exploitation rate objectives do
not serve steelhead populations well.
The Society appreciates the opportunity to provide you input and looks forward to your earliest
response to both this letter and this dire situation.
Yours truly,
<Greg Gordon for>
Brian Braidwood,
President
Enclosure: 176204 Farlinger.pdf
c.c. Minister Steve Thomson, BC Forests, Lands, and Natural Resource Operations <email>
Ms. Jody Shimkus, ADM BC Forests, Lands and Natural Resource Operations <email>
Mr. Colin Masson, DFO Marine Conservation Caucus salmon committee <email>
Mr. Don Radford, DFO Marine Conservation Caucus salmon committee <email>
Mr. Mark Saunders, DFO Marine Conservation Caucus salmon committee <email>