Here's a letter that was sent from a coalition of concerned groups. Please feel free to use some of the content for ideas as to how to craft your letter. Its never too late to send your letter. The more people who write in the better, and your efforts are greatly appreciated - thank you!!
Honorable Catherine McKenna, Minister of Environment and Climate Change
ec.ministre-minister.ec@canada.ca
Honorable Dominic LeBlanc, Minister of Fisheries and Oceans Canada
min@dfo-mpo.gc.ca
Sent via email
July 11, 2018
RE: External Review of Draft Amended Recovery Strategy for Northern and Southern Resident Killer Whales
Hon. McKenna and LeBlanc,
Please accept this letter on behalf of the following groups:
- West Coast Aquatic Governance Board
- West Coast Fishing Guides Association
- Alberni Sport Fish Advisory Committee
- Area G Trollers Association
- BC Commercial Fishing Caucus
On July 10, 2018, a conference call was held between the DFO SARA Directorate, West Coast Aquatic representatives and other groups on the West Coast of Vancouver Island regarding the 30-day external review of the draft Recovery Strategy Amendment. West Coast Aquatic brings together diverse people who are passionate about the west coast of Vancouver Island – people who make a living from its waters, rely on its health for food, and protect its beauty – to help improve their connection with the living landscape that they are a part of. The WCA Governance Board includes representatives from all levels of government, Nuu-chah-nulth, aboriginal fishing, commercial fishing, sport fishing, environment, labour, processing, tourism & recreation, aquaculture, marine transportation, and forestry.
There are a few points made on the call that we wish to formally document as part of the external review process.
First, there is strong concern about the science advice that has been used to inform the Recovery Strategy amendment. The Canadian Science Advisory Secretariat (CSAS) Science Advisory Report 2017/011 titled “Identification of Habitats of Special Importance to Resident Killer Whales Off the West Coast of Canada” is cited as the catalyst for considering the waters on the continental shelf off southwestern Vancouver Island (including Swiftsure and La Pérouse Banks) as additional critical habitat. A major weakness in this report is that local or traditional knowledge holders were not a formal part of the process that led to the writing of that report. For instance, from the one-hour discussion with local and traditional knowledge holders, it is clear that there are issues with using acoustic data from Swiftsure Bank as an indicator for whale activity at La Pérouse Bank. Local and Indigenous knowledge holders are prepared to work with the Department on practical ways for their knowledge to better inform decisions about critical habitat.
Second, the 30 day review period for this external review, and the upcoming 60 day public consultation of the proposed Recovery Strategy amendment fail to meet the August 19, 2016 Minister of Fisheries, Oceans and the Canadian Coast Guard Mandate Letter direction to “work with...Indigenous Peoples, and other stakeholders to better co-manage our three oceans”.
Further, the Department of Justice’s Principles Respecting the Government of Canada’s Relationship with Indigenous Peoples states that “meaningful engagement with Indigenous peoples aims to secure their free, prior and informed consent when Canada proposes to take actions which impact them and their rights on their lands, territories, and resources. Both the 30 and 60 day processes are being or will be held during the fishing season, and neither include in- community sessions. Compared to the duration and process afforded to develop the CSAS paper, the consultation process is not conducive to ensuring the adequate inclusion of local and indigenous knowledge. This directly and negatively affects the ability for local and indigenous knowledge to be meaningfully considered as part of the decision making process.
Third, communication is needed regarding what possible management measures are being discussed by Government in the proposed critical habitat areas. Again, local and Indigenous knowledge holders have valuable information to contribute to this discussion. While DFO has stated that there are no immediate plans to add fishing closures in 2018 (as one example of a possible management measure), now is the time to engage communities regarding future measures.
We are calling upon the Department to: 1) immediately extend the timelines for this process; 2) reconsider the science being used to inform the Recovery Strategy amendment once local and Indigenous knowledge has been included; and 3) commit to working with First Nations, fishers, and other community groups, in a meaningful process, on designing critical habitat measures to address killer whale recovery.
Sincerely,
Tony Bennett
Co-Chair
West Coast Aquatic Governance Board
Bob Cole
Alternate
Alberni Sport Fish Advisory Committee
Jim McIsaac
Coordinator
BC Commercial Fishing Caucus
Pat Ahern
President
West Coast Fishing Guide Association
Original Signed
Doug Kimoto
Director
West Coast (Area G) Trollers Association
2
Response:
Please direct responses to Tawney Lem, Executive Director, West Coast Aquatic
tawney@westcoastaquatic.ca
CC:
Heather Brekke - DFO SARA Recovery Planner
Heather.Brekke@dfo-mpo.gc.ca
Christie McMillan - DFO Senior Habitat Assessment Biologist
Christie.Mcmillan@dfo-mpo.gc.ca