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Kwicksutaineuk/Ah-Kwa-Mish First Nations feedback on the Pacific Salmon Forum report

Wednesday, February 25th 2009 3:34:50pm

BC Pacific Salmon Forum
Attention: John Fraser, Chair

February 23rd, 2009

Kwicksutaineuk/Ah-Kwa-Mish First Nations feedback on the Pacific Salmon Forum report

I provide my feedback to the Pacific Salmon Forum's (PSF) report as chief of the Kwicksutaineuk/Ah-Kwa-Mish First Nation (KAFN) whose Territories encompass the Broughton Archipelago.

We applaud the diligence of the Forum in assessing the impacts of open net-cage salmon farms and in striving for solid solutions. The KAFN is encouraged by the many aspects of the report that acknowledge the problems and address the necessity for change.

However, as a Nation experiencing firsthand the environmental and cultural impacts of the farms in the Broughton Archipelago, it is necessary that we share our continued concerns in light of the PSF report.

Specifically, we commend the PSF for:
• Acknowledging the interaction between open net-cage salmon farms and the presence of sea lice on wild juvenile salmon.
• Confirming that the current system of fish farm management and regulation does not allow for coordinated decision making; consideration of cumulative effects; nor transparent monitoring of ecological impacts.
• Delivering governance recommendations that recognize First Nations as a level of government to be involved in the proposed changes put forward by the PSF.
• Promoting shared government-to-government decision-making as per the New Relationship (founded on respect, recognition and reconciliation of Aboriginal rights and title).
• Highlighting that ecosystem-based management must be employed in the management and regulation of aquaculture.
This begins to address our concerns of severe impacts to further species, such as clams, thatare also essential to the cultural, ecological and spiritual integrity of our Territories.
• Concluding that there is a need to move to closed containment.
• Recognizing the necessity of transparent and coordinated management of watersheds with the direct involvement of local councils.
• Acknowledging the Broughton Archipelago as an area specifically impacted by open net-cage salmon farming.

Our concerns include:
• The report does not adequately deal with the urgency of the problem for the salmon of the Broughton Archipelago. It will be 2012 before there is a BC Water and Land Agency and a set of ecosystem indicators.
• There is a bias in the report to the use of neurotoxins as a regulatory measure. The use of chemicals to control pathogens is contrary to the very principles of ecosystem-based management put forward by the PSF. The continued reliance on chemicals creates a selection pressure for resistance and the potential to damage the ecosystem in ways yet to be understood.
• While it is to be applauded that the limits for lice are to be set on infection levels outside the net-cages, the limit for number of lice per wild juvenile salmon is not sufficient. The recommendation pairs a very young fish size (0.5 gram or less) against a very old lice stage (chalimus or later). This rarely occurs and cannot therefore serve as a precautionary threshold for infection of wild juvenile salmon.
• The absence of consideration for the suite of problems related to open net-cage aquaculture. There is a focus on the issue of sea lice transmission but inadequate consideration of issues such as escapement, antibiotic resistance, impacts of waste and disease transmission.
• The proposal involving closed containment is insufficient as it only allow for a single "demonstration project" and development being controlled by a "technical committee". This does not deal with the urgency to make salmon farming a closed system as soon as possible.
• The proposal to maintain current production levels for farmed fish is in no way a "precautionary approach to protecting wild salmon returns". It defies logic to maintain the production levels that led to the very problems requiring the formation of the PSF in December of 2004. Furthermore, with the recommendation to fallow farms but maintain production, this would lead to increased farming intensity in another part of the ecosystem e.g. clam beds.

Coordinated Area Management Plan (CAMP)

Most importantly, the KAFN know the coordinated area management plan (CAMP) referred to in Appendix 3 to be inadequate to protect the juvenile salmon in our Territories. The plan does not incorporate sufficient fallowing and is heavily reliant on pesticides.

With our firsthand and extensive knowledge of our Territories and the impacts of open net-cage salmon farming upon them, we support the Musgamagw Tsawataineuk Tribal Council's solutions for the Broughton Archipelago as presented to MAL on July 15th, 2008 (as attached).

Given that some of the recommendations are longer timeframe deliverables, we of the KAFN are seeking meaningful precautionary steps with the Wild Salmon as the primary focus, not production levels of companies in a given area/region.

It is many of these same concerns that necessitated the KAFN's classaction lawsuit recently filed against the BC Government to rectify the unjustified infringement of our aboriginal fishing rights resulting from the failure to adequately license and regulate the 29 open net-cage salmon farms in the Broughton Archipelago.

Ultimately, we hope the PSF report will compel the provincial government to strategically engage with the Kwicksutaineuk Ah-kwa-mish First Nation in developing an action plan relating to the Pacific Salmon Forum's report and recommendations.

In the Spirit of Growth and Unity,
Chief Bob Chamberlin


Gordon Campbell, Premier British Columbia, Gordon.Campbell.MLA@leg.bc.ca
Ron Cantelon, Minister of Agriculture and Lands, ron.cantelon.mla@leg.bc.ca
Gail Shea, Minister of Fisheries and Oceans, shea.g@parl.gc.ca
Chief Shawn Atleo, BC Assembly of First Nations, bcchief@bcafn.ca
Grand Chief Stewart Phillip, Union of British Columbia Indian Chiefs, president@ubcic.bc.ca
Grand Chief Doug Kelly, Chair British Columbia First Nations Fisheries Council; DKelly@fns.bc.ca
Chief Charlie Williams, Gwawaenuk Tribe, gwawas@shaw.ca
Joey Willie, Chairman Tsawataineuk First Nation, tjosephw@uniserve.com
Chief Bill Cranmer, Namgis First Nation, Billc@Namgis.bc.ca
Carole James, Leader British Columbia New Democratic Party, carole.james.mla@leg.bc.ca
Claire Trevena, North Island MLA, claire.trevena.mla@leg.bc.ca
John Duncan, MP Vancouver Island North, Duncan.J@parl.gc.ca