November 5, 2007

Darcy Miller, Enhancement Manager

Puntledge Hatchery

38 Powerhouse Road

Courtenay BC

V9N 5N3

Dear Darcy,

Losses of salmon and trout stocks in the Puntledge and Tsolum Rivers are significant. The construction of a hydro dam, over fishing, the loss of forested cover over the majority of the watershed, urban and agricultural land-clearing and drainage of wetlands and alteration of streams and rivers reduced stocks precipitously by the mid-fifties. These stocks have never rebounded in a sustainable and consistent manner and continue to require massive hatchery production from the Puntledge Hatchery.

We have information that indicates two factors with seal populations. One, there are no more seals now than there were historically and two, seals are becoming more and more “habituated” to the easy feeding offered particularly, during smolt outmigration and adult returns in the Courtenay River. There is no doubt in anyone’s mind that seals have become a real problem over the past twenty years but we feel strongly that this is particularly due to the fact there are far fewer fish.

Even though hatchery successes and restorations to improve water quality and habitat have occurred fish stocks remain depressed with habitat loss continuing, further draining of headwaters and wetlands and new sets of problems with chemical fertilizers, pesticides and invasive species including “habituated” seals. Extensive ditching both on forestry lands and throughout the Comox Valley has become an overall drain on the ability of the landscape to retain water exacerbating extreme low flows and erosion. This entire picture adds up to less fish.

Less funding and changing enforcement mandates has made it more difficult for proponents to affect overall habitat gains. There have been budget cuts to DFO with no accounting for inflation meaning fewer resources on the ground for DFO to effectively lead, monitor and enforce compliance with existing law. We continue to lose the natural and sustainable support for fish and aquatic species’ survival.

The Tsolum River Restoration Society (TRRS) has always and will continue to appreciate and support the work of DFO staff and programs in our community and we welcome DFO's participation and leadership in the rehabilitation of the Courtenay River and its estuary.

The TRRS represents the voice of our community along the river and beyond. We have had successes in improving water quality with ongoing treatment of Acid Rock Drainage, successes in outreach and education and successes in habitat restoration. When we broach the subject of support for an electronic seal deterrent fence the reaction from our community is mixed to say the least. Here are some comments from the TRRS Board of Directors:

“I can't support a deterrent fence without a cull and complexing of the estuary. If any estuary could actually recapture some of the old estuary habitat for fish it's the Courtenay River estuary. With Ducks Unlimited owning a large part of the alienated estuary I am sure some side channel escape route for the salmon could be created. The lights have to be shielded as a first step.”

“We do not support taking measures in the absence of an holistic, ecological restoration plan.”

“Will it affect other aquatic species as well as seals?  We need more information.”

“I'm pleased that DFO is at least interested in the problem enough to want to do something but where is the evidence that this is going to work or that the money couldn’t be better spent somewhere else?”

“Fry em, shoot em, bomb em”

“I support any and all action to control the seal population in the Courtenay River As much as I love watching them swim and play, the salmon hardly stand a chance running the gauntlet. I support a cull and anything else that will keep their numbers down during salmon migration.”

“What is the evidence that this [type of deterrent] works?”

“I have reviewed the letter representing our concerns and totally concur with the opinions expressed. One of our biggest problems with dealing with ecological issues is the patchwork solutions that we apply to the problem. The "ripple effect" of such actions can sometimes cause more damage by destabilizing other species and thereby causing "collateral" damage. As stated, we must take a "holistic" approach to the problem and address all of the issues to restore and maintain the delicate environmental balances that would lead to increased fish and supporting species populations.”

One of the most pertinent questions that arose during our discussion of this matter was; Is the Courtenay River, because of the special conservation concerns with the Tsolum River and the sensitivity of the Puntledge River’s summer run Chinook the best system in which to be experimenting with or testing new technologies? Wouldn’t it be better to test this technology in a system that is in better shape?

The TRRS is strongly in support of doing something to reduce seal impacts and we would support a deterrent fence and a cull as a part of a comprehensive restoration plan for the Courtenay River and estuary.

To this end we wish to partner with other stakeholders to form an ad hoc community committee to look at estuarial successes in other communities, research and study the work already accomplished locally and can see that the “Courtenay River Estuary Management Plan” published after a collaborative and inter-agency process in 1999/2000 could inform that beginning.

We wish to see a process such as this reinstated, involving government, industry along the Courtenay River and Estuary and local environmental and stewardship organizations working together towards a land use and waterway plan with restorative activities addressing the needs of the aquatic system for the long-term, sustainable health of the Courtenay River and Estuary..

Sincerely,

Stewart Duncan, President

TRRS

Page Top