Mayhood, D. W. 2020. Comments on the proposed recovery strategy for the bull trout, Saskatchewan River drainage populations. Report prepared on behalf of Timberwolf Wilderness Society, Pincher Creek, Alberta, for Species At Risk Directorate, Department of Fisheries Oceans and the Coast Guard Ottawa, Ontario, iii+23 p. FWR Technical Note No. 2020/07-1 doi:10.13140/RG.2.2.28345.60008
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Canada’s Minister of Fisheries, Oceans and the Coast Guard released a proposed recovery strategy under the Species At Risk Act (SARA) for the designated unit (DU) of Bull Trout (Salvelinus confluentus), Saskatchewan-Nelson rivers populations, in Canada on 1 June 2020. Comments on the document were solicited from the public.
Here I comment on this document on behalf of Timberwolf Wilderness Society and FWR Freshwater Research Limited. The comments focus on
• to what extent the document meets the requirements of the Species At Risk Act (SARA), and
• to what extent the proposals constitute good conservation science that could be expected to
recover the species sufficiently so that it reasonably could be delisted.
In brief, I make the following main points.
• The stated goal does not provide a quantitative target against which progress can be measured, and which can be used to determine objectively when the program has been successful. I make several suggestions about how to correct this problem.
• The definition of residence is limited to only the redd, so does not meet the specifications of SARA section 1(2), which describes residence as “including breeding, rearing, staging, wintering, feeding or hibernating.” Biologically, the lake or stream occupied by the Bull Trout population is its residence.
• The definition(s) of critical habitat are internally contradictory, which will make management difficult and enforcement of SARA protections next to impossible. The entire stream used by the fish at some point in its life history is critical habitat, not just (as described in this document) a few specific, carefully limited features, and not just when those features are used by Bull Trout at carefully limited times. This is the biological reality, and it needs to be stated clearly as the unequivocal definition of instream critical habitat in this recovery strategy.
The document correctly recognizes critical habitat as extending into the terrestrial realm, but only to a highly limited degree: a 30-m wide riparian “buffer” strip on either side of those parts of the channel with the very specific, limited “functions, features, and attributes” identified as inchannel critical habitat. In reality, the watershed as a whole is the true terrestrial portion of critical habitat, and needs to be clearly defined as such in this recovery strategy.
The proposed recovery strategy identifies where critical habitat may be found as extending upstream in the entire watercourse network to the watershed boundary, but again, only to a highly limited degree. In reality, critical habitat includes the entire watercourse network draining to those parts of that network used by Bull Trout during some part of their life history.
• Action plan. Eight years after Bull Trout were formally identified as threatened by the Committee on the Status of Endangered Wildlife in Canada, this recovery strategy proposes to leave an action plan describing in detail the specific actions that will be taken to actually begin recovering Bull Trout populations, for up to five years more. This Bull Trout DU is projected to decline by a further ≥ 30% over the next three generations as of 2012, so it has declined a further 10% by now. This recovery strategy intends to allow the DU to decline by yet another 5% before acting.
• The Fish Sustainability Index (FSI) assessments for individual watersheds lack any evidence supporting them. The problem can be rectified by posting technical reports with the supporting data and analyses on the SARA registry.
• The recovery strategy is designed to work around continued multiple land-uses sanctioned by the Government of Alberta. It is seriously unrealistic to expect to recover already at-risk species, such as threatened Bull Trout, while the lands and waters needed for recovery are subjected to ever-increasing (ab)use from industry, urbanization, grazing, and recreation. The total intensity of land-uses is about to increase by orders of magnitude as the Government of Alberta closes parks, opens most of the Bull Trout critical habitat watersheds to strip mining of coal, and encourages a 30% increase in timber exploitation by 2030. To retain any credibility at all, some recognition of these overwhelming threats to the success of Bull Trout recovery must be acknowledged in the final version of the recovery strategy.