Good morning. My name is Wayne Strelioff, I hold the position and responsibilities of the Auditor General of British Columbia. My office serves the Legislative Assembly and the people of British Columbia by providing independent assessments and advice on the accountability and performance of government.

This morning, I will discuss our report on a recent audit. The report is Salmon Forever: An Assessment of the Provincial Role in Sustaining Wild Salmon.

This report represents a departure from our usual practice. For this examination, three offices, the Auditor General of Canada, the Auditor General of New Brunswick and our office, undertook coordinated work. We did this because management of wild salmon and salmon aquaculture is a joint federal-provincial responsibility.

Each office examined similar issues. Our field work was carried out from May 2003 to December 2003. Each office issued a report on the same day, October 26, 2004.

Our report and that of the Auditor General of Canada address wild salmon issues, including the impacts of aquaculture. The New Brunswick report focuses on aquaculture issues only.

The three reports each had the same summary, that is, a common message, signed by 3 Auditors General and the Commissioner for the Environment and Sustainable Development.

This common message identified several themes.

We acknowledged that salmon stocks are under pressure on both coasts, that the federal government has been struggling since 2000 to finalize a wild salmon policy, and that in BC, the government does not have a clear vision and overarching strategy for wild salmon sustainability.

We acknowledged that both levels of government have responsibilities related to wild salmon with the federal government having the senior responsibility. Although many agreements and committees exist, we found problems with coordinating efforts.

Each of the three audits looked at aquaculture issues and found there are major gaps in knowledge about the potential effects of salmon aquaculture.

Our concerns are not new but progress has been slow. The collaboration of a variety of agencies within each government and between governments is essential and we urged the respective governments to take immediate action on these important issues.

Why we undertook this audit

BC is one of the few remaining locations in the world to support relatively large numbers of wild salmon. But, over the last several decades, the long-term sustainability of wild salmon in British Columbia has come into question. Salmon habitat can be impacted by various human activities, such as forestry, water use, urbanization and agriculture. Concerns have also been expressed about the potential impacts of salmon aquaculture.

When we started the audit, we recognized that the Department of Fisheries and Oceans Canada, under the auspices of the Fisheries Act, has senior responsibility for managing all wild salmon including allocation, inventories, escapement, and habitat management.

At the same time, the provincial government participates in the day-to-day management of wild salmon issues through legislation and regulations that govern land use, water use and resources development activities.
The province’s role in managing the habitat is significant.

• Legal obligation – the province has obligations under agreements with the federal government and obligations under provincial legislation
  
  
• Socio-economic value – salmon have important economic value, $607 million in 2002 for commercial and recreational activities and 4500 person years of employment.
  
• Stewardship of the environment – the province is responsible for being a good steward of public lands, so it needs to manage activities that can affect fish habitat.
  
• Demonstrating sustainability –increasingly, global markets are requiring some form of eco-certification for resource- based products. Certification of wild stock for marketing will require being able to demonstrate the viability of wild stocks.
  
• Protecting the public interest – Salmon are an important public symbol for BC. Sustaining them is a demonstration of the government’s commitment to protect the public interest.

Audit purpose

This purpose of our audit was to assess whether the province has effective programs in place to ensure the sustainability of wild salmon in British Columbia.

We examined how the province protects and restores habitat as well as how it mitigates the potential impacts of salmon aquaculture on wild salmon stocks.

Overall Conclusion

Overall, we concluded that the Province needs to be more aggressive if it is to ensure the future sustainability of wild salmon. Its role in managing habitat is significant, but the absence of a provincial vision and strategic plan have prevented establishment of a coordinated program.

Protecting habitat and restoring past problems are essential if our wild salmon are to be sustained. However, existing legislation does not provide adequate protection because some key provisions are either not in force or not being acted upon.

Although aquaculture impacts are recognized and addressed, gaps exists and more research and studies are needed.

Vision and Leadership

The first major issue we considered was the adequacy of vision, strategy and leadership.

Sustaining wild salmon requires a clear vision to reflect the province’s intentions regarding wild salmon. We concluded that the province does not have a clear vision in place to protect and/or restore salmon habitat, or to guide and support policy and program development for maintaining wild salmon and their habitat.

Through a clear vision, the province would describe the future it is working towards

• is the plan for the future to restore wild stocks and their genetic diversity to previous levels
  
• or, is it to maintain exisitng stocks and diversity
  
• or, is it to allow for depletion of wild stocks and their genetic diversity

A clear vision would guide priority setting. As well, because of the significant federal influence around wild salmon, a common federal/provincial strategy and approach needs to be developed to better coordinate efforts and achieve results.

The shared federal-provincial responsibility has led to a mosaic of agreements and protocols that have not substantially clarified roles. This has created awkward arrangements and working relationships.

Within BC, we also found an absence of strong leadership. Several ministries and agencies have a role but there is no one lead agency to give clear policy direction for setting provincial goals or objectives.

Protecting Habitat

We concluded that the Province can play a more active role in protecting habitat. Although there is no legislation outlining the provincial role in regulating wild salmon issues, provincial acts and regulations that include provisions beneficial to wild salmon exist and can influence the extent to which fish habitat is affected. These, however, vary in their value for protecting wild salmon.

The provincial Fish Protection Act, for example, provides incomplete protection for wild salmon. The lack of implementation of several important provisions significantly weakens its value.

The provincial Water Act also contains provisions beneficial to wild salmon, but this Act has not been used as an effective tool for protecting fish habitat. The Act does not require that water needs for fish be considered in a consistent or rigorous manner.

The Forest Practices Code and related guidebooks provide good direction on best practices. A key provision in the Forest Practices Code, and one continued in the Forest and Range Act is the requirement for the establishment of riparian reserves and riparian management zones.

We also noted that changing business processes are creating uncertainty. The move from a prescriptive approach to a results-based approach means government will not be in position to identify and fix problems before they occur.

Compliance and enforcement regimes are being redesigned. Greater emphasis is being placed on the use of risk assessment to determine where and how infractions will be weighted and pursued.

Restoring Habitat

Restoring habitat is another way that government can contribute to the sustainability of wild salmon.
We found that government has reduced its involvement in habitat restoration. Major programs no longer exist. Also, information on restoration needs is incomplete. There is no single inventory of the work previously completed or a ranking of watersheds and habitat requiring restoration.

Effectiveness evaluations

Effectiveness evaluations are necessary to ensure scarce resources have been allocated in an efficient and effective manner. We found there have been limited evaluations carried out to assess the effectiveness of legislation or prescribed standards in protecting fish and fish habitat. As well, very few evaluations have been undertaken to assess past efforts in restoring salmon habitat.

Inventory Information

On the issue of managing information on wild salmon, we found that the Province has collected a considerable amount of inventory information about fish and fish habitat. Historically, this information was collected by a number of ministries and agencies. Government has now begun to centralize and consolidate this information in one agency, the Ministry of Sustainable Resource Management. Although this information lacks a focus on salmon, it is useful, but gaps do exist.

In addition, concerns were expressed about the accuracy of data collected because of third party involvement in data collection and uncertainty about standards and quality control conformance by these third parties.

Impacts of Aquaculture

Our final findings are on the salmon aquaculture component of this audit.

Salmon aquaculture started in BC about 30 years ago. Today the province is the fourth largest producer in the world. Concerns exist about the industry’s impacts on the environment and wild salmon, and whether risks are completely understood. An incomplete understanding of the risks has generated considerable and intense debate in BC.

The three main areas of risk in the salmon farming industry concern:

- marine environmental impacts of aquaculture operations,

- competition from escaped farmed fish, and

- health effects from the transfer of parasites and diseases.

We found that, through a policy framework and regulations, the province has put constructive measures for fish health, waste, escape prevention, best practices, and compliance and enforcement into place. However, important issues remain unsolved. Because properly sited farms, for example, can reduce impacts, the province has developed 15 criteria for locating such farms. But outstanding disagreement persists between federal and provincial agencies on: the criteria for locating net cages in close proximity to wild salmon streams; fish habitat buffers; seabed characterization; and grandfathering of old sites. As a result, efforts to relocate poorly sited existing farms have been slow.

The Province’s ability to manage the risks associated with the interaction between wild salmon and salmon aquaculture is still hindered by gaps and uncertainty in knowledge. There is a need to address the priority knowledge gaps associated with wild and farm salmon interactions in several areas, particularly around issues of fish health and cumulative effects.

Recommendations

We made 14 recommendations for improvement. Three criteria relate to the federal role. These are:

• The province, in conjunction with the Department of Fisheries and Oceans Canada, develop a clear vision, with goals and objectives, for sustaining wild salmon and provide public policy direction about what is an acceptable risk to salmon habitat and what is an acceptable loss of salmon runs.
  
  
• The province, in conjunction with the Department of Fisheries and Oceans Canada, develop an overarching strategy to manage for wild salmon sustainability.
  
• The province pool its research resources with those of relevant federal agencies to more efficiently address the priority knowledge gaps associated with wild and farmed salmon interactions.

That concludes my presentation. Our report has been referred to BC’s select standing committee on public accounts. In January, the committee is likely to meet to address our findings, conclusions and recommendations.

Now, I would be happy to answer any questions, thank you.

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