Freshwater fish Freshwater Conservation planning

WCS Canada comments on the Position Statement on the Consideration of Cumulative Effects on Fish and Fish Habitat in Support of Decision-Making under the Fisheries Act

O'Connor, C., Mantyka-Pringle, C., Murdoch, A.


Abstract

"Thank you for the opportunity to submit our remarks on the draft Position Statement on the Consideration of Cumulative Effects on Fish and Fish Habitat in Support of Decision-Making under the Fisheries Act (hereby referred to as the draft Position Statement) released by Fisheries and Oceans Canada (DFO).

We submit these remarks in our capacity as conservation scientists on behalf of Wildlife Conservation Society Canada. WCS Canada (www.wcscanada.org) is a national non-government organization with a mission to save wildlife and wild places in Canada through science, conservation action, and by inspiring people to value nature. WCS scientists lead research and policy development in northern boreal and arctic regions. We are affiliated with global WCS programs in more than 60 countries in the world and active at the science-policy interface in Canada and internationally. More specifically, we are three freshwater scientists leading multiple programs studying the cumulative impacts of climate change and industrial developments on freshwater ecosystems and fish species.

We are pleased that the updated Fisheries Act (2019) has included renewed commitments to protect fish and fish habitat, strengthens the role of Indigenous knowledge informing habitat decisions, establishes a public registry, and includes recognition of principles of sustainability, the precautionary principle, ecosystem management, and consideration of cumulative effects. We share the concern with DFO that failing to adequately consider cumulative effects will lead to continued loss of fish habitat in Canada, and we are pleased that DFO is working to better address cumulative effects.

However, we have an overarching concern that the draft Position Statement falls short of providing clear and actionable guidance for the implementation of considering cumulative effects under the new Fisheries Act. Therefore, this document contains: 1) a description of our concerns on the draft Position Statement and our corresponding recommended revisions to strengthen the Position Statement (p. 2), and 2) our recommendations for implementation in the Yukon and northern Ontario -- two landscapes where we have regional expertise."

Recommended citation

O'Connor, C., Mantyka-Pringle, C., Murdoch, A. (2023). WCS Canada comments on the Position Statement on the Consideration of Cumulative Effects on Fish and Fish Habitat in Support of Decision-Making under the Fisheries Act. WCS Canada. https://library.wcs.org/DesktopModules/Bring2mind/DMX/API/Entries/Download?EntryId=45203&PortalId=96

Constance O'Connor

Constance O'Connor

Director, Ontario Northern Boreal Program

Chrystal Mantyka-Pringle

Chrystal Mantyka-Pringle

Co-Director, Northern Boreal Mountains Program

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