IN THE MATTER OF : ENBRIDGE NORTHERN GATEWAY PROJECT JOINT REVIEW PANEL

NORTHERN GATEWAY PIPELINES INC.

Application for ENBRIDGE NORTHERN GATEWAY PROJECT Certificate of Public Convenience and Necessity

Hearing Order: HO-4-2011

“…it’s going to gain for somebody, but it’s not going to gain for any of us that live here.”*

WRITTEN EVIDENCE OF THE INTERVENORS UNITED FISHERMEN AND ALLIED WORKERS’UNION-CAW (UFAWU-CAW)

January 2012

Submission: UFAWU-CAW 1.3 Fish and Fisheries: Salmon Pink-Chum

Pages 17-39

UFAWU-CAW 869 Fraser Street Prince Rupert, B.C. V8J 1R1 Phone: 250 624 6048 Head Office: Fax: 250 627-7951 United Fishermen and Allied Workers’ Union-CAW E-mail [email protected] First Floor 326 12th Street New Westminster, B.C. TABLE OF CONTENTS

FISH AND FISHERIES ...... 17 SALMON: ...... 17 Escapements and Conservation: ...... 17 Salmon lifecycle: ...... 18 Adult Return Migration: Pink, Sockeye, Chum ...... 21 Harvesting technology: ...... 21 Cumulative Salmon Fishery Effort ...... 23 SALMON: CENTRAL / NORTH COAST FISH AND FISHERIES ...... 25 PINK SALMON (Oncorhynchus gorbuscha): ...... 25 Central/north coast pink harvests: ...... 28 Catch figures: ...... 30 Pink salmon products: ...... 30 Conservation and Escapements: ...... 30 CHUM SALMON (Oncohhynchus keta): ...... 32 Central / north coast chum harvests: ...... 33 Catch figures: ...... 34 Chum salmon products: ...... 35 Conservation and Escapements ...... 35 Endnotes: ...... iii

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FISH AND FISHERIES

24 There are many species and stocks or sub-stocks of species that are harvested in the commercial fishing industry. There are also many other species not commercially harvested yet play a significant role in the wellbeing of the commercially harvested stocks and/or an important economic role in the financial wellbeing of the Union’s fishing industry members.

25 The following is a brief presentation of the fish that are commercially harvested, the major locations of those fisheries, and the landed value of these fisheries.

26 The Union submits that the impacts of an interruption of fisheries due to an oil spill is not best measured as percentage of coast-wide harvests, but as a percentage of the harvests in the normal fishing areas of the fishermen who engage in the fishery. Many of the fishing areas are delineated by Department of Fisheries and Oceans (DFO) licensing regulations and are much smaller than the entire BC coast. Other areas for a fishery are restricted by the size of the vessel or type of gear that the fisherman owns in that a fisherman may not own a boat or fishing gear that can fish, for example, in the outer, more open areas of the coast. Fishermen are also restricted by their individual knowledge of a fishing region; fishermen specialize in certain areas where they do well and will do poorly in areas that the y are not familiar with. Much of this local fishing knowledge is passed on by families or by fishing groups and is considered ‘private’.

SALMON:

27 There are five species of commercially harvested salmon that live some or all of their life cycle on the central and north coast - they spawn in fresh water, rear, feed as juveniles and adults at sea, and then return to spawn. Salmon can be caught by licensed gillnetters, trollers or seiners in the marine environment or in inland fresh water fisheries in gillnets, dip nets, beach seines or fishwheels.

Escapements and Conservation:

28 DFO’s conservation policy for salmon is set out in Canada’s Policy for Conservation of Wild Pacific Salmon, commonly referred to as the Wild Salmon Policy (WSP) The methodology for ensuring the maintenance of diversity and health of wild salmon stocks is through the identification and protection of “Conservation Units” (CUs).

A CU is a group of wild salmon sufficiently isolated from other groups that, if extirpated is very unlikely to recolonize naturally within an acceptable timeframe, such as a human lifetime or a specified number of salmon generations. There are important implications to this definition of a Conservation Unit. The persistence of salmon within the CU, and its associated production, demand responsible management of its population structure and habitats, as well as the ability of fish to move among habitat areas (connectivity). The loss of a CU for the length of a human lifetime would clearly have serious consequences for the people and other ecosystem components that 24 benefit from or depend on it. (WSP p.10) 17

29 Escapements, or the number of salmon that arrive on the spawning grounds, are set by DFO to ensure that the stock remains healthy and that future fisheries can occur. Preseason estimates assist DFO to manage the fishery but most marine commercial fisheries are managed in-season when run size is more certain.

Salmon lifecycle:

30 Generally, salmon eggs are deposited in gravel in moving water. Depending on the individual salmon stock, the hatched fry may immediately migrate downstream to the ocean or may remain in fresh water for up to 3 years. Once in the marine environment, the juveniles must alter their physiology from fresh-water to salt water which is usually done in estuaries or brackish water. Most salmon juveniles migrate relatively close to the coastline northward to the Gulf of Alaska or the North Pacific Ocean where they grow to maturity. However some stocks remain to rear in the marine environment close to their natal stream. After 1-4 years at sea, the now adult salmon migrate back down the coast into their natal streams where they spawn and die. Fisheries take place on the adult returning salmon.

Juvenile Salmon migration routes:

31 In 1985 the Department of Fisheries and Oceans responded to questions raised regarding the impacts of offshore oil exploration. They presented the following information on the general migration routes 25 of juvenile salmonids. (DFO Responses1985)

 Young salmon in their first summer at sea tend to migrate along the BC mainland coast and in a narrow band approximately 37 km wide. (DFO Responses1985 p 98 s4-12)  Within this band, juveniles tend to be the most abundant in the inner 6-15 km adjacent to the coast (DFO Responses1985 p 98 s4-12)  Juvenile salmon of a number of origins may be constrained to use a common migration route, and that along such routes, the numbers and densities per unit area may be very high over significant periods of time (DFO Responses1985 p95 s 4-9)  This migration starts as early as July and extends through November. (DFO Responses1985 p53 s2-2)  The number of stocks present in the coastal migration belt increased northward, with stocks of southern origin being joined by smaller and later migrants along the way (DFO Responses1985 p53s2-2)  In general, juveniles from California, Oregon, Washington and the Fraser River migrate up the west coast of Vancouver Island, across Queen charlotte Sound or into and eventually follow the coast to the Gulf of Alaska (DFO Responses1985 p54 s2-3)  Young salmon off the west coast of Vancouver Island continued their migration through Queen Charlotte Sound and Hecate Strait, and Dixon entrance. (DFO Responses1985 p54 s2-3)  Juvenile salmon migrating though Johnstone Strait continue their coastal migration through Hecate Strait (DFO Responses 1985 p102 s4-17) 18

 About 1 billion young salmon leave Canadian rivers annually, half from the Fraser River and half from the central and north coast systems; most will migrate north to Alaska (DFO Responses1985 p100 s4-14)  It is conservatively estimated that at least 100 million juvenile salmon from major Canadian rivers survive to reach the waters of S.E. Alaska (DFO Responses 1985 p99 s4-13)

32 DFO concludes that a portion of the stocks of all species from virtually the whole coast south of Dixon Entrance use and mingle in the migration routes in the Hecate Strait area and there is intensive use in the nearshore waters surrounding Hecate Strait by large numbers of young salmon rearing as 26 they migrate seaward. (DFO responses 1985 p103 s 4-17)

33 The following DFO Habitat Management Division Map, Chart and Notes are from Map No.1 Juvenile Salmon Resource. The map shows the juvenile migration routes. The Chart shows where juveniles are in the various months. Note that chinook and coho juveniles are present in coastal areas for 12 months in the year. All species spend from 2-3 months in estuaries and 5 months in inshore waters migrating northward.

MAP NO. 1 JUVENILE SALMON RESOURCE

27 DFO Hab Man Div 1985 19

Department of Fisheries and Oceans, Pacific Region Habitat Management Division February, 1985

28 DFO Gottesfield

Juvenile Salmon Resource Chart from Map No. 1

DFO Hab Man Div 198529 20

Adult Return Migration: Pink, Sockeye, Chum

30 DFOAd Ret Path

Harvesting Technology:

34 A seiner is the largest salmon harvesting vessel with a length usually between 16-26 metres. It has a five person crew and harvests salmon with a purse seine net. The seiner encircles the salmon with the seine net, then purses (tightens) the bottom edge of the net creating a bag – top open, bottom closed, with the salmon inside. The mesh of the net are too small to let the target fish escape. The fish is then removed from the net with a brailer or by ramping and stored in the hold of the seine vessel. Although seiners can catch any species, pinks, chum and sockeye are the normal target species and are brought to the processing plants fresh. 21

35 A gillnet is a smaller salmon vessel that also fishes with a net called a gillnet. A gillnetter is usually 8-12 metres long and will have one or two people on board. The gillnet is hung off the end of the vessel in a line. Salmon swim into the net and entangle themselves by poking their heads through the net mesh or by rolling themselves up in the net’s web. Although gillnetters can catch any species, sockeye, chum, chinook, and pinks, are the normal target species and are brought to the processing plants fresh.

36 A troller is usually an intermediate sized vessel usually 11-17 metres which is distinguished by fishing with hooks and lines that are towed behind the vessel similar to recreational trolling. A troller will have a crew from one to four, depending on the size of vessel and the type of salmon it is targeting. Trollers on the central/north coast usually target chinook, coho, and pinks but also in some areas will target chum. A troller will deliver fresh fish to the plants or will stay at sea for longer periods and individually freeze its salmon catch as a frozen-at-sea product.

37 A salmon fisherman must have on his vessel an A, N or F category license. The type of A license (seine, gillnet, troll) defines the gear that the license permits. An A license is a vessel based license which permits the vessel to engage in salmon (and a few other named species) fishing. The category F license is issued to First Nations under Aboriginal Communal Fishing License Regulation. The Nation can lease an F license onto any salmon vessel and restrictions are the same as for the A license

38 The N license is a special license category used by the Northern Native Fishing Corporation (NNFC). N licenses are gillnet-only licenses. The NNFC is owned by three north coast First Nations and the corporation has 254 gillnet N licenses they lease to aboriginal gillnet fishermen, most of whom gillnet the central/north coast.

39 In order to fish on the central/north coast, each salmon gear type must also have the appropriate area selection: gillnetters must have an Area A selection, seiners must have an Area B selection and Trollers an Area F selection to harvest salmon in Fishing Management Areas 1-10.

40 Some seine and troll fisheries also require transferable quota of a salmon species in order to engage in the fishery.

41 There are 645 Area A (A, F and N) gillnet licenses that are eligible to fish the central/north coast. There are 108 Area B (A and F) seine licenses that are eligible to fish the central/north coast. There are 282 Area F (A and F) troll licenses that are eligible to fish the central/north coast. Not every license is fished every year. Central/north coast fish are harvested in DFO opened fishing areas or sub-areas and openings for seiners and gillnetters are usually from 18-24 hours. If fishing good and the stocks abundant, the Department may extend the opening or re-open the following day or another day later in the week. Trollers usually have a block of days in which they can fish. DFO may cut the troll fishery short or extend the number of days depending on the abundance of the target stocks.

42 Each gear type can engage in selective fishing if required where time, area, gear or fishing methods are altered in order to avoid or release alive non-target salmon stocks.

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Cumulative Salmon Fishery Effort

31 32 PNCIMA Atlas Map 34 Seine PNCIMA Atlas Map 35 Gillnet

33 PNCIMA Atlas Map 36 Troll Effort for the salmon gillnet commercial fishery is displayed on the accompanying maps as boat days by Salmon Catch Estimate Areas (SCEAs).

Because fleets fish at different times for different species, theSCEAs have been digitized to represent where all openings took place for the given geographic unit. When a certain geographic area is

consistently not opened for any gear type, for example a ribbon boundary around a creek mouth or protected area, that feature has been removed from the SCEA.

(PNCIMA Atlas)34

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Salmon Harvests:

43 The following chart shows the total BC harvest and value of wild salmon 2008-2010. The central/north coast area catch, landed value and wholesale value are included in the totals below. The Union will submit a further breakdown of central/north harvests in the sections following.

35 (BC Gov MOE)

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SALMON: CENTRAL / NORTH COAST FISH AND FISHERIES

PINK SALMON (Oncorhynchus gorbuscha):

44 Pinks are the smallest salmon (adults weigh 1 - 2.5 kg) yet are the most abundant salmonid species both in BC and on the central/north coast of BC. On the central/north coast, pink salmon spawn in small coastal creeks, coastal river systems and in larger tributaries far inland on the Skeena and Nass rivers. A large part of the spawning habitat is a few kilometres from the sea, especially in Fishing Management Areas 5-8. Pinks bury their eggs in gravel in running water and may even lay their eggs in parts of streams that are periodically covered by marine tidal waters.

45 On the central/north coast pink salmon spawn mainly in August to October, although fishing occurs on returning pinks from July to September. As with all salmon, pinks die soon after spawning.

46 The eggs hatch in early spring and upon emergence the pink fry migrate quickly downstream to to feed first in the estuary, then along the shore north towards the Gulf of Alaska and the North Pacific Ocean where they grow to maturity. After 18 months at sea, pink salmon return to spawn in the stream or area from which they emerged.

47 Pink salmon are distinguished from other salmon by having a fixed two year life span. Because of this strict two year cycle, pink salmon are reproductively and genetically isolated from each other as fish from ‘even years’ never spawn with pinks from ‘odd years’. As fry from one year class leave the river system to travel to Alaska, adults from the previous year’s fry are leaving Alaska and returning to spawn. One year class is usually strong and the other year class in the same geographical area is usually numerically much smaller. On the central/north coasts, for example, even year pinks return in large numbers to Haida Gwaii, while odd year returns are very small. On the north coast mainland and on the central coast, at present the odd year spawning populations are the large returns and the even year pinks have smaller returns

48 Pink fry emerging from shorter coastal streams do not usually feed in fresh water – they tend to migrate to the sea prior to feeding. However, fry from spawning grounds inland, on the Nass and Skeena systems particularly, will feed on their way to fresh water as their out-migration will take some time. Exogenous feeding for some pink fry may occur in the gravel prior to emergence. (Heard 36 1991) When pink fry do emerge from the incubating gravel they must immediately swim to the 37 surface in order to ‘swallow’ air into their swim bladder to achieve neutral buoyancy. (Heard 1991)

49 The principle fresh water food for pink fry are larval and pupal stages of dipteran insects, particularly 38 chironomids, mayflies and stoneflies along with freshwater copepods. (Heard 1991) Once in the marine environment, early marine schools of pink fry in tens or hundreds of thousands tend to follow shorelines, and during the first weeks at sea spend much of their time in shallow water only a few centimetres deep.39 During active northerly migration, schools of fry have been seen in island channels moving well offshore. Pink fry need large quantities of food to sustain their rapid growth and are opportunistic and generalized feeders. In the marine environment along the central/north coasts, pinks eat harpacticoids, calanoids and other pelagic zooplankters, various copepods, barnacle 25

40 nauplii, myssids, euphausiids, eggs of invertebrates and fishes and fish larvae. (Heard 1991) It is estimated that the growth rates of pinks in their nearshore early sea life is from 3.5%-7.6% per day. 41 (Heard 1991)

50 Pink fry, which are the smallest and usually the most abundant salmon juveniles in both fresh water and marine areas, are an important food source for larger salmonids and other species of fish. In fresh water, coho, charr, steelhead and other trout are the prime predators; with pinks being an important food source for coho juveniles. In estuaries, when the fry first outmigrate from fresh water, herring is a prime predator. Coho are important at-sea preditors of young pink and in some areas pinks provide the predominant food for Coho. Sockeye and Chinook also feed on pink juveniles. 42 (Heard 1991) Pinks adopt a schooling behavior as a defense.

51 On the central/north coasts, pink juveniles are not only found from central/north coast streams but from rivers further south. Starting in July and continuing into November juvenile pinks migrate rapidly northward in a narrow band through Queen Charlotte Sound, Hecate Strait and Dixon Entrance. (DFO Responses1985)43 Pinks from southern B.C. (Fraser River, Mainland Inlets and Vancouver Island) and from Washington (Puget Sound) and Oregon migrate to Alaska along the inner B.C. coast. For example, lower Strait of Georgia juveniles out-migrate in July heading up through Hecate Strait. Different stocks may migrate separately, or together. Along the BC Coastline, 44 the band of juvenile salmon is up to 1,800 km long and often less than 40 km wide. (Heard 1991)

52 Relatively few studies have been done on juvenile pink salmon migration routes. In 2006, Raincoast Conservation Foundation studied the outmigration of juvenile pink and chum salmonids from Roscoe Inlet, above Bella Bella. They found that the

 the timing of the migration in Roscoe Inlet began at the beginning of April and ended near the middle of May  juvenile pinks did not remain in the estuary areas but quickly migrated to the coastal shoreline  various runs of pink and chum salmon within Roscoe Inlet enter the salt water at different times  the migration routes through Roscoe Inlet run parallel to the shoreline  juvenile fish from different tributary streams joining the main migration route out of Roscoe  the fry did not necessarily moving quickly out of Roscoe Inlet but instead spend time feeding and growing within the protected inlet for extended periods of time.  all captured fish were observed within 1 meter of the surface of the water.  the entire length of shoreline habitat was being used by the juveniles and no salmon were 45 caught in the middle of the channel (Williamson 2006)

53 The study did not follow the pink and chum juveniles out of Roscoe and the specific northerly migration route was not known.

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54 Studies were done on and area pink salmon in 2004 and 2005. These studies, led by Allen Gottesfield, focused on collecting salmon in the littoral zone, where pink juveniles are the most common species; over 95% of salmonids collected were juvenile pinks. The test area was from Anger Island in the south to Dundas Island in the north. Most pink fry were observed in offshore coves next to area of upwelling or near island groups that jutted into channels with strong tidal currents, good mixing, higher salinities and which contained bull kelp. (Gottesfield et al 2006 )46

In coastal streams pink salmon emerge in April. Upriver [Skeena] populations emerge later at the time of the snowmelt peak in May and early June with peak fry migration occurring in mid-May…visual observations of pink salmon abundance in mid May show high densities on the upriver facing islands at the mouth of the Skeena, and on the eastern side of islands along the western edge of Chatham Sound… in June, pink salmon occur in moderate to high densities along the western side of Chatham Sound ad at low to moderate densities in Odgen Chanel and Petrel Channel. In July, aggregations of pink salmon smolts are restricted to the islands and passes along the western part of Chatham Sound and the western part of Ogden Channel. By mid August most of the pink salmon smolts have left the estuarine are of the Skeena River. Small numbers only are found along the western passes out of Chatham Sound and at the western end of Ogden Channel… We infer that the pattern of multiple sized fish…shows that some of the smolts reach the western side of Chatham Sound early in the season, perhaps without stopping at other sites, while some of the smolts arrive in the western zones after growing at shallow water sites further up-flow … (Gottesfield et al 2004 )47

2004 Summary of Observed Juvenile Densities from Shoreline Survey (Gottelfield,Allen et al 2006)

55 The figure to the left is the density of pink fry in mid-May, 2004. The fry are beginning their out- migration from the Skeena River. The densest areas are close to the Skeena mouth and the most scattered schools are on the outside areas with greater salinity.

56 In May, there are a small number of pink juveniles and they are found close to the Skeena mouth at the north end of Porcher Island.

57 In June there are large numbers of pinks and they are found from the north end of Grenville Channel, Elliot, Mc Micking, Porcher andAnger Islands through to Dundas Island.

58 In July, fewer pink juveniles are found. They are moving north or out into Hecate Strait via the south end of Porcher Island. In August, pinks were scarce.

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59 The following figure is the Skeena pink salmon migration route as proposed in Gottesfield, Allen et al. 2004. Sea Lice and Pink Smolts on the North Coast of . The paper states:

60 “This migration route is credible because the origin of the majority of pink smolts is clearly the Skeena River and it is reasonable to imagine the migratory path split among components that move through Ogden Channel and through Chatham Sound since much of the movement of the small fish is via current action. The tidal currents enhanced by estuarine circulation currents move at….an order of magnitude above the sustained swimming speed of the smaller pink fry (Bell 1973, Bjornn and Reiser 1991). Essentially the young fry might be thought of as planktonic….On the northern branch of the Skeena outflow, Coriolus forces cause flows into Chatham Sound to turn northward. Likely impingement sites for juvenile salmon are along Melville, Dunira and Dundas Islands, places we observed with early and sustained high smolt densities”. (Gottesfield et 48 al 2004)

61 Pink salmon stay one winter in the North Pacific Ocean before migrating back to the

central north coasts to spawn. While at sea 49 (Gottesfield et al. 2004) and on their migration home, pinks eat larger prey: crustaceans, squid and fish.

Central/north coast pink harvests:

62 Pinks are caught by all 3 salmon gears: Seine, troll and gillnet. However, pinks are mostly harvested in seine fisheries (75%) and in many years provide the largest catch (by poundage) and income for that fleet. It can be an important fishery for gillnetters and trollers in some years, as well. pink salmon on Haida Gwaii have the opposite dominant brood year to salmon on the mainland permitting pink harvests in both even and odd years for salmon licenced Area A and C vessels.

63 Major pink harvests take place in Area 3 (Nass) on northern BC and southern Alaska pinks; in Area 4 and 5 on Skeena River pinks and in Areas 6, 7 and 8 on coastal BC pinks.

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Pink Harvests by gear, by quantile based on average catch per area

50 BCMA Atlas Commercial fisheries pink Salmon (seine) 2001-2007

51 BCMA Atlas Commercial fisheries pink Salmon (gillnet) 2001-2007

52 BCMA Atlas Commercial fisheries pink Salmon (troll) 2001-2007

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Catch figures:

64 Please refer to the attached appendix for information on harvest statistics.

Pink salmon products:

65 The majority of central/north coast pink salmon are canned as high end canned products in the Prince Rupert processing facility. However, there are growing markets for pink salmon fillets and for fresh and frozen dressed (cleaned) pinks. Trollers mainly sell pinks in a lucrative frozen-at-sea market. Pink eggs are valuable and are worth far more per kilogram than the pink flesh.

Conservation and Escapements:

66 Pink salmon have been divided into eighteen Conservation Units (CU) on the central/north coasts (out of 32 pink CUs in BC).

Ten Odd year pink salmon CUs: Eight Even year pink salmon CUs: .

Pink salmon Conservation Units

DFO Conservation Units for Pacific Salmon under the Wild Salmon Policy53

67 Pink salmon spawn in Fishery Management Area 1 though to Area 8. In different years, different areas of the central/north coasts have different return success. At times Area 3 pinks could return in large numbers, in other years it could be Skeena (Area 4) or Area 6, 7 or 8 coastal pinks. Accurate predictions are very difficult. Adult return migration routes are usually similar to juvenile out- migration pathways, but adults from different stocks and different systems co-migrate and it is sometimes difficult to tell which stocks are returning to which river during the peak of the pink run.

68 On Haida Gwaii, large pink returns come in even years.

69 In Area 1, Yakoun River is the major producer along with Naden River and Davidson Creek. Good size pink fisheries have taken place in recent years in Masset Inlet and Naden Harbour.

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70 In Area 2E, Deena and Copper Rivers are the largest producers. Large pink runs also occur in Cumshewa inlet and in Darwin Inlet (particularly to the Salmon River).

71 The largest return in Area 2W is to Rennell Sound where in some years many small streams together produce a large run size. Haida Gwaii, like the rest of the central/north coast, has many small systems that can, in some years, see surprising large individual returns or an area may see a large run size made up from returns to many smaller streams.

72 In Area 3 (Nass), the major pink systems are the Kwinamass, Khutzemateen and Iknouk Rivers however, pinks return to most small coastal streams. Intermingled with Canadian pinks are large numbers of returning SE Alaska pinks. Area 3 fisheries target both Alaska and Areas 3 and 4 returning stocks

73 In Area 4 (Skeena) 128 systems have a recorded pink presence. The majority of Skeena pink salmon production occurs in the Kitwanga, Kispiox, Babine and Morice River systems which are hundreds of kilometres from the ocean as well as in the following below Terrace: the mainstem channels of the Skeena, the Lakelse watershed, and the Ecstall, Khyex and Kasiks Rivers. The Skeena has a large combined pink return: fisheries of 1-2 million pinks are not uncommon.

74 In Area 5, there is no one major pink stock but a number of small coastal streams which all contribute to Area 5 harvests. Coastal Area 5 pink stocks are managed in accordance with Skeena pink runs (as a good proportion of Skeena-bound pinks return through Area 5) until mid-August when the coastal pinks returning to Area 5 streams become prevalent.

75 Area 6 also has many coastal pink streams with the Quaal and Kemano Rivers and Bish Creek being the largest single producers. (In 2009, Area 6 over 9 million pink salmon returned to spawn for a catch of over 6 million).

76 Area 7 is not a big pink producer; Mussel, Kainet and Neekas Rivers having the largest returns and other coastal systems will have small pink stocks.

77 Area 8 has had large fisheries in the past, however returns are present are relatively low. Atnarko, Kwatna and Koeye Rivers are the major pink producers, yet like all coastal areas, most small coastal streams will have pink returns.

78 Salmon Management Areas 3-8 all have a dominant run (large returns) in odd years.

79 Pink salmon stocks in all areas are considered overall to be in good shape. Overfishing has not been an issue, however recent environmental changes, such as vigourous fall floods have negatively impacted pink stocks in the past 5 years.

80 Conservation Units for pinks are relatively small in number (18 for the central/north coasts compared to 141 for sockeye in the same geographic area). DFO manages pinks on the Skeena and Nass by overall abundance as measured near the mouth of the rivers by the abundance testing tools (Nisga’a fish wheels on the Nass and the Tyee test net on the Skeena). DFO manages pink harvests by the 31

accumulated pink run size on these two major watersheds, not by individual Conservation Units. By the time the pinks would have reached their natal inland spawning beds in the 3 inland CUs, the chance to harvest them in the marine environment would be passed.

81 For the coastal systems, DFO manages to the spawning requirements for each individual stream. Therefore, on the coast, DFO manages in units smaller than Conservation Units (there is only one CU 54 covering the central/north coast coastal pink systems, as can be seen in the figure above). (DFO)

CHUM SALMON (Oncohhynchus keta):

82 Chum salmon are also distributed throughout Fishery Management Areas 1-8. They return as larger salmon, from 3 – 8 kg at ages from 3-5 years. Central/north coast chum, like pinks, spawn in rivers of different sizes, from small coastal streams to large rivers and lay their eggs in moving water. Chum adults are usually classified by fishermen as ‘summer chum’ which return in July through early September and ‘fall chum’ which return to spawn in late September through to November.

83 Fisheries can occur in Areas 3 and 6 on early chum in late June through to early August and on late chum in Areas 1 and 2 on Haida Gwaii and Areas 7-8 on the central coast from late August to October.

84 The Skeena and Nass rivers are not large chum producers; chum caught in Area 3 are from a diverse number of small systems, including Alaskan wild and hatchery chum. There is no targeted chum fishery in Area 4.

85 Again, like pink salmon, chum fry migrate to salt water as soon as they emerge from gravel. Chum fry are larger than pink fry of the same age and tend not to school when out-migrating, but to swim downstream independently. Chum hatching far inland will feed as they out-migrate on small larvae. 55 Fry out-migration occurs on the Skeena from mid-March to mid-April. (Salo 1991)

86 Coho and various trout feed on chum fry in fresh water; smaller fry are targeted.

56 87 Chum salmon are second only to Chinook salmon in dependence upon estuaries .(Salo 1991) where they linger feeding for up to three weeks, as they have a good tolerance for waters of differing salinity. The out-migration of the fry usually coincides with the warming of nearshore waters and accompanying plankton blooms, but chum fry, while in the estuary area, feed on both fresh-water and 57 marine organisms, taking advantage of their ability to tolerate differing levels of salinity. .(Salo 1991) When chum juveniles have grown to a larger size they move out of the estuary area to swim along the shoreline where they feed on larger epibenthic and neritic food resources. Chum and pink fry aggregate strongly along the shoreline, often within a 10-20 metres of shore and especially at the heads of bays or inlets where a number of different stocks may collect, feeding on harpacticoid copepods. Numbers of chum (biomass per unit area) can be very high for significant periods of time from a few to six weeks. This implies a high demand for food in a restricted area, and near-shore

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epibenthic food organisms can be more densely concentrated for an extended period of time than 58 typical pelagic plankton. (DFO Responses 1985)

88 Chum salmon migrate northward to the Gulf of Alaska and the North Pacific where they will spend 2-4 years before returning. Chum juveniles from the Strait of Georgia leave the Strait in July joining 59 Fraser River and Puget Sound chum in a northerly migration.. (Salo 1991) Chum juveniles often travel with pink salmon in what is thought of a predator avoidance technique and the Raincoast Conservation Foundation Roscoe Inlet study findings as reported in the pink section above applied to 60 chum juveniles, as well as to pinks. (Williamson 2006)

61 89 Chum stay near-shore while migrating northwards.(Salo 1991) but there is little specific information on chum migration routes through the central/north coasts. DFO reports that wild juvenile chum leave coastal areas to enter Hecate Strait and Dixon Entrance from Mid-June to August. Bella Coola chum fry entered coastal waters from March to May. (DFO Responses 1985)62 It is thought that most chum reside in the North Pacific for their first winter, however, some chum juveniles have been found in northern Hecate Strait during November.

90 North coast chum juveniles tend to co-migrate with pinks and sockeye at the beginning of their out- migration but Gottesfield et al found that the Skeena chum out-migrated from in-shore areas approximately three weeks earlier than pink juveniles. On the other hand, chum found south of the Skeena estuary near their natal stream on Anger Island were found in chum only schools. By early May, the Anger Island chum had out-migrated. (Gottesfield et al 2006 p30) 63

91 Chum salmon are raised in central/north coast hatcheries for harvest purposes and information about freshwater chum fry release timing from hatcheries is readily available. Unfortunately, no more is known about juvenile migration patterns of hatchery chum.

92 Chum spend 2-4 winters in the North Pacific Ocean and migrate back to the central and north coasts, feeding on crustaceans, crab larvae, squid and fish. Adult chum return to spawn on the central/north coasts predominantly as 4 year olds, although some may return as 3 or 5 year olds.

93 In general, returning adults follow the same migration routes back to their natal streams. Chum are very particular spawners, they will return to the exact same gravel that they emerged from, even if water flows or channel pathways have changed since they out-migrated as fry (Gottesfield and Rabnett 2008) 64

Central / north coast chum harvests:

94 Chum are harvested primarily by gillnetters and seiners. Standard central/north coast sharing arrangements are about 50% for each gear type. Chum fisheries are lucrative due to the price per pound and the large size of chum salmon. Chum target fisheries take place on Haida Gwaii, Douglas Channel and on the central coast.

33

2001-2007 average chum harvest sorted by gear and.quantile

65 66 BCMA Atlas Commercial fisheries chum Salmon (seine) 2001-2007 BCMA Atlas Commercial fisheries chum Salmon (gillnet) 2001-2007

2001-2007 average chum harvest sorted by gear and.quantile

67 BCMA Atlas Commercial fisheries chum Salmon (troll) 2001-2007

Catch figures:

Please refer to the attached appendix for information on harvest statistics.

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Chum salmon products:

95 The majority of central/north coast chum salmon are marketed as fresh or fresh frozen dressed product. Chum portions are gaining acceptance on the market. Chum are the wild salmon most commonly used for smoking. Chum eggs are the premium caviar product.

Conservation and Escapements

96 There are 17 chum Conservation Units on the central/north coast and a total of 38 in BC

Chum salmon Conservation Units

The Spiller- Fitz Hugh (yellow), North Central Coast Coastal (red) and the Douglas Channel (green) CUs presently have the most productive chum runs.

The Haida Gwaii chum CUs produced large runs in the1950s – 1990s but have

had spotty returns in the past 15 years. Skeena and Nass chum stocks are at low levels of productivity at present.

DFO Conservation Units for Pacific Salmon under the Wild Salmon Policy68

97 Chum run sizes vary year to year in different areas; a system that produces well one year, can be a poor producer the next. As most chum salmon spawn in coastal systems productivity is very dependent on freshet/flood timing and early availability of food in estuarine and near shore areas.

98 Chum salmon spawn in Fishery Management Area 1 though to Area 8. In different years, different areas of the central/north coasts have different return success.

99 On Haida Gwaii, chum returns are spotty. Different stocks can return in wildly different run sizes – with two streams side by side having very different productivities. In the 1950s-1990s, there 35

were large fall chum fisheries every year on Haida Gwaii. At present, there are a few good chum returns each year, but to different systems, making predicting fishing opportunities difficult. The fishery is not managed by CU but by individual inlet or sound as the largest management zone and individual stream escapements as the smallest management zone.

100 The major chum producers in Area 1 are the Ain and Awan River s in Masset Inlet and the Naden River in Naden Harbour. Harvest opportunities are only considered if surpluses have been identified in-season.

101 In Area 2 East, Deena River, Lagina and Slatechuck Creeks, are the major producers in East Skidegate Inlet, although there are many small chum creeks as well. Mathers and Pallant Creeks have large returns that fuel the Cumshewa Inlet fishery; Pallant creek hatchery enhanced Pallant and Mathers chum stocks until 2011, when DFO dismantled the hatchery infrastructure. Selwyn Inlet and Darwin Sound have both recently had large chum returns, with Lagoon and Sewel Creeks being the major producers in Selwyn and Salmon River the largest single producer in Dawin.

102 In Area 2 West, fishing areas include West Skidegate Inlet, Englefield Bay and Tasu Sound. Harvestable surpluses in 2 West are mostly from a combination of many small streams; Tasu and Security Inlet Creeks are the two larger producers.

103 Area 3 (Nass) has no single major chum producer but significant stocks return to Kshwan, Stagoo and Khutzeateen Rivers. The chum return begins in early July and continues into October. Large numbers of Alaskan hatchery chum co-mingle with Area 3 chum and it is difficult to differentiate between the plentiful U.S. hatchery stocks and the Canadian wild chum.

104 At present, Area 3 chum are quite depressed and Canadian fisheries (gillnet and seine) are configured to fish selectively to avoid or to live-release chum salmon bycatch. The DFO has also instituted ‘ribbon boundary closures’ - closing areas in Area 3 to sockeye and pink directed fisheries because there are high incidental catches of Area 3 chum. We are concerned that any ill- effects from an oil spill on Area 3 chum will lead to further closures of pink and sockeye fisheries.

69 (IFMP)

36

70 (IFMP)

105 Area 4 (Skeena) chum stocks are also depressed. There are 43 chum streams in Area 4. Chum salmon are the least abundant salmonid specie in the Skeena Watershed. Chum salmon spawning areas are most common in the Skeena tributaries below Terrace - with spawning areas in side channels of the lower Skeena, at the confluence of tributary streams and in the Extall River. The Kitwanga and Kispiox Rivers, hundreds of kilometres up the Skeena River also have significant spawning populations. Fishing on pinks and sockeye is restricted in order to rebuild the Skeena chum stocks.

106 Skeena chums are not fished in chum directed fisheries; instead they are caught as inadvertent bycatch in sockeye and pink targeted fisheries. In order to avoid excessive impacts on Skeena chum, gillnetters and seiners engaged in pink and sockeye directed fisheries are closed in mid- August thereby losing fishing opportunities and income. As well, when fishing in the Skeena in late July and early August, gillnetters and seiners must alter normal gear and fishing methods and 37

use selective fishing practices to enable the successful live release of Skeena chum salmon. These sacrifices are meant to rebuild the chum stocks to the level that they would be able to, at the least, withstand normal bycatch fishing pressure and permit the lengthening of the pink/sockeye fishing season. Of grave concern is that an oil spill would negatively impact the weak chum stocks and then there would be no tolerance for any chum bycatch, resulting in the complete closure of pink and sockeye fisheries whenever chum were present, from the last week of July through August and September.

71 (IFMP)

72 (IFMP)

107 Area 5 There are many small chum streams in Area 5 on the islands and on the mainland. The chum stocks are numerically small in each system. DFO says that Area 5chum stocks are depressed.

108 Area 6 chum are both wild and enhanced with the Kitimat hatchery creating the largest fishable surpluses which are harvested in a terminal fishery in Kitimat Inlet close to the City of Kitimat and the proposed oil terminal. Chum catches in Douglas Channel have varied from 3,000 – 200,000 in recent years. The Douglas Channel fishery takes place in July and early August and is considered a summer chum fishery. Fisheries on pink salmon in the areas outside of Douglas Channel release chum alive back to the water in an effort to reduce impacts on Area 6 chum wild stocks. Dala, Kitimat, Kemano and Khutze are the largest chum producers in Area 6.

73 (IFMP)

109 The major wild chum salmon in Area 7 are from the Mussel, Kainet, Neekas, Quartcha, and Roscoe systems. Fisheries for these stocks only take place in approach and terminal areas when DFO is satisfied that chum escapement targets will be met. Enhanced chum from Kitasoo and McLoughlin Bay chum provide harvesting opportunities on a regular basis. Chum harvests in Area 7 take place in late August, September and can extend into October, and is considered a fall chum fishery. Flooding and other environmental changes have made chum returns to Area 7 unstable. For the past 5 seasons, wild chum have been depressed; in 2011 the total Area 7 chum

38

stock returned to the level of the third largest in two decades. Chum harvests were high in 2011 as a consequence of the large returns.

110 Area 8 chum remain depressed and did not show the large increase that occurred in Area 7. Chum fisheries in Area 8 target stocks The Douglas Channel fishery takes place in July and early August and is considered a summer chum fishery from the Kimsquit and Bella Coola Rivers. Elcho, Cascade and Jenny Rivers in the Dean Channel area are also significant chum producers. The Bella Coola hatchery enhances chum stocks that return to the Bella Coola River. Very large floods in this area are the likely reason for poor returns.

111 Chum have a greater number of Conservation Units than pink salmon when you consider that pinks have a maximum of 10 for one year class. There are 17 chum Conservation Units on the central/north coasts. Management is not done on the CU level but by small sub area or even by individual stream. Wild chum salmon stocks are considered to be in poor shape in most streams on Haida Gwaii, although every year one or two stocks return in harvestable numbers. Nass and Skeena chum are in poor shape as well, although Skeena chum stocks have never been large and have never supported a targeted fishery. Central coast stocks are unpredictable – in some years there are large returns to some systems however, vigorous fall floods have negatively impacted chum stocks in the past five years.

112 Chum hatchery stocks, from Kitimat, Hartley Bay, Kitasoo, McLaughlin Bay and Bella Coola are 74 doing well, providing stable fishing opportunities for the commercial fleet. (DFO)

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Endnotes:

*Angel, Eric. Potential Impacts of the Enbridge Northern Gateway Pipeline Project on Commercial Fishing and Fishing Communities on BC’s north coast. 2011 (p 26) Prepared for UFAWU-CAW

24 Her Majesty the Queen in Right of Canada, 2005. Department of Fisheries and Oceans. Canada’s Policy for Conservation of Wild Pacific Salmon. P.10 http://www.pac.dfo-mpo.gc.ca/fm-gp/species- especes/salmon-saumon/wsp-pss/docs/wsp-pss-eng.pdf

25 Department of Fisheries and Oceans. Government Responses to Requirements for Additional Information West Coast Offshore Oil Exploration. Government of Canada and Province of British Columbia. February 1985. Prepared for West Coast Offshore Exploration Panel. pp53-105 s2-2 to 4-17

26 Department of Fisheries and Oceans. Government Responses to Requirements for Additional Information West Coast Offshore Oil Exploration. Government of Canada and Province of British Columbia. February 1985. Prepared for West Coast Offshore Exploration Panel. p103 4-17

27 Department of Fisheries and Oceans, Pacific Region, Habitat Management Division. February 1985. Map No.1 Juvenile Salmon Resource. Courtesy of Allen Gottesfield

28 Department of Fisheries and Oceans, Pacific Region, Habitat Management Division. February 1985. Map No.1 Juvenile Salmon Resource. Courtesy of Allen Gottesfield

29 Department of Fisheries and Oceans, Pacific Region, Habitat Management Division. February 1985. Map No.1 Juvenile Salmon Resource. Courtesy of Allen Gottesfield

30 Department of Fisheries and Oceans, Pacific Region, Habitat Management Division. February 1985. Map No. 3 Adult Pink, Chum and Sockeye Salmon Migration Routes. Courtesy of Allen Gottesfield.

31Pacific North Coast Integrated Management Area Initiative. 2011. Atlas of the Pacific North Coast Integrated Management Area, Cumulative Salmon Seine Fishery Effort Map 34 Available at www.pncima.org

32 Pacific North Coast Integrated Management Area Initiative. 2011. Atlas of the Pacific North Coast Integrated Management Area, Cumulative Salmon Gillnet Fishery Effort Map 34 Available at www.pncima.org

33 Pacific North Coast Integrated Management Area Initiative. 2011. Atlas of the Pacific North Coast Integrated Management Area, Cumulative Salmon Troll Fishery Effort Map 36 Available at www.pncima.org

34 Pacific North Coast Integrated Management Area Initiative. 2011. Atlas of the Pacific North Coast Integrated Management Area, Cumulative Salmon Fishery Effort Map 36 Available at www.pncima.org

35 BC Government. Ministry of Environment Oceans and Marine Fisheries Branch. BC Wild (Capture) Salmon Production. http://www.env.gov.bc.ca/omfd/fishstats/graphs-tables/wild-salmon.html iii

36 Heard, William R. Life History of Pink Salmon (Oncorhynchus gorbuscha) in Groot C. and Margolis L. ed. Pacific Salmon Life Histories. UBC Press in cooperation with DFO. Vancouver. 1991 p.170

37 Heard, William R. Life History of Pink Salmon (Oncorhynchus gorbuscha) in Groot C. and Margolis L. ed. Pacific Salmon Life Histories. UBC Press in cooperation with DFO. Vancouver. 1991 p 164

38 Heard, William R. Life History of Pink Salmon (Oncorhynchus gorbuscha) in Groot C. and Margolis L..ed. Pacific Salmon Life Histories. UBC Press in cooperation with DFO. Vancouver. 1991 (p 171)

39 Heard, William R. Life History of Pink Salmon (Oncorhynchus gorbuscha) in Groot C. and Margolis L. ed. Pacific Salmon Life Histories. UBC Press in cooperation with DFO. Vancouver. 1991 (p175).

40 Heard, William R. Life History of Pink Salmon (Oncorhynchus gorbuscha) in Groot C. and Margolis L. ed. Pacific Salmon Life Histories. UBC Press in cooperation with DFO. Vancouver. 1991 (p177).

41Heard, William R. Life History of Pink Salmon (Oncorhynchus gorbuscha) in Groot C. and Margolis L. ed. Pacific Salmon Life Histories. UBC Press in cooperation with DFO. Vancouver. 1991 (p 180)

42 Heard, William R. Life History of Pink Salmon (Oncorhynchus gorbuscha) in Groot C. and Margolis L. ed. Pacific Salmon Life Histories. UBC Press in cooperation with DFO. Vancouver. 1991 (p180)

43 Department of Fisheries and Oceans. Government Responses to Requirements for Additional Information West Coast Offshore Oil Exploration. Government of Canada and Province of British Columbia. February 1985. Prepared for West Coast Offshore Exploration Panel p56 s 2-5

44 Heard, William R. Life History of Pink Salmon (Oncorhynchus gorbuscha) in Groot C. and Margolis L. ed. Pacific Salmon Life Histories. UBC Press in cooperation with DFO. Vancouver. 1991 (p183)

45 Williamson, Chris. Juvenile Salmon Migration Mapping: A Pilot Study in Roscoe Inlet 2006. Raincoast Conservation Foundation. http://raincoast.org/files/publications/reports/Migration_finalreport_20060131.pdf

46 Gottesfield, Allen et a. 2006. North Coast Marine Baseline Survey and Sea Lice Research 2004 and 2005 Final Report April 2006. Skeena Fisheries Commission (p.49)

47 Gottesfield et al 2004. Sea Lice and Pink Smolts on the North Coast of British Columbia. January 2005. p.13

48 Gottesfield et al 2004. Sea Lice and Pink Smolts on the North Coast of British Columbia. January 2005. pp31-32

49 Gottesfield et al 2004. Sea Lice and Pink Smolts on the North Coast of British Columbia. January 2005. p.19

iv

50 British Columbia Marine Conservation Analysis. 2011. Marine Atlas of Pacific Canada: a product of the British Columbia Marine Conservation Analysis (BCMCA), Commercial Fisheries –Pink Salmon (Seine) Available online at www.bcmca.ca

51 British Columbia Marine Conservation Analysis. 2011. Marine Atlas of Pacific Canada: a product of the British Columbia Marine Conservation Analysis (BCMCA), Commercial Fisheries –Pink Salmon (Gillnet) Available online at www.bcmca.ca

52 British Columbia Marine Conservation Analysis. 2011. Marine Atlas of Pacific Canada: a product of the British Columbia Marine Conservation Analysis (BCMCA), Commercial Fisheries –Pink Salmon (Troll) Available online at www.bcmca.ca

53 Fisheries and Oceans Canada. Salmon and Freshwater Ecosystems Division. Science Branch. Power point presentation 2008 Conservation Units for Pacific Salmon under the Wild Salmon Policy. http://www.pac.dfo-mpo.gc.ca/consultation/ wsp-pss/2008/docs-eng/strat1.pdf

54The information provided in this section is generally known by the UFAWU-CAW and can be substantiated by the presentations made at the Salmon Post-Season Review, December 8, 2011 which can be found at the DFO North Coast site under Salmon Post Season Review : http://www.pac.dfo- mpo.gc.ca/northcoast/post-seasonreview/default.htm and by the Integrated Fishing Management Plans Salmon North Coast at: http://www-ops2.pac.dfo-mpo.gc.ca/xnet/content/MPLANS/MPlans.htm#Herring

55 Salo E.O. Life History of Chum Salmon (Oncorhynchus keta) in Groot C. and Margolis L. ed. Pacific Salmon Life Histories. UBC Press in cooperation with DFO. Vancouver. 1991 (p253)

56 Salo E.O. Life History of Chum Salmon (Oncorhynchus keta) in Groot C. and Margolis L. ed. Pacific Salmon Life Histories. UBC Press in cooperation with DFO. Vancouver. 1991 (p257)

57 Salo E.O. Life History of Chum Salmon (Oncorhynchus keta) in Groot C. and Margolis L. ed. Pacific Salmon Life Histories. UBC Press in cooperation with DFO. Vancouver. 1991 (p258)

58 Department of Fisheries and Oceans. Government Responses to Requirements for Additional Information West Coast Offshore Oil Exploration. Government of Canada and Province of British Columbia. February 1985. Prepared for West Coast Offshore Exploration Panel ( pp 92 s4-6 &101 4-15)

59 Salo E.O. Life History of Chum Salmon (Oncorhynchus keta) in Groot C. and Margolis L. ed. Pacific Salmon Life Histories. UBC Press in cooperation with DFO. Vancouver. 1991 (p 260).

60 Williamson, Chris. Juvenile Salmon Migration Mapping: A Pilot Study in Roscoe Inlet 2006. Raincoast Conservation Foundation. http://raincoast.org/files/publications/reports/Migration_finalreport_20060131.pdf

61 Salo E.O. Life History of Chum Salmon (Oncorhynchus keta) in Groot C. and Margolis L. ed. Pacific Salmon Life Histories. UBC Press in cooperation with DFO. Vancouver. 1991 (p264)

v

62 Department of Fisheries and Oceans. Government Responses to Requirements for Additional Information West Coast Offshore Oil Exploration. Government of Canada and Province of British Columbia. February 1985. Prepared for West Coast Offshore Exploration Panel p58 2-7

63 Gottesfield, Allen et a. 2006. North Coast Marine Baseline Survey and Sea Lice Research 2004 and 2005 Final Report April 2006. Skeena Fisheries Commission. p. 30

64 Gottesfield, Allen and Rabnett, Ken. Skeena River Fish and their Habitat. Skeena Fisheries Commission 2008. Published by Ecotrust Portland (p19)

65 British Columbia Marine Conservation Analysis. 2011. Marine Atlas of Pacific Canada: a product of the British Columbia Marine Conservation Analysis (BCMCA), Commercial Fisheries –Chum Salmon (Seine) Available online at www.bcmca.ca

66 British Columbia Marine Conservation Analysis. 2011. Marine Atlas of Pacific Canada: a product of the British Columbia Marine Conservation Analysis (BCMCA), Commercial Fisheries –Chum Salmon (Gillnet) Available online at www.bcmca.ca

67 British Columbia Marine Conservation Analysis. 2011. Marine Atlas of Pacific Canada: a product of the British Columbia Marine Conservation Analysis (BCMCA), Commercial Fisheries –Chum Salmon (Troll) Available online at www.bcmca.ca

68 Fisheries and Oceans Canada. Salmon and Freshwater Ecosystems Division. Science Branch. Power point presentation 2008 Conservation Units for Pacific Salmon under the Wild Salmon Policy. http://www.pac.dfo-mpo.gc.ca/consultation/ wsp-pss/2008/docs-eng/strat1.pdf

69 Department of Fisheries and Oceans. Pacific Region Integrated Fisheries Management Plan. Salmon Northern B.C. June 1, 2011 –May 31, 2012 p.45 http://www.dfo-mpo.gc.ca/Library/343940.pdf

70 Department of Fisheries and Oceans. Pacific Region Integrated Fisheries Management Plan. Salmon Northern B.C. June 1, 2011 –May 31, 2012 PP59-60 http://www.dfo-mpo.gc.ca/Library/343940.pdf

71 Department of Fisheries and Oceans. Pacific Region Integrated Fisheries Management Plan. Salmon Northern B.C. June 1, 2011 –May 31, 2012 P.65 http://www.dfo-mpo.gc.ca/Library/343940.pdf

72 Department of Fisheries and Oceans. Pacific Region Integrated Fisheries Management Plan. Salmon Northern B.C. June 1, 2011 –May 31, 2012 P.45 http://www.dfo-mpo.gc.ca/Library/343940.pdf

73 Department of Fisheries and Oceans. Pacific Region Integrated Fisheries Management Plan. Salmon Northern B.C. June 1, 2011 –May 31, 2012 P.45 http://www.dfo-mpo.gc.ca/Library/343940.pdf

74 The information provided in this section is generally known by the UFAWU-CAW and can be substantiated by the presentations made at the Salmon Post-Season Review, December 8, 2011 which can be found at the DFO North Coast site under Salmon Post Season Review : http://www.pac.dfo- mpo.gc.ca/northcoast/post-seasonreview/default.htm and by the Integrated Fishing Management Plans Salmon North Coast at: http://www-ops2.pac.dfo-mpo.gc.ca/xnet/content/MPLANS/MPlans.htm#Herring vi