How could we think otherwise?

Jeff Surtess

Trout Unlimited Canada (TUC) was asked to make a submission to the House of Commons Standing Committee on the Environment regarding the creation of a National Conservation Plan for Canada. 

CEO Jeff Surtees (right) appeared before the committee in Vancouver on Wednesday May 15, 2012. 

For additional information and to view a copy of Jeff's speaking notes please visit the Newsroom section of the TUC website.

Although Jeff's presentation was directed to the topic of a National Conservation Plan for Canada, Jeff found it necessary to mention TUC's concerns regarding proposed changes to the fisheries act (Bill C-38).

Here are some of those comments:

Question 5 – What should be the implementation priorities of a National Conservation Plan?

17. In light of the budget bill, Bill C-38, currently before Parliament, this question proved very difficult for us. After a great deal of thought and discussion we concluded there are currently too many uncertainties to answer the question.

18. Mr. Chairman, you have told us this morning that we are to stick to the topic at hand, the development of a National Conservation Plan, that we are not to get into the legislative changes that are proposed. But whether you like it or not, these things are all connected.

19. In the natural environment, everything is connected to everything else. To have any lasting effect, to make a difference in the environment, all actions must be consistent. You always want to start at the top of a watershed and work down, because water and problems flow downhill.

20. So when we are asked for recommendations about implementation priorities to be included in a National Conservation Plan for Canada, we are forced to take into consideration the legislative changes that are being proposed. .

21. As I said at the start, Trout Unlimited Canada is an action oriented organization. We try to work cooperatively. We will, ultimately, learn to work within whatever legislative and regulatory framework our elected representatives put in place. Subject to our funding constraints we will always offer our expertise and our assistance to help.

22. Under the existing legislation if any activity causes harmful alteration, disruption or destruction of fish habitat, an environmental assessment would be triggered. Under the new legislation, our understanding is that will not necessarily be the case. A lot depends upon what is included in the regulations, which are not yet written. So we can’t answer the question.

23. We support improvements to regulatory efficiency so long as the conservation outcomes are not compromised. When considering the amendments to the legislation within Bill C-38, we acknowledge that the increased penalties and the new provisions related to invasive species are positive steps. But we view some of the changes that are being made as steps backwards. We are firmly of the view that destruction or alteration of any real fish habitat should always trigger an environmental assessment. Protection of fish habitat is the reason our organization exists. How could we think otherwise?