Re: Consultation on the addition of narwhal and two bowhead whale populations to the SARA List

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1 March 31, 2006 Central & Arctic Region SARA Coordinator Freshwater Institute Fisheries & Oceans Canada 501 University Avenue Winnipeg MB R3T 2N6 Re: Consultation on the addition of narwhal and two bowhead whale populations to the SARA List Note: Questions from the workbook on narwhal and two bowhead whale populations produced by Fisheries and Oceans Canada have been copied and answered below. Narwhal Questionnaire What is your interest in narwhals? (for example: fishing/hunting as a food source, tourism, guiding, research, inherent value, etc.) Sierra Club of Canada (SCC) is concerned about the future of narwhals and in support of the preservation of biodiversity and protection of species at risk under the Species at Risk Act (SARA). SCC be lieves that SARA has the potential to be an effective tool for species recovery and conservation. This process can only begin, however, if those species that are at risk are listed under SARA. These comments are therefore being submitted to urge Fisheries and Oceans Canada to recommend that the Minister of the Environment list the narwhal as special concern under SARA in accordance with the COSEWIC status report released by the scientific community. 1) Are you in favour of the Government of Canada adding narwhals to the SARA list? Yes. Why? According to the 2005 COSEWIC status report, two of the three populations of narwhals known to exist occur in Canada. These populations face numerous potential threats from hunting, climate change, environmental contaminants and commercial fishing. Hunting is believed to pose the most significant threat to narwhals in Canadian waters. Both the Baffin Bay and the 1

2 Hudson Bay populations of narwhals are hunted and COSEWIC notes that limits for sustainable hunting are not identified and reliable records of numbers hunted are not available. COSEWIC also notes concern about a recently opened commercial fishery in Baffin Bay and the potential effects of climate change on narwhals which are uncertain but may include changes in the species distribution, range, migration patterns, and more. The narwhal is significant historically as an important resource in the traditional subsistence economy of the eastern Canadian Arctic and Greenland. The narwhal is the only species in its genus and is a significant part of the arctic food chain linking artic cod and humans or killer whales. There is considerable public interest in this species due in part to its unique tusk and remote habitat and this species is arguably important to all Canadians despite the fact that many may not rely on this species directly or ever see it. The on-going struggle to protect whales around the globe is testament to the significance of these mammals. Given the significance of this species, threats from recent developments in commercial fishing, the uncertainty of its ability to adapt to imminent changes due to climate change and to survive current levels of hunting, the federal government must act to ensure that this species is not further endangered by adding it to Schedule 1 and following-through with a management plan that properly assesses the risks to narwhals and provides mitigative measures to address these risks. The purpose of SARA is not only to prevent species from becoming extinct and to provide recovery initiatives for endangered species but also to prevent species of special concern from becoming more critically at risk. It is essential that the federal government recognize the need to address the threats to these species before their populations become increasingly at risk. 2) Based on what you have learned about the Species at Risk Act, do you think adding narwhals to the SARA List would affect your activities? b) If Yes, do you see these effects as a cost or benefit to you, and in what way? c) If you think adding narwhals to the SARA list will have a negative effect on you or your activities, can you suggest ways to reduce the impact? 3) Do you think you could contribute to the conservation of narwhals as an individual or organization? Can you give a few examples of activities? 2

3 4) To be effective, the recovery or conservation of a species at risk must be a cooperative process that includes organizations and individuals with knowledge of the population and the threats it faces. Please tell us which organizations or individuals you feel should be involved in the recovery or conservation of narwhals? The collaborative effort to implement protection and recovery strategies must ensure that all interested and affected parties are given the opportunity to comment on and provide input towards the recovery plans. In this regard, SCC wishes to encourage the DFO to include not only those stakeholders whose activities may be negatively affected but all interested parties including First Nation and Inuit communities, environmental groups, and the general public, whose input must be regarded as equally important. 5) Please add any other comments or concerns (include additional sheets, if necessary). Sierra Club of Canada is concerned that this workbook does not adequately seek to determine the opinions of those in favour of the listing of this species who may not be directly impacted or associated with resource-based activities that may be affected. SCC would like to emphasize that the crisis in the decline of species in Canada has resulted from placing socio-economic interests above the preservation of biodiversity and ecological integrity. According to the Canadian Biodiversity Strategy, which is responsible for the creation of SARA, biodiversity supports human societies ecologically, economically, culturally and spiritually. Although the implementation of recovery plans may have immediate socio-economic impacts, there are important long-term benefits to society from the protection and recovery of species, which must not be ignored. These include not only the recovery of the narwhal but the protection of critical marine habitat and the regulation of ecologically damaging activities which can help to maintain the health and biodiversity of marine ecosystems in the Canadian Arctic and the ecological services they provide. Although recovery plans may meet with some opposition due to regulatory measures imposed on commercial fishing, hunting, tourism, etc., this must not be used as an excuse to reject the body of scientific evidence that led to the recommendation of the addition of this species to Schedule 1. The decision not to list the narwhal would not only deny this species the mandatory implementation of a management plan to ensure its survival but also deny the rest of Canadians and co-existing species the long-term benefits from measures implemented to protect this species and its ecosystem. It is essential that the DFO act impartially in conducting these consultations so as not to place the economic losses of stakeholders over the importance of species conservation and the input from parties that are not directly affected resource-based sectors. Sierra Club of Canada therefore urges the DFO to recommend that the Minister of the Environment list the narwhal as special concern under SARA. Refusal to add this species to the list of species at risk under SARA is a violation of the original spirit of the Act and furthermore a complete abdication of the federal government s responsibility to Canadian citizens and species at risk. 3

4 Bowhead Questionnaire Bowhead whale population of interest: Sierra Club of Canada is submitting comments on both the Hudson Bay-Foxe Basin population and the Davis Strait-Baffin Bay population of bowhead whales. What is your interest in bowhead whales? (for example: fishing/hunting as a food source, tourism, guiding, research, inherent value, etc.) Sierra Club of Canada is concerned about the future of both the Hudson Bay-Foxe Basin population and the Davis Strait-Baffin Bay population of bowhead whales and in support of the preservation of biodiversity and protection of species at risk under the Species at Risk Act (SARA). These comments are therefore being submitted to urge Fisheries and Oceans Canada to recommend that the Minister of the Environment list both of these populations of bowhead whales as threatened under SARA in accordance with the COSEWIC status report released by the scientific community. 1) Are you in favour of the Government of Canada adding bowhead whales to the SARA list? Yes. Why? According to the 2005 COSEWIC status report, both of these populations were severely decimated by commercial whaling in the 19 th and early 20 th century. Due to the cessation of commercial whaling the populations have recovered to some extent but remain small and vulnerable. COSEWIC notes that the Hudson Bay-Foxe Basin population may consist of as few as 300 mature individuals. The threats to these two populations, accor ding to COSEWIC, include illegal hunting as well as direct and indirect effects of climate change, particularly increased predation by killer whales due to a reduction in ice coverage. Predation by killer whales is noted as possibly the greatest threat to bowheads in the eastern Canadian Arctic and an especially significant threat to the Hudson Bay-Foxe population. Another threat that is noted is from potential oil and gas developments. The significance of the bowhead whale extends beyond biological significance to cultural, historical and socio-economic significance. The bowhead whale is intimately linked to the survival and cultural practices of Inuit in the Canadian Arctic. COSEWIC also notes that the bowhead whale has the potential to be a renewable subsistence and aesthetic resource. This species is not only extremely important to communities in Canada s Artic but is a species that commands global attention and is arguably important to all Canadians despite the fact that many may not rely on this species directly or ever see it. The on-going global struggle to protect whales is testament to the significance of these mammals. The bowhead whale is a well-known species from the Family Balaenidae and is listed as endangered worldwide. Given the 4

5 significance of this species and the vulnerability of the two eastern populations, the federal government must act to ensure that successful recovery of the bowhead whale occurs by adding these populations to Schedule 1. 2) Based on what you have learned about the Species at Risk Act, do you think adding bowhead whales to the SARA List would affect your activities? b) If Yes, do you see these effects as a cost or benefit to you, and in what way? c) If you think adding bowhead whales to the SARA list will have a negative effect on you or your activities, can you suggest ways to reduce the impact? 3) Do you think you could contribute to the conservation of bowhead whales as an individual or organization? Can you give a few examples of activities? 4) To be effective, the recovery or conservation of a species at risk must be a cooperative process that includes organizations and individuals with knowledge of the population and the threats it faces. Please tell us which organizations or individuals you feel should be involved in the recovery or conservation of bowhead whales? The collaborative effort to implement protection and recovery strategies must ensure that all interested and affected parties are given the opportunity to comment on and provide input towards recovery plans. In this regard, SCC wishes to encourage the DFO to include not only those stakeholders whose activities may be negatively affected but all interested parties including First Nation and Inuit communities, environmental groups, and the general public, whose input must be regarded as equally important. 5) Please add any other comments or concerns (include additional sheets, if necessary). Sierra Club of Canada is concerned that this workbook does not adequately seek to determine the opinions of those in favour of the listing of this species who may not be directly impacted or associated with resource-based activities that may be affected. SCC would like to emphasize that the crisis in the decline of species in Canada has resulted from placing socio-economic interests above the preservation of biodiversity and ecological integrity. According to the 5

6 Canadian Biodiversity Strategy, which is responsible for the creation of SARA, biodiversity supports human societies ecologically, economically, culturally and spiritually. While some sectors may experience immediate socio-economic impacts after a species is added to Schedule 1 and prohibitions are enforced, it must be recognized that society at large benefits from the protection and recovery of species that SARA aims to achieve. Further, this workbook limits the scope of accounting, taking into consideration only short-term socio-economic impacts and not considering long-term societal and ecological benefits. For example, there would be long-term economic benefits ensuing not only from the recovery of bowhead whales but from the protection of critical habitat and the regulation of ecologically damaging activities that can help to maintain the health and biodiversity of marine ecosystems in the Canadian Arctic and the ecological services they provide. The addition of this species to Schedule 1 will likely result in regulations and restrictions on certain activities such as hunting and oil and gas development, and will inevitably meet with some opposition. This opposition, however, must not be used as an excuse to reject the body of scientific evidence that led to the recommendation of the addition of the bowhead whale to Schedule 1. Furthermore, consultation with Inuit communities in the Canadian Arctic must occur during the development of management plans for the two eastern populations of bowhead whales so that the needs of these communities may be met within the constraints of the recovery strategies developed. The decision not to list these two populations would not only deny this species the habitat protection measures necessary to its survival but also deny the rest of Canadians and co-existing species the long-term benefits from the protection of its ecosystem. It is essential that the DFO act impartially in conducting these consultations so as not to place the economic losses of industry over the importance of species conservation and the input from parties that are not directly affected resource-based sectors. Sierra Club of Canada therefore urges the DFO to recommend that the Minister of the Environment list the Hudson Bay-Foxe Basin population and the Davis Strait-Baffin Bay population of bowhead whales as threatened under SARA. Refusal to add this species to the list of species at risk under SARA is a violation of the original spirit of the Act and furthermore a complete abdication of the federal government s responsibility to Canadian citizens and species at risk. Signed: Rachel Plotkin Director, National Forests and Biodiversity Program 6

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