Benchmark Statement Respecting the Fish, Fish Habitat and Fisheries of Fish and Little Fish Lake, within the Taseko River Watershed. Information Supporting the Environmental Assessment of the Prosperity Mine Project (Taseko Mines Ltd.) Ministry of Environment Environmental Stewardship Division Cariboo Region August, 2008 1
1.0 Introduction The suite of possible impacts associated with potential mineral extraction in the Fish Lake area of the South Chilcotin sub-region (Taseko River watershed) has been the subject of natural resource inventory and assessment activities over the past two decades. There has been considerable reflection on the options for mine development, and upon the measures that might be applicable to eliminate, mitigate or compensate for the identified impacts. The area of the mine development, including the lakes and associated stream habitat, have been subject to intensive resource inventory and impact assessment work. The results of this work will be reported in an application for an environmental assessment certificate expected to be filed by Taseko Mines Ltd. in the fall of 2008. The loss of the lakes and associated stream habitat will impact rainbow trout and the habitat that supports this species. In addition, there may be intermittent fish habitat that is subject to seasonal water flows in the lower reach of the stream that drains Fish Lake into the Taseko River. The current mine development proposal would require the elimination of Fish and Little Fish Lakes and associated stream habitat for some of the time period that the mine is active. The proposal would replace lost lake and stream habitat while the mine is active, and would re-create lake habitat after the mine is closed. This document articulates the stewardship objectives of the Ministry of Environment (Cariboo Region) respecting the fish, fish habitat and fisheries of Fish and Little Fish Lakes. These objectives and associated statements establish the relative significance of the two lakes and their fisheries in the regional context. The statements may be considered as benchmarks for consideration of any mitigation and compensation measure that may be proposed to address the impacts to the fish, fish habitat and fisheries of the two water bodies. 2.0 Habitat and fish stock values This section provides a brief summary of what is known of fish and fish habitat in the lake and stream environments. A more fulsome characterisation and quantification of the habitat and fish stock is provided by reports and data summaries compiled through inventory and assessment works undertaken since the mid 1990 s. File information is held by the ministry, and by the consultants supporting Taseko Mines Ltd. environmental assessment initiatives. 2.1 Fish Lake and Little Fish Lake Fish Lake and Little Fish Lake provide a wild trout fishery in an area of land that is considered by some to be a remote part of the province. Both lakes have a higher than average productivity (TDS 130mg/l) and are capable of supporting a substantial standing crop of trout. The lakes currently are inhabited by high densities of rainbow trout (85,000 estimated for Fish Lake, approximately 700 fish/ha). 2
Fish populations inhabiting the lakes are monoculture rainbow trout, meaning they do not face ecological competition from other fish species. Monoculture populations are relatively rare in the region with less than twenty percent of the region s 600 lakes being rainbow trout monoculture. The Eleven Sisters chain of lakes, to the northeast of the project site, is the closest known monoculture rainbow trout system to the Fish Lake system. Genetic studies of the Fish Lake stock have not shown particular distinctive genetic variation as compared to wild stocks in other lakes of the sub-region. However, these findings do not mean the population is not of unique character, and adapted to their specific ecological surroundings. 2.2 Stream habitat Fish Lake and Little Fish Lake are connected together, and to the Taseko River, via an ephemeral stream called Fish Creek. Fish Creek has a lower section potentially accessible to fish moving upstream from the Taseko River, and an upper section bounded by a set of falls downstream of the lakes. The creek has an above average productivity (TDS 112 to 125 mg/l). 2.2.1 Below the falls to Taseko River The lower section of Fish Creek is of low fish habitat value. The stream habitat may also act as a juvenile sink attracting fry or yearlings and trapping them in pools as the creek dries each summer. The creek exhibits features of channel instability, and is subject to intermittent seasonal slows. The substrate is angular, unsorted, and the banks are unstable as the creek cuts across glacial-fluvial deposits. Fish presence in the lower reaches of the stream is probably a result of downstream migrants from habitat above the falls, or from the immigration of juvenile salmonids from the Taseko River. Spawning habitat for chinook, steelhead and other fishes is of very low value as stream flows are low, the channel is naturally unstable, and the bed material too angular to support significant spawning. 2.2.2 Above the falls to the lakes, and lake tributaries The stream habitat from the lakes downstream to the falls, is highly productive, fully functioning and intact. This section has stable habitat features with good spring flows, stable substrate, and ideal pool/riffle frequencies. The inlet streams and outlet reaches provide for adult spawning and are capable of rearing yearling rainbow trout depending on annual flow conditions. There are approximately 26,000 square meters of late summer stream habitat above the falls capable of producing 18,000+ one year rainbow trout or equivalents. In evaluating the habitat and lake populations it is clear there are sufficient flows and quantity and quality of habitat to provide sufficient natural stocking of the lakes. 3
3.0 Fish Lake and Little Fish Lake Recreational Values In contrast to the biological productivity of Fish Lake, the recreational potential of the resource is currently not being utilized to its full potential. Current angler use is between 200 and 400 angler days annually. Many lakes in the region support fisheries of between 5,000 and 15,000 angler days per year. Sheridan Lake alone supports more than 20,000 angler days in an average year. Fish and Little Fish Lake habitat is productive and fish densities are high which currently provide a high yield fishery for smaller rainbow trout. The average catch rate in Fish Lake it is over 20 fish per day for an average angler, while across the region the rate averages 2 fish per day. The average size of the fish is 26 cm (10 inches), which is small by regional standards for wild stock trout. The high catch rates on a wild stock in a wilderness setting provide a unique fishing experience well suited to families, consistent with initiatives to provide a range of recreational fishing opportunities across the region. The lake has the biological capacity to support a substantially more valuable fishery in the future (in terms of fish size and fishing effort), if decisions were made to apply management techniques specific to that outcome. Initiatives that are designed to compensate for the loss of the lake and fishery during the period of mine life, and to re-create the lakes and the fishery at mine closure, should consider that current recreational use is lower than what the lake could support with a focussed fishery management initiative. The ministry s preferred outcomes for the recreational fishery are set out in section 4.1 below. 4.0 Corporate goals and objectives The proposed project intersects the corporate goals of the Province of British Columbia, the goals and objectives of the Ministry of Environment, and elements of the ministry s Fisheries Program Plan. As stated in two of its five corporate goals, the Province of British Columbia will: Lead the world in sustainable environmental management, with the best air and water quality, and the best fisheries management, bar none. Create more jobs per capita than anywhere else in Canada. http://www.bcbudget.gov.bc.ca/2008/stplan/default.html#1 An application for an environmental assessment certificate should provide information specifically addressing the balance between these two goals. Goals set out by the Ministry of Environment service plan include: Healthy and diverse native species and ecosystems British Columbian s share responsibility for the environment Sustainable use of British Columbia s environmental resources. http://www.bcbudget.gov.bc.ca/2008/sp/env/default.html#2 4
Under these ministry goals are certain objectives against which the Prosperity project may be considered: Protected, maintained and restored native species and ecosystems Shared environmental stewardship is a priority for all British Columbians Industry and client groups implement best management practices Optimize public, outdoor and commercial opportunities for British Columbia s parks, fish and wildlife Within the Ministry of Environment, the aim of the Fisheries Program is a naturally rich and sustainable freshwater fish resource supporting uses for all British Columbians. Objectives of the Fisheries Program Plan that pertain to the Prosperity project are: Conserve wild fish and their habitats Optimise recreational opportunities based on the fishery resource http://www.env.gov.bc.ca/esd/ffpp_intro.html Options to reduce, mitigate, or compensate for impacts generated by this project should be crafted with express reference to these goals and objectives. These statements should be respected as some of government s primary considerations respecting the project. An application for an environmental assessment certificate will be evaluated relative to these statements. 4.1 Regional Objectives The Cariboo Region is developing a Small Lakes Management Strategy to guide assessment and development of economically viable small lakes fisheries for the region. The aims of this initiative are to: increase angler participation while ensuring the long term sustainability of wild stocks, promote stocked lake fisheries, provide a diversity of opportunities to ensure quality of experience for all anglers, evaluate and respond to angler preferences for stocked lake fisheries, rationalize our lake specific management plans and stocking programs to reflect angler preference and deliver reasonable return on investment, and simplify our fishery regulations. The regional small lakes management initiative has to date focused on those lakes in the region that are supporting, or are capable of supporting, fisheries that contribute substantively to the stability and diversity of the regional economy, and to opportunities for First Nations to undertake traditional fisheries. The fishery supported by Fish Lake provides only a small increment of regional economic benefit as compared to other regional lakes. However, there remains an inherent natural value in the fishery, which is often carried out by families, for the numerous small wild trout typical of these waters. Fish Nations make reference to trout fishing activities in these waters that provide resources to their communities. The character of this fishery has not yet been fully 5
documented, but it is known that such information is available within the Xeni Gwetin First Nation community. Consistent with the aims of the regional small lakes management initiative, the regional fisheries program considers that management initiatives for the Fish Lake and Little Fish Lake, and associated stream habitat should result in: maintenance of the genetic line exhibited in the trout population of the Fish Lake system, lake and stream environments of similar or better productive capacity for trout as provided by the Fish Lake system now, a healthy, self sustaining trout population, and a trout fishery for First Nations and the public of at least similar character to what is supported by Fish Lake under current conditions. The Ministry has been considering how to characterise the type of fishing experience that is to be delivered by compensation measures. Replacement or re-creation of lake habitat offers an opportunity to tailor management initiatives to deliver different types of fishing experiences for example, a large number of smaller trout for family fishing, as compared to small numbers of large trout for specialist anglers. The ministry would prefer that the re-created fishery provide for increased recreational activity that yields reasonable catch per unit of effort (6 to 10 per day) of fish ranging up to 1 kg. Information to be acquired from the public during the environmental assessment process will inform decisions on the character of the fishery in any replaced or re-created lake environment. Practicable consideration of these outcomes in light of mine development options would indicate that it is not appropriate, nor necessary, to require that the lake be maintained through the life of the mine. There should instead be a commitment to implement compensation measures, which would be effective in augmenting ministry fishery management initiatives, in order to provide enhanced First Nations and public fishing opportunity in small lakes of the Chilko/Taseko watershed. These measures would need to be effective for at least the period of time that either: the lake and fishery does not exist due to mining activities, or replacement habitat is not fully functional in delivery of a fishery. 5.0 Risk of impact and consequences respecting resources supported by Fish Lake The loss of the lake and stream environments for the period of mine operations is considered to be a serious issue. Dialogue with Taseko Mines Ltd. has assured ministry staff that this concern is shared, which will result in these matters being addressed in appropriate detail within the environmental assessment process. There are shared expectations that a practicable suite of mitigation and compensation measures can be developed and applied to deliver the outcomes preferred by the ministry s regional fisheries program. 6
Aside from the management of the lake and associated stream environments, the most substantive risk associated with the Prosperity proposal is the potential long term impact on water quality that may occur if there are discharges to the Taseko River watershed. The Taseko and Chilcotin watersheds are of provincial significance, providing habitat for a variety of anadromous salmonids (chinook, sockeye, and steelhead) and resident species (bull trout, rainbow trout, whitefish). Full consideration of the potential for discharges from the mine site and its operations, and the risk and consequences of any potential discharges on water quality over the long term, will be a critical focus point for the environmental assessment. 6.0 Considerations for Compensation Considering the biological and recreational values associated with the lake and stream habitats, mitigation and compensation measures are expected to specifically address the loss of these habitats and the fishery. Specific attention is expected to be applied to the aforementioned aims of the regional small lakes management program. As almost all the lake and stream habitat that is subject to development impacts is inhabited by nonanadromous salmonids (rainbow trout), the primary focus of mitigation and compensation initiatives should be these non-anadromous trout. Appropriate measures might include, but are not limited to: An initiative to preserve the genetic attributes of Fish Lake rainbow trout. While there is debate about how genetically unique the strain may be, there are sound biological and social reasons to maintain the lineage of the Fish Lake stock. Re-establishing lake and stream ecosystems to replace the Fish Lake complex. As preliminary discussions have revealed, the mine operational plan should unfold based on the vision of creating a lake in the area once occupied by Fish Lake. These works would be expected to include management of overburden for purposes of delivering aquatic and near-shore habitat complexity, contouring tailings to mimic natural littoral areas, water management initiatives, and specific reclamation works. A fund to support work with First Nations on non-anadromous fisheries projects including opportunities for food/ceremonial harvest and public recreation. There are several precedents where funds are held in trust for administration by a joint board for the purposes of undertaking fisheries projects within the scope of the fund s intent, including habitat restoration activities within the Taseko and Chilko watersheds. Increasing opportunities for First Nations food/ceremonial fisheries and recreational angling/camping opportunities in the Taseko and Chilko watersheds. Establishing measures to deliver water quality parameters consistent with reestablishing fish stocks and recreational use of the lake area, and ensuring any discharges to the Taseko watershed pose no risk to fish and fish habitat. 7