I think that the government…

I think that the government response statement outlines a good path forward for research and planning regarding long-term action, but it fails to call for sufficient short-term actions. There needs to be some revisions to some of the Actions reflect this.

  Action 7 requires specific and immediate reductions in the mortality of adult eels as they migrate through hydropower facilities. We risk managing to zero. What I mean by this is that with no short term plans to mitigate further harm in terms of population decline and with a strong focus on continually monitoring the population, the eel population may decline to such low numbers that it is no longer even feasible to recover. The research is pretty clear that hydropower facilities have impacted American eel populations through mortality from turbine passage. Some provisions for hydropower operations to reduce mortality/injury would contirbute to reductions in adult eel populations.

  Eels grow in the lakes and river systems upstream of the St. Lawrence/Lake Ontario system, and these eels are important in the population (these eels are often larger and highly fecund). Thus, there should be revisions to Action 8 to require immediate provision of upstream passage (e.g., eel ladders) for juvenile eels at barriers in the lower reaches of rivers in Ontario (including the Carillon Generating Facility at the base of the Ottawa River). It will also be essential to test the efficacy of these eel ladders, assessing that they  are in fact increasing passage efficiency of juvenile eels migrating upstream in the affected Ontario waters.

  Eels require migration to upstream areas in watersheds within their home range to live and grow larger, important parts of their life cycle. Given the impacts of hydropower facilities on eel migration, there should be revisions to Action 9. Under Action 9, I think that the government response should commit to reviewing hydropower mitigation plans for American Eel, and require revisions or revoking exemptions when hydropower producers fail to take reasonable steps to reduce the adverse effects of hydropower facilities on the eels.

[Original Comment ID: 211887]