The Ontario Federation of…

The Ontario Federation of Anglers and Hunters (OFAH) is committed to the conservation and recovery of Ontario’s biodiversity, and as such, we are highly supportive of the recovery of American Eel. The completion of a Government Response Statement (GRS) has been long-awaited.  On behalf of the OFAH, its 100,000, members, subscribers and supporters, and 740 member clubs, we have reviewed the draft GRS and have the following comments.

  There is general support for many of the actions identified in the GRS. While we appreciate that six immediate actions have been identified as provincial priority, to be undertaken by 2020, we believe the actions that deal specifically with mitigating eel passage should be of highest priority as they are the most critical to ensuring recovery. We agree, for other actions to be effective, a strategic approach to mitigating eel passage must be implemented immediately. American Eel are a culturally important fish species in Ontario, particularly for many Indigenous communities.  Therefore, we support continued consultation and collaboration on American Eel recovery.

  We support the development and implementation of a strategic passage plan for American Eel on key watersheds. The recovery of American Eel in Ontario largely depends on effective mitigation of the ecological effects of hydroelectric facilities.  Passage should first be facilitated at hydro-electric facilities situated on major arterial waterways such as the St. Lawrence, Ottawa and Trent Rivers.  Mitigating anthropogenic mortality of eels should be prioritized in order to achieve natural increases in population levels.

  Promoting the natural expansion of American Eel into historic locations can only be achieved by providing effective fish passage. We agree this should be done immediately to introduce some resilience into the Ontario subpopulation.  The Recovery Strategy states it should be done strategically, not only including hydroelectric facilities located on the Ottawa River, Lake Ontario and the upper St. Lawrence River, but to restore  access to all tributaries of these major water systems.

  We appreciate that translocations are not being supported as a recovery tool until the results of the program can be fully evaluated. Introducing the species into additional areas beyond their historical range (i.e. either by translocation or by natural means) should not occur without full consideration of all the ecological and socio-economic impacts that may be associated with this action. However, in the interim, translocation of eels from below dams to above dams in Ontario would be acceptable and effective (assuming appropriate consultations and other planning processes have been carried out).

  The current level of harvest and export of eels (outside of Ontario), threatens any long-term recovery of the species. More than ever, there is a need for better coordination, particularly internationally.  We are pleased to see some high priority actions identified to engage other jurisdictions in developing and implementing inter-jurisdictional conservation, recovery and management strategies for American Eel in bi-national and inter-provincial boundary waters.

  As the Recovery Strategy notes, enhancing the recovery of Ontario eels will also benefit the global population of the species given that they are all female and the most fecund in their entire range. Ontario and many other jurisdictions (e.g., Quebec, the United States and Maritime Provinces) will benefit if eels are effectively recovered in Ontario.

  Understanding the cumulative effects associated with barriers to fish passage is essential for their recovery and there is support for policy direction and tools to evaluate and address these impacts as a priority. Given the history of hydroelectric development on rivers where fisheries values have not been adequately protected, protecting the migratory corridors are essential actions. While the GRS states there is “sufficient habitat” available for growth and maturation in Ontario the definition of “habitat” should also include spawning and breeding.  We would argue that efforts to manage and protect American Eel and its habitat through implementation of the Endangered Species Act have not been adequate to date.

  The Recovery Strategy recommends that planned mitigation of upstream and downstream passage be provided by hydroelectric facilities on all key watersheds. Existing mitigation plans under regulation – most of which were developed prior to a finalized Recovery Strategy do not include the provision for permanent safe upstream and downstream passage. How does that government plan to reconcile the difference in habitat protection?

  As many more facilities are proposed for future development within the historical and current range of eels we believe there must be stronger habitat provisions applied to ensure all new hydroelectric facilities on watersheds within the native range of eels are designed to allow effective passage.

  We appreciate the opportunity to review the draft GRS and we look forward to a rapid response and dedication of sufficient resources to implement these actions.

[Original Comment ID: 211524]