Letters

Hydro Project Approval Threatens Steelhead and Salmon Habitat

The habitat for the steelhead rainbow trout, is under threat due to plans by a private power project to divert the Kokish River into a pipe. For the first time, the B.C. government has approved a run-ofriver power project that diverts water from salmon or steelhead habitat. It means that no wild river in B.C. is safe from diversion and industrialization, regardless of its value to fish and wildlife.

The Kokish River is a small, wild stream on northern Vancouver Island. It cascades from Ida Lake through a steep white-water canyon to the ocean at Beaver Cove near Port McNeill.

This 10-kilometre long stream is home to a rare population of wild summer-run steelhead - seagoing rainbow trout that migrate to the ocean at a young age and return to their river as salmon-sized adults one to three years later.

Summer-run steelhead are usually found in streams that are so steep and fast that cold-blooded fish can't ascend them in the winter because the water is too cold to allow for the necessary high leaps. Only three streams on the east coast of Vancouver Island still have reasonably healthy runs of wild summer-run steelhead, highly prized by anglers and an important contributor to the local tourism economy.

The private power project approved by the province would divert much of the Kokish River into a pipe three metres in diameter and nine kilometres long. The entire length of the diversion is important rearing, spawning and migration habitat for summer-run steelhead, other trout, char and salmon.

The project also involves construction of a diversion weir, water intake, and fish ladder just downstream of Ida Lake and a power house, switchyard, tailrace and half a kilometre of transmission line a short distance upstream of Beaver Cove.

If the project proceeds, we anticipate at least three major, ongoing fisheries habitat impacts:
 

         - The amount and quality of fish habitat will be severely reduced as a

            result of decreased stream flow.

 

         - Adult fish migrating upstream will be blocked or delayed at the both

            the upstream water intake and the downstream tailrace, as well as in

            the reduced-flow diversion reach.

 

         - Juvenile fish migrating downstream will encounter entrainment, blockage

            or delay when migrating downstream by the water intake, and further

            delay in the reduced-flow diversion reach.


These impacts would be very difficult and perhaps impossible to successfully mitigate. If you take large amounts of water out of an already small stream and create additional migration barriers, it's not going to be good news for fish, despite anything the Environmental Assessment Office may tell you.

The Capilano and Seymour Rivers in North Vancouver were once world famous for their summer-run steelhead. Water is extracted from these streams to supply domestic water for Metro Vancouver. Despite millions of dollars spent on habitat and hatchery enhancement over several decades, Capilano and Seymour summer-run steelhead are close to extinction. The lesson is that protecting habitat is the only certain way to protect salmon and steelhead.

With the province approving, for the first time, a project that diverts water directly from salmon or steelhead habitat, the stakes are now very high. We used to think that run-of-river power would only be approved in rivers with no or minimal fish values.

If the Kokish is not off-limits to power production, then no river in B.C. is safe. The provincial government would like us to view this as "green power." It's hard to understand how
compromising a very valuable and unique fish habitat can be considered green or sustainable. Twenty years ago, no one would have predicted that today B.C. would have more run-of-river power projects than it has summer steelhead streams.

In our quest for more power, do we really need to put the Kokish into a pipe? Let's remember that once they're gone, wild fish and wild rivers are gone forever.

 

By Poul Bech, Vancouver Sun December 17, 2011

Poul Bech is a director of the Steelhead Society of B.C. and vice-president of the B.C. Federation of Fly Fishers. Now retired, he was a B.C Fisheries branch technician working with Steelhead from 1979 to 1997. In 2010, he was the recipient of the Cal Woods Memorial Conservation Award.

 

 

Letter to DFO Farlinger re Johstone Strait Commercial Chum Fisheries

September 26th, 2011
 
Ms. Sue Farlinger
Regional Director General
Fisheries and Oceans Canada
Suite 200 – 401 Burrard Street
Vancouver, B.C. V6C 3S4
(by email)
 
Dear Ms. Farlinger,
 
Re: Announcement of Johnstone Strait Derby Chum Openings
 
Dear Ms. Farlinger,
 
The Steelhead Society of B.C. (SSBC) is very alarmed at the recent announcement by Greg Hornby, DFO Resource Manager, Campbell River, of the derby style commercial chum openings for Johnstone Straight in this coming week.
As you arelikely aware, these mixed stock commercial chum fisheries can have a devastating effect on Interior B.C. Fraser River fall-run steelhead stocks which co-migrate with Fraser River bound chum salmon.
 
Evidence of the detrimental impact these Johnstone Strait fisheries represent can be found in Bison 2011 (abstract) which states that: “With the closure of the Thompson sport fishery, all of the material fishing mortality on Thompson steelhead during the 2010 fishing season remains in the form of by-catch mortality in salmon directed purse seine and gillnet fisheries. The dominant factor influencing the overall fishing mortality rate index was diversion rate. This result is consistent with relatively low levels of chum fishing effort in the US fishing areas along the southern migration route in comparison to effort levels along the Johnston Strait migration route.”

 

Further, Bison 2011 (p.2) indicates thatSome southern BC and Washington State salmon fisheries are known to intercept Thompson steelhead (Anonymous 1998). These fisheries are gillnet and purse seine fisheries and in most cases, these fisheries target chum salmon. The potential fishing mortality resulting from the combined effect of these fisheries can far exceed thatwhich is administered by catch and release sport fishing (Anonymous 1998).” 
  
For the past three of four years the Thompson River steelhead sport fishery has remained closed due to extreme low returns of steelhead, last year an estimated 500 steelhead, the lowest on record. These closures, tied to the Integrated Fisheries Management Plan, have had a devastating effect on local Interior B.C. economies and are effectively removing a once-vibrant, internationally significant sport fishery from public memory.
Given the preceding, and with the knowledge that legally, derby style commercial fisheries must be opened to all commercial gear types, the SSBC is left with few options but to strongly recommend that the announcements of the Johnstone Strait chum fisheries scheduled for this coming week immediately be rescinded and, further, that these derby style fisheries remain closed. For your department to do any less makes a mockery of Canada’s commitment to the Wild Salmon Policy.
 
A viable alternativeto the proposed mixed stock non-selective Johnstone Strait chum fishery would be a terminal fishery that utilizes demonstrated selective harvest techniques such as beach seines or carefully monitored small-meshed tangle tooth nets.
 
Yours truly,
Greg Gordon (for)
Brian Braidwood
President        
  
c.c. by email
Honourable Keith Ashfield, Minister of Fisheries and Oceans <Min@dfo-mpo.gc.ca>
Honourable Steve Thomson, Minister B.C. FLNRO FLNR.Minister@gov.bc.ca
Honourable Terry Lake BC Minister of Environment ENV.minister@gov.bc.ca
Ms. Rebecca Reid, DFO Regional Director <rebecca.reid@dfo-mpo.gc.ca>
Mr. Don Radford, DFO Area Director South Coast <don.radford@dfo-mpo.gc.ca>
Mr. Greg Hornby, DFO Resource Manager Campbell River <greg.hornby@dfo-mpo.gc.ca>
Mr. Barry Rosenberger, DFO Area Director BC Interior <barry.rosenberger@dfo-mpo.gc.ca>
Ms. Jody Shimkus, Assistant Deputy Minister BC FLNRO < Jody.Shimkus@gov.bc.ca>
Mr. Andrew Wilson Manager Fisheries Management MFLNRO <Andrew.Wilson@gov.bc.ca>
Mr. Colin Masson, DFO Marine Conservation Caucus salmon committee <MassonC@pac.dfo-mpo.gc.ca>
Mr. Mark Saunders, DFO Marine Conservation Caucus salmon committee <SaundersM@pac.dfo-mpo.gc.ca>
Dr. Craig Orr, Watershed Watch Salmon Society <wwss@telus.net>
Mr. Rob Bison, Fisheries Stock Assessment Biologist B.C. FLNRO <Robert.Bison@gov.bc.ca>
Mr. Steve Mathews, Fish and Wildlife Section Head B.C. FLNRO <Steve.Matthews@gov.bc.ca>
Mr. Rod Clapton, President BC Federation of Drift Fishers <rodney.a.clapton@sunlife.com>
Mr. Perry Wilson, President BCFFF <pwilson@northlandfly.com>
Mr. Jon Pew, Inland Fisheries Chair BCWF jpew@telus.net
Mr. Stephen Rice Spences Bridge steverice53@msn.com
Mr. Mark Hume, Globe and Mail  <mhume@globeandmail.com>
Mr. Robert Koopmans, Kamloops Daily News <rkoopmans@kamloopsnews.ca>

Mr. Scott Simpson, Vancouver Sun <SSimpson@vancouversun.com>     

Letter to Ms. Sue Farlinger, Regional Director General - Fisheries and Oceans Canada

June 30, 2011

Ms. Sue Farlinger
Regional Director General
Fisheries and Oceans Canada
Suite 200 – 401 Burrard Street
Vancouver, B.C. V6C 3S4
(by email and Royal Mail)

Dear Ms. Farlinger,

Re: May 10/11 Shimkus letter to Farlinger reference 176204 (attached)

In reference to the letter above, the Steelhead Society of BC (SSBC or Society) appreciates that, in
accordance with the Marine Stewardship Council (MSC) certification process, the Province of B.C.
and your department appears to be examining ways of further reducing or eliminating incidental
interception of Fraser and Skeena bound steelhead in non selective market fisheries.

The Society also appreciates the efforts your department has undertaken in the past to minimize the
impact of commercial fisheries upon steelhead populations through time and area closures and other
initiatives.

Given the perilous status of fall-run Fraser River steelhead stocks, however, the SSBC remains vitally
concerned that such measures may not be adequate. Therefore, the Society is in agreement with
the province that additional restrictions are warranted on commercial fisheries that may have an
impact upon commingling steelhead stocks. Further, in the SSBC’s opinion, such restrictions must be
undertaken irrespective of the MSC process and on a much broader scale to adequately protect other
vulnerable fish stocks like Dean River steelhead.

The SSBC is also in agreement with the province about the use of selective live harvesting in those
salmon fisheries where incidental interception of steelhead stocks is problematic. Through the more
pragmatic and timely implementation of selective live harvesting methodologies, market opportunity is
maintained, upstream economic activity is maximized, while identifiable non-target fish stocks, such as
steelhead, are preserved.

The Society also shares the concerns of the province regarding the notion that gillnets, through the
use of the “short net, short set” practise, can be truly effective as a selective live-harvest methodology
given the poor survival rates of gill net released fish, the current paucity of effective enforcement and
monitoring and the likelihood of diminishing resources towards that end in the future.

You may be aware that the Society has long been an advocate of selective live-harvest in Pacific salmon
fisheries. To that end, in 1995, the SSBC published the booklet “Going backward to go forward: why
selective live harvesting is vital to the survival of Pacific salmon” (an e-version can be found at http:/
/issuu.com/going-backward/docs/going_backward). This document, and the harvest methodologies
described therein, remains relevant today, perhaps more so, as some steelhead stocks appear to
dwindle towards extirpation.

As was the case in 1995, once again, the Society maintains that the implementation of selective live
harvest methodologies in the Pacific salmon fishery are necessary not only to preserve Fraser and
Skeena steelhead to meet MSC certification requirements but, additionally, wherever the interception
of weak fish stocks is problematic.


Lastly, the SSBC is in agreement with the Province of B.C. that the time to act is now and that, given the
inconsistencies of accurate catch reporting in all salmon fisheries, current exploitation rate objectives do
not serve steelhead populations well.

The Society appreciates the opportunity to provide you input and looks forward to your earliest
response to both this letter and this dire situation.

Yours truly,
<Greg Gordon for>
Brian Braidwood,
President

Enclosure: 176204 Farlinger.pdf

c.c. Minister Steve Thomson, BC Forests, Lands, and Natural Resource Operations <email>
Ms. Jody Shimkus, ADM BC Forests, Lands and Natural Resource Operations <email>
Mr. Colin Masson, DFO Marine Conservation Caucus salmon committee <email>
Mr. Don Radford, DFO Marine Conservation Caucus salmon committee <email>
Mr. Mark Saunders, DFO Marine Conservation Caucus salmon committee <email>

Northern Branch Letter to DFO's Sue Farlinger

Rob Browns letter via Jessea Grice to DFO

Steelhead Society of British Columbia - Northern Branch
P.O. Box# 126
Telkwa B.C.
Canada
V0J 2X0

Sue Farlinger
Regional Director General
Fisheries and Oceans Canada
Suite 200 - 401 Burrard Street
Vancouver B.C.
Canada
V6C 3S4

Dear Ms. Farlinger:

The letter of 10 May 2011 from the Assistant Deputy Minister
for the Coast Area, Jody Shimkus, to you, has been circulated and
discussed by the members of the Northern Branch of the Steelhead
Society of B.C.

As long time advocates for steelhead, we are pleased to see
that the Ministry of the Environment and Fisheries and Oceans
Canada appear to be giving greater attention to the plight of our
province’s steelhead stocks.

While we endorse ADM Shimkus’ recommendations and see
their adoption as significant step toward alleviating some of the many
problems that face our wild steelhead stocks, we feel that her
suggestions do not go far enough to address the crisis our steelhead
face.

We have the luxury of being unencumbered by
intergovernmental protocols. Our concern moves us to speak clearly
and directly. Our forthrightness grows out of decades of frustration
over the federal government’s unwillingness to embrace obvious
solutions that would have (and still can) stave off the extirpation of
steelhead. Please don’t take this directness as confrontational but
rather as a reflection of our appreciation of the urgent need to protect
what remains of our steelhead stocks.

We believe that the welfare of all Pacific Salmon is inextricably
linked to the health of its most fragile stock. We understood this and
adopted it as our fundamental operating principle long before Gro
Brundtland’s Commission went public with the concept of biodiversity,
and years before the idea became the scientific consensus. Since
biodiversity is now axiomatic, the endangerment of Thompson River
steelhead must be seen as a symptom of a sickness affecting all
Fraser salmon.

The extinction of a race of fish demands drastic action. In the
case of Thompson Steelhead, modifying the gillnet fisheries is not
enough. They must cease. Gill nets are a relic of a bygone age. That
they are still tolerated in Canada is our shame. The First Nations
along the Fraser River did not use gill nets traditionally. They must
revert to traditional methods.

The misuse of water and land adjacent to the Thompson and its
effect on the tributary streams so vital to the well being of salmonids
is well known. As stewards of the salmon, your department has to
start dealing with the assault on fisheries habitat in that area
vigorously.

We don’t agree with ADM Shimkus’ assertion that the issues
surrounding the management of Skeena steelhead are “not currently
driven by a conservation concern.” The minimum escapement figures
suggested by the Pacific Salmon Assessment and Review
Committee (PSARC) in their report many years ago are questionable
since the methodology used by the scientists on the committee was
not rigorous enough. A much better way to assess the historic
abundance of steelhead on the Skeena system is to examine the
historic catch figures generated by the commercial fishery throughout

the twentieth century. Doing this suggests that steelhead, like all
species of Skeena salmon, were far more abundant then than they
are now. The fact that these fish, like chum salmon and races of
sockeye other than the enhanced Babine stocks, were exposed to
harvest rates set to maximize the killing of artificially enhanced
sockeye stocks of Fulton and Pinkut sockeye for over a century
suggests that their numbers must be considerably reduced.

The forest mining euphemistically know as logging in this
province has compromised many Skeena streams. In the first half of
the last century, spawning streams were mined for gravel to build
roads. Other salmon bearing streams had roadbeds laid through
them. Hundreds had their riparian vegetation stripped. To pretend
that this violence done to fish habitat did not have an adverse effect
on steelhead is naïve.

Though they are not as extensive as those in the lower
mainland, urban development and agricultural development have
also had a deleterious effect on Skeena’s salmon.

Exacerbating all these crippling factors is climate change. Over
the last 40 years the retreat of glaciers has affected flow regimes and
water temperature on our streams. The problem can only get worse,
and would continue to worsen, according to the climatologists, even if
carbon emissions were halted tomorrow. The precautionary principle
suggests that the more steelhead there are, the better their chance of
species’ survival.

The Skeena gill net fishery is wasteful. A gillnet can’t be fished
selectively. Tangle tooth nets can, as has been demonstrated by
former gillnet fishers Fred and Linda Hawkshaw on the Skeena and
Mark Petrunia on the Fraser. Fisheries and Oceans Canada could
have encouraged – even mandated – the use of those selective nets.
Instead they encouraged the adoption of preposterous measures like
holding boxes, shorter gill nets, short set times, and weed lines,
which were little more than cosmetic measures that did nothing to
meaningfully address the interception on non target species.

If the Department of Fisheries and Oceans actually wanted to
address the problem of by-catch, they would have striven to gather

robust data on the number of steelhead intercepted in the net
fisheries. This data could have been gathered using surveillance
cameras and by having fisheries officers board boats to ascertain
how many steelhead had been caught or by having monitors aboard
boat as a condition of license. Instead of these measures DFO relied
upon hail figures: data gathered by fisheries officers who powered up
next to boats and politely asked skippers, whose profits could be
affected by disclosing the number of steelhead they caught, how
many steelhead they had on board. It is our understanding that this
hail data can now be phoned in by the fishermen. You can appreciate
why we have no confidence in data gathered this way.

The DFO staff could have had personnel in the canneries to
look for steelhead brought there. The Ministry of the Environment
hired J.O. Thomas and Associates to do this. The contractor’s reports
(a matter of public record) state that they witnessed totes of
steelhead moving through these facilities unreported.

The gill net fishery is unsustainable and would not have
survived this long had the taxpayer not subsidized it. We don’t mind
tax subsidies that create employment, but paying people to use an
antiquated and ecologically harmful technology to deplete a common
property resource is unconscionable.

Chasing salmon in the sea with a boat, as seiners and trollers
do, is illogical and wasteful. The former can be tolerated only so long
as they act responsibly by bringing their nets alongside their boats
and brailing non target species before closing their nets and hauling
the catch on board then spilling the contents of bag onto the deck.

Gillnetting, seining, and trolling are all inefficient wasteful ways
to fish when the catch could be caught in the river by employing
beach seines, fish wheels, traps, and dip nets. These fishing
methods are easier to police, provide better escapement data, and
are selective. First Nations employed them for ages before
Europeans arrived and reported staggering salmon abundance.
Despite the efficacy of these fishing methods, your department has
only reluctantly allowed them, and then only after we brought
international attention to the issue.

It’s clear that the dying gill net fishery has to cease. It’s also
clear that the other components of the salt water salmon fishery need
to be put on notice that they will be greatly curtailed and eventually
phased out while FOC does its utmost to go back to the future by
encouraging the in river fishing techniques mentioned above.

Your department has long been an enabler for commercial
fishing interests to the detriment of the stocks federal law insists they
must protect. The way they have treated steelhead in Skeena
underscored their failure to execute their mandate. We think it’s
scandalous.

We don’t need band-aid solutions. We need a massive
reorganization of you branch of the civil service and a paradigm shift
in fisheries management. You have the blue print for such change.
It’s called the Wild Salmon Policy.

Sincerely,

Jessea Grice
Chairperson
Steelhead Society of British Columbia - Northern Branch

Letter to Premier Clark Regarding the Kokish River Hydroelectric Project

Dear Premier Clark

Re: Kokish River Hydroelectric Project

The Kokish River is a small stream on northern Vancouver Island with extremely high fisheries and biodiversity values. The Kokish contains a rare population of wild summer-run steelhead (as opposed to the more common winter-run steelhead). Only two other streams on the east coast of Vancouver Island still have reasonably healthy runs of wild summer-run steelhead. Summer-run steelhead are highly prized by sport anglers and the Kokish fishery is an important contributor to the local tourism economy.

The mainstem Kokish River is only about ten kilometres in length. Brookfield Renewable Power proposes to divert the majority of the stream flow into nine kilometres of pipe in order to produce “run of the river” electricity.  The entire length of the proposed diversion reach is important rearing, spawning and migration habitat for summer-run steelhead and other anadromous trout, char and salmon.

If the project proceeds, we anticipate at least three major, ongoing fisheries habitat impacts:

  • 1. The amount and quality of fish habitat in the diversion reach will be severely reduced  as a result of decreased stream flow;
  • 2. Blockage or delay of adult fish migrating upstream at the both the upstream water intake and the downstream tailrace, as well as in the reduced-flow diversion reach; and
  • 3. Entrainment, blockage or delay of juvenile fish migrating downstream by the water intake, and further delay in the reduced-flow diversion reach.


The Steelhead Society does not believe these impacts can be sufficiently mitigated with any degree of certainty.   In terms of potential anadromous fisheries impacts, the Kokish proposal may be the worst example of an existing or proposed small hydro project in British Columbia. This is not “green power” as any perceived carbon reduction values cannot possibly outweigh the destruction of this very valuable and unique fish habitat. This proposal reflects poorly on all hydro power projects.

Premier Clark, in order to save Kokish River steelhead, we ask you to halt the proposed Kokish Hydroelectric Project. We look forward to your response.

Sincerely,

original signed by

Brian Braidwood
President,
Steelhead Society of BC

Cc  (by electronic mail only)

Terry Lake, Minister of Environment
Steve Thompson, Minister of Forests, Lands & Natural Resource Operations
Claire Trevena, MLA North Island
Adrian Dix, MLA
Mike Farnworth, MLA
John Horgan, MLA
Gail Shea, Minister of Fisheries and Oceans     
John Duncan, MP
Finn Donnelly, MP    
and wide distribution in the fisheries conservation and environmental community

Letter to the Environmental Assessment office regarding the Garibaldi project

July 17, 2009

Submitted by electronic mail

Graeme McLaren, Projects Assessment Director

Environmental Assessment Office

PO Box 9426, Stn Prov Govt.

Victoria, B.C. V8W 9V1

Re Proposed Garibaldi at Squamish Project (2006)

Dear Sir

The following is the submission of the Steelhead Society of British Columbia regarding this matter.

We urge the Environmental Assessment Office to not issue a certificate to the project proponent because the project, as currently described, will almost certainly have significant and permanent impacts on steelhead habitat in Brohm Creek.

Brohm Creek is a uniquely productive steelhead stream because of unusually high levels of naturally occurring phosphorous, and is therefore capable of producing 3 to 5 times as many steelhead as other streams of similar size. It is the major steelhead spawning tributary of the Cheakamus River, which in turn is the most important spawning tributary of the Squamish River.

The uniquely productive water chemistry in Brohm Creek also makes the stream exceptionally fragile and susceptible to pollution impacts.

The Garibaldi Project threatens Brohm in at least three ways:

o Removal of water resulting in lower stream flows and changes to Brohm’s hydrograph;
o Changes in water chemistry; and
o Physical changes to aquatic and riparian fish habitat.

Development in headwater areas has the highest opportunity to influence the overall aquatic ecosystem supported by the drainage. Headwater habitat largely defines the water quality and chemical composition of the stream water. Headwater health also plays an important role in food and nutrient contribution and debris flow. Whatever changes occur in the headwater areas can be expected to affect the entire watercourse downstream and all its inhabitants. There are too many examples involving poor forest practices that make this point very clear considering the damage done to many small streams over a very short period of time as a result of logging in headwater areas.

This proposed development is positioned over the entire headwaters of Brohm Creek. There will be road, trails, golf course fairways, ski hill runs all crossing Brohm Creek over and over again. Essentially, the headwaters of this creek will become semi-urbanized overnight. While the project EA states that the development will only result in approximately 6% impervious surface, there are still likely to be impacts such as:

* Altered hydrograph due to stormwater contributions;
* Elevated nutrient levels and changes to water chemistry as a result of golf course fertilizer and runoff water;
* Elevated temperatures as a result of insolation occurring in exposed channels and pond discharge and runoff from water surface (i.e., roads)
* Elevated sediment loads as a result of development and operation. A casual attitude to erosion and sediment control during the development phase alone could render Brohm Creek sterile for many years, if not permanently. We did not see this issue addressed anywhere. High sediment loads over a prolonged period of time are insidious. Even with the best ESC management, there will still be sedimentation impacts and considering the massive scope of the proposed development, likely a lot of sedimentation will occur.

Brohm Creek is too small, too sensitive and much too valuable to use as a domestic water supply for this project. The Steelhead Society has concerns that the methodology used by the proponent to determine water supply was inappropriate in this case. We assert that the outstanding issues regarding surface water withdrawal should not be deferred to a post- Environmental Assessment Certificate stage as these issues are difficult and potentially without remedy. In addition, the domestic water requirements of the development may be significantly underestimated.

It has been noted that there is only one Brohm Creek and that there is a conservation concern for steelhead in this watershed and elsewhere in southern BC. On the other hand there is no shortage of golf courses or ski hills in the Squamish area. Why would we take the chance that this development could irreparably damage the function of this extremely important stream?

Discharge of treated sewage into the Cheakamus River is proposed. Accidents happen. All we need is another spill in the Cheakamus. The EA document did not address the potential for accidental releases of deleterious substances.

We recommend that the proponent modify the development proposal as follows:

1. Find an alternative source of water so no water is directly or indirectly removed from Brohm Creek;
2. Reduce the amount of impervious surface in the headwater development, and take additional steps to minimize headwater development impacts on Brohm’s hydrograph and water chemistry; and
3. Delete the proposed golf course development from the lower Brohm valley.

We further recommend designation of the lower Brohm watershed downstream of Brohm Lake as a park or other protected area in order to preserve these unique steelhead values in perpetuity.

Please publish this submission on your website.

All of which is respectfully submitted,

Poul Bech, Ralf Kroning and Trevor Welton

Directors,

Steelhead Society of BC