Clearly a Class EA is…

Clearly a Class EA is required for Pacific Salmon stocking in Lake Superior. To proceed with this stocking plan is akin to the definition of stupidity “repeating the same exercise expecting different results”. There is nothing of substance in this new plan to allow for a continued stocking program for Pacific Salmon to exist. The plan essentially has the same goal (to develop a self sustaining population in the Kaministiquia River) as the previous plans which to date (27 years) have demonstrated a laughable success (failure) rate of 1 or 2 %.( Appendix 1) The fact that the Kaministiquia River is the only major river along the North Shore of Lake Superior that does not have an established self sustaining population of Pacific Salmon is rather illuminating when noted that it is the only river on which there is an operating hatchery! This demonstrates a direct correlation and strongly suggests that stocking on top of an existing population has had a detrimental effect on both the wild and hatchery fish population. Numerous scientific articles (many listed in the stocking plan document) have recently been written to explain this relationship. It is time for a new approach! The conclusion in the Planning document to suggest the continuance of the stocking program is surely a politically derived decision “unlikely to have a negative effect on other species or on naturally reproducing salmon populations” and, “persistent interest in the activity and the lack of clearly identified risk in continuing the activity”) being the highest “pro” statements in a sea of “cons”. (ref page17) This is not how fisheries management policies are to be made. I would expect the MNRF to hold itself to a greater standard, and flat out cancel the program, rather than yielding to political pressure from a small group with a self serving interest in harvesting Pacific Salmon. Management of the fisheries resources is not a popularity contest, and given the stated lack of the support from the MNRF’s own FMZ 9 council (4 of 8 opposed, 2 of 8 support and 2 non-committals (likely due to group affiliation)) it is apparent that there is not clear support ref. page 15. The “lack of identified risk” ignores or minimizes the many current scientific articles explaining the adverse effects of stocking on top of existing populations. Ref appendix 2. I urge the Minister to follow the lead of other jurisdictions (Minnesota, Wisconsin and Michigan (pending) and cancel this program immediately and let what might be left of the wild population to establish itself as has occurred in all other rivers in this area. Give the wild population 27 years (same period of time as stocking) and I am convinced that the goal of a self sustaining population will be established. It is absurd to waste my tax dollars and those of the MNRF in assisting this project in any way. With the ministry’s often stated lack of funding, it seems unnecessary to provide support for a demonstrable failed Pacific Salmon hatchery program and that includes the staff (monitoring, meetings) and equipment (electro-shocking boat) etc. This plan if somehow adopted must include stated outcomes with directions in the event the objectives are not met. A clear statement regarding the future of the stocking program should the monitoring fail to meet the objectives as stated in the Plan. Such as “The stocking program will cease immediately if the short term goals are not meet” What happens if the results after the initial 4 years do not meet the goals of 50/50? What if the ratio in the first year or even 4 years is in fact the expected 98-99 wild and 1-5 stocked? Will the adaptive plan allow for a cessation of the program? Other comments regarding the Stocking Plan If the goal is to improve the overall Pacific Salmon population in Lake Superior, then the removal of gametes from rivers such as the Nipigon River and Wolf River, both of which have self sustaining populations in order to support a failed hatchery program is doubly detrimental. The avian population and the existing fish populations on the Kaministiquia River will have a constant influence on the survival of the YOY and changing stocking sites is not likely to have any measurable effect on the survival rate. This has been done in the past to no avail. Thank you for this opportunity