Backcountry Hunters and Anglers
c/o P.O. Box 10294, Airdrie, Alberta, T4A 0H6

December 13, 2017

Honorable Shannon Phillips,
Minister of Environment and Parks,
208 Legislature Building
10800 – 97 Avenue
Edmonton, AB
T5K 2B6

Re: North Central Native Trout Recovery Plan

Dear Minister Phillips,

Alberta Backcountry Hunters and Anglers (ABHA) members attended a workshop (in Calgary)
hosted by various AEP fisheries biologists on Dec. 12, 2017 to understand the rationale behind
the forthcoming North Central Native Trout (NCNT) Recovery Plan. As Albertan anglers who
value quality habitats, the wilderness, and the conservation of native species, we offer the
following feedback on the recovery plan and recommendations with regard to native trout
recovery in Alberta.

We do not support the proposed angling closures, as detailed in the current revision of the
NCNT. It is our view that the burden of recovery is being placed on anglers, with little effort
undertaken to remedy the underlying root causes of the population decline, which can
specifically be defined as: public roads, industrial disturbances, forestry, and OHV activity. The
AEP Fish Sustainability Index (FSI) tool predicts that the impact of a full angling closure, results
in a minor improvement in native trout populations, at the cost of alienating the very
champions of this natural resource. The FSI also predicts dramatically higher population
recovery if the root causes are managed appropriately.

Attempting to recover fish populations by only regulating angler harvest has failed in the past.
For example, public concern, spearheaded primarily by anglers, about Arctic grayling,
Athabasca rainbow trout, and bull trout all led to past proposals to eliminate or rigorously
control industrial activity in, among others, the upper Little Smoky, Berland, and McLeod River
systems. Previous government administrations chose only to regulate angler harvest with the
hopes of population recovery/improvement, and now we are seeing the negative results of that
policy, as the same root causes as identified above were not managed, and reducing the fish
populations to a shadow of what they once were. Angling is not the primary problem these
fisheries face: habitat degradation is. Anglers, in fact, have been the main advocates for species
recovery. It’s time for Alberta to deal with the real problems: habitat degradation and
cumulative effects.

We feel that more concrete actions are needed to protect and restore habitats, thus achieving
the goals that Alberta residents and anglers desire. Although the NCNT mentions some
measures to assess habitat damages, it is our opinion that a great deal more needs to be done
in this area to ensure recovery of the native trout population. Key watersheds for native fish
should be prioritized for habitat restoration, as outlined in the plan; however, more detail on
where and how protection and restoration of habitat will occur is needed to address the
important impacts of public roads, industrial disturbances, forestry, and OHV activity.
Coordination with your fellow Ministers (Energy, Infrastructure, Transportation, Agriculture and
Forestry) is required to establish effective recovery plans that restore both habitat and fish
populations. We are not proposing the expenditure of funds. Instead, we are proposing to
address the fundamental flaws with how Alberta balances the needs of industry, the public, and
wildlife, whilst protecting the wilderness. The Alberta Government must break with the past
failed policies and set the course for effective recovery. Given the gravity of the situation, the
government will find willing partners within industry, conservation groups, and the general
public.

Our final recommendation is that the NCNT should address all native cold-water fish on the
Eastern Slopes including westslope cutthroat trout and southern populations of bull trout.
Creating multiple plans with different approaches for different areas of the Eastern Slopes will
create confusion for anglers, fisheries managers, and enforcement officers. A single landscape
level plan covering the entire Eastern Slopes is needed to achieve native fish recovery and
ensure province wide support and understanding. The single landscape plan should focus
primarily on habitat restoration and protection, and not anglers, many of whom are this
province’s most committed and vocal proponents for native fish recovery.
We appreciate the opportunity to provide comments on the draft NCNT Recovery Program and
look forward to working with you to expand and enhance a landscape level program for habitat
restoration and recovery of all native fish species on the Eastern Slopes.

Sincerely,
Neil Keown
Chair, Alberta Backcountry Hunters and Anglers

Cc: Deputy Minister Andre Corbould, Alberta Environment and Parks
Premier Rachel Notley