SALMONID COUNCIL OF NEWFOUNDLAND and LABRADOR COMMENTS ON PUBLIC DISCUSSION PAPER: DEVELOPING AN ENERGY PLAN FOR NEWFOUNDLAND AND LABRADOR NOVEMBER 2005 Submitted by Donald Hustins, President February 2, 2006

Introduction The Salmonid Council of Newfoundland and Labrador (SCNL) congratulates government on developing this discussion paper and for entertaining public debate on the provinces future energy needs. Council recognizes that new energy needs are required to support the developing economy and that government will be assessing all alternatives. Council is also pleased to be able to participate in this process and to offer government advise on meeting these future energy needs while preserving the valuable sport fishery for Atlantic salmon and trout in the province. While most of our comments are directed towards the recreational salmon fishery they also apply to the trout stocks. Salmonid Council of Newfoundland and Labrador The Salmonid Council of Newfoundland and Labrador is an umbrella organization consisting of a variety of groups whose main objectives are dedicated to the conservation and wise management of salmonids (Atlantic salmon, brook trout, brown trout, sea trout) and their habitat. Membership has grown from eight affiliates in the early years to twelve affiliates today. Current membership is as follows: - Salmonid Association of Eastern Newfoundland - Salmon Preservation Association of the Waters of Newfoundland - Environment Resource Management Association - Burin Peninsula Association for Salmon Enhancement - The Federation of Newfoundland Indians - Bay St. George South Development Association - Indian Bay Ecosystem Corporation - Gander River Management Association - Freshwater-Alexander Bay Ecosystem Corporation - Miawpukek First Nations - Newfoundland and Labrador Outfitters Association - Norris Arm and Area Economic Development Committee

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Other organizations including the Atlantic Salmon Federation, the Harry’s River Salmon Working Group and the Ragged Harbour Working Group, while not currently official members of SCNL, actively support the aims and objectives of Council. SCNL also operates as the regional council of the Atlantic Salmon Federation in the province. Council’s objectives are to work for the sound management of salmonid stocks through conservation, protection and enhancement of the habitat and stocks of anadromous and resident fish stocks for the long-term benefits of all residents and the outfitting industry. Since inception in 1979, Council has been very active in numerous activities some of which include the following: - The development of Salmon and Trout Management Plans. - The establishment of the Cooperation Agreement for Salmonid Enhancement. - The moratorium on the commercial exploitation of wild salmon. - The moratorium on small hydroelectric development. - The growth and development of community stewardship groups. - The conservation and restoration of salmon stocks in the province. - The promotion of catch and release angling. Council has presented numerous briefs, reports and comments to a variety of federal and provincial Ministers over the years respecting the health and management of our salmonid stocks. Value of Sport Fishing Industry There are approximately 200 scheduled salmon rivers in the province, which have considerable runs of Atlantic salmon and another 100 unscheduled rivers which have small but sustainable runs of salmon. Scheduled waters range from the large rivers such as mighty Exploits which has an annual run of approximately 20-30,000 salmon; the Eagle with runs of over 50,000 salmon; the Humber and Gander which each have runs of over 15,000 salmon; to moderately sized rivers such as the Castors, Portland Creek, Harry’s, Crabbe’s, Pinware, Forteau and River of Ponds which each annually produce approximately 4-8,000 salmon; to the smaller rivers such as Hughes Brook, South East Placentia, Salmonier each of which have runs of 1- 3,000 adult salmon. Each and every one of these rivers is an important contributor in maintaining healthy populations of salmon in the province. Scientists agree that each river has a unique genetically different group of salmon distinct from other rivers. Therefore the maintenance of all salmon rivers is extremely important to the sustained development of healthy salmon stocks in the province. Resident anglers rely on the smaller rivers for their annual recreational outings and for a fish for the table while most nonresident anglers resort to using the bigger and more remote rivers with outfitting lodges and practice release fishing. A study conducted in the 1990’s (Strategy for the Development of Recreational Fisheries, Newfoundland-Labrador, 1994) estimated that the gross economic value of the sport fishery was $106 million dollars of which $30- $50 million was associated with

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salmon angling. The study also stated that about 120 outfitters operated in the province and that nonresidents spent anywhere from $1,000 to $4,000 per trip. The same study indicated that direct and indirect wages generated by the industry was estimated to be $11 million or equivalent to 650 person years. This includes persons employed at outfitting camps, hotels, restaurants, guides etc. These economic values have greatly increased in recent years. It is therefore evident that this natural resource is a major economic engine for rural parts of the province. Stock Status The Atlantic salmon are no longer an abundant resource in this province. During the past 35 years stocks throughout the world have declined dramatically including those in this province. Rivers which once teemed with wild salmon and trout have been seriously depleted of former runs. The Department of Fisheries and Oceans states that in the early 1970’s about 1.5 million salmon entered our rivers. Today the run is about 300,000! That’s only 20% of former runs. In addition, a number of rivers remain closed to angling or are open to release angling because of depleted stocks. Many rivers are not even meeting conservation requirements which are essential to sustaining a future healthy population. The island of Newfoundland has suffered a major loss of salmon over the past few decades due to hydroelectric development, improper logging practices, poaching and poor construction. The recent moratorium on the commercial fishery for salmon in 1992 has yet to produce the returns expected suggesting that stocks are still vulnerable and will need a much longer time to recover. Additional hydroelectric development in the province will further reduce salmon stocks and greatly reduce the potential of the development of a strong recreational sport fishery in rural parts of the province. Effects of Hydroelectric Development on Salmon At first glance one would assume that hydroelectric development has had little effect on salmonid populations in the province. However, such is not the case. Currently, there are approximately 500 dams on ponds and rivers in the province. There are about 35 hydro projects supported by 200 dams. About half of the islands watersheds are controlled for the production of hydroelectricity. There has always been a trade off between industrial development and preservation of the environment and in the past the environment did not win. The Bay d’ Espoir development in the 1960’s is a case in point. Past hydro developments have seen major destruction of salmon stocks in several rivers. Salmon runs have been completely eliminated on Rattling Brook. The Norris Arm and Area Economic Development Committee is now working with government and Newfoundland Light and Power to restore these stocks to former abundance. When completed, salmon returns to the river could be 2-3,000 fish. A number of former Avalon salmon rivers are completely void of salmon as a result of a system of dams and diversions all of which are for hydroelectric purposes. In 1924, the damming of a major tributary of the Humber River, Junction Brook, saw the permanent loss of thousands of adult salmon, which once migrated up stream as far as Grand lake and Sandy Lake. The

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headwaters of the Indian River were diverted years ago creating a loss of habitat and adult salmon production. The development of the Bay d’Espoir system for hydroelectric use in the 1960’s reduced water flow into the White Bear and Grey Rivers thereby making downstream habitat less suitable for spawning and rearing salmonids. It is difficult to determine how many salmon have been lost as a result of the hydro development because there are no estimates of the production of these rivers prior to the hydroelectric development. However, make no mistake, these developments have reduced salmon production significantly and also destroyed countless millions of brook trout and sea trout. When a river is dammed salmonid stocks are affected in several ways: - The most obvious impact is that adult salmon are prevented from returning to their spawning beds. Several proponents have argued that mitigation measures can be put in place to prevent or minimize this impact. However, worldwide experience with hydroelectric development has proven that these measures are not sufficient to maintain fish stocks and eventually stocks decline. - Smolts migrating downstream to the ocean are killed by the turbines and from other impacts. This problem is less visible but over time will quickly destroy a river’s salmon run. There are no proven technologies which prevent this destruction. Smolt migration is interrupted by impoundments and the smolts tend to migrate at an inappropriate time. The experimentation with deflectors to protect smolt at Grand Falls has met with limited success. - Spawning and rearing habitats downstream from the dam are destroyed or made inaccessible. With the loss of this habitat, salmon stocks are destined to be destroyed. Proponents quickly say that they are able to regulate the flow of water downstream to protect fish. However, evidence is to the contrary. When there is no rain for a week or a month and salmon are stuck in the warm water and shrinking river, one can’t expect the hydro operator to release the precious water in favor of the salmon vs. power. It is not done elsewhere, and it will not be done here. Draw down of water levels up stream causes eggs deposited in shallow areas or near the shoreline to be exposed to dry conditions and eventually die. - Dams changes forever the biological and physical characteristics of rivers and leaves permanent hydrological changes, which are negative to salmonid fish stocks. - Hydro projects increase siltation in rivers. This siltation occurs during construction and operation. Shorelines change in a process called ‘draw down’ as the water level rises and falls on a continuing basis. With each cycle a new change of silt is brought into the water. - Increased water flows will prevent salmon from spawning and higher water temperatures will cause eggs to hatch too soon and will lead to smolt starvation as the young fish arrive in the wrong season. - Mercury pollution is a regular side effect of impoundments. Studies indicate that it takes 5-6 years for mercury pollution to peak after flooding. It takes decades to reduce mercury levels back to acceptable levels. - Hydroelectric proponents claim that wild fish stocks can be replaced by

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hatcheries. The construction of hatcheries to compensate this loss is not an acceptable solution since hatcheries are not cost effective and lead to weakened genetic structure of wild fish. In addition, The Department of Fisheries and Oceans does not operate any hatcheries in this province. Proponents also state that hydro development provides economic benefits to the province and no doubt they do during construction. However, very few jobs remain after the initial construction is completed. The maintenance of a strong sport fishery will also provide many long-term jobs all of which are selfsustaining. Returning salmon kelts provide up to 30% of salmon runs in some rivers and an average of 8% to 10% for all rivers. These are almost always killed when a hydro project interferes with the downstream migration. Hundreds of kelts are annually killed this way at Grand Falls.

Candidate rivers for hydroelectric development The discussion paper indicates there is still a potential production of 1,200 MW of hydroelectric energy from undeveloped rivers on the island. However, it does not mention the rivers being considered or the generation capacity of these rivers. Early in 2002, Council received a list of candidate rivers from the Department of Mines and Energy. Based on this list, it is evident that the development of 1,200 MW of electricity on the island will have serious negative impact on numerous salmon rivers and salmonid populations. The following information was taken from the list of rivers studied: - The list identified 198 rivers of which 65% (128) were scheduled salmon rivers. - 19 of the sites were considered large hydro sites, each of which could produce 20 MW or more power, for a total of 1,242 MW. Some of the rivers included Bay du Nord, two sites (238 MW); Exploits, 4 sites (92 MW); Terra Nova, 2 sites (144 MW); Humber, two sites (131 MW); the Main River, a Canadian Heritage River (110 MW); River of Ponds (35 MW); Pipers Hole, two sites (206 MW); and Southwest Brook (30 MW). - Of these 19 sites, only two are not scheduled salmon rivers. - The 109 remaining sites on salmon rivers were all considered small hydro sites, capable of producing from 1 to 17 MW of power for a total of 876 MW of power. Some of the rivers included the Castor (13 MW); Torrent (19 MW); Portland Creek (20 MW); Crabbes (17 MW); Piper’s Hole (11 MW); Southeast Placentia (3 MW); Conne (10 MW); Grand Codroy (2 MW); Great Rattling (14 MW); Harry’s (9 MW); Robinson’s (2 MW); Rocky River (2 MW); Isle aux Morte (3 MW); and numerous other rivers. - In addition, it is our understanding that several Labrador Rivers including the Pinware and the Forteau are also candidates for hydroelectric development. It is therefore evident that government would have to develop a large number of pristine rivers on the island to achieve the 1,200 MW if this energy option was chosen. This would be disastrous for the salmon stocks and the sport fishing industry. The impact

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on each river will be devastating and the overall cumulative impact on all salmon rivers would be tremendous. Additional salmon habitat loss is unacceptable in today’s technical world as many new alternative energy options are available. Recent Investments The federal and provincial governments spent approximately $90 million rebuilding salmon stocks in the 1990’s by enhancing rivers and buying out the commercial fishers licenses. Rocky River, which never had a salmon run until the Salmonid Association of Eastern Newfoundland planted fry in the system in the 1980’s, is now a productive river. The Department of Fisheries and Oceans enhanced the Exploits River which had salmon runs of less than 5,000 prior to enhancement and now have annual returns over 20,000 salmon and the potential for 60,000. They also enhanced the Torrent River, which now has a run of over 5,000 salmon. A number of local community stewardship groups have recently become involved in restoring salmon rivers all over the province. Both the federal and provincial governments have also been very supportive of these groups and have encouraged them to take an active role in managing and protecting the resource. Examples of such local interests are The Harry’s River Working Group and the Bay St. George Development Association both of which have been actively restoring the Harry’s River and other Bay St. George Rivers in recent years. New volunteer, community stewardship groups are springing up all over the province to enhance and protect salmon rivers in their areas. The benefits of these expenditures and volunteer stewardship initiatives are only now making their way through the system with increased salmon returns in a number of rivers. The Provincial Government, which has no jurisdictional role in the inland fishery, recently recognized the importance of the sport fishery and allocated $800,000 annually towards apprehending poachers. The development of salmon rivers for hydroelectric energy will quickly dampen the spirit of these groups and the development of this sustainable resource for residents and the outfitting industry. Hydroelectric dams are bad for salmon stocks. Witness the construction of three dams on the St. John River New Brunswick. The river, which formerly had up to 60,000 or more salmon now has runs of a few thousand. The river also has a hatchery for salmon and even this hatchery is not able to restore stocks to former abundance. Attempting to restore salmonid habit and stocks is an expensive experience. South of the border, Americans are currently in the early stages of restoring the Penoboscott River. The river, which once produced 100,000 salmon, now has a run of about 1,000. Part of the restoration includes the spending of over $150 million and the removal of obsolete dams on the river. I am sure this is not a scenario the province of Newfoundland and Labrador would like to entertain in the future.

Recommendations SCNL recognizes that the province will need additional energy to expand and diversify the economy. However, new sources of energy must be created in an

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environmentally friendly fashion, which does not deplete or destroy the precious salmonid resources. Government’s challenge will be to find workable solutions, which meet the demand and respect the environment. In general, our view is that the province should focus on the projects, which produce the maximum amount of power with the least environmental damage. Our specific recommendations are as follows: 1. Government should not bring forth energy development, which forecloses on other real economic development options such as tourism and recreational fisheries. As such, the province’s long term energy needs should not be met from hydroelectric sites on rivers, which contain sustainable runs of salmon. These rivers produce long lasting eco-tourism and recreational job opportunities, which add to the economic wealth of rural areas. 2. Government should maintain pristine rivers and populations of Atlantic salmon, as they are a present and future high value economic engine for rural areas. 3. Government should clearly state its intentions regarding Churchill Falls power when the contract expires in 2041. Will the power become available to Labrador, to the island of Newfoundland, or will it be sold. If the power is to be available internally, there will be no need to develop rivers. 4. The current moratorium on small hydro development should continue. 5. The Holyrood plant should be expanded with a forth oil fired generation turbine. In addition, the plant should be modernized so that stack omissions and toxic gases are minimized. 6. Newfoundland Hydro should actively pursue discussions with Newfoundland offshore operators to assess the availability and feasibility of expanding and modifying the Holyrood plant to utilize locally produced natural gas. 7. The province should develop wind power to supplement energy requirements. This is the only province in the country, which does not have wind power generated energy. We are lagging behind other provinces in this area and missing the opportunity to create an alternative energy source. SCNL was surprised to see Government recently reserve support on the proposed wind facility by the Metis Nation in Labrador. 8. The province should encourage all energy consumers to be more conservation oriented and save power thereby reducing the demand for additional energy. Spending money on conservation is cost effective as it creates surplus energy, defers massive expenditures and has a positive effect on the environment. Coupled with this, government should offer incentives for cost effective lighting, home heating and insulation. 9. If hydroelectric development is required on the island, existing facilities such as in the Bay d’ Espoir watershed should be considered as much as possible, thereby minimizing environmental damage and further destruction of salmonids and habitat. 10. In Labrador, new energy needs should be met with the development of the Lower Churchill not the damming of salmon –trout tributaries. The development of the Lower Churchill should be given the highest priority to meet long term energy needs of the province as the experts say it is the most cost effective source of new energy.

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11. Government’s long term plan should include a periodic review of all current hydroelectric dams that exist on salmon rivers (and former salmon rivers) to ascertain if new alternative energy sources can produce the energy more efficiently and environmentally friendly. Where more effective energy sources are found to exist, the dams should be removed and salmon stocks should be restored. In addition, government should adopt the Department of Fisheries and Oceans ‘no net loss’ policy when retrofitting and upgrading old plants. 12. Government should never grant long-term agreements to operate dams like we have done in the past. All dams, both old and new, should be given licenses to operate for shorter periods and these licenses should be reviewed every five to ten years with the intention of removing older less efficient dams and those dams that pose the greatest problem or impact on for fish migration and the environment. Summary SCNL’s vision is to double the growth of this sustainable recreational sport fishery over the next ten years and see the salmon industry valued at $100 million. This can occur through improved management of the resource, better protection of fish stocks, enhancement of selective rivers and the maintenance of all fish stocks and habitat. The salmonid natural resource is as unique as an ecological reserve. The resource generates economic wealth throughout the province particularly in rural areas that are severely challenged in available economic opportunities and enables residents to annually participate in a traditional recreational fishery highly central to their culture and way of life. The resource is also an important component of how we market the image of the province to tourists. Healthy, pristine, free flowing salmon rivers are a commodity lacking in many other parts of Atlantic Canada and the world. They still exist in this province. We must do everything possible to maintain these free flowing rivers and the fish which inhabit the rivers. As indicated above, in the United States, the federal and state governments are spending millions of dollars to restore salmon rivers. It is a very costly venture and there is no guarantee the results will be positive. However, they see the value of restoring these rivers. We have the opportunity to save our rivers and to avoid this cost in the future. However, we must make the right decisions today. SCNL also wishes to see the province’s economy expanded and diversified so that Newfoundlander’s and Labradorians forced to move away in the past are able to return and enjoy the life style the province offers. We also like to see new opportunities for our youth and those currently in the province. However, industrial development should not occur by destroying one natural resource for another. Former CEO of Newfoundland Labrador Hydro, V. Young, in a letter to Minister K. Aylward, August 21, 1997 summed up the impact of developing additional rivers on the island: “There are no major hydro electric developments remaining on the island of Newfoundland which can make any significant contribution to our future economic and/or industrial development. For instance, there is no single hydro project, which could even come close to providing enough power and energy to supply the INCO smelter in Argentia, which requires some 200 M. Moreover

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these potential small hydro projects are high cost and carry with them large environmental impacts...The point, which needs to be made, however, is that future energy requirements on the island of Newfoundland cannot be met by proceeding with a multitude of smaller hydro projects. Larger energy decisions are required. The best electrical alternatives involve (1) proceeding with further oil/gas generation (175 MW) to supply Argentia;(2) proceeding with the cost effective Granit Canal (45 MW) and Island Pond (20 MW) developments in the Bay d’Espoir watershed; and rejecting any further small hydro as a matter of environmental policy in favor of fish, wildlife, wilderness habitat, eco-tourism and good common sense, i.e. do the right thing for the right reason and in the right way. Government can be proactive and develop new alternative energy sources, promote conservation of existing energy and expand existing energy sources while minimizing the impact on the environment and the salmonid resource. Or, government can be short sighted and ignore the environment and destroy the salmonid resource with its sustainable eco-tourism jobs and incur tremendous costs in an attempt to restore rivers in the future. SCNL hopes the right decisions will be made at this point in time for the right reasons and that the salmonid resources are conserved for future generations.

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