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Additions To Species At Risk Act


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On March 23, 2019 the Government of Canada Department of Environment announced an order amending Schedule 1 to the Species at Risk Act (SARA).  Pursuant to section 27 of SARA and on the recommendation from the Minister of the Environment, the Governor in Council is proposing the Order Amending Schedule 1 of the Species at Risk Act to add or reclassify 32 species to Schedule 1 of SARA."(Canada Gazette)


Three of those species are sport fish that are present in Alberta:

  • Bull Trout (Western Arctic Populations)
  • Bull Trout (Saskatchewan - Nelson Rivers Populations)
  • Rainbow Trout(Athabasca Populations)


The two Bull Trout species are identified on the list as 'Special Concern' i.e  “a wildlife species that may become a threatened or an endangered species because of a combination of biological characteristics and identified threats.” Species listed as species of special concern are not subject to the general prohibitions of SARA. However, there is a requirement under SARA for the preparation of a management plan, which must include measures for the conservation of the species that the minister considers appropriate.


The Rainbow Trout (Athabasca River Populations) is identified as 'Endangered' i.e. “a wildlife species that is facing imminent extirpation or extinction”. Once an aquatic species is added to Schedule 1 of SARA as threatened, endangered or extirpated, the general prohibitions under sections 32 and 33 of SARA automatically apply, making it an offence to:

  • kill, harm, harass, capture or take an individual of a listed species;
  • possess, collect, buy, sell or trade an individual of a listed species, or any part or derivative of a listed species; and
  • damage or destroy the residence of one or more individuals of a listed species.

 Also, the preparation of a recovery strategy and of one or more action plans, and the identification and protection of critical habitat are required. Critical habitat is defined in SARA as “the habitat that is necessary for the survival or recovery of a listed wildlife species and that is identified as the species’ critical habitat in the recovery strategy or in an action plan for the species.”


Canadians have 30 days to appeal any part of the Order after which it is finalized.


Species are considered by the Dept. of the Environment for inclusion under SARA based on the recommendation of the Committee on the Status of Endangered Wildlife in Canada (COSEWIC), an independent body of scientific experts established under the Species at Risk Act .

It is anticipated that COSEWIC may soon be recommending the inclusion of Arctic Grayling to Schedule 1 of SARA.  Arctic Grayling in Alberta are currently considered a species of 'Special Concern' by Alberta Environment and Parks.



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  • 2 weeks later...

Correction:   the Saskatchewan-Nelson Rivers populations of Bulltrout are in fact listed as "Threatened" - i.e. a species likely to become endangered if nothing is done to reverse the factors leading to its extirpation or extinction.  This species is restricted to Alberta and found primarily in the drainages of the North and South Saskatchewan rivers.

The same prohibitions as for Athabasca Rainbows  apply to this species of bulltrout although not for the Western Arctic bull trout species which is found in the Mackenzie River system and major tributaries, such as the Liard, Peace and Athabasca rivers.


We have been advised that DFO is considering excluding angling from the prohibitions of the Act in order to avoid angling closure of waters in which Saskatchewan river bulltrout or Athabasca Rainbows occur.


The Chapter will be submitting a response in support of the addition of these species because of the added protection afforded them under the Species at Risk Act (SARA). Based on discussion at the April 3rd meeting of the Chapter the letter will also include support for the exclusion of angling from the prohibitions of SARA, provided that measures are implemented to minimize potential harm from angling e.g. catch and release regulations, seasonal closures as needed, angler education, recommended use of barbless hooks to reduce handling, etc. In addition, the letter will stress the need for additional attention to habitat protection and restoration if long term sustainability objectives are to be met for all coldwater species.

Consideration is also being given to the Chapter lobbying for the assessment of Arctic Grayling by the Committee on the Status of Endangered Wildlife which recommends additions to the federal list of species at risk.  This Committee identified Arctic Grayling as a high priority for assessment in 2014 but we are unaware of anything happening since.


Please post or email Communications@nlft.org as soon as possible if you have any questions, suggestions or concerns regarding the Chapter's proposed response.

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We are on a slippery slope....


Although I do not disagree with the SARA amendments, we must be cautious in the response.

Angling, catch and release, does in fact constitute "harm and harass"....Are we not hypocritical?  Do I want full scale closures?....no...but I am playing devil's advocate...


I would also submit that logging and resultant increased water temps from that logging has resulted in a significant decline in cold water species numbers ( among other factors).  Does logging and its resultant effects not constitute damage to the residence of that species?


It just seems that COSEWIC has no difficulty putting species on the SARA list...but doesn't really offer any productive solutions.  Once a new species is put on the list...groups seek exemptions to sections 32 and 33....just sayin'...

The definition above of special concern is given as“a wildlife species that may become a threatened or an endangered species because of a combination of biological characteristics and identified threats.”  If the threat has been identified...shut it down....That seems to be a road that DFO doesn't have the courage to go down....

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Thanks for the comments.  Brings to mind the saying, "Be careful what you ask for . . . . . . you may just get it."


I think many share your concern about the potential hypocrisy.  On the one hand we have a species 'in imminent danger of extirpation or extinction' and on the other we look for permission to stick a hook in them and drag them around a bit.  It becomes a philosophical issue (though probably not for the fish).  Which causes more harm, angling or no angling?  The best summary of research I've read on the degree of harm and mortality from catch and release angling stated "the only conclusion we can state definitively is that it is not zero."  Angling closures remove many advocates for conservation and stewardship from the land, alienate the angling community, reduce public support for recovery strategies and do very little to address the primary problem, that of habitat degradation from climate change, logging, etc. This became very apparent in some public reaction to Alberta’s recent North Central Native Trout Recovery Plan.


I asked Carl Hunt, biologist and long term advocate for Alberta's east slopes fisheries, for his opinion on the proposed additions to SARA and on this apparent dichotomy  His response:

"Finally, for your dichotomy, I'll offer the advice from Canadian biologists, John Madson & C.H.D. Clarke (1964) in Waterfowl Tomorrow. P 710. 

'The consummate offense to wildlife is not hunting, but the extirpation of a species by an indifferent technology in which wildlife is wiped out - not by man's passion - but by his single minded devotion to a material world in which creatures have no place.  It might be nobler for man to deliberately hunt down the last wild creature in one final declaration of value,  than to sweep it away forever as an unknown and unmourned technological casualty.'  


We are already at the 'Endangered' stage and the next step is 'extirpation' because we have seriously compromised fish habitat in favour of 'jobs & economy'.  I could support angling closures as required, if habitat was protected and the damage of the past 40 years was repaired, otherwise angling closures just get rid of anglers and delays the demise of fish."

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The attached letter from Northern Lights in support of the proposed addition of Alberta's Bull Trout and Athabasca Rainbow Trout to Schedule 1 of the Species at Risk Act has been sent today to the Dept. of Fisheries and Oceans. It is based on an attempt to reflect the opinions of those members who provided input.. There is still time (until April 22nd) to send individual letters


NLFF Letter to DFO re SARA.docx

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  • 1 month later...

Received today a response to the NLFF Letter to DFO re SARA as follows :


Thank you for your correspondence of April 11, 2019, addressed to Julie Stewart, Director, Species at Risk Program, Fisheries and Oceans Canada, regarding the Government of Canada’s notice of consideration of listing Rainbow Trout (Athabasca River populations), Bull Trout (Saskatchewan – Nelson Rivers populations), and Bull Trout (Western Arctic populations) to the list of wildlife species at risk in Schedule 1 of the federal Species at Risk Act (SARA).


DFO appreciates your comments and recommendations, and they will be taken into consideration on whether or not there is support to add these species to the official list of wildlife species at risk under the Species at Risk Act.


Should the federal government decide to add Rainbow Trout (Athabasca River populations), Bull Trout (Saskatchewan – Nelson Rivers populations), and Bull Trout (Western Arctic populations) to the list of species in Schedule 1 of SARA, Recovery Strategies for Rainbow Trout (Athabasca River populations) and Bull Trout (Saskatchewan – Nelson Rivers populations), and a Management Plan for Bull Trout (Western Arctic populations) must be developed, with further public consultations at that time.  Any proposed federal plans require public consultation and we invite you to visit the Species at Risk Public Registry for information and updates on the progress of SARA listing and recovery planning and to learn about opportunities to provide your comments and feedback.


Thank you for writing.  Fisheries and Oceans Canada takes its responsibilities for the conservation and protection of species at risk seriously, and is committed to working with the provinces and territories, Indigenous groups, non-government organizations, and all Canadians for their recovery.



Yours sincerely,


Peter Rodger


Species at Risk Program, Ecosystem Management,

Fisheries and Oceans Canada

peter.rodger@dfo-mpo.gc.ca / Tel: 204-984-3677

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