Thank you, Francis.

In the interest of time I will provide a quick overview of our recommendations. Additional details can be found in the CEA's written submission.

I will start with the three recommendations for amending the act itself. Firstly, we believe that the Fisheries Act requires a clear statement of its purpose and the principles that guide its application. The purpose of the Fisheries Act should be to provide for the sustainability of Canada's marine and inland fisheries by ensuring that environmental, economic, and social considerations, including the impact on other water resource uses, are systematically taken into account in the management of fisheries, and the conservation of fish and fish habitat. The underlying principles should be ecosystem-based management and sustainable development.

Secondly, the definition of “serious harm” needs refinement. The definition of “serious harm” should focus on the sustainability of fisheries by protecting fish populations or stocks, and not individual fish, and it needs to still cater for both harvest fish and species at risk. We also believe the act would benefit from a definition of what constitutes the sustainability of a fishery.

Thirdly, there is a need for the act to make provision for the long-term authorization of facilities. The act currently does not specify a time limit nor expiry of Fisheries Act authorizations and as such leaves this to the discretion of the minister. In addition, there is no process in the act through regulation or in policy to formally amend or extend Fisheries Act authorizations. This creates uncertainty for the electricity sector where many activities and ongoing operations are long term.

The association also believes that there is a need and an opportunity for the federal government to enhance public trust in the act, mainly through the implementation of modern safeguards. We would like to offer the following seven recommendations.

One, we would like to see an increase in staffing and funding to the DFO fisheries protection program. This would ensure that staff are active in the field and understand the activities and operations that they are required to authorize.

Two, we believe that there should be more focus placed on supporting and encouraging partnerships and stewardship activities, including broad area planning initiatives to protect and restore fish habitat.

Three, there is a need for fisheries management objectives to be documented up front as part of the initial review process. This will assist in determining whether or not there is a commercial, recreational, or aboriginal fishery that requires protection and what is required to ensure its ongoing sustainability.

Four, with regard to offsetting harm, we would like to see more innovative and modern approaches to offsetting residual project impacts. Some of the approaches that could be considered include conservation agreements, correction of legacy issues, and third-party offset habitat banks.

Five, a public authorization registry of Fisheries Act authorizations should be developed to increase transparency and accountability in the authorization process.

Six, DFO should consider developing a risk-management approach to authorization. This could take into consideration established fisheries management objectives, mitigation of adverse impacts, significance of effects, and the ongoing sustainability of fisheries. A risk-based approach could also be used for existing facilities that predate the act.

Finally, the federal government could consider incorporating approaches by reference into the act. A good example of this is the incorporation of class authorizations for routine operation and maintenance.

This concludes our recommendations. I will now hand back to Francis.

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