Fraser River Part 3
Stop Restoring the Damage
While the Pollution Keeps Flowing
For more than three decades, Veins of Life Watershed Society has worked around storm drains, creeks, shorelines, contaminated sediments and marine waters.
After looking at the Fraser River from its headwaters to the sea, reviewing decades of government studies, and comparing those findings with 32 years of our own field experience in Greater Victoria, we keep coming back to the same conclusion:
Source control has to come first.
Canada has spent enormous amounts of public and private money studying rivers, restoring salmon habitat, replacing culverts, rebuilding shorelines, planting riparian areas and creating environmental programs.
Much of that work is worthwhile.
But if pollution continues entering the water upstream, we are repairing habitat while allowing it to be contaminated again.
That makes little sense environmentally or financially.
And it is one of the biggest lessons we have learned from 32 years of working on the ground.
The Fraser Is the Watershed
One of the first things we need to simplify is the language.
The Fraser River is the watershed.
Creeks, storm systems, roadside ditches, small streams and local drainage networks are drainage areas within that watershed.
That distinction matters.
Over the years, environmental management has increasingly divided large watersheds into smaller organizations, projects and geographic areas.
Many have done excellent work.
But there is a danger.
Limited environmental funding can follow population, political pressure, successful grant writers or whichever issue has the loudest voice.
The largest municipalities usually have planning departments, engineers, environmental staff, consultants and grant-writing capacity.
Smaller communities and regional districts may not.
Yet pollution does not care how large a municipality is.
And, as the old saying goes, everything flows downhill.
What happens around Prince George, Quesnel, Williams Lake, Kamloops, the Fraser Canyon or a small rural drainage area can eventually become part of the same Fraser River system.
The Fraser therefore has to be treated as one connected watershed, while the work of finding and stopping pollution is carried out region by region and drainage area by drainage area.
Everyone Is Responsible — So Nobody Is Responsible
This is one of the most persistent governance problems we have encountered.
Municipalities have responsibilities.
Regional districts have responsibilities.
The Province has responsibilities.
Federal departments have responsibilities.
Industries, landowners and operators have responsibilities.
Road authorities have responsibilities.
First Nations have governments, stewardship programs and responsibilities within their territories.
But when pollution enters a creek, ditch, storm drain or river, responsibility can become fragmented among those jurisdictions.
We have experienced this repeatedly in Greater Victoria.
The Capital Regional District has developed considerable environmental expertise and has done excellent work.
But the CRD's ability to carry out stormwater source-control work has limits. Cooperation by municipalities has played an important role, and historically that has meant some jurisdictions participate more actively than others.
That is not a criticism of CRD staff.
In fact, it demonstrates something important:
a regional program can work very well, but it needs the authority, resources and long-term mandate necessary to do the job consistently across the entire region.
The Fraser cannot be built around another system where participation depends upon invitation.
That eventually leaves us with the same old problem:
everyone is responsible, but nobody is responsible for making sure the complete investigation gets finished.
We Have Been Here Before
When we began working around Victoria Harbour and the Gorge Waterway in the 1990s, even identifying a stormwater discharge could become confusing.
There were six separate numbering systems being used by different agencies.
The same physical outfall could be identified differently depending upon which organization you were dealing with.
We did not throw those systems away and invent another one.
With the full cooperation and assistance of the Capital Regional District, we worked with the existing outfall information and helped establish a practical way for the discharge point at the receiving environment to be consistently identified.
That was the important part.
The physical place where the water entered the creek, harbour or marine environment had to be identifiable.
One discharge point had to mean the same place to everyone dealing with the problem.
It sounds simple.
It worked.
Think Like a Bureaucrat
There was an important moment early in this work that has stayed with us.
At a high-level meeting with the Province, we were trying to explain the scale of pollution entering local waters.
The response was essentially:
We believe you. But you have one proof.
We left disappointed.
But that meeting exposed the real problem.
Knowing pollution existed was not enough.
Government needed something it could document.
A location.
A number.
A report.
A history.
Something that could be retrieved later.
Very shortly afterward an opportunity arose to work with the provincial emergency reporting system, the CRD and municipalities.
The concept came together quickly.
Use the outfall information.
Identify the discharge.
Put signs at the locations.
Give the public the provincial number to call.
Suddenly the public, the Province, regional staff and municipalities could all be talking about the same physical location.
That changed things.
The Public Became Part of the System
This may have been one of the most successful things we ever did.
The signs were simple.
They did not require someone to understand environmental legislation.
They did not require expensive equipment.
They identified a discharge and told people who to call.
Members of the public became thousands of additional eyes along the shoreline.
They did not become regulators.
They became witnesses.
Someone walking a dog could see something unusual.
A fisherman could see a plume.
A child could notice coloured water.
A paddler could smell fuel.
A shoreline resident could see sewage.
Instead of trying to describe vaguely where they were, there was an identifiable discharge point.
Some of those signs are badly worn today.
But decades later, people still use them and still report problems.
That tells us something important:
Simple systems survive.
One Practical Solution for the Fraser
We are not proposing another giant Fraser River bureaucracy.
We are not proposing another temporary commission.
We are not proposing another five-year plan that disappears when the funding ends.
And we do not want Ottawa or Victoria to take this concept, build another senior-government program around it, and then download the work back onto regional governments without the staff, authority or money to carry it out.
We have seen enough versions of that already.
What we are proposing is much simpler.
Build permanent Source Control capacity within the Fraser Basin regional districts and provide them with the authority and long-term resources needed to operate it.
That does not mean every regional district has to become Metro Vancouver.
Quite the opposite.
The smaller regional districts are exactly why a long-term system is needed.
What a Regional Source Control System Could Do
Each Fraser Basin regional district could operate a standardized Source Control program appropriate to its size and circumstances.
At a minimum, that regional function would maintain the environmental picture of where water is entering the Fraser system.
It would:
maintain the inventory of known outfalls;
identify and map receiving-water discharge locations;
document drainage areas;
maintain photographs and field records;
coordinate standardized sampling;
record laboratory results;
investigate suspicious discharges;
assist with source tracing;
document complaints and spill reports;
identify the municipality, ministry, industry, property owner or other party responsible for the source;
refer matters to the authority possessing the necessary enforcement powers;
track corrective action;
conduct or coordinate follow-up sampling;
and maintain the record over the long term.
The Regional District does not need to become responsible for another party's pollution.
The polluter remains responsible for the pollution.
The municipality remains responsible for its infrastructure.
The road authority remains responsible for its infrastructure.
The industrial operator remains responsible for its discharge.
The Province and federal government retain their respective regulatory responsibilities.
But the regional Source Control program provides something that is presently too easy to lose:
continuity.
Someone remains responsible for keeping the environmental file alive.
That Will Eventually Require Legislative Change
We should be straightforward about this.
A permanent Fraser-wide system cannot depend forever upon goodwill and voluntary participation.
The Province would eventually have to change the legislative and regulatory framework so that regional Source Control is a recognized and properly empowered function.
The important distinction is that the Province should enable and require the system — not operate the Fraser from Victoria.
Regional districts understand their local infrastructure, communities, industries, geography and drainage systems.
First Nations understand their territories and waters.
Municipalities understand their infrastructure.
Community organizations know what is happening on the ground.
Universities and colleges can provide science, training and technical support.
The Province's job should be to establish the common requirements, provide appropriate authority, ensure cooperation among jurisdictions and supply dependable long-term funding.
The federal government's role should similarly be to provide regulatory support, scientific resources and stable funding where federal responsibilities are engaged.
Neither senior government needs to create another temporary Fraser organization to run the program.
Build the capacity where the work actually occurs.
Long-Term Money — Not Another Round of Grants
This is equally important.
A Source Control program cannot be built on organizations spending half their time applying for the next grant.
We do not yet have enough Fraser-wide information to say exactly how funding should be divided.
Population alone may not be fair.
Known pollution alone may not be fair either, because some areas have more monitoring simply because they already have more resources.
Development pressure, industrial activity, vulnerable salmon habitat, transportation corridors, contaminated sites and other factors may eventually need to be considered.
We need the data before pretending we know the perfect formula.
But we already know one thing.
Every Fraser regional district participating in the system would need enough core funding to maintain basic Source Control capability year after year.
That means people.
Equipment.
Vehicles.
Sampling supplies.
Laboratory access.
GIS and database support.
Training.
Administration.
Follow-up investigations.
And money to keep doing the work after the first announcement and photo opportunity are over.
Additional project funding could then be directed to demonstrated problems and emerging pressures.
But the core program should not disappear because a three-year federal contribution agreement ended.
The Money Should Build Local Capacity
This is where First Nations, communities and universities can become extremely important.
A regional Source Control program does not have to mean hiring hundreds of new government employees immediately.
There are opportunities for partnerships involving:
First Nations, Guardian programs, community organizations, universities, colleges, students, environmental technicians and regional governments.
People can be trained in:
drainage mapping;
outfall identification;
field investigation;
water sampling;
GIS;
pollution tracing;
environmental technology;
laboratory procedures;
data management;
and restoration monitoring.
Those are transferable skills.
That creates jobs and capacity within the watershed instead of repeatedly flying consultants into communities to prepare another report.
Start With What We Already Know
We do not need to map every hidden ditch in the Fraser Basin before beginning.
Start with the known outfalls.
Use existing regional and municipal information wherever possible.
Do not reinvent databases unnecessarily.
Identify the known receiving-water discharge locations.
Make sure each can be consistently identified.
Map them.
Photograph them.
Document them.
Place simple public signage where practical.
Connect the location to a digital record.
Then put feet on the ground.
The Maps Will Not Show Everything
This is another lesson from experience.
Public information does not show every drainage pathway.
Small streams disappear from maps.
Roadside ditches change.
Old pipes remain in the ground.
Drainage gets redirected.
Seepage appears.
Informal connections are made.
Properties redevelop.
That is why field investigation matters.
First Nations, community groups, students and trained field teams can walk drainage areas and document what the existing records missed.
A ditch or small stream that nobody has mapped today can be recorded so somebody can return to it tomorrow.
That becomes part of the Fraser's permanent environmental record.
Development Is Moving Upstream
There is urgency to this.
Development pressure is not confined to Greater Vancouver.
Communities throughout the Fraser system are changing.
Roads expand.
Industrial lands expand.
Housing expands.
Impervious surfaces expand.
Stormwater systems expand.
We should not repeat upstream the mistakes already made downstream.
A drainage system is not automatically a water-quality system.
A storm drain may move water efficiently while moving metals, hydrocarbons, tire-wear chemicals, bacteria, sediment, pesticides, endocrine-disrupting compounds and other contaminants just as efficiently.
Source Control should be built into development before those problems become tomorrow's contaminated sediments and restoration projects.
One Number for the Public Still Matters
The public component remains beautifully simple.
When someone standing beside a creek, ditch or signed outfall sees something wrong, they should not have to work out which government department has jurisdiction.
They should have a simple reporting route.
The existing provincial reporting system gives us something to build upon.
The important part is linking a public observation to an identifiable environmental location.
A report then becomes part of the history of that discharge point.
Over time, repeated reports can reveal patterns that a single annual inspection may never detect.
Source Control Before Restoration
This is ultimately why we are proposing this.
We support habitat restoration.
We have spent decades doing it.
But restoration without source control is often an incomplete job.
You can rebuild a creek.
Restore a shoreline.
Plant riparian vegetation.
Improve salmon habitat.
Remove contaminated sediment.
Build wetlands.
Reconnect floodplain habitat.
And then contaminate it again from the same uncontrolled drainage area.
That is not a criticism of restoration workers.
It is a failure of the system surrounding them.
Do not restore downstream what we are still allowing to be contaminated upstream.
This Cannot Become Another Fraser Plan
The Fraser River has already had plans.
Lots of them.
Government programs have started.
Studies have been completed.
Recommendations have been made.
Organizations have been established.
Funding has arrived.
Funding has ended.
Programs have changed names.
Then another generation begins studying many of the same problems again.
We are proposing something different.
Build permanent operating capacity.
Not another temporary study.
Not another advisory committee.
Not another short-term funding envelope.
Not another organization competing with the people already working throughout the Fraser.
Give regional governments the capacity to maintain the system.
Give First Nations and communities meaningful ways to participate.
Give universities and colleges a role in training and science.
Give the Province and federal government clear responsibilities for legislation, regulation, technical support and long-term financing.
Then leave the operating knowledge in the regions where it belongs.
Over time, some areas may decide that an integrated stormwater or storm/sewer utility is the best permanent mechanism for funding and delivering that work.
Others may use different structures.
We do not need to decide all of that today.
First build the Source Control foundation.
We Do Not Need to Know Everything Before We Start
This would take years to build across a river the size of the Fraser.
That is not a reason to delay it.
Start with what is known.
Use the existing information.
Identify the known outfalls.
Make them consistently identifiable.
Sign them.
Map them.
Document them.
Train people.
Sample where resources allow.
Investigate known problems immediately.
Allow field teams to find what the maps have missed.
Build the digital record as the work progresses.
Most importantly, make sure the information remains available so another generation does not have to start from zero.
There will be failures.
We had failures.
Programs changed.
Governments participated differently.
Signs deteriorated.
Some pollution sources were difficult to solve.
But many of the basic systems we helped develop and use more than thirty years ago are still operating in some form today.
That is what a long-term environmental program should do.
Our Best Assessment After 32 Years
This is not yet legislation.
It is not a detailed engineering design.
It is not a finished funding formula.
And it is not another Fraser River master plan.
It is our best assessment after 32 years of watching what happens when contamination crosses boundaries and responsibility becomes divided among too many governments.
The Fraser has been studied enough to know there are problems.
We have also studied it enough to know that fragmented responsibility remains one of those problems.
Our proposed starting point is therefore simple:
Use the information we already have.
Identify the known discharges.
Give the public a simple way to report what they see.
Put trained people on the ground to find what the maps have missed.
Give First Nations, communities, universities and regional governments the resources to participate.
Build permanent Source Control capacity within the regional districts.
Change provincial legislation where necessary so participation and investigation do not depend upon invitation.
Provide long-term provincial and federal funding without senior governments taking over the regional program.
Trace contamination back to its source.
Keep the legal responsibility with the actual polluter or responsible authority.
Correct the problem.
Then go back and prove that it stopped.
Do that consistently from the headwaters to the sea and we begin doing something governments have talked about for decades:
treating the Fraser River as one watershed.
And perhaps then the millions of dollars we spend restoring damaged habitat will have a much better chance of staying restored.
Footnote — Fraser Watershed Governance Scale
Regional Districts — 2021 Census population
Metro Vancouver — 2,642,825
Fraser Valley Regional District — 324,005
Thompson-Nicola Regional District — 143,680
Fraser-Fort George Regional District — 96,979
Cariboo Regional District — 62,931
Columbia Shuswap Regional District — 57,021
Squamish-Lillooet Regional District — 50,496
Regional District of Bulkley-Nechako — 37,737
First Nations — registered population; working Fraser-drainage list
Lower Fraser / Coast Salish: Musqueam 1,496; Sts’ailes 1,174; Seabird Island 1,095; Skwah 733; Tsleil-Waututh 707; Chawathil 671; Katzie 659; Tzeachten 620; Cheam 586; Leq’á:mel 547; Shxwhá:y 504; Soowahlie 460; Kwantlen 414; Tsawwassen 414; Sumas 384; Sq’éwlets 301; Skowkale 300; Matsqui 281; Shxw’ow’hamel 250; Squiala 221; Yale 210; Peters 192; Union Bar 173; Kwikwetlem 147; Semiahmoo 104; Skawahlook 93; Yakweakwioose 88; Kwaw-kwaw-Apilt 59; Aitchelitz 41; Qayqayt 24; Popkum 13.
St’át’imc: Lil’wat 2,292; Xaxli’p 1,128; Tsal’alh 735; Ts’kw’aylaxw 597; T’it’q’et 510; Bridge River/Xwísten 501; Skatin 423; Douglas/Xáxtsa 391; N’Quatqua 387; Samahquam 383; Cayoose Creek/Sekw’el’was 210.
Fraser Canyon / Nicola: Lytton 2,144; Lower Nicola 1,551; Upper Nicola 1,004; Coldwater 952; Spuzzum 491; Ashcroft 441; Cook’s Ferry 383; Boothroyd 339; Siska 339; Boston Bar 318; Nooaitch 247; Kanaka Bar 245; Nicomen 226; Skuppah 151; Shackan 130; Oregon Jack Creek 74.
Secwépemc / Thompson–Cariboo: Tk’emlúps te Secwépemc 1,549; Esk’etemc 1,203; Bonaparte 1,152; Williams Lake First Nation 1,053; Splatsin 965; Simpcw 884; Stswecem’c Xget’tem 857; Adams Lake 866; Neskonlith 693; Tsq’éscen 600; Skeetchestn 582; Xatśūll 468; Skwlāx te Secwepemcúl̓ecw 389; High Bar 307; Whispering Pines/Clinton 232.
Tsilhqot’in: Tl’etinqox 1,749; Tŝideldel 695; Yuneŝit’in 506; Tl’esqox 488; Xeni Gwet’in 476; ?Esdilagh 279.
Dakelh / Carrier — Nechako, Cariboo and Upper Fraser: Nak’azdli Whut’en 2,080; Tl’azt’en 1,555; Saik’uz 1,000; Takla 947; Lheidli T’enneh 887; Stellat’en 628; Nadleh Whut’en 621; Nazko 435; Cheslatta Carrier Nation 389; Binche Whut’en 230; Lhoosk’uz Dené 232; Yekooche 220; Lhtako Dené 209; Ts’il Kaz Koh 206; Skin Tyee 192; Nee-Tahi-Buhn 144.
Population note: Regional-district numbers are whole-district 2021 Census populations. First Nation figures are registered membership and should not be read as the number of people physically living within the watershed. Traditional territories also cross modern watershed and regional-district boundaries.
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