AWA Comments on the Proposed Multi-species Action Plan for the Alberta At-risk Native Trout in Canada

May 11, 2026

On May 11, 2026, AWA provided comments to Fisheries and Oceans Canada on the proposed Multi-species Action Plan for the Alberta At-risk Native Trout in Canada. This plan includes recovery strategies and action items to protect Alberta’s three native trout at risk: Rainbow Trout (Athabasca River populations), Bull Trout (Saskatchewan – Nelson Rivers populations), and Westslope Cutthroat Trout (Alberta population). These species were listed on schedule 1 of the Species at Risk Act (SARA) as endangered in 2019, threatened in 2019, and threatened in 2013, respectively.

Our full letter can be found below, or at the PDF link: AWA Comments on the Proposed Multi-species Action Plan for the Alberta At-risk Native Trout in Canada.

To Whom It May Concern,

Alberta Wilderness Association (AWA) appreciates the opportunity to provide comments on the proposed Multi-species Action Plan for the Alberta At-risk Native Trout in Canada.

Founded in 1965, AWA strives to help Albertans understand the intrinsic values that wildlife and wilderness provide and encourage communities to participate in conservation initiatives that will ensure a legacy for future generations. With over 10,000 members and supporters across Alberta and around the world, AWA is dedicated to conserving Alberta’s wild spaces and species and advocating for conservation strategies that protect Canada’s biodiversity.

AWA supports greater protection for Alberta’s tributaries and the native freshwater fish and other species that rely on them, especially our native coldwater trout. We appreciate the time and effort that has gone into creating the Multi-species Action Plan. AWA supports the grouping of these three at-risk species into one action plan due to significant overlap in recovery needs, as well as the ability to implement protection strategies more quickly across broader ranges of native trout habitat. We would like to reiterate that each species must also be considered individually, and conservation measures must be addressed according to the needs laid out within each individual Recovery Plan. Please see the following for AWA’s detailed comments regarding the proposed Multi-species Action Plan.

Comments on The Plan

The Action Plan notes in the Executive Summary that “Climate change is also a threat to these species, reducing suitable habitat and increasing risks such as the spread of non-native species, pathogens, diseases, and displacement by warmer water species.” However, it is specifically stated that there are no actions included in the Plan to directly address the impacts of climate change on these species at risk. It should be stressed that climate change mitigation strategies in the province, monitoring of how warmer and changing climatic patterns are influencing native fish, and how native fish can be best supported in a changing climate should all be included within this Action Plan. It is not sufficient to assume that other conservation strategies will be enough to support native trout recovery in a changing climate.

More research into bull and brook trout hybridization potential should also be incorporated in the Action Plan. Franks et al. (2025)[1] found that bull/brook trout hybridization is occurring throughout the Eastern Slopes of Alberta, although the resulting offspring likely have a reduced ability to reproduce. Still, any form of hybridization reduces the potential population of genetically pure native bull trout and may lead to further species decline and lower reproductive success. This Action Plan should list further monitoring and prevention of hybridization between these species as a higher priority, as well as incorporate the new research by Franks et al. on the subject in the background information, as it was not available when the Recovery Strategy for bull trout was developed. Habitat remediation and brook trout removal should be prioritized as actionable ways to restrict the threat of hybridization between these species.

Some of the prioritized outreach and education components of the Action Plan focus on the efforts of the Alberta Native Trout Collaborative (ANTC) and their associated branch, the Native Trout Communication Collaborative. This collaborative received funding through the Canada Nature Fund for Aquatic Species at Risk (CNFASAR) from Fisheries and Oceans Canada, which has now been discontinued. As a result, the ANTC has been disbanded. The Action Plan must emphasize how education and outreach, as well as the on-the-ground restoration work completed by the ANTC, will be substituted in the final version of the Plan, whether by the member organizations of the former ANTC, a new coalition, or new funding projects to re-establish the ANTC.

The lead and partner(s) column within the Implementation schedule (1.3.1) lists each strategy as being under the jurisdiction of “DFO and others”. The specific project partners and leads for these strategies should be properly defined within this section to maintain accountability and ensure that the work is being accomplished in a timely manner by all involved parties. Additionally, as partner and collaborator funding is reduced or eliminated, such as in the case of the ANTC, the Action Plan should include safeguards and contingencies to ensure that critical work delegated to the partner organizations is still accomplished, with backup support networks clearly defined.

The Action Plan must also be more specific about what rules and regulations will be created and enforced to mitigate the ongoing impacts of industrial disturbances within and near trout critical habitat. Although SARA critical habitat orders have been put in place for these species at risk, these are not always sufficient to protect areas or species from destruction. Exceptions are granted frequently in Alberta to allow the destruction of critical habitat for industry, and industrial activities often do not meet the habitat protection requirements put in place to safeguard these species. The Action Plan must include stronger regulatory requirements for industry that cannot be bypassed by Ministerial discretion or exemption permits.

As demonstrated in AWA’s recently published report, A Review of Timber Harvest in the Oldman Headwaters, with Observations on Species at Risk Trout Habitat[2], DFO has granted numerous exemptions to regulations put in place to protect native trout. Additionally, mitigation measures undertaken by forestry companies such as West Fraser Cochrane are often missing or ineffective. In addition, multiple coal mining companies hold active leases within trout critical habitat areas and are in the process of exploratory or mining work in these regions. It is evident from the scientific research[3]^,[4],[5],[6] that coal activities release sediments and contaminants into waterways at elevated concentrations that are harmful to aquatic species like native trout, which best available practices and preventative measures have been insufficient in addressing.

The Action Plan must include detailed requirements for reducing the number of DFO-granted exemption permits and instill more rigid requirements for companies when installing and maintaining mitigation measures near critical habitat. Alberta’s native trout must be prioritized within these sensitive areas, with the Action Plan reflecting strategies to reduce industrial activity in these areas when possible, and stronger mitigation measures being implemented when the first option is not feasible. Related to this, Strategy #2 in the implementation schedule, “apply cumulative effects considerations to manage effects of resource extraction, land, and water use,” should be listed as high priority, as it is likely to have an immediate and direct influence on the species.

The following recovery measure should be added to Table 2 in the implementation schedule (section 1.3.1): amend the proposed Coal Mining Effluent Regulations (CMER) so that all effluent quality standards are compliant with the Canadian Water Quality Guidelines for the Protection of Aquatic Life. Stringent standards on effluent would reduce the threat to water quality from coal mine effluent and address objectives 1, 2, and 3 in the Multi-species Action Plan. This recovery measure should be a high priority with a short-term timeline, as the CMER itself is long overdue, having undergone almost a decade of engagement at this point.

Table 2 in the implementation schedule (section 1.3.1) should also be amended to include the recovery measure: Reduce public and industrial access to areas bordering critical habitat as required. Although recreational impacts are included within outreach strategies, there must also be options in place to prevent access to certain areas if negative impacts on native trout are found to be increasing.

Finally, 10 years for the implementation of high-priority topics is too long for meaningful trout recovery. Freshwater Conservation Canada stated in 2020 that “Future declines are predicted to be 10-70%, 10-100% and 50-100% for Westslope Cutthroat Trout, Bull Trout, and Athabasca Rainbow Trout, respectively, within the next three generations (15-30 years) based on their current depleted state and current practices[7].” We are already 6 years into these continuing declines, and action to halt and reverse diminishing populations must be taken as soon as possible to prevent population losses that are unrecoverable.

Thank you for considering these comments and concerns for the proposed Multi-species Action Plan for the Alberta At-risk Native Trout in Canada. We look forward to seeing the finalized version of the Plan.

Sincerely,

ALBERTA WILDERNESS ASSOCIATION

Sara Heerema

Conservation Outreach Specialist

References:

[1] Franks, E. R., Kissinger, B. C., Amish, S., Post, J. R., & Mee, J. A.. (2025). The extent of hybridization between bull trout (Salvelinus confluentus) and brook trout (S. fontinalis) across Alberta’s Eastern Slopes. Canadian Journal of Fisheries and Aquatic Sciences, 82, 1-13. https://doi.org/10.1139/cjfas-2025-0004

[2] Alberta Wilderness Association. (2026). A Review of Timber Harvest in the Oldman Headwaters, with Observations on Species at Risk Trout Habitat.

[3] Cooke, C. A., Graydon, J. A., Luek, A., Lu, X., Yu, H., Le, X. C., & Reichert, M. (2025).Fish Remain High in Selenium Long after Mountaintop Coal Mines Close. Environmental Science & Technology.

[4] Cooke, C. A., Emmerton, C. A., & Drevnick, P. E. (2024). Legacy coal mining impacts downstream ecosystems for decades in the Canadian Rockies. Environmental Pollution, 344, 123328.

[5] Storb, M. B., Bussell, A. M., Caldwell Eldridge, S. L., Hirsch, R. M., & Schmidt, T. S. (2023). Growth of Coal Mining Operations in the Elk River Valley (Canada) Linked to Increasing Solute Transport of Se, NO3–, and SO42– into the Transboundary Koocanusa Reservoir (USA–Canada). Environmental Science & Technology, 57(45), 17465-17480.

[6] Foster, M. J., Storb, M. B., Blake, J. M., Schmidt, T. S., Nustad, R. A., & Bussell, A. M. (2024). Evidence of Long-Range Transport of Selenium Downstream of Coal Mining Operations in the Elk River Valley, Canada. Environmental Science & Technology Letters, 11(8), 856-861.

[7] Freshwater Conservation Canada. (2020, February 10). What’s Threatening Native Trout in the Canadian Rockies?