SFAB to DFO re: Draft 2020/21 Five Nations Multi Species Fishery Management Plan
SFAB Executive Response to DFO Draft 2020/21 Five Nations Multi Species Fishery Management Plan
March 16th 2020
Thank you for the request to provide feedback on the Draft 2020 5 Nations Fisheries Management Plan
We present this response to the proposed management plan from the perspective of the Sport Fishing Advisory Board (SFAB) representing the Public Fishery on Canada’s West Coast which has the responsibility to provide formal advice and makes recommendations to the Department of Fisheries and Oceans Canada (DFO) on matters relating to tidal recreational fisheries and non-tidal anadromous fisheries.
The local Sport Fishing Advisory Committees on the west coast of Vancouver Island are also engaged on this request for advice and are submitting local SFAC advice to you directly as well.
The SFAB executive is opposed to the proposed changes in the draft 2020 Court Defined 5 Nations fishing plan that increase the size Court Defined Fishing Area and/or those requests that increase the harvest from 2019 plan for the following reasons:
1.) The bypassing/usurping of the DFO Minister mandated Salmon Allocation Policy Review (SAP). This 4 Phase, Co-developed collaborative process with First Nations and Stakeholders, initiated in November 2019 by the Minister, is now underway with all the relevant parties participating.
Any reallocation of Pacific Fishery Resources now, in advance of any recommendations provided to the Minister from the review undermines the Canadian societal interests participating at the direction of the Minister within the SAP review process.
It is our understanding from current discussions on the SAP, that future increase or reallocation of the resource exceeding the Court decision would be made by using existing or future FN treaty negotiations and NOT by amending FN FMP’s. This should also be clearly communicated to all stakeholders and FN groups.
2.) The industrial scale of the proposed changes for Chinook, Halibut, Prawn and Crab far exceeds the court defined recommendations for a small scale, artisanal, local, multi-species fishery.
3.) The Draft 5 Nations court defined fishery FMP does not consider at all, in any way, the impacts to other “Non 5 Nations Canadians” who also rely heavily upon the existing public fishery for food, incomes and other far reaching local community benefits. We assure you that the impacts of the proposal are significant.
4.) This proposal would set a coast wide precedent if implemented. This could result in immediate “me-too” initiatives from other First Nations as it relates to Canadian natural resource allocation. This would particularly disruptive to other treaty and reconciliation initiatives underway.
Halibut Long Lines:
The SFAB does not support to the use of this commercial/industrial scale style of Halibut fishery.
• Does not meet the small scale, artisanal, local, multi-species fishery objective.
• Causes conflict amongst users since long lines eliminates meaningful opportunity for anglers fishing in the same area.
• Favours 5N quota utilization away from its own small vessels towards the industrial vessels.
• Favors large vessels, more capacity, can haul lines in poor sea conditions.
• Disadvantages to small vessels, grounds would be fished down faster making it harder for small vessels using hook and line or short long lines.
• Represents a move towards exclusive access for 5N fishers. Commercial style long lines out-fish individual hook and line gear used by anglers, results in way more fishing time, more hooks, effectively blocking off areas the public fishery uses.
• Results in increased mortality of bycatch of stocks of concern.
Hatchery Coho:
• Adipose fin clip (Hatchery) Coho are produced with public funds and mass marked with the intent to be harvested by all fishing sectors including the Public Fishery. The benefits of Hatchery origin Salmon fisheries to Canada are currently underutilized. The SFAB supports retention of hatchery Coho and Hatchery Chinook in all Canadian Fisheries consistent with the current Salmon Allocation Policy Framework.
Fishery Monitoring:
• Where the 5 Nations continue to utilize industrial scale vessels in fisheries, we support DFO’s proposal to fund VMS requirement for use on those vessels deployed in fisheries.
• Coastwide, small vessels used in First Nations Fisheries including the 5 Nations Court Defined Fishery, have the potential to be mistaken and accounted for in DFO catch estimate systems as recreational fishing vessels during multi-sector effort survey overflights. Identifying features are hard to identify, especially in less than perfect weather.
These small vessels are being counted as recreational effort, then landed creel estimates from shore or Irec interviews of recreational anglers are being applied to this overall effort count. This in addition to the 5 Nations reporting of the same catch via 5 Nations systems, unfortunately, double accounts for the 5 Nations Court Defined fishery catch in both AABM and ISBM fisheries. While the scale of this issue is unknown, we do know that some of double accounting is occurring.
A possible solution is to remove the daily reported 5 Nations effort from the overflight estimates, before extrapolating catch estimates.
A recreational fishing licence is the only means by which ordinary Canadians can have access for personal use to the Canadian common property fishery resource. We accept without reservation the right of indigenous Canadians to fisheries priority for food, social and ceremonial purposes. We acknowledge that the court has defined a right by the 5 Nations to fish and sell fish, and the access priority this implies. What we seek is ways in which the public fishery can co-exist with the 5 Nations fishery and potentially similar fisheries in other part of the coast to the mutual benefit of everyone.
In conclusion, when considering the 5 Nations FMP DFO needs to take into account the extent to which decisions on the size of particular allocations as well as the conduct of the fisheries create a precedent to be exploited by other First Nations, and that any costs associated with reconciliation should be the responsibility of all Canadians and not of particular groups of commercial or recreational harvesters who live, work or reside in these impacted coastal communities.
Respectfully
On Behalf of the SFAB Executive Committee
Martin Paish
Sport Fishing Advisory Board, Main Board Chair.
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The 5 Nations Multiple Species Management Plan referred to above is a lengthy pdf file. I do not know how to link or post that from this end. Any who wish to view that background material pm me with your email address.
Regards,
Nog
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Originally Posted by Bear Brawler
