NCSA Letter to DFO March, 2009

Here is a letter we recently sent to the DFO Regional Director General Paul Sprout. He is absically in charge of the DFO Pacific Region and is 'the boss' supposedly of the North Coast DFO office.




Mr Paul Sprout

Regional Director General

Pacific Region

Department of Fisheries and Oceans



March 9, 2009



Re: Skeena Fishery Management in 2009


Dear Mr Sprout,


We are writing to voice our concern over the lack of any concrete action plans with regard to the issue of Skeena river fishery management. Specifically, we are concerned that with just three months to go before the traditional start of commercial fishing in the area, your North Coast office has done absolutely nothing in the way of systemic change. Granted, planning and consultation is under way for possible input into the 2009 IFMP process, but even in this DFO North Coast has shown no appetite for major change.


It is now 10 months since the Independent Science Review Report came out and 4 months since the Economic Dimensions of Skeena Salmonid Fisheries study was released. The North Coast office of DFO has not implemented any substantial changes to fishery management that reflect either of these documents.


And with only three months to go before commercial fishing starts up again, we feel the likelihood of status quo in Skeena fishery management to be a very real possibility, even a probability. Why does your Department, and more specifically the North Coast office, continue to stall or prevent any positive change from occurring in the management of this fishery?


The ISRP Report clearly laid out fundamental shifts that should occur for this fishery to move towards sustainability and the Blewett Economic Report clearly shows the importance of the sport fishery in comparison to the commercial fishery, so why has no systemic change seriously been planned or even contemplated?


If you refer us to the current Skeena Watershed Initiative as the main conduit for discussing or planning possible change, then we would say this process is not being fully utilized by DFO for credible discussion. I have sat through this entire process and have yet to hear or see any concrete DFO positions on systemic change either presented or referred to. And with the major ‘trade-off’ discussions not even scheduled yet how can our group believe any serious change will occur for 2009 when these discussions might only occur weeks prior to the opening of the season? It does not seem realistic to believe your Department would wait until the last possible minute to announce major change in the management of the Skeena fishery, so we are left to presume 2009 will not see any major change and we are back to status quo.


Moreover, in the two public SWI meetings with sizeable cross sector attendance, I have yet to hear one concrete position on moving towards a sustainable fishery from North Coast staff. Their major focus, repeated ad infinitum, seems to be the uncertainties of climate change and ocean survival and how they ‘might’ effect future management with zero acknowledgement of or emphasis on the impacts of non-selective fishing methods on non-target species.


And given how the SWI discussions are progressing, it would appear to us that in 2009your Department plans to just tinker further with harvest rates in yet another failed attempt to find the management middle ground that will try to please every sector somewhat, but leave the fish, especially steelhead as losers. Furthermore, with the unreliability of the DFO assessment tools, such as the Tyee Test Fishery (38% overestimate in 2008), how anyone believes that your Department can manage to within single digit percentage point accuracy in harvest rates for sockeye, or any other stock, is of major concern to us, if this is the sole DFO strategy to be utilized in 2009.


Thus, in 2009 it appears to us status quo will reign and we will probably again see over 300+ non-selective gillnetters wreaking bycatch impacts on important non-target species like steelhead. And by further compressing the window of commercial opportunity in July, the negative impacts of gillnetting will be further transferred onto the early run steelhead….the very fish our group has been criticising your Department for overfishing for years. Moreover, the early run steelhead is the very fish that is most important to the sport fishing economy which, as the Blewett Report clearly shows, far surpasses the economic contribution of the commercial sector.


We don’t know how much clearer our organisation can make the point to your Department that the upriver sport fishing sector that relies on steelhead has had enough of federal bureaucrats arbitrarily deciding how many steelhead is ‘enough’ for our industry, let alone the biodiversity of the species. We have repeatedly made the point that every steelhead is valuable, yet your Department annually ‘allocates’ thousands of these fish to the commercial sector when you technically don’t even have management responsibility for them. Moreover, your own DFO policies state that bycatch is not to be allocated, yet there is no other way to describe this allowable non-target kill other than as an allocation. This situation has to stop and the systemic change to eliminate steelhead bycatch needs to start in 2009. Unfortunately for steelhead, and the associated sport fishery upstream, your Department has shown absolutely no willingness to even entertain changes in fishery management that would lead to eliminating their bycatch. There is not even a hint of a plan to address this acute problem in either the short term or long term, yet your Department has known about it for decades. This is why we are concerned over expectations for the 2009 season DFO management Skeena fishery plan.


Why does your Department continue to manage in this manner when other avenues of management are available? Why does your Department continue to subsidize a commercial endeavour that not only loses money but wreaks havoc upon important non-target species like steelhead and depressed wild salmon stocks? Why does your Department ignore its very own prime directive of conservation first? Your Department’s current management regime makes absolutely no sense to the outside observer and furthermore your Department’s unwillingness to implement any substantial change towards sustainability is even more baffling.


Political realities of the current economic downturn aside, your Department still has an obligation to protect weak stocks and manage this fishery for all Canadians by conserving (i.e. not wastefully killing) important species and stocks that contribute to upstream economies. Yet by your Department’s behaviour in 2008 you still prefer to favour one sector, the commercial industry, over conservation, First Nations food rights, or the sport fishery contrary to the Department’s own policy. Whether it is by the actual amount of commercial fishing allowed, or by the lax enforcement and monitoring of the fishing regulations, your Department’s North Coast office undeniably continues to favour the marine commercial fishing industry. And, by the way, was anyone in the North Coast office ever held responsible for the overfishing on weak stocks or steelhead that occurred due to not acknowledging the inherent uncertainty in the Tyee Test Fishery in their management actions? We know of no such disciplinary action and feel strongly that accountability is another important issue your Department should address. Possibly if there were serious consequences for a fishery manager to ignore the uncertainty of tools such as the Tyee Test Fishery and to not apply any precautionary approach, then poor decisions might not be made so glibly.


And even after receiving a broad range of advice on Skeena fishery management issues from a panel of esteemed fishery scientists recently in the ISRP Report, your North Coast office appears to be trapped in the past unable to envision a fishery any different than what occurred for the previous 100 years. How is the fishery supposed to move towards sustainability with these very same people who basically managed the fish stocks into this mess in the first place? Is there no one within your Department with the vision required to enable the change needed within the Skeena fishery?


Please take the time to assure our group, and other upriver stakeholders, that status quo will not reign in 2009. Please outline your Department’s plans for systemic change in the Skeena fishery with specific emphasis on providing both a short term and long term plan to eliminate steelhead bycatch in 2009 and beyond.


And please be assured, our organisation along with many others, will not sit idly by in 2009 if your Department appears to continue with the same management regime it utilised in 2008.


Please don’t bother having any North Coast staff write your reply, as per normal DFO procedure, as we are already well aware of their positions on these issues.


Yours truly,

K. Douglas

Chairperson

North Coast Steelhead Alliance