NCSA Critique of the 2009 Draft IFMP

Here is a copy of the NCSA Critique of 2009 Draft IFMP (Fishing Plan).
We were invited to meet with North Coast Area Manager David Eiarson to discuss the DFO document and our concerns with it. But, after careful consideration we passed on that invitation. This stems from the fact that Mr Einarson is the same person who has been in charge of managing the Skeena fishery for years. He is the person who brought us the 2006 debacle that started the whole fishery management furore in Skeena. Expecting any change in management from brief discussions with someone so entrenched is not likely...hence our decision to decline his invitation. We believe efforts and energy would be better expended on a more regional scale rather than at the north coast level.
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NCSA 2009 DRAFT IFMP Feedback/Critique

A.) Sockeye exploitation rate:
The NCSA agrees with the outline presented by Skeena Wild that DFO’s proposed lower sockeye exploitation rates are still above levels outlined by the ISRP.
The sockeye exploitation rate issue requires further examination to clarify the assertions made by Skeena Wild copied below.

DFO derived the 20-30% exploitation rate schedule described in the draft IFMP from data and recommendations taken from the “Report of the Skeena Independent Review Panel” (ISRP). Unfortunately, DFO calculations are incorrect. The 20% to 30% exploitation rate schedule shown in the draft IFMP exceeds the ISRP’s recommendations for Canadian commercial exploitation rates by as much as 30%.

DFO has also explicitly referenced ISRP exploitation rate recommendations in its draft MSC action plan as a strategy to ensure MSC conditions to protect weak stocks of concern are met.(p.16). The Department is putting MSC certification at risk by not following the ISRP recommendations in the 2009 IFMP.

We strongly urge the Department to employ a Canadian Commercial Exploitation Rate Schedule of between 15% - 25% as recommended by the ISRP.

Additionally, we would comment that whatever sockeye exploitation rate is finally attained be conservative enough to ensure that weak, wild sockeye stocks of concern such as Nanika, Slamgeesh, and Kitwanga are protected and allowed to rebuild.

Moreover, we wholeheartedly support conservative sockeye exploitation rates that guarantee First Nations access to their traditional food fisheries.


B.)Weekly harvest rates/Aggregate rate
The NCSA also agrees with Skeena Wild on this proposal. The idea that harvest not attained in certain weeks will be carried over to the following weeks in the season seems like an unwise proposal. This is because of several reasons including; DFO does not have the capability to adjust harvest between weeks as the Tyee Test Fishery is a proven unreliable measuring tool and harvest added to subsequent weeks could raise harvest rates into unsustainable levels for weak, wild sockeye stocks.
Moreover, this proposal for ‘harvest to be carried over’ could result in some weeks having incredibly high harvest rates of over 50 or 60% during peak steelhead migration timing. Obviously, such high harvest rates would inflict substantial bycatch impacts on Skeena steelhead. We find this ‘carryover’ scheme to be of incredible importance and cannot agree with any proposal that potentially allows such high weekly harvest rates.

Because of the uncertainty around the ‘carryover’ scheme, it appears there is a need for a daily or weekly plan that is written out or formalized somehow, that outlines the mandatory conservation measures in place for that time period. This would give all concerned a clear perspective on what is occurring and why.

C.) Tyee Test Fishery Uncertainty
There is nothing substantive in the IFMP to deal with the situation like 2008 where the Tyee Test Fishery was found to have overestimated by 36-38%. Where is the hard evidence of precaution built into management to prevent overharvest and over-exploitation of steelhead? It is simply unacceptable to allow commercial fishing first and then figure out the impacts three or four months later.

D.) Selective Fishing:
The only substantive change from 2008, or any other season, is the mention of cameras on board seiners.
If implemented this measure could assist in selective fishing compliance by the seine fleet. However, there is no mention of steps to validate the efficacy of the measure via dockside corroboration of catch, for example. Further, there is no mention of substantive penalties for non-compliance either with the camera implementation or with non-compliant acts viewed via the camera.

Moreover, since this enforcement program will be undertaken via a private contractor it raises questions regarding integrity and veracity. Is the contractor an outside entity, not based in Prince Rupert, who will review the camera hard drives in a completely unbiased fashion? Who overlooks their work?
We feel if DFO is going to the extent of utilizing such a monitoring program, then it might as well make sure it is a useful tool that all sides of the issue have confidence in.

The camera proposal also only deals with the seine fleet. There are no new selective measures in the Plan for 2009 aimed at gillnet fleet selectivity and compliance.
There is the usual mention of weedlines, short sets/nets etc, but no mention of how or when these measures will be implemented or whether they will be utilized at all.
There is no mention of specific location closures to avoid steelhead encounters.
Basically, there is a lack of specifics and generally no change from any previous years in terms of selective fishing measures.

E.) Consultation:
There is a huge gap in DFO consultation in this Plan: It appears whenever the term ‘industry’ is used, it is apparently used in reference to the commercial fishing industry. However, as the 2008 Blewett Skeena Economic Survey shows quite clearly that another industry presently dwarfs the economic contribution of commercial fishing and that industry is the recreational sportfishing tourism industry. The 2008 Blewett Skeena Economic Survey showed a total economic contribution of $54 million dollars for Skeena sportfishing while showing only $15 million for the commercial fishery.

It does not make economic sense for DFO to continue to allow one industry to monopolize the use of the salmon resource, especially in light of the above economic contribution comparison. Moreover, the Blewett Survey highlighted the fact the commercial industry actually lost money during the time period covered by the study. Furthermore, with an expensive DFO management system required to implement commercial fisheries, the commercial fishing industry is actually heavily subsidized by the general public.

Nowhere in the Draft IFMP is consultation with the sportfishing tourism industry mentioned as being sought out for input into the Fishing Plan. Nor is it mentioned at the IHPC level. Current composition of the SFAB, the formal DFO consultation conduit, does not represent this most important sector. There is no one who attends the one or two meetings per year in Smithers for the Upper Skeena SFAB representing the sportfishing tourism sector. Evidently, there is basically no consultation with the industry that generates far more economic benefit to the Province than the commercial fishing industry does. Why is this situation so skewed in favor of commercial fishing? This historical bias by DFO needs to change as it does not reflect the new economic realities.

The concern generated over the recent Quality Waters System surely reflects a huge interest in fisheries issues by upper Skeena communities and this constituency is not being heard in this IFMP process. This lack of consultation with such an important industry is a major flaw in the Draft Plan that requires addressing for 2009 and the future. It is no longer adequate to only consult commercial and recreational fishermen. The socio-economic aspects of fisheries in the Skeena region require DFO to consult more broadly with local Town Councils, Chambers of Commerce, and Tourism Associations, especially in upper Skeena communities such as Houston, Hazelton, or Smithers.

At present, there is no evidence of anything in the 2009 IFMP that addresses the concerns of the sportfishing tourism industry. Concerns such as steelhead bycatch are not given near enough the level of importance they should be. And with the economics of the fishery clearly tilted in favor of the sportfishing industry why this is not a major management input is astonishing. It appears that to DFO the only ‘industry’ in the Skeena region to consult with is the Prince Rupert based commercial fishing industry.

F.) Steelhead Bycatch:

There is no mention of any Provincial Ministry of Environment goals and objectives for Skeena steelhead in the Draft IFMP. Why is this?

There is also evidently no new DFO measures in the Draft Plan aimed at steelhead bycatch for 2009. One could argue the seines/cameras proposal is aimed at increasing compliance with selective fishing measures, which could assist steelhead survival. But on a practical level there are zero new initiatives in the Plan directly aimed at reducing or eliminating steelhead bycatch.

The lack of any new initiatives clearly sends the message out that DFO is content with the present steelhead bycatch impact. This seems contrary to the DFO submissions to the Marine Stewardship Council on the subject of certification for the sockeye fishery.

Additionally, the same management system that failed miserably with regard to steelhead bycatch in 2008 is touted for use again in 2009. The measuring device (Tyee Test Fishery) is the same: the enforcement regime is the same; the supposed ‘precautionary approach’ is the same….and none of these measures worked in 2008 so why should we, or more importantly DFO, presume they’ll work in 2009??

The Tyee Test Fishery failed by overestimating the sockeye run, thus allowing managers perceived freedom to allow increased commercial fishing, which in turn caused significant steelhead bycatch impacts. (Anecdotal claims by commercial fishermen in 2008 related very high steelhead catch and encounter rates.) Thus, no precautionary approach could be seen to be in evidence in 2008.
The enforcement regime failed to properly monitor the fleets for compliance with selective measures, thus further contributing to steelhead bycatch impacts. As an example of lackluster enforcement in 2008, on opening day for the gill net fleet C&P supposedly ”…sent a strong message to the gillnet fleet that enforcement would be strong…” by checking a total of 3 gillnetters out of 350+ boats participating in the opening. And to drive the point home, all three gillnetters were found to be out of compliance…..3/3….100% non-compliance on the miniscule number of boats they checked.


Also, the assertion that lowering the overall commercial sockeye catch is a direct ‘selective measure’ is hard to accept, especially when the scale of the commercial fishing effort is still an industrial scale endeavor. Whenever 350+ non-selective gillnetters are allowed to fish, their effort will surely cause substantial bycatch impacts on valuable non-target species like steelhead.

With no new measures or initiatives in the Draft IFMP for 2009 DFO has failed to address the non-selective gillnet issue yet again.

From the IFMP:
The objective for Skeena steelhead, as well as all north coast steelhead, is to minimize commercial impacts.
Steelhead retention throughout BC is not allowed in commercial fisheries. The Skeena fishery, as well as others, is shaped to avoid steelhead encounters, and when encountered, to increase the likelihood of steelhead surviving the encounter. Various methods such as weedlines (used partially in Areas 3, 4, and 5 and in approach waters to Dean Channel), daylight fisheries, timing, boundaries, revival tanks, short sets and nets, and other methods are used at various times and areas to minimize commercial impacts.

The passage quoted above from the IFMP is completely inadequate in our opinion to describe the requirements for Skeena steelhead. Firstly, the objective needs to be changed to ‘eliminate’ the bycatch mortality of steelhead. This would signal a true desire on DFO’s part to address the issue of steelhead bycatch.
As for the methods cited to ‘minimize’ steelhead bycatch, none of these are any good if there is little compliance or utilization by the gillnet fleet. Moreover, there is no wording in the Plan that actually states these measures will be fully utilized and for how long.

And lastly, to repeat from previous NCSA critiques of DFO fishing plans, there is little scientific basis for the supposed efficacy of any of these selective gillnet methods anyway. So, to tout using unproven techniques to ‘minimize’ a most important issue such as steelhead bycatch, just reinforces our belief that DFO has absolutely no concern over Skeena steelhead at all.

Steelhead Cont’d.

Additionally, the quote:
The Skeena fishery, as well as others, is shaped to avoid steelhead encounters, and when encountered, to increase the likelihood of steelhead surviving the encounter.

We would have to point out that this phrase does not seem to align with the Draft Plan’s proposal to ‘carry over’ unattained harvest from one week to the next in-season. For example, if unattained harvest accrues toward weeks of peak steelhead migration, and the fishery managers sanction concentrated commercial openings to reach the harvest goals, the resulting steelhead bycatch could be significant. This situation does not at all lend itself to being described as “…shaped to avoid steelhead encounters….” In fact, it could lead to quite the opposite effect: concentrated commercial fishing during the peak steelhead migration times.

If the sockeye fishery, or any other fishery, was truly shaped to avoid steelhead encounters there would be no commercial fishing in known high steelhead interception areas such as the River-Gap-Slough area. If the commercial fishery was truly shaped to avoid steelhead encounters, there would be no gillnetting allowed.

G.) Other Issues of Note:

Draft IFMP and MSC Certification:

The 2009 Draft IFMP is very similar to the DFO Action Plan submitted to the MSC recently: they both lack specifics and they both lack clear commitments to act on conservation or bycatch issues.
In our opinion, the 2009 IFMP does not address any of the conditions laid out for certification by MSC nor does it move the fishery any closer to addressing the conditions laid out by MSC.

Chum salmon:
Management Area 3 commercial gill net ribbon boundary on Pearse and Wales Island shore has been modified. This shoreline is a known chum migration route, and the change in the ribbon boundary closed area is to prevent gill net vessels targeting on chum salmon, providing increased protection to Area 3 chum stocks.

With chum salmon on the north coast being in such a depressed state any changes to ameliorate the effects of commercial fishing on them should be applauded. But, shouldn’t this type of minor change be part of a much larger recover plan for chum salmon?
Shouldn’t such a plan include more direct measures than just a small location closure? Remember, in 2008 DFO allowed 5 days of fishing in Area 3 up to July 15th, where only 27,000 sockeye were caught but 14,000 chum salmon were killed as bycatch. That seems an excessively wasteful fisheries management approach for a stock of such conservation concern. Moreover, with management actions like those of outlined above, why would DFO think changing a ribbon closure would mitigate such intense commercial fishery impacts on chum salmon?

Allocation Policy:
The Allocation Policy for Pacific Salmon identifies the priority for allocation of salmon harvest and sets sharing arrangements for each of the three commercial fishing gear groups. The target gear share is 40% seine, 38% gill net and 22% troll. The CSAB provided advice to the Department on 2009 sharing arrangements in April 2009. For 2009, the sharing arrangements based on pre-season estimates of expected harvests are estimated to be 39% seine, 34% gill net and 27% troll.

This passage in the Draft IFMP is of concern to us. We would question why this allocation sharing arrangement is in any IFMP when it appears to preclude numerous other objectives of the Department.
How can other objectives, such as The Selective Fishing Policy, be fully implemented when there is an overarching agreement in place to ‘allocate’ certain percentages to non-selective gear types? The two policies appear to be at complete odds with each other. How does DFO allow such contradictory policy statements as these two in the same planning document?
Allocating a guaranteed access and amount of catch to an outdated non-selective gear type surely precludes any real change towards true selective fishing in our opinion. The apparent contradictory policies in the Draft IFMP further highlight systemic flaws in overall DFO fishery management.

More contradictory language:
8.5. Domestic Allocation Objectives
The objective is to manage fisheries in a manner that is consistent with the Allocation Policy for Pacific Salmon and the 2008 Pacific Salmon Allocation Implementation Plan.
While fisheries were managed to address conservation objectives, they were generally conducted in a manner consistent with the Allocation Policy for Pacific Salmon. However, inconsistencies (and significant levels of disagreement) exist regarding the allocation of by-catch .page 93

There are several mentions of bycatch and whether it is ‘allocated’ or not. This passage quoted from page 93 of the Draft IFMP implies bycatch is allocated. While the passage from page 40 states:
All harvest groups have recommended that the Department consult on by-catch/incidental harvest allocations. However, the Department does not allocate by-catch or portions of the acceptable exploitation rate on stocks of concern. Rather the Department considers a number of fishing plan options and attempts to address a range of objectives including minimizing by-catch and incidental catch. Page 40
If the Department really does not ‘allocate’ bycatch then why is there the inconsistency shown in the Draft Plan wording?