Friday, June 24, 2011

The Top Ten Reasons DFO's 2011 IFMP Steelhead Objectives Suck:

The Top Ten Reasons DFO's 2011 IFMP Steelhead Objectives Suck:

Here 2011 North Coast IFMP is the Skeena steelhead objectives section copied from the 2011 Integrated Fisheries Management Plan ( IFMP). As you can see, DFO has again seen the need for an explanation as to what has gone on with steelhead over the years. Note, there is no explanation of how things will be done better this year, or in the future, just more of the same old tired rationale.
1.) The reliance on statistical Modelling:
The major problem with the steelhead section is the DFO thinking behind it as evidenced by the inclusion of all the Modelled impacts. This reflects DFO's desire to keep using these flawed methods. Why is the Department so focussed on telling us what a great job they've done over the years limiting impacts on steelhead? Why is the Department focussing so much on the results spewed out by a statistical Model whose usage was totally discredited by the Skeena ISRP Report from 2008? The inclusion of all the Model results shows DFO wants to keep using statistical Models to help manage the fishery and to continue with some form of agreed upon allowable kill of steelhead. This is totally contrary to what our group and the general public have loudly told the Department since 2006: there is no more agreed upon acceptable amount of steelhead to be killed by the commercial industry in pursuit of their activity. The Department still hasnt absorbed the reality of a new paradigm in Skeena: commercial fishing has sunk to a barely viable activity while recreational sportfishing for steelhead has become a hugely successful economic contributor to the region. The socio-economic pendulum has swung away from commercial fishing yet DFO has refused to accept this fact and still manages the fishery as though we are in the heyday of commercial fishing.

2.) The refusal by DFO to acknowledge new paradigms in fishery economies:
By touting the same old management and enumerative methods, DFO is refusing to acknowledge the transition that has occurred in commercial fishing and sportfishing over the last decade. A new paradigm exists in Skeena for these activities that are headed in different directions; commercial fishing has been losing value for many years while sportfishing is on the rise. DFO steadfastedly refuses to acknowledge these facts as evidenced by their continued avoidance of dealing with non-selective capture methods and ensuring other fish capture methods are properly regulated and enforced to minimise negative impacts on valuable non-target fish such as steelhead.
We characterise the situation like this: steelhead are like $2000 dollar bills swimming back upstream...this valuable commodity is being stolen from upriver communities and users by commercial fishermen too lazy and uncaring to fish responsibly. The fishermen are aided and abetted in this theft by a management agency unwilling to enforce its own policies and regulations for fear of political retribution from industry, unions, and coastal town councils.

3.) The IFMP Steelhead Section is a recipe for status quo:
The IFMP regurgitates the same tired old measures that DFO claims are selective in nature; daylight only fisheries, weedlines, time and areas closures, short net/short set for gillnetters, etc.etc. All these measures have dubious efficacy for steelhead, and as this blog has discussed in the past and the Skeena ISRP Report confirmed, most of these measures if they have been required have not been adequately monitored or enforced. The ISRP Report goes even further stating "The whole notion that traditional gillnet fisheries can be made selective, and more broadly that captured fish can be released with high survival rates from any commercial fishing operation (seien,gillnet, or beach seine) must be viewed with suspicion. The only really reliable 'selective fishing' practices are those that avoid capture of non-target species in the first place."
And yet, DFO continues to ignore this type of advice and proceed with their weak generic 'selective measures' that are also poorly enforced or monitored. Furthermore, DFO wants to again proceed to add these specious practices into their statistical Models to arrive at supposed impacts on steelhead. The public has had enough of this poor approach to the issue it is time for systemic change. If, according to the ISRP Report, avoidance is the best selective measure then why is commercial fishing allowed to occur in the worst places and times for steelhead migration? Why are fishers allowed in historically high interception areas such as the Skeena rivermouth, or the River-Gap-Slough area?
Why isnt the Department telling us what they will do to eliminate the bycatch issue THIS YEAR? Where is the verbiage outlining measures to be taken to minimize steelhead encounter rates? Where is the verbiage outlining the strong enforcement presence that will ensure high commercial fisher compliance rates crucial for steelhead survival after encountering commercial nets?
Note, the recent low steelhead exploitation rate percentages have absolutely nothing to do with DFO management changes or new measures aimed at reducing steelhead bycatch by commercial fishermen. The low exploitation rates are solely due to lack of commercial fishing activity due to low sockeye returns. Basically, since the uproar over the 2006/07 seasons DFO has done nothing to directly address the steelhead bycatch issue.

4. The DFO steelhead position in the IFMP completely ignores the Province's steelhead objectives:
While focussing on statistical modelling in an effort to try and tell the public that steelhead are only impacted lightly by commercial fishing nowadays, the Department conveniently ignores what the Province wants for steelhead. The Province has very clear objectives for steelhead: The Ministry of Environment's long term steelhead management objective is to reduce non-selective fishery mortality rates for steelhead to negligible levels so as to maximize steelhead escapement and the social, economic and ecological benefits that a robust Skeena River steelhead population provides..."
As a reflection of DFO's disdain for the Province and steelhead, they basically just copy and paste the Province's Steelhead Objectives into the IFMP and leave it unsupported by any accompanying verbiage on how DFO will meet, or even attempt, to meet those objectives. DFO pays lip service to 'working with' their Provincial counterparts on the steelhead bycatch issue, yet only one meeting per year occurs between the two agencies on the topic. This is a longstanding issue that reflects DFO's disgusting lack of respect for both steelhead and the sportfishing sector.

5. The Dept's IFMP Steelhead Section panders to commercial interests again...:
By not requiring so called 'selective gillnet' measures all season, the Department panders to the commercial lobbyists who claim such methods are a hardship on their members. This is an amazing but true statement from fishing Union lobbyists that commercial gillnetters are too old to utilise the short set/short net technique all day for a 16 hour opening. They make the case that it is somehow 'unsafe'...and even more amazingly DFO buys their sob story and negates this requirement.
Even worse, DFO now states such selective gillnet measures will only be utilised when a conservation concern is evident...again pandering to commercial fishing lobbyists who cry they are over-regulated and shouldnt have to use selective measures unless conservation is a concern. We wonder how DFO rationalises this on the broader scale: what about Skeena chum stocks that have been depressed for over a decade now?? Arent they a 'conservation concern' worthy of being afforded selective gillnetting techniques?
Moreover, the root of the word conservation seems to be 'conserve'...i.e. not to waste....yet DFO wilfully allows valuable Skeena steelhead to be wasted in commercial fisheries that have become barely viable in recent years. How is that managing the resource in the interests of all Canadians?

6. The Dept's IFMP Steelhead Section exposes the blatant double standard that DFO has towards steelhead:
DFO displays a particularly disgusting double standard when it comes to Skeena steelhead: the Dept feels comfortable unilaterally deciding how many steelhead are adequate for the resource, the sportfishery, and the upriver tourism industry...yet, when it comes to any conservation measures to protect this valuable fish the Department claims it has to consult with 'other users' to ensure any measures are acceptable to them. Basically, DFO is saying 'we'll tell you sporties how many fish are good enough for your business or recreation, but we have to ask the commercial fishermen for permission before we do anything to conserve them'. The double standard from the Department shows a complete lack of respect for steelhead and its users. Moreover, the Dept's double standard further reinforces the apparent bias towards commercial extraction when commercial fishermen get such an opportunity to comment on and possibly veto any steelhead conservation measures. The loss of the requirment for short set/short net gillnet issue is a prime example of this double standard by the Dept.

7. The IFMP Steelhead Section completely ignores the promises DFO made to the MSC
In the conditional approval of the Skeena sockeye fishery by the Marine Stewardship Council, DFO made numerous commitments to address steelhead bycatch and improve the selective nature of commercial fishing capture techniques overall. The 2011 IFMP reflects none of these commitments....not even small initial steps to start to try and address the commitments.
This is no small point as without Certification fish sales into world markets could be severely curtailed.

8.The IFMP Steelhead Sections sucks because of no forward movement on the bycatch issue:
Here we are in 2011, almost 5 years after the 2006 season debacle and corresponding sports sector uproar that led to the Skeena Independant Science Review Panel Report and the Economic Study of Skeena Steelhead and Salmon, yet this IFMP shows absolutely no forward movement on addressing the steelhead bycatch issue. It seems DFO's overriding concern continues to be to not add any further negative impacts to an already ailing commercial fishing industry. Couple this short sighted DFO attitude with steelhead being in a fair to good ocean survival cycle and DFO thinks it can just ignore steelhead concerns for a while.

9.The IFMP downplays the impacts of the seine ITQ fishery:
Just because seine fishing can be more selective than other capture techniques this 'potential' isnt a guarantee of high non-target survival rates. As with any other 'selective' measure, the effectiveness of the technique is directly related to the effort put in by the crews doing the fishing. Seine crews actually have to be committed to fishing responsibly or the 'inferred' selective nature of seining is lost. Where in the IFMP are the guidelines for proper brailing or small size brails to ensure non-target fish dont get squished in the brail? Where in the IFMP are the enforcement and monitoring sections which state the frequency and nature of Fishery Officer patrols. Where are the IFMP sections outlining camera monitoring on commercial boats to ensure, or at least aid in, selective measure compliance?
These sections are nowhere to be found, yet one section does mention that seine non-compliance continues to be a concern: page 71 "Seine fishery release compliance remains a significant concern, and maintaining harvest opportunities will directly linked to successful live release of the bycatch."

What a lame threat to include in the IFMP as when have we ever seen a fishery opening shut down due to these types of concerns? Pure lip service due to the fact that Fishery Patrols are rare events and when they do happen the effectiveness is far removed from the verbaige contained in any DFO documents.

10.The Steelhead Section of the 2011 IFMP sucks because the overall goals stated by DFO are insufficient to fully protect steelhead:
DFO's objective for Skeena steelhead is "...The objective for Skeena steelhead, as well as all north coast steelhead, is to maintain healthy stocks and rebuild weak stocks."

Wow, what an underwhelming objective for such a valuable fish as steelhead. With such a vague and non-descript objective as this its no wonder DFO could apparently care less for steelhead. More worrying is the idea that with similar such goals DFO North Coast 'managed' Smith/Rivers Inlet sockeye into near extinction and are well on their way to doing the same for north coast chum salmon. One wonders how a fish worth literally thousands of dollars each to the Provincial and Canadian economy can be so marginalised by the Department. The value of a single steelhead far outweighs the value of any target fish caught in commercial fisheries yet the Department continues to relegate this valuable fish to 'pest' status.

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