Saturday, August 06, 2011

DFO reply to our email

Let's quickly examine the RDG's reply to NCSA:
1.Page 67 NC IFMP:
The pre-season estimate for 2011 is predicted to be between 800,000 and 3,500,000 sockeye, with a point estimate of 1,700,000; therefore, only a small fishery is expected. This run size will allow for an estimated four (4) days for gillnet fishing based on recent average fleet sizes, distribution and catch rates

This gives both the forecast and estimated amount of gillnet fishing. It clearly states 4 days gillnetting not 5 as you infer.

The most recent return estimate for the sockeye run is approx 1.6 million. This is very close to but not more than the IFMP estimate of 1.7m. How has this "more fish" idea been arrived at? If you were going to allow 4 days gillnetting at 1.7m how did we get to 6 openings (as of Aug7th) for less fish??

2.Short set/short net:
Weak stocks and non-target species cannot be 'protected' via any gillnet, however dressed up it is. Avoiding having fish come in contact with a gillnet in the first place would be a form of 'protection'. Remember what the ISRP Report stated: 'avoidance' is the best selective tool. Squeezing 250-300 gillnetters into the Skeena rivermouth and approaches does not equal 'avoidance'.
Furthermore, the compliance rate of the gillnetters with selective measures is always under question. The Department's well known lax enforcement translates into skeptical results for fleet compliance. Checking 3 boats out of 250-300 and extrapolating the results is not adequate enforcement coverage, nor is it especially useful information on which to base further openings on.
Moreover, it doesnt appear your Department actually has any visible policy on what constitutes 'good compliance'? How is 'good compliance' derived and quantified? Can you see the fishing grounds from the north coast office because if no one is out on the water checking how is this fleet compliance derived?
3.Reminding 'industry' about conservation measures when there is little to no enforcement seems wasted effort. If there is little chance of getting caught then why should fishers bother complying with rules that get in the way of their fishing? Has anyone in C&P ever actually timed 'short sets'? How many sets were timed on August 4th that showed 'good compliance' thus allowing further openings? Has there ever been a charge for exceeding soak time?
4.Weekly conference calls:
Is this where we get to hear the predetermined plans that industry and your Department has worked out about how much commercial fishing will take place? How is it industry and fishers know about openings far in advance of the public?
I participated in these conference calls a couple of years ago and not once to my knowledge were my views or perspective ever able to change,delay, or stop a commercial opening....And your north coast office knows our views and perspectives probably by verbatim now and still steelhead conservation seems a secondary consideration in their management decisions. If steelhead really were a consideration for your Department, why wasnt the so-called selective gillnet techniques implemented all season? Tyee Index numbers for steelhead were low right from the start of the Test Fishery but your Department didnt seem to care at all.

5. I encourage you to take advantage of these calls and bring your views and perspectives to the North Coast Fisheries Management staff directly.
Hopefully this isnt a nice way to say "talk to them, not me"...because we are sick and tired of talking to all of you when there is no change forthcoming from the extensive discussions. Whether it is SFAB,SWI,MSC,IHPC,IFMP...or the plethora of other consultative processes you bog the public down in, your talk is nothing but diversionary and aimed at maintaining the status quo.

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