There is a Draft Policy on Bycatch coming from DFO. It can be seen here.
Our response is copied below.
Feedback is accepted until Feb.29 at Consultations@DFO-MPO.GC.CA
Fisheries & Oceans Canada
13th Floor North
200 Kent Street, Mail Station 13N159
Our submission today will focus on the issue of interception of Skeena steelhead by commercial fisheries and how it relates to the Draft Policy on Managing Bycatch and Discards.
By far the biggest problem we have this document is the overarching consideration that commercial fisheries that inflict these bycatch/discard damages take precedence over and above everything else. This document is on fishery bycatch and discards, written by the Department of Fisheries, whose role is to facilitate commercial fishing activity. It seems zero consideration has been given to not sanctioning the fisheries in the first place if impacts are too negative or the impacts outweigh the benefits. It appears commercial activity clearly dominates and actually skews the Department's consideration of what is the best use of fisheries resources for Canadian society, when in many cases this is just not true anymore, such as with Skeena steelhead.
Moreover, while Conservation is supposed to be the prime management directive, the Department completely misinterprets one key definition of conservation: that being 'not to waste'. In the Skeena example, this equates to the Department allowing and even facilitating the killing of large percentages of the yearly returns of very valuable Skeena summer run steelhead in order to allow barely viable gillnet fisheries to occur. This is a form of social welfare, not fishery management, carried out on the backs of both Skeena steelhead themselves and the upriver sportfishery tourism industry that relies on them.
Skeena steelhead are worth literally thousands of dollar each to the in-river sportfishing tourism industry that has grown over the last 30 years to out-contribute the commercial fishery in gross income to the overall economy of the region. (* Blewitt; 2008 Economic Dimensions of the Skeena Watershed Salmonid Fisheries).
Year after year, we see the Department make the value judgement that allowing non-selective gillnet fisheries, which kill thousands of valuable Skeena steelhead, is an acceptable trade-off. Even when confronted with hard economic data from truly independent sources which clearly state the economic disparity between the two activities, the Department blatantly ignores the information, the impacts, and allows the bycatch killing to continue. Where in this Draft Policy is any verbiage to suggest this attitude from the Department will change?
North Coast Steelhead Alliance