DFO Draft Policy on Bycatch

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


DFO Discussions
Fisheries & Oceans Canada
13th Floor North
200 Kent Street, Mail Station 13N159
Ottawa, Ontario
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RE: Draft Policy Framework on Managing Bycatch and Discards

The North Coast Steelhead Alliance is a group committed to securing the escapement of wild steelhead in sufficient numbers to sustain healthy wild steelhead stocks and a robust sport fishery in northwestern British Columbia. The NCSA is dedicated to working with all levels of government, industry, community and stakeholder groups to preserve Skeena steelhead.

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).

Why are we as a society allowing completely non-selective gillnet fisheries, those that have no hope of minimising or ameliorating their impacts on bycatch, to continue to inflict such negative impacts on a species and a successful, green industry that relies on them?

How does your Draft Policy answer those types of questions and concerns? The following passage from the 'Guiding Principles' section is one of few to mention socio-economic benefits and relative contributions the resource makes to Canadian society, yet we submit this is sheer lip service to any other use other than commercial fishing exploitation. We come to this belief from decades of seeing and experiencing the results of commercial fishing bycatch on our valuable steelhead. Consistently, Skeena steelhead come out on the bottom of management decisions regarding commercial fisheries and we see no reason for any of that to change within this new Draft Policy.

The fishery is a common property resource to be managed for the benefit of all Canadians, consistent with conservation objectives, the constitutional protection afforded Aboriginal and treaty rights, and the relative contributions that various uses of the resource make to Canadian society, including socio-economic benefits to communities.

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?

Where in your Draft Policy is there verbiage which allows a fulsome discussion of the cost-benefit considerations of allowing various fisheries? Where is the Policy to guide Managers on reaching socio-economic decisions where commercial fishing is not the best use of the public's fishery resources?

The Department's history of trying to manage the bycatch/discard issue of non-selective gillnetting by dressing up gillnets in short length forms, short set lengths, mesh size configurations, and on and on ad nuaseum are truly pathetic attempts to keep an outdated and outmoded method of fish capture alive at the great expense of valuable steelhead and sportfishery businesses that rely on them.

We dont beleive new policy papers like this one will deal with the core issues of Skeena steelhead bycatch. The root causes are the systemic, built-in bias of a bureaucratic department whose sole function it seems is to facilitate commercial fishing at any cost. Add to that industry bias, a geographic bias of basing the Department's office in the chronically depressed town that relies heavily on commercial fishing and shoreworker jobs and you have a recipe that no new Policy will overcome with regard to fairly managing the Skeena steelhead issue.

We have just learned this Draft Policy available on-line, with feedback and comments invited until the end of February, has actually already been re-written and accepted. This just typifies the Department's approach to new Policy; first, the Policy itself is completely lacking, and second, your Department had already written the real final document without considering any public input.

And finally, we would sum up this Draft Policy as just one more in a long line of Departmental verbiage that will be ignored by Managers on the north coast as they continue to do whatever they want in terms of allowing non-selective fisheries to continue. This Bycatch Policy will join the Wild Salmon Policy; the Selective Fishing Policy, and dozens of other DFO policies that sit on shelves completely ignored by north coast fishery managers. We wonder how much public funding was wasted in this paper process exercise when very little, if any, benefit to Skeena steelhead will reach the water?

Yours

Keith Douglas
Chairperson
North Coast Steelhead Alliance
Smithers, BC
http://www.ncsteelheadalliance.ca