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
K1A 0E6

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

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Editorial on Fraser Salmon and DFO

Here is an example synopsis of the current situation down on the Fraser system regarding sockeye salmon management and DFO by Dr craig Orr of Watershed watch.

Just substitute Skeena for Fraser and all the same criticism applies. Again, the call...actually the public DEMAND for the federal government to reform DFO is loud and clear.

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Salmongate....? DFO caught in a mess

Check out The Salmon Guy blog for interesting posts on the information coming out of the Cohen Commission right now. It is becoming more apparent DFO was not completely truthful in dealing with this salmon virus issue.

Also a story on the Globe & Mail about DFO intimidating scientists.

For anyone with experience dealing DFO on Skeena issue this wont come as any surprise at all. DFO is the ultimate example of: "...were not lying...were just not telling you the whole truth..."

And after reading Bob Hooton's Skeena Steelhead book, we could have our own SteelheadGate. As Hooton presents numerous examples of DFO blatant disregard for steelhead.

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Editorial on DFO by the Courier-Islander

Interesting editorial from the Courier-Islander regarding DFO:http://www.canada.com/shores+malfeasance/5869518/story.html
We tend to agree with the writer, this is a good time to shake up DFO completely. This line is classic: The ministry has become nothing but a laughing stock, a stand up comedian on the world stage of fisheries management.

The shores of malfeasance

Editorial, Courier-Islander

Published: Friday, December 16, 2011

One would wonder how the Department of Fisheries and Oceans could hand out layoff notices to 200 scientists at such a critical time. But, then again, it only seems natural. Natural in that DFO has long since been changed from a protector and nurturer of things oceanic, to a simply oligarchic political poison.
It has been run by the few at the top who know more about boot licking than fisheries. The chosen few have made decisions not on common sense, but on puerile and punitive whims. The ministry has become nothing but a laughing stock, a stand up comedian on the world stage of fisheries management.
One of the most vital commissions in the history of west coast fisheries is going to be wrapping up soon and thereafter produce a report that won't say everything is fine. Everyone knows it will be harsh, it will point fingers and, hopefully, give some direction to solve this sorry saga. And a DFO with 200 fewer scientists won't be able to handle it. Maybe, this will be DFO's escape clause.

But there is a solution, even without waiting to consider the Cohen commission's findings. Take the bottom 80 per cent of the employees of DFO and let them manage the place. Or better yet, give complete and total control of our west coast fisheries to the province.

Cutting 200 jobs for fisheries scientists is an easy thing to do if you live in Ottawa. Managing it properly isn't.
We need to follow the state of Alaska and take back decisions on our fisheries, the jobs it creates, the natural wealth it hands us and the better world it makes.
Alaskans don't listen to Washington when it comes to cleaning their fish. So why should we listen to Ottawa, a bureaucracy that is only interested in cutting out the heart and letting the carcass rot on the shores of malfeasance.
© Campbell River Courier-Islander 2011

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Tyee Gadget

Here's the new version of the Tyee Gadget, courtesy of Northern Rivers Conservation Trust.
As of Sept.09, 2011; Index @ 131.69

Last year to this date: 220.20

To Date Averages:
All Years: 99.13
2000's: 133.48
1990's: 99.23
1980's: 117.96

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Atlantic Salmon Article of interest

Excellent article by Orri Vigfusson of the North Atlantic Salmon Fund outlinging the need to manage fish stocks for abundance not basic minimum spawning requirements. Obviously something we need to continue pushing here in BC as commercial industry and DFO always try to defer to the bare minimums required for any stock.

Northern Ireland forced to change salmon policy

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Orri 23/06/2010 11:48:00

A Milestone for the Foyle; Entering a New Era where salmon abundance is the target, not minimum levels
On 14th June 2010 The Loughs Agency, Foyle Carlingford and Irish Lights Commission, announced that due to a collapse in the salmon stock of the River Finn, all netting in the greater Foyle river system area would be stopped for a minimum of four years to promote stock recovery. Angling would be permitted, but only on a catch and release basis, as a result of a previously agreed protocol requested by anglers to help guard against poaching and pollution, and agreed by The Loughs Agency.

This represents a milestone in the development of salmon fisheries policy in the North West of Ireland; the Foyle system is a cross-border river system administered on a joint basis by two sovereign Governments, The Republic of Ireland, and The United Kingdom.

This change in policy has come about to protect stocks, but also because a failure to act by the Loughs Agency would have rendered The Republic of Ireland and The United Kingdom liable to infraction proceedings from the EU for breach of the Habitats Directive.

The history of salmon policy in the North of Ireland is not an advertisement for good Government. It has been characterised in the early years by a bureaucratic neglect to the extent that when NASF asked the responsible senior Civil Servant to outline Government policy on salmon, he was unable to do so, simply because no policy existed.

In the face of falling stocks, through pressure from anglers led by NASF and others, Government in time were forced to set out their policy on salmon - which amounted to neglect of duty. Instead of looking at the problem, Government simply allowed mixed stock interceptory netting to continue largely unhindered.

It is an interesting commentary on salmon policy in the North of Ireland that Governments always end up doing what NASF and anglers tell them they must do, but there is a lethal time lag while they do what they can to hide the fact that their previous policies were in error. Saving face, it seems, is more important than saving the salmon.

When NASF told Governments in the early 1990s that we needed to stop netting and conserve the freshwater habitats, we were literally laughed at; we were told in fact that the Foyle salmon netting effort may need to be increased, “to make sure we don’t allow too many salmon to reach the spawning grounds”. This is typical of the wilful refusal to look to the future that NASF has faced down through the years.

Time and again when NASF submitted plans to reduce or buy out netting, we were told it was not necessary, Government had everything in hand; all would be well, the bureaucrats knew much more about salmon than mere anglers in NASF. In fact, all was not well, and it now turns out that the anglers and NASF were right all along.

The collapse in the salmon stock of the River Finn must now mark a complete break from the misguided policies of the past as promoted by the Loughs Agency and supported by the two sovereign Governments, The Republic of Ireland, and The United Kingdom.

The Lough Agency has used models based upon minimum spawning escapement levels instead of listening to the NASF call for a return to abundance and the creation of a stronger population base through greater numbers. We at NASF criticize the narrow focus on egg deposition targets because rivers need far more spawning fish than are necessary to satisfy meagre theoretical minimum levels.

The practice of calculating backwards from juvenile habitat surveys to an estimation of required egg deposits is insufficient on its own, because it ignores the salmon's need for the diversity and protection against threats that abundant numbers provide. It also takes no account of the normal but highly variable occurrence of lethal weather, pollution, and other events that inflict high egg and fry mortality. There is good reason why salmon populations are prodigious when it comes to spawning. The fish deposit large numbers of eggs because so few of their ova survive and every season is different in terms of the unpredictability of weather, damaging events, and water levels.

It is not reasonable ignore these diverse factors and assume that a one-fits-all scenario can be safely constructed on a computer which does not recognise what mother nature has been very successfully doing for the last ten thousand years. Given the current abysmally low number of adult salmon in many rivers, the only rational strategy is to maximize egg deposition from the current runs and to work simultaneously to re-establish the environmental qualities of the rivers.

In the Loughs Agency area, this milestone presents an opportunity which must not be squandered.

We are running out of time to save the salmon, we can no longer afford the lethal time lag while Government Agencies try to save face. We need a complete break from a sterile dependence solely on minimum Conservation Limit targets; while these may form a useful contribution to a management regime, we must no longer rely on the concept of minimum numbers as targets for spawning.

We must firstly negotiate with the remaining netsmen to bring a permanent end to all netting in the entire Foyle area, with suitable safeguards on angling exploitation. Then we must embark on a long term programme of habitat conservation, protection, and enhancement, to maximise freshwater productivity. We must strive to achieve the NASF objective of abundance of salmon in our rivers, and to aim to achieve this every year. Only by doing this can we protect our salmon runs for the future.

Orri Vigfusson. NASF

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DFO is willing to buyout licenses...just on the wrong coast

Yet another article on east coast lobster license buyouts. This is relevant because DFO on the west coast has steadfastedly refused to buyout the non-selective, aging, uneconomic gillnet fleet.

The article here describes DFO paying $18 million to retire some lobster licenses. Why the discrepancy on different coasts?
The gillnetters on the north coast of BC have 650 or so licenses with the marktet price of a license being advertised at around $60,000. Probably most license holders would accept less just to get some dollars out of a mostly useless investment.
So 650 x 60k= $39 million. Small price to pay to ensure truly sustainable fishery management on our coast.

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DFO Minister quote

In this St John's newspaper article, DFO Minister keith Ashfield is quoted as saying the 'fishery is probably broken'. He is referring to the east coast fishery but the basic approach seems to be the same on our west coast.
And if he thinks making 20-30 thousand dollars is unacceptable to young people how about west coast fishers, especially gillnetters, who make 1/4 of that...??  We wonder what Minister Ashfield thinks is acceptable to the Canadian public when commercial fishermen contribute so little to the economy yet inflict such onerous impacts on fish stocks in addition to bycatch impacts on much more valuable fish such as steelhead.
The budget cuts Ashfield hinted at wont make DFO more efficient in our opinion. Only a major restructuring or even a completely new organisation will change the negative feelings towards this dysfunctional bureaucracy.

The Weekend Telegram, St John's, NFLD
It’s not just Newfoundland and Labrador’s fishery that needs fixing, according to federal Fisheries Minister Keith Ashfield.

Speaking to The Telegram Friday afternoon, Ashfield conceded the fishing industry is “probably broken” and major steps need to be taken if a younger generation of harvesters is going to get into the business.

“It’s not only in Newfoundland and Labrador, the fishery in general could be considered broken, to some degree,” Ashfield said.

“We’re worried about that and we’re not going to have new people come into the fishery unless they can make a living at it. People aren’t happy to make $20,000-$30,000, especially the younger people.”

But while Ashfield acknowledged the government may need to do more to restructure the fishery, he gave no indication that Ottawa is prepared to put up money to do so.

Instead, he said, the answer lies in making the Department of Fisheries and Oceans as efficient as possible.

“There’s things that we can do, when we look at the layers of rules and regulations and all of the red tape that are tied to the fisheries department that have just grown year after year after year,” Ashfield said. “It doesn’t make for a good business model, and it makes it very difficult for people to earn a sustainable living.”

Liberal MP Gerry Byrne questioned what exactly that would mean.

“What red tape is he talking about? Is he talking about less enforcement officers? Is he talking about the red tape of those pesky scientists? Is he talking about the red tape of consultation on fisheries management plans? Or is he talking about the red tape of the fleet-separation policy and not allowing processors to also be the harvesters of fish?” Byrne said.

Ashfield’s notion of making DFO “more efficient” left a bad taste in NDP MP Ryan Cleary’s mouth, too.

“That’s the code word for cuts,” he said.

Cleary has been sounding the alarm about impending cuts to DFO’s science program, as the federal Conservative government tries to bring the budget deficit back into balance.

“The guts have been cut out of science going back not just with this Conservative government, going right back to 1995 under the Paul Martin regime,” Cleary said. “I don’t see any move by the federal Conservative government to put more emphasis back on science.”

But in his interview with The Telegram, Ashfield said science is part of the department’s core mandate, and it remains a priority.

“Absolutely. Science is very much important, now more so than ever,” Ashfield said. “The science around fisheries is pretty interesting, to say the least.

“But if we don’t use a science-based approach, we won’t have a fishery.”

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Our C.E.C Submission update

From earlier in August: we were informed by the Secretariat that they were not recommending proceeding with the preparation of a factual record.
For more information on our Submission and this process here is the C.E.C page.

This process came out of the 2006 season and the lack of Fishery Officers patrolling the commercial fishery on the north coast. Interestingly enough, here we are in 2011 and a similar lax enforcement situation has occured with regard to the chum bycatch/discard issue. Some things never change....

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Allocation Policy Roadblock

Copied below is a Table from the North Coast Update to August 24th. It shows the sockeye catch and Allocation split between gear types for Areas 3,4,5. In the Integrated Fisheries Management Plan (IFMP) the formal Allocation split of sockeye is 75% gillnet to 25% seine.

We have approached DFO with this inquiry in the past but have received no replies worthy of mentioning but this Allocation split seems to be the crux of the issue over selective fishing. How is it that the Department can talk about selective fishing to the public or the Marine Stewardship Council when there is a formal agreement in place that guarantees 75% of the Skeena sockeye available to non-selective gillnetters?

Fisheries types call the Allocation process the 'third rail' of fishery topics....touch it and you die type stuff. But, this situation is really at the heart of the matter. We will not see any forward progress on selective fishing, as promised by DFO to the MSC, until this small but overwhelmingly important Allocation agreement is changed. And until DFO does formally change this split, anything they say about selective fishing will be pure rhetoric...

DFO: When will you come clean and change this policy??

Allocation for Areas 3,4,5:

                           Gill Net             Seine        Totals

Area 3                   70,148               61,428       131,576

Area 4&5             250,055              65,186        315,241

Skeena Inland      33,230              14,450        47,680

Totals                  353,433            141,064        494,497

Gear Allocation      71%                 29%

Overage/underage -17,440 17,440

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DFO: Outlived its usefulness...??

DFO has had a busy year in 2011. First, they spent some time and energy screwing the saltwater recreational sector over the halibut quota issue. DFO then moved on to screwing the saltwater recreational fishery and fishing tourism industry in Port Alberni by allowing the gillnetters and seiners to pillage the returning sockeye run. To add insult to injury, DFO allowed extensive openings right before the lucrative and important July long weekend. After the commercials cleaned out the Inlet, the tourists and fishermen left in droves...the negative impact felt on the Port Alberni tourism economy was large.

DFO then moved onto screwing the Skeena steelhead, its sportfishermen, and related tourism industry by allowing more extensive gillnet openings. Worse yet, selective fishing measures were not required for the earlier openings thus impacting an already below average early steelhead return.DFO didnt care or flinch one bit as questions about this were raised. The IFMP was ignored and gillnetting was  sanctioned to double the preseason estimate....and they havent even formally finished yet. For every gillnet opening in mid-August thousands of steelhead will be negatively impacted.

How, in the year 2011, do we allow an industrial activity to kill upwards of 30% of a return of fish just as bycatch in fishing for other fish? It is absolutely criminal behaviour by an agency that purports to know better...and actually tries to tell international marketing schemes such as MSC Certification, that it does an excellent job of managing BC's fisheries. DFO defined the term 'smoke and mirrors' through a long history of saying one thing to the public while allowing a completely different story to unfold on the water.

Now, we learn DFO has rescinded longstanding selective measures on the central coast where gillnetters are fishing for depressed chum and sockeye. The fishery impacts probably the best known steelhead race on earth: the vaunted Dean river fish.
Again, it is absolutely criminal mismanagement that allows fisheries of dubious economic contribution to negatively impact individual fish that are worth thousands of dollars each to sportfishing related businesses and the tourism economy in general.

Are we so stupid as a society to continue to allow this happen again and again? I know the answer is: NO. No, we are not going to sit idly by and allow a morally bankrupt bureaucracy piss away one of the most unique resources in the world.

It is time to seriously consider taking a run at and dismantling the agency known as DFO. It would involve reaching out to the broad constituency of conservation, sportfishing, and sportfishing tourism related sectors in order to apply as much political pressure on the federal government as possible.
Maybe a large enough contingent arriving at the Cohen Commission hearings with a demand to eradicate the completely lost agency would work. Face it, DFO cannot be fixed...they are institutionally bereft of moral compass and damaged beyond repair.

Time for a change...now.

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More info on Oregon Gillnet Ban Initiative

More info on the Oregon Gillnet Ban Initiative:
http://www.cbbulletin.com/410979.aspx

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Fishery Notice: Assessment Areas 3,4

The latest Fishery Notice about assessing the Skeena and Nass returns. The section highlighted in red by us sounds like DFO code for " the run is late...we are going to fish heavily into August...."
This adds up to big trouble for steelhead (and depressed Skeena chum)....Time to let DFO know what the public feels about our steelhead getting hammered in 2011.


Category(s):

COMMERCIAL - Salmon: Gill Net
Fishery Notice - Fisheries and Oceans Canada
Subject: FN0691-COMMERCIAL - Salmon: Gill Net - Area C - Areas 3,4,5 - Assessment

Area 3
Migration of Nass sockeye through marine waters is nearly complete. Sockeye escapements through the Nass fishwheels and to Meziadin are projected to meet target. Assessment of coastal pink streams continues with over-flights scheduled for tomorrow, Tuesday, August 9. No commercial surplus of pink identified at this time. Next update at 14:00 hours, Thursday, Aug 11.

Area 4
The Skeena sockeye run timing appears to be late. Daily run size forecasts have increased steadily since around July 25. The current run size estimate to August 7th is 2.0 million with a range of 1.8 to 2.5 million. Escapement past the Tyee test fishery is estimated to be 1.3 million.

Under the IFMP, the allowable Canadian commercial exploitation rate at a run size of 2.0 million is 20%. In addition to the aggregate Skeena sockeye commercial exploitation rate limits, management decisions are also informed by the following factors described in the IFMP:

• In recognition of the requirement to protect and rebuild stocks of concern such as late run sockeye and Skeena chum, there will limitations on sockeye harvests in the last week of July and in early August.

• Even if there was a late season determination that increased the sockeye harvest allowance, any potential harvest opportunities will still be restricted because of concerns regarding harvest impacts to late run stocks of concern.


• These measures include non-retention of some species, gear and fishing modifications, and specific timing closures or sockeye harvest rate reductions when weak stocks are present.

Next update at 14:00 hours, Tuesday, Aug 9.

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Further DFO reply

Here is Mr Kotyk's reply. Note the Skeena sockeye return is now estimated at 2.0 million, up from 1.7. This kicks in the sliding exploitation scale up to 20% up from 10%. This now rationalizes all this futher commercial effort...at least to DFO.
He mentions impacts to non-target species being monitored on a daily basis....we would guess he means the infamous Skeena Management Model that was criticized for how it was used by the ISRP...But no matter, it is a statistical model that DFO can use to produce whatever numbers fit their agenda for the season. Want steelhead impacts to be low....just pump in 'good compliance with selective measures' for the gillnetters and voila...steelhead impact problem gone. Doesnt matter that the province has stated repeatedly that the old steelhead exploitation rates are not valid anymore...and havent been for a few years. So, DFO ends up unilaterally deciding for us how much steelhead impact is OK. Thanks very much DFO.

And note the reference to 1...as in single...Fishery Officers observations leading to continuing the gillnet openings. DFO doesnt say how many gillnetters were checked during this patrol....or how many sets were timed...or the results. And how does 1 Officer cover 250 gillnetters in all of Chatham Sound and expect the public to believe his observations actually reflect the fleet performance? A totally ridiculous premise for DFO to foist on the public.

And to request we talk some more about all this when for the past 5 years discussions have gotten nowhere in lessening the steelhead bycatch problem...The 2011 season is showing us that DFO hasnt changed one bit from 2006. DFO is so good at acrewing the steelhead public....all the while smiling and asking to talk about it...nice.

Dear Mr. Douglas. I have been asked to respond to your email on behalf of the RDG.


With regards to your first point, the Integrated Fisheries Management Plan outlines a Skeena Sockeye Commercial Exploitation Rate for 2011 is a sliding scale based on an in-season estimation of the total return (page 66 of the IFMP). As of today's estimation, the total return is approximately 2.0 million fish, and therefore the exploitation ceiling is set at 20%. Commercial fishers are continued to be allowed limited access as they have yet to reach this exploitation rate, however their access is being limited to by time and gear restrictions in order to protect weak stocks, stocks of concern, and steelhead. The total catch and impacts to non-target species is being monitored on a daily basis.

Your second and third point speaks to compliance issues and please be assured that DFO Fisheries Officers are on the fishing grounds checking for compliance and undertaking enforcement action when necessary. The comments received from the Fisheries Officer reflect an observation that compliance by industry is generally quite good.

Again, speaking to your fourth and fifth points, I do encourage and invite you to participate in the weekly conference calls as they are a good means in which to obtain information as to the stock strength and decisions regarding commercial fishing opportunities as that is the best venue in which your issues can be addressed.

Thank-you again for your email.



Mel Kotyk, R.P.Bio.,

Area Director
Fisheries and Oceans Canada
Pêches et Océans Canada
207- 417 Second Ave West
207-417 Seconde Avenue Ouest
Prince Rupert, B.C.
Prince Rupert, C.-B. V8J 1G8
mel.kotyk@dfo-mpo.gc.ca

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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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DFO reply to NCSA

Earlier this week we wrote to the DFO Regional Director general Susan Farlinger (post here)
Yesterday afternoon we received this reply:

Dear Mr. Douglas,

Thank-you for your email of August 4th regarding commercial fishing and Skeena steelhead. The conservation of Skeena steelhead is one of the priorities that the Department takes very seriously in the management of Skeena River fish stocks. The Integrated Fisheries Management Plan estimated 5 gill net openings for the Skeena River, however the run size for Sockeye appear to be coming in stronger than forecast and therefore additional openings have been executed. Commercial gill net fishers have been limited to "short net, short set" as a condition of licence, with the sole purpose to protect weak stocks and non-target species. The fishery is managed on a daily basis and there are regular calls with the industry to remind them of the mandatory conservation measures that need to be taken aboard each vessel. I also understand that there are weekly calls with environmental non-government organizations, such as yourself, to hear your views and discuss some of the in-season management decisions being contemplated. I encourage you to take advantage of these calls and bring your views and perspectives to the North Coast Fisheries Management staff directly.

Thank-you again for bringing your views to my attention.

Susan Farlinger

Regional Director General

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Enough already! Commercial effort 2011

For what was forecast to be an average to below average year for most species of salmon on the north coast, the Department has sure made the most if it for the commercial fishermen.
By our count, they are up to 37 gillnet openings spread out over Areas 3,4,5,6,8, and 10. The seine days count is 18 spread out over Areas 3,4,6,and 8.

That totals 55 days of commercial fishing on the north coast this summer. In the DFO jargon of 'boats days' ( how many boats participate in a given opening) the totals are 200 seine boat days and 1780 gillnet boat days of effort.

Now, we are all for a viable, sustainable commercial fishing industry on the north coast but enough is enough. Extending massive commercial effort into August inflicts substantial damage on valuable Skeena steelhead, coho, and depressed chum salmon stocks.

According to DFO's own management hierarchy, commercial and sport sectors are supposed to be managed equally. We dont see how allowing additional fishing time into mid-August follows this policy as clearly the steelhead recreational sector will come out on the short end of this equation.

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Let's get to know the new Fisheries Minister

With the Skeena situation looking very much like it has the potential for an increased amount of commercial fishing in August, we thought it would be a good idea to get familiar with the new DFO Minister. If DFO North Coast continues to favour commercial fishing over steelhead conservation then we will probably be sending his office quite a few nasty messages over the next couple of weeks.

After the last federal election DFO Minister Gail Shea was replaced by a new guy....Unfortunately, he is yet another 'easterner'...this time from New Brunswick. Ms Shea didnt even know what a steelhead was...and we can probably assume the same for this guy. If his Pacific Region people and North Coast office people keep sanctioning more commercial openings in August, Mr Ashfield is going to learn pretty fast exactly what a steelhead is and how passionate its supporters can be.
More info can be had here and here   Contact info is copied below.

The Honourable Keith Ashfield
House of Commons Minister of Fisheries and Oceans
Parliament Buildings, Wellington Street
Ottawa, Ontario
Canada K1A 0A6
Min@dfo-mpo.gc.ca

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Email to DFO Regional Director General Farlinger

With things this afternoon looking like a ramping up of commercial activity for  August, we took the time to let the DFO boss know what we think about this possibility.

 

Dear Ms Farlinger,

The North Coast office of your Department has now allowed 5 gillnet openings in Area 4 Skeena. This is above the estimate provided in the 2011 IFMP.
Meanwhile, sockeye numbers have remained fairly strong and this raises the spectre of more gillnetting into August.

We would just like to take this opportunity to remind your Department that northern upriver users are not like the quiet folks at Port Alberni, who just allowed rampant gillnetting to basically annihilate their recreational sportfishery and tourism sector this summer. We take our stewardship of the Skeena steelhead resource very seriously and we will not sit idly by while your Department sanctions extended gillnetting that will ruin our fall fishery and hurt our steelhead tourism economy.

Mr Kotyk was not around for the 2006 season, but please be forewarned that if his office shows the slightest appearance of moving towards anything close to the 2006 level of over-fishing in August, with its substantial negative impacts on Skeena steelhead, the steelhead sportfishing sector will react in a very similar fashion to 2006.

Please shows us your Department has learned from the 2006 debacle and respects the value of Skeena steelhead to the upriver sportfishing tourism economy by curtailing any further gillnetting in August. And not to be flippant, but please dont bother replying with anything relating to 'selective' gillnetting...as it is just a ridiculous premise.....you know it and we know it.

Yours truly,

Keith Douglas
Chairperson
North Coast Steelhead Alliance

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More proof DFO's priorities ly with Industry

The recent 'retroactive' Fishery Notice...announcing a gillnet opening that had already taken place...really provides more proof just exactly where DFO's priorities lie.
It has come out that DFO informed the processors on Sunday of the planned opening on Monday....But DFO had failed to inform the public via the online Fishery Notice system or even more incredibly, the independant fishers who dont work for the processors.

We're sure DFO will use some lame excuse involving the 'long weekend' or some such BS...but if someone was around to make the decision to open a fishery, then you'd think someone would be around to send out the official notice to the Public (which also includes independant fishermen).

Just really more proof, as if we needed any, that DFO is continuing to maintain its primary role as the facilitator of the commercial fishing industry....everything else appears secondary.

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