The 2016 Draft Northern Salmon IFMP is out and it contains a proposal from the Tsimshian first nations that is of concern. It appears they want an allocation of sockeye and propose to catch it in fishing days outside of the regular openings in Sub-Areas 4-12 and 4-15 (River-Gap-Slough).
We have sent a criticism of the proposal to the DFO office in Prince Rupert. It is copied below. Please feel free to let her know what you think also.
Sandra Davies sandra.davies at dfo-mpo.gc.ca
We note in the Draft Northern IFMP the proposal by the various Tsimshian native groups to allow increased gillnetting for Skeena sockeye in Sub-Areas 4-12 and 4-15 for the 2016 season.
Our organization is completely against this proposal for its potential to further negatively impact Skeena steelhead.
Please find below our detailed criticisms of this poorly designed proposal.
4.7. Skeena Sockeye Proposal (Tsimshian – NCSFNSS)
First Nation Group: North Coast Skeena First Nations Stewardship Society
Allocation: 4.968% of the allowable commercial harvest of Skeena sockeye
which has been recently based on actual weekly commercial catches of sockeye in
Area 4. This percentage is based on a 1/3 share of the 14.9% of Skeena sockeye
allocation associated with the 88 Area C and 19 Area A licences in the DFO
Inventory. What kind of rationale is this? The FN’s are demanding a defined allocation of sockeye based on how many licenses there are being held by DFO? Or are these numbers the licenses the Tsimshian own?
Either way, there should be no guarantee of fish or obligation by DFO to provide fish just for someone holding a license.
II. Proposal Overview
Weekly catch targets for the Tsimshian Area 4 Sockeye Fishery will be
determined using the methods used by DFO for Skeena Sockeye Inland
Demonstration Fisheries in recent years.
In-season, the Tsimshian weekly catch target will be equal to 5.83% of the weekly
commercial sockeye harvest in Area A and C fisheries in Area 4, such that the
allowable Tsimshian catch is equal to 4.968% of the total weekly allowable
commercial catch for Skeena Sockeye in all Area 4 commercial fisheries and
inland Demonstration fisheries. The equation used to calculate the 5.83% value is
1/3 * 14.9%/(1-14.9%).
The NCSFNSS will also calculate the weekly target harvest levels based on the in
season estimates of CTAC for Skeena sockeye and a proposed weekly distribution
for the Tsimshian catch. These values will be compared with DFO weekly catch
targets based on Area 4 commercial catches to assess the potential for using
CTAC to implement First Nations commercial fisheries for Skeena sockeye in
It appears the Tsimshian are demanding a ‘double dipping’ scenario whereby their license holders get to participate in regular commercial openings for Skeena sockeye and then get their own special openings on top of that.
How is this 5% of weekly catch allocation determined when the Tsimshian fishermen are already participating in the regular openings?? This would equate to 5% on top of whatever amount of sockeye they already catch in the normal openings wouldnt it??
The Tsimshian Area 4 commercial sockeye fishery will be conducted using gillnet
and/or purse seine gear in Area 4-12 and 4-15 at times when Area C fisheries are
closed for these areas.
This is the most significant aspect of this proposal as they are demanding more commercial effort in the highest steelhead interception areas of 4-12 and 4-15. Plus, it is on top of regular planned commercial openings so instead of seeing 1 or 2 days per week of gillnetting in these high interception areas we might see 3 or 4 days per week. That is a major step backwards in the fight to avoid intercepting valuable steelhead.
The last time 4 days per week of gillnetting occurred was probably in the 1980’s I’d venture. (Possibly also the acrimonious 2007 season)
Your own DFO Selective Fishing Policy would speak against this type of proposal, especially if it involves gillnetters.
The ISRP also very clearly stated the best way to avoid bycatch impacts of any sort is AVOIDANCE….so putting more net in the water is not subscribing to avoidance.
The Tsimshian harvest share would be distributed equally between the 6
Tsimshian First Nations.
III. Fishery Elements/Attributes:
Location – Area 4-12 and 4-15
The worst areas imaginable for this experiment. For decades steelhead advocates have been trying to close these sub-areas to fishing not increase the amount of commercial effort.
Gear type – gillnet and/or purse seine vessels similar to Area C and A fisheries.
Number of vessels – to be determined based on the number of fish to be harvested
and number of participating First Nations. Anticipated to be 1-3 vessels per
Tsimshian First Nation for each fishing week in 2016.
So possibly up to 18 gillnetters or seiners operating in extra fishing days in the worst possible location….what could go wrong with that plan…??
Small numbers of commercial boats fishing in high interception areas can inflict severe impacts in a short period of time.
Target Species – Skeena sockeye
Bycatch – likely less than 1% of the total catch will be other salmon species,
handling requirements would be similar to those for Area C fisheries.
Not a believable number for a bycatch estimate given the locations…Plus, describing the impact as percentages to make the appearance of low impact is completely disingenuous. For the steelhead sport-fishery every steelhead is important and just because you predict a small percentage of fish caught will be bycatch it doesnt mean it wont still be a significant number of valuable steelhead.
Other nearby/relevant fisheries – marine FSC fisheries, all citizens commercial
fisheries and recreational fisheries in Area 4. Fishing plans will be coordinated
with local First Nations to ensure assess to Skeena sockeye for FSC purposes.
Will DFO coordinate with upstream steelhead fishermen, guides, lodges etc letting them know to expect fewer steelhead when these extra openings are occurring?
Fisheries operations – Tsimshian First Nations may collaborate on harvesting
their shares depending on the number of fish to be harvested. This could change
in season depending on the number of vessels available and the relative success of
the individuals involved.
IV. Harvest Guidelines and Management Decision Rules
Guidelines and management decision rules used to implement the Tsimshian
fishery will be similar to those for other Area 4 commercial fisheries that target
Skeena sockeye salmon.
Wow, thats so comforting given how ineffective the regular DFO guidelines and management decisions are for ameliorating the impact of commercial fishing on steelhead.
Proposed fishery management controls
– Fishery Timing Controls – dates and times for each fishery opening would be
identified in the pre-season plan and modified in season as required, at least
one week prior to each fishery opening.
– Fishing Gear Control – each Tsimshian FN would identify the vessels that
may participate in a fishery at least 2 days before each fishery opening.
– Output controls – each FN would be allocated an equal share of the target
weekly catch and fishing by a specific FN would stop when their harvest share
has been reached. Target catch amounts could be defined as group or
individual vessel quota.
– Further discussions will occur in early 2016 to develop a fishing plan to detail
how each community’s FSC access requirements for salmon will be met and
to coordinate fishery openings with existing fisheries to ensure that there will
be adequate harvest opportunities for food, social and ceremonial purposes for each member Nation.
So DFO will further coordinate these openings so they dont interfere with FSC effort….so the same fishermen can also go food fishing the next dyas. So after participating in the regular opening, then participating in special openings, the gillnetter has time left to go food fishing.
Thus leaving how manys per week when there is no gillnetting in 4-12 / 4-15??? Accepting this proposal means almost constant gillnetting throughout the season?
V. Monitoring and Compliance Plan
Type of program to monitor – at-sea patrols and designated landing sites.
– At-sea patrols – to confirm the number of fishing vessels participating,
ensure compliance with fishing times and area boundaries and to assess the
bycatch of non-target species by observing a sample of net sets.
DFO patrols are notoriously unreliable in enforcing the regulations. Asserting there will be special monitoring for this proposal is not being realistic.
– Landing sites – all of the catch would be enumerated and potentially
sampled at the designated landing sites.
Level of coverage – 100% dock side validation.
Biological sampling requirements – any sampling requirements will be discussed
Monitoring plan – implemented by NCSFNSS
In-season Reporting – numbers of each species caught, sold, kept and released by
each participating FN will be provided to DFO within 48 hours of the end of each
Communication protocol – NCSFNSS will be responsible for all pre-season, in
season and post-season communications with DFO and participating FNs.
VI. Communication and Coordination
NCSFNSS recommend that a Local Harvest Planning Committee (LHPC) be
established to discuss and coordinate fishing plans. The LHPC should include
representatives from DFO, CSAB, Tsimshian First Nations, and other Skeena
NCSFNSS representatives will participate in pre-season planning meetings, in
season weekly conference calls and any post-season review meetings related to
the operation of the Tsimshian fishery. Representatives from participating
Tsimshian FNs will be encouraged to participate in these meetings and calls.
The current DFO C&P monitoring and compliance leaves a lot to be desired, such as last years mid August Skeena openings where the FO’s didnt even bother to check the gillnet set times during the short net/short set regulations.
Additionally, with DFO C&P complaining of being short staffed every year and therefore unable to properly monitor or police the normal commercial openings, you are thinking about increasing the number of openings…and under even more special regulations that need to be adhered to…thus adding to the workload of the DFO’s enforcement division. How will this aspect of this proposal be dealt with?
As usual, DFO proclaims to run a well managed, fully regulated fishery yet when it comes to on the water the reality is most often very different. Your Department could’nt even police a ‘special’ opening of only 1 or 2 seiners in Howe Sound last year without messing up…and then you even tried to cover up the mess up. Only FOI’s revealed the poor management.
The Tsimshian Area 4 Commercial Sockeye Fishery will finally permit the
Tsimshian First Nations an opportunity to harvest their portion on the catch
represented by the 19 Area A and 88 Area C licences in the DFO inventory.
As we asked above, what is this allocation aspect whereby the proponent thinks they are owed fish for holding a license?
The proposed fishery will allow the participating First Nations to determine the
appropriate amount of fishing effort (vessel-days) needed to harvest their share of
the weekly catch targets.
How is that a benefit to anyone else? Who cares? A gillnet is a gillnet is a gillnet: it doesnt care who is operating it.
The fishery will assist each of the participating First Nations with their goal of
maintaining the fishing capacity needed to access salmon and other fish species
for both commercial and domestic (FSC) purposes.
Is this code for: not many first nations people want to fish anymore and they are leaving this welfare dependent pastime in droves….so to keep the ones who do want to fish we need to provide more welfare in the form of sockeye for them to afford to pay for fuel or upkeep on their boats….Basically you are admitting this proposal is a form of welfare payment or subsidy to commercial fishermen in order for them to survive!! Fish as welfare payments to commercial fishermen….while others absorb the negative impacts.
There could be future benefits associated with improved in season estimates of
sockeye returns resulting from timely data on daily catch rates from Tsimshian
fisheries conducted at locations close to the mouth of the Skeena River with
similar fishing effort each week (i.e. small fleet test fishery to augment the
information from the Tyee Test Fishery).
RIDICULOUS assumption!! Trying to assert that greater accuracy of the Tyee test Fishery numbers will come from allowing more commercial fishing is just ludicrous. Indeed, the Tyee Test Fishery is so uncertain that gaining a small degree of accuracy at the cost of hundreds of more dead steelhead is an incredibly ill considered idea. So you could tighten up Tyee estimates by 1 or 2 % at a cost of a few hundred or thousand steelhead: that is incredibly poor fishery management.
Please note that there could also be greater benefits for getting as many steelhead upstream as possible that far outweigh any welfare related decision to allow more gillnetting or data gathering.
Lets face it this is just another push for more access to fish and fishing by commercial fishermen…it shouldnt matter what race they are.
For these reasons and more our Alliance is completely against proposals like this. DFO would be remiss to their duty to manage fisheries resources for all Canadians if they allow such narrow minded proposals like this to go forth.