SFAB LETTER TO FISHERIES MINISTER 2009

Discussion in 'Conservation, Fishery Politics and Management.' started by fishingbc, Feb 1, 2009.

  1. fishingbc

    fishingbc Active Member

    Honorable Gail Shea Jan 26 2009
    Minister of Fisheries and Oceans
    House of Commons
    Ottawa, ON
    K1A 0E6
    Dear Minister,
    On behalf of the Sport Fishing Advisory Board, and its member organization the Sport Fishing
    Institute, I would like to thank you for taking the time to meet with us on Jan 16th in
    Vancouver.
    Because of the urgency attached to a decision about halibut allocation, I thought it would be
    helpful if we were to reiterate the key points which we put forward during the meeting. We
    also discussed very briefly the need for renewed support for the Salmonid Enhancement
    Program and the process underway to define a vision for the recreational sector and look
    forward to pursuing these and other issues with you in the future.
    With the support of Canada’s commissioners, the International Pacific Halibut Commission
    has decided to reduce our country’s allowable harvest to 7.635 million pounds for 2009,
    which is significantly less than our historic share. When combined with the previous Liberal
    government’s fixed percentage allocation policy which limits the recreational sector to 12% of
    the fish available for recreational and commercial harvest, this creates a situation in which
    significant value will be removed from the coastal and Canada’s economy unless you
    exercise your ministerial discretion to change the allocation policy.
    Even after new constraints had been placed on anglers, the recreational harvest in 2008 was
    1.5 million pounds. Holding the sector to the 88/12 division in 2009 would mean an allocation
    of 918,360 pounds. Since each pound of recreationally-caught halibut brings $18.63 to the
    provincial economy, compared with $3.60 for each pound of commercially caught fish, such a
    decision would extract value from the coastal economy at a time when the opposite is
    needed.
    The current situation exposes the fundamental weakness of trying to express the recreational
    allocation in percentage terms. It means that in times of lower abundance, as at present, the
    sector is artificially restricted while in times of high abundance it would have allocated to it a
    volume of fish that it could not possibly harvest.
    We think it makes much more sense to view the recreational allocation in terms of what your
    officials calculate will be harvested in the coming season, given the possession rules in place
    at any point and the expected fishing effort. This is the process that has been used for more
    than 10 years with respect to Chinook and Coho, two other species that are central to the
    economic value of the recreational fishery. Since it is possible for the department to have a
    clear idea of the total recreational harvest by the end of the summer, any surplus can be
    reallocated to the commercial quota holders for harvest in the fall.
    _______________________________________________________________________
    Sport Fishing Advisory Board c/o 6150 Ferguson Road, Port Alberni, BC, V9Y 8L4
    604-786-3439 murphymar@shaw.ca
    While in percentage terms the recreational share would go up in years of lower overall
    abundance, the opposite would be true in the more abundant years that are predicted to be
    coming, without any need for the cumbersome “market-based” arrangements between the
    sectors that were required by the “Thibault Policy” and which have proven to be unworkable.
    To operate on the same basis as last year, continuing restrictions which have already
    removed value from the fishery, the recreational sector requires an allocation similar to last
    year’s actual harvest of 1.5 million pounds. Because Canada’s commissioners agreed to a
    reduced national portion for the 2009 season, this amounts to 20% of the fish available for
    commercial/recreational harvest. If government feels it must compensate commercial quota
    holders for this percentage change in 2009, you could recover this cost over time from
    recreational halibut anglers through increased license fees or some other measure such as a
    halibut stamp. We would suggest, however, that the size of any such compensation should
    take into account the fact that the commercial sector left fish in the water at the end of the
    2008 season, as it has done many times in recent years, that is nearly equal to the projected
    recreational shortfall in 2009.
    During the recent IPHC meeting some commercial processors actually argued that the
    allowable harvest ought to be reduced for 2009, and the opening of the season delayed,
    because they had millions of pounds of unsold frozen halibut in cold storage; and that the
    majority of Canada’s commercial quota is now owned by shore-bound speculators who
    simply lease quota in order to profit at the expense of the skippers and deckhands who
    actually go fishing.
    It is time for government to turn a new page and admit that the allocation policy imposed by
    former Minister Thibault was ill-considered and that it has failed. The policy had three
    components.
    • It called for a market-based transfer mechanism.
    • It imposed the 88/12 division until market-based transfers were possible.
    • It promised that there would be no in-season closure of the recreational fishery.
    Since government has declined to move forward with the consensus proposal for
    compensated transfers, and since your officials have broken the ministerial promise about inseason
    closures, surely it would be unfair to continue imposing the 88/12 division, especially
    when this means undermining the social and economic value of the fishing sector that now
    accounts for the single largest share of Canada’s West Coast fishing economy. Failure to act
    would seem to confirm that the halibut quota system has fettered your statutory allocation
    power and confirmed ownership of fish prior to harvest, contrary to Justice Binnie’s ruling in
    the recent Saulnier case that such proprietary interest in fish was “contingent, of course, on
    first catching it.”
    _______________________________________________________________________
    Sport Fishing Advisory Board c/o 6150 Ferguson Road, Port Alberni, BC, V9Y 8L4
    604-786-3439 murphymar@shaw.ca
    We look forward to an early positive decision that will allow recreational anglers to continue
    having fair access to halibut under rules that ensure Canada gets the highest level of social
    and economic benefits from this common property resource. We believe that such a decision
    would be consistent with the department’s Operational Policy Framework for recreational
    fisheries which says that “further consideration will be given to increased or priority access for
    recreational use under the concept of ‘best use’ of the resource after obligations to First
    Nations are met.” It also would reflect the statement in the Atlantic Fisheries Policy that a
    “best use” decision is one “that will generate the greatest possible public good or best serve
    the interests of all Canadians.”
    Yours sincerely,
    Marilyn Murphy
    Chair
    Sport Fishing Advisory Board
     

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