DFO Halibut Reg Proposals (very long)

[Last Chance]

quote:Originally posted by Tailspin

Legal or not it's still toast after sitting on a longline, swinging on a circle hook for a week[:0]

How does DFO really determine how many pieces the rec sector has or is taking? Guesstimation? Tell me it's not data collected by a creel survey. I do know how many my boat took last season, however i am fairly certain that DFO has not done any info gathering on me or anyone i know fishing Hali recreationaly in the Sooke/Vic area.

"Lets just knock Febuary out of the equation, that should fix things up on Swiftsure for the intirm". Last i checked, not many fish Swiftsure or Bigbank in Febuary. How do they come up with this stuff? The guys that suffer are the Sooke/Victoria fisherman. From what i have read through, it would appear that the primary consevation area of concern is area 121 not 19/20.

Is it not possible then, assuming that creel survey data is not accurate, that DFO is implimenting this one month measure so they can say to the powers that be "Look, we did something". They could do this full well knowing that they have inconvenienced a few guides and early season anglers, while preserving the season for prime time (March-June for Inside fishermen, June-Oct for West Coast)..

Just imagine if some paper pusher who's uncle employed him with DFO calculated the total sport catch, divided it by the 11 months it was open, and said "Let's close a month, that ought to bring it down". The powers that be smiled and nodded, and poof, here is what we have.

Just another theory, that would explain why they just didn't drop the one fish per boat bomb on us right away at the same time as the late opening message.

Government incompetance can work for the people as well.

 

[bigredsnapper]

I know last July we were at Winter Harbour for a week and there was a guy there as soon we tied up and he measured and weighed every Hali we brought in. He did'nt want any info on salmon.

 

[chris73]

I am fairly certain that the sportfishing yearly catch is not measured but theoretically derived for the quota calculations. LC, I am also convinced that what you suspect is exactly what happened...that's how they came up with Feb.

 

[Mr. Dean]

quote:Originally posted by Concerned Angler

yup-- 81.3cm or 32 in.

So.... The commercials POUND the mature fish... The 'little' one's get tossed back in the drink... The dead 'little' one's get the honourary distinction of "wastages", as their tossed back... And now they want OUR fish???


OK...
Then with the impementation of the 'new' regs. We're only being permitted to fish for thier left-overs, on a reduced season.

It's sounds as if DFO just wants a commercial fishery, and that there would be little, if any,,, conservation on the year class in question.

If everything remained the same, how long would it take for our 12% of a reduced TAC, w/ NO harvest of mature fish,,, before that class of fish came around, with the comercial harvest being allowed to continue???


I predict not very long;

These preposals are going to be the demise of the Halibut Sport Fishery, pure and simple. Take away my RIGHT to access a hawg, and it's not worth my time to make the trip. It's the alure of a monster that keeps me commin back! Plain and simple.

And I bet that it's the same for most...

 

[Tailspin]

It just appears as though there was not much thought put into the Feb. closure. More than likly just a time grab tactic, to allow more time to sort out whats really coming down the pipes for March.

I am all for conservation, however i know the flip side of the coin well from a good friend. He now has almost dormant Salmon Licenses with boats sitting idle. Commercial Hali full time is now his primary game, first on his quota then on to others quota's bought for pennies as they choose to stay home during inclement weather or to watch Opera.

Now the tax paying rec guy gets to sit home too, only not by choice [V]

 

[Mr. Dean]

Holy ****!

Here's another thing I learned.
DFO want's the TAC, CAUGHT!

Sporties don't use theirs up, and it'll slide over to the commercials.

'POOF'.... gone.
More and more restrictions will mean less and less participation. I'm firmly convinced that DFO see's us as mearly a tick on a dogs back, using restrictions as bug spray.

 

[fishingbc]

All of the approx 2500 independent guides working on the BC coast and a couple hundred thousand anglers who fish in BC coastal waters should be up in arms about all three senarios presented to the Canadian public.
One point should be made public and that is the fact that the lodges on the BC coast take 50% of the rec halibut and more in some areas,

"We do not have specific stats however we estimate it averages over 50% coastwise with some areas higher and some lower.Devona Adams DFO" when asked how much of the quota is taken by lodges so quit slaggin' the independant guides, they contribute to many small communities on Vancouver Island. The cancellations are coming in from all over the place, while the lodges are booked solid. These are guys like me and you and not multi million dollar corporations, they work their butts off day in day out, most days in the blazing sun and not so comfortable conditions....

The big lodges will contribute nothing under the present three senarios to the reduction in catch as the minimun stay at a lodge is three days, thus three days = three halibut. The ones paying the price is the rec fishermen and the independant guides who all will have their one day limits cut in half. Wonder who helped DFO come up with this intelligent plan. The lodge lobby is very well connected....Can anyone remember where the only place on the whole BC coast you could catch and retain a Coho during the Coho crisis not too long ago?.....

If the American thievery of "our " halibut is not resolved at the Swiftsure then why would any Canadian think that American rec anglers should be able to come up here and take any hali's back home. Guides out of Neah Bay taxi, bus etc their clients into Canada to purchase saltwater licences then proceed into Canadain waters, harvest Hali's take them back to the states and have it included in our quota without even stepping foot inside Canada....There are American guiding operations working in almost every sportfishing port on Vancouver Island, DFO Revenue Canada and others know full what is going on but don't seem the give a ^%**&^&^ and consistanly turn a blind eye to it in Nootka, Ucluelet,Port Renfrew on and on....

two hali's first day, zero and zero...ten per year no size limit. The average size rec catch is 20lbs under the DFO formula

 

[fishingbc]

Category(s):
RECREATIONAL - Fin Fish (Other than Salmon)



Fishery Notice - Fisheries and Oceans Canada

Subject: FN0044-Halibut: All Tidal Waters - Delayed Opening of Recreational Fishery

Fishing for halibut will remain closed effective 00:01 February 1 to 29, 2008.
The fishery will open March 1, 2008.

The assessment for Pacific halibut is conducted annually by the International
Pacific Halibut Commission (IPHC) which is provided at the January 2008 IPHC
annual general meeting. Results from this meeting indicated that the biomass
of older halibut or the exploitable biomass was continuing to decline. They
concluded that a reduction in harvest rate was necessary to provide the optimal
combination of harvest and to ensure viable spawning biomass for the future.
Therefore, the Total Allowable Catch (TAC) for Canada will be reduced from 11.4
million lbs in 2007 to 9 million lbs for 2008.

This situation will require changes to the recreational fishery in order to
stay within domestic allocations.

DFO has been working in consultation with the SFAB to develop management
options for 2008. Consultations and decisions are still underway. In order to
complete the necessary consultation requirements and avoid in season changes to
the recreational fishery, the opening date will be delayed.


FOR MORE INFORMATION:
Bill Shaw - 250-756-7152,
Devona Adams - 604-666-3271 or
Tamee Mawani - 604-666-0912.

Fisheries and Oceans Canada Operations Center - FN0044
Sent January 28, 2008 at 11:45
Visit us on the Web at http://www.pac.dfo-mpo.gc.ca

 

[fishingbc]

Good Evening Devona and Chuck,



Please consider my personal response and comments regarding the Halibut options provided, as well as approx. 10 separate responses from members of our local Tofino-Ucluelet SFAC committee. These will be forwarded to you separately following this e-mail.



First and foremost, I have deliberated in length to which proposed scenario would best serve the broad interests of the recreational fishing community, as well as citizens of Canada.

I consider the fact that the conundrum we face is not based on conservation concerns, but is due to a sectoral allocation which we have adamantly disputed as a Canadian common property resource, turned beneficial commodity. I don't need to remind you that the benefits are currently not pointing to the Recreational Sector in this allocation based mechanism.



I can not find a suitable solution to the issues at hand, based on the provided options alone. My recommended approach to DFO for Short and Long term solutions are;



Neah Bay Fishery;

To be forced into the allocation process and growth cap to our popular and economically beneficial Canadian Halibut fishery is one step that our sector has had to adapt. To witness an illegal, non-resident fishery extract a percentage of our allocation, it seems logical that this issue should receive priority focus by DFO. I try to understand the political challenges, but the fact is we are witnessing Canadian Halibut being "stolen" while we watch.

Consider if you were a Car Dealership, and your neighbouring Car Dealership came over and took about 20% of your vehicles to sell on their own lot, while you watched-with no compensation. Unfortunately those were the only cars made for that year, and the local law enforcement were already too busy with people stealing hubcaps...........I'm sure you understand.



On-Line License sales are a start, and potentially a way to decrease a fair portion. Adding area 1-23 to the existing area 1-21 exclusion is important.

Area 1-21 closure outside 12nm may be necessary as a pilot to assess the decrease of Neah Bay Fleet. Understanding that this fleet also fishes 1-23, temporary closure of the main accessible area of 1-21 should provide a message to this fleet, along with changes to the on-line licenses, that Canada is not welcoming this illegal activity. To date, it has been far too easy for them, but this will not work alone. Increased enforcement will have to be juxtaposed with these new measures to get the message across.



I am not an advocate for requesting decreased access for Canadians that fish area 1-21, but this is not unlike what we have lived with in Clayoquot for some time. We have had to face measures in a terminal area that are unlike other areas. Ideally this would not be a long term closure if DFO/IHPC/WSFG deal with this accordingly.



Transfer Mechanism

Aside from focus on stopping the Neah Bay fishery, the potential transfer of allocation should be exercised if at all possible, and that DFO should utilize existing funds held in trust by the PHMA to acquire quota for the recreational sector in 2008.





Size Limits

I do not agree or support any of the options regarding the listed maximum size limits, as I question the legitimacy of these size limits being beneficial to the health of the overall biomass. Understandable that these were factored in the absence of quota transfer and unknowns of decrease in the Neah Bay fleet, but a maximum size limit of such small proportion is not the answer. Numerous scenarios, that include increased release mortality, and degradation in the global sportfishing market are probable.

Consider that you are planning a fishing trip somewhere in North America prior to attending the 2010 Olympics. You peruse the Web, and collect copies of various Sport Fishing magazines like "B.C. Outdoors", "Island Fisherman" and "Fishing Alaska" It doesn't take long to consider which destination might fulfill the fish of your dreams.....The British Columbia angler is proudly displaying his maximum size Chicken Halibut of a whopping 18lbs. The front cover of "Fishing Alaska" shows Halibut in the 70 lb. range. Though this is not an outrageously large Halibut, it easily helps the travelling angler with his choice.............



Possession/Daily Limits

I am adamant that the only option to consider at this time, is the temporary reduction in possession from 3 to 2 Halibut, with a daily limit remaining at 2 per day. Keeping the size limit the same will still achieve the desired temporary decrease in catch, combined with decrease of Neah Bay fishery and/or Transfer of Quota.

We have been told that a change in the possession limit would require 2-3 years. I have confidence that there is a way to make it happen if there is a will within the department and Ottawa to facilitate the change.

The Tofino area is an example of challenges to the Size limit and daily limit combined. We are currently fortunate to have a consistent mixed size Halibut fishery, within a very safe and fuel efficient distance of our coastline. Often this happens within 1-3 miles of Lennard Island Lighthouse, with very few Halibut in the proposed max size of 85-90cm. If anglers are not fortunate to find a legal Halibut in this area, they can then choose to travel approx. 12-16 miles further offshore to known Chicken Halibut areas to fish for their 1 (18-20 lb) Halibut per person. The Juice isn't worth the squeeze!!!







In Conclusion; Facilitate Allocation Transfer, Neah Bay Decrease, Change on-line Lic. sales, No Max. Size Limit, Temporary 2 possession Limit



Thank You for your time and efforts in helping with this process, and the favourable outcome.







Jason Mohl



Chairman Tofino-Ucluelet SFAC

Chairman Tofino Harbour Authority

Director SFI of B.C.

Clayoquot Ventures Guide Service ltd.
Clayoquot Vista Guesthouse
Jay's Fly & Tackle

 

[fishingbc]

30th January 2008


Response to DFO on proposed Halibut Management Measures:



Communication with Victoria SFAB Constituents:

In the past five days I have fielded a large number of telephone calls from angry and upset anglers, concerned about the potential of restrictive halibut management regulations being implemented this season. I have also met in person with several key local committee members. It should also be noted that I have received and forwarded over seventeen email responses to DFO from concerned constituents in my community. The majority of all of these responses do not look favourably on ANY of DFO’s proposed scenarios.

Also I find the last minute eleventh-hour rush attempt to seek advice from the recreational angling community on halibut most egregious.


Our Intolerable Position is Not Related to Conservation:

I, as do many of my constituents, hold a very negative opinion about the recreational sector being placed under any additional halibut angling management restrictions by DFO when there is NO conservation concern.

This whole halibut allocation situation forced upon us by the DFO and the government has been a farce from the start in 2003, when then Minister Thibault implemented a 12% recreational allocation ceiling and suggested the recreational sector would have to secure additional halibut quota on an open market.

At the spring 2007 Main Board SFAB meeting the RDG explained to the delegates that no in-season measures during 2007 would be taken and the department would work with the recreational sector to resolve the allocation issue. Yet another full year has passed and our sector is again placed in an intolerable position at the eleventh hour. Why has the Department spent yet another whole year and has still not secured the necessary quota for the recreational sector?

Witnessing how the events and circumstances have changed for the recreational sector since 2003 and hearing from the Minister and the department how positive the 12% allocation ceiling was for our sector, makes me now seriously question why in only FOUR SHORT YEARS our sector has arrived at the point where restrictive measures will be placed on our fishery. I personally believe that this serves to prove what the SFAB has always maintained that percentages of TAC, forced allocation quotas and market-based transfers do not work for our sector.


Why the DFO Presented Scenarios DO not Work:

While each scenario presented by DFO may provide a “savings” of halibut poundage caught over the course of a year, each measure has significant pitfalls or harms specific groups within the halibut fishing community.

SIZE LIMIT - Implementing a halibut size limit will result in significant halibut mortality and will also be a safety concern. This is not an acceptable regulation change.

LOCAL AREA CLOSURES – closing one specific area over another area only serves to harms the local angling community in the area where the closure is established and makes this a very unfair method of reducing catch where no conservation concern has been identified.

MEASURES THAT USE TIMING – the fishing for halibut in Area 19, 20 and off Swiftsure Bank (accessed by many by Victoria area anglers and guides in the summer) have completely different timing focuses. Choosing to utilize regulatory management measures bounded by time will again only serve to penalize and hurt one group that fishes over another.

DAILY BAG LIMIT CHANGES – reducing the daily catch limit to (1) halibut per day will serious harm the healthy guided fishing business off Swiftsure Bank and reduce business revenue in Port Renfrew as fewer anglers will venture there. The halibut from Swiftsure are generally small (chickens) and the cost involved to access the offshore bank are high.


Response to DFO on the presented Halibut Management Scenarios:

As a chair of the local SFAB committee with many constituents (both primary and secondary) and a local angling community of 7.000 anglers in the greater Victoria area (CRD), I am not willing to suggest or choose any of the department’s scenarios as presented. There is very simple reason for this. I cannot with a clean conscience recommend any scenario that favours one group within the recreational halibut community that I represent over another. The Department’s request places me, as chair, in a very intolerable and awkward position. By providing any preference to a single scenario will only serve to divide the sub-groups within my diverse angling community. I cannot and will not be party to dividing my constituents amongst themselves. They deserve better of me.

Please also be clear I would be, as I am sure my many constituents agree, most angry if the department touted any new restrictive regulations as having received the approval or acceptance of the Victoria SFAB Committee.

American Halibut Charters in Canadian Waters:

Allowing American fishing charters to enter Canadian waters with non-resident alien anglers on Canadian Halibut when Canadians will now face restriction is totally unacceptable.


What the Victoria SFAB Committee Can And Do Recommend:

The long-term successful management of coast-wide recreational halibut fishery has to include the ability for the fishery to be vibrant and provide opportunity for reasonable future growth when there is no conservation concern.

The department must:

Immediately stop American fishing charter operators catching Canadian halibut in Canadian waters.

Immediately introduce a change of regulations to amend the possession limit of halibut from the current (3) three total possession to a reduced (2) two total possession

This will (or in combination with a small halibut quota transfer) provide the immediate reduction in total recreational halibut catch to meet the 2008 poundage targets of the 12% forced allocation.

The department can in future also:

Institute a license where the annual number of halibut a license holder can catch be capped at 20 fish

If the department seeks to rebuild confidence and trust with its client groups, there must be a commitment to consult effectively on any proposed regulatory changes with the client groups. I received a firestorm of complaints about the unexpected “delayed season opening” for halibut, because many local Victoria anglers are negatively and /or financially damaged by this department action that received no consultation.

Finally, the department has to address and resolve the halibut allocation transfer issue in a timely manner. This matter has been in the department’s hands for four years since November 2003. Many anglers in area 19 and 20 rely on certainty of opportunity when planning their holidays, booking their clients trips or budgeting for their business. Our local recreational fishery puts millions of dollars into the regional economy and provides hundreds and hundreds of better paying jobs. It is really not acceptable when the national economy is poised to slow down, the US/Cdn dollar value has changed significantly and there is no halibut conservation concern, to further harm the many individuals who rely on recreational fishing for a living.


Respectfully Submitted,


Christopher Bos
Victoria Committee Chair
Sport Fishing Advisory Board

 

[Mr. Dean]

BRAVO!!!

 

[Last Chance]

Sounds reasonable to me.

 

[fishingbc]

Hi Devona

Please accept the following as our Area 14 SFAC response to the draft DFO recently issued on possible changes to reduce catch.



While we appreciate the timing was not of DFO's doing, we still have to object to ANOTHER example of reactive management.



Thanks

Bryan Allen

Acting Area 14 SFAC Chair



26-Jan-08



Area 14 Sports Fish Advisory Committee

Acting Chair: Bryan Allen

Courtenay, BC



Attn: Devona Adams









RE: Potential 2008 management Actions for the Recreational Halibut Fishery



The Area 14 Committee has reviewed the referenced draft document and has the following comments to put forward for consideration.



We feel that this no-win situation for recreational fishers has been instigated and mishandled by the Department of Fisheries and Oceans. The LONG term solution is for the Department to work out a fair Allocation Transfer Mechanism that will not put the recreational halibut fishery in jeopardy. The fish in our waters belong to ALL Canadians, not just the commercial sector.




The proposal to reign in the American Neah Bay charter fishery operating in Canadian waters has our full support. A temporary groundfish closure outside of 12 nautical miles in Area 121 , while onerous, may be acceptable to our committee after further discussion. Expanding the e-licensing restriction for aliens in areas 121, 23, and 123 makes sense in view of the expanding capability of the US charter fleet to range further up the BC coast. It is seen however, as just a temporary stop-gap measure until the issue of Americans landing halibut in Canada, and having those fish counted toward OUR quota is properly dealt with.




Our committee is adamantly OPPOSED to the implementation of a small MAXIMUM size limit for recreational halibut. It makes NO sense whatsoever to expect the recreational fleet to pick up essentially what are the commercial undersized discards, while at the same time watching the commercial fleet continue taking any decent sized fish that comes over the rollers. In addition, it would result in a large increase in discards and an increase in mortality. It makes far more sense to take a fish AFTER is has grown large enough to have spawned, rather than removing it from the biomass BEFORE it can spawn.




We are willing to discuss the possibility of implementing a MINIMUM size limit. We believe that minimum size limit in the 85cm range would result in less discards as anglers would not be willing to sit on a patch of very small halibut. Rather, they would move to another area in order to find acceptably sized fish.




The proposal to reduce the daily limit to 1/day, with a possession of three, is not acceptable to our committee. It imposes an unnecessary hardship on independent anglers, who may only have the opportunity to fish halibut a couple of times a year, as well as charter operators with a one day charter. What IS acceptable, however, is an ANNUAL LIMIT of 10 halibut. This would, of course, result in reduced annual catches in some areas and sectors. ( and prevent the practice of some guides giving thier personal daily limit to clients)




Adjusting daily limits to reduce catch at this time (early 2008) for the upcoming 2008 season is particularly onerous to the charter fleet , as well a large number of anglers from across BC and the rest of Canada, who plan their trips a long time in advance.








Area 14 Sports Fish Advisory Committee

 

[HALILLAMA]

Hi, I am sending you this letter to advise you of my position on the new Halibut regulations.
I'm not happy with any of the new proposals put forward! We're getting thumbed paying our taxes while the Gov't sells the resource. Halibut is everyone's resource. 12 % is not enough for the sport/rec allocation. Sportfisherman said that, no-one listened,in 2003.
The first choice of any DFO Scenario 1,2,or 3 ? is this the only way? How come there is no formal notice with these changes? Which are best? Closest to my choice...Not!. Who thought these up ?

No, I cannnot support any size limit restrictions.... Period! NO! Don't do It! Any one who has actually caught a halibut would never suggest size restrictions. Too many dead fish! Safety! ... and almost every choice in your 'Scenario's contains a max size restriction. How do you measure it (the fish)? We have to keep what the commercial guys have to throw back?
None of it makes common sense!
No! to 1 fish /day also. Anyone that goes to work/lives here in Canada deserves to catch/ keep two in one day if they are so lucky to get out fishing. Cut any Non-resident angler to 1 per day and 1 Possesion! How many lbs would that save! Leave it all alone and monitor closer the fishery to see!
The best two choices of the three scenarios then would be:
#1st... Scenario 2@ Transfer100Klbs with closure Time/Area 121 and
Coastwide limit July, Aug to 1 Fish per day...... is the 'better' of the choices that is available given these 3 Scenario's
#2nd ... Scenario 3@ Transfer200 Klbs with Coastwide limit of 1 fish
per/day in July, Aug.
My real vote is to close 'nothing' because they won't be able to
police it..... (Show me some USA fishers /charters/ border/
convictions/121/ Swiftsure/Big Bank etc)
If we take any conversion (transfer method), then we have to pay to
buy it. Most say commercial Quota is 38$/lb to purchase and is good % for this years TAC. This is a lifetime licence and therefore represents a percentage of the TAC. How do we buy it? Lets get on it and raise every Canadian's right to fish halibut. How? Thru licence fee's, lump sum? Who is going to pay? when? and to whom? There is not even enough time to think these through
clearly......
NO! Max or min. size limit is no good! a 80- 90 cm fish? Small, Ping pong paddles that aren't even mature. One should ask if thats smart? IPHC did studies? Kill all the young because you can kill more of them before the same poundage is achieved, that's not right. That is a fish that is released on a commercial boat (32" min.size.). If they have it as a min size..We should be the same! Min size, Not using it as our max size! IPHC won't like that..taking our 12% all of young stock? I can't imagine trying to get close enough to measure a hali without harpooning it or gaffing it, then releasing it after its too Big? Come on get real....Ever seen a fresh halibut hit the deck??? Someone will get hurt.. Safety on board is paramount. Don't have a size limit!
Stop US boats fishing Canadian halibut PERIOD. All Areas incl trouble spots 121,122,123. Save our CANADIAN Quota of tens//thousandsLBS ! or let us transfer/catch some of their Washington quota....they owe us already 4-500,000 lbs for catches in the last 5yrs....Keep it real! Stop it now!
It's Canada's quota!
If you are intent on having them take a lions share of the quota then they must pay..thats it. For our sake come-on we are paying too!.
Stop fishing for Hali's in Dec, Jan and Feb. That's 1/4 of the year! That is a good 1
Stop all abuse of the existing regulations in place first before doing anything else.
Stop Dragging trawl nets on the bottom! Midwater only in specified areas!
NO more foreigner fishboats...Hello it is Canada! Only let
Canadians fish here.
Stop Charters taking home the guides own daily limit will help toward
goals.
Stop Guessing and Perform a proper creel count, not a study. For real too! the whole coast!
I hope you will consider these points I have brought forward, and I
know there will be more to come with more time spent assessing our position/goals.
I think we as Sport/Recreation Hali fisherman will face more
pressure/competition from the salmon chinook fishery as fishers look
elsewhere for their goals of catching something. This will also put more pressure on other salmon species and bottomfish.
I must wonder again after the release of the news of the fishery being delayed in opening till the 1st of March on monday. Does anyone else consider 3 days notice is a little late. How can this prove confidence in our leaders of this fishery? Considering this wasn't even a option or brought up for discussion.
I don't like these changes and will stand the ground of 'no change'
....leave everything as is today! Use the tools, regulations,laws etc in place and other than those mentioned above don't do it! I must submit something stating that this is life changing for me.
[xx(]

 

[fishingbc]

Hon. Loyola Hearn, PC, MP Jan 30 2008 Minister of Fisheries and Oceans
Parliament Buildings, Wellington Street Ottawa, ON KIA OA6
Dear Minister,
I am writing you on behalf of the Board of Directors of the Sport Fishing Institute of British Columbia to outline our views with respect to your department's proposed halibut management regime for 2008. We have given this issue serious consideration over the past several months and are extremely disappointed that by adhering to the halibut allocation policy of the previous Liberal government, you will be under-mining the recreational halibut fishery.
To be clear, in 2008 DFO Pacific Region will be imposing restrictions on recreational halibut fishing that are not based on halibut conservation objectives. Indeed, while overall halibut abundances have dropped, stocks are healthy, and your department's proposed restrictions are designed to meet allocation rather than conservation objectives.
While we are disappointed with the outcomes of this flawed allocation policy, we have nonetheless given serious consideration to Pacific Region's proposed management measures and would offer the following recommendations:
1) DFO should be directed to use existing funds held in trust by the Pacific Halibut Management Association (PHMA) to acquire quota to offset the needs of the recreational halibut fishery in 2008 and beyond. In addition, the government needs to move quickly to implement the recommendations on a market-based transfer that will be coming to you soon from the recreational and commercial sectors via your Pacific Region staff.
2) DFO should not seek to reduce the normal daily possession limit of halibut from two to one.



In our view, this measure would have a tremendous negative impact on independent local anglers and customers of day-charter operators.

*****WHAT ABOUT THE CHARTER OPERATORS AND THEIR FAMILIES****







Most anglers have to travel long-distances offshore to fish for halibut and we believe that reducing the daily possession limit to one halibut would discourage many anglers from halibut fishing entirely.
More importantly, reducing the daily possession limit could have the unintended consequence of encouraging anglers to target other ground fish species that while not threatened, could not support more targeted fishing activity. Rather than changing the daily limit, we recommend that DFO change total halibut possession limits.

3) DFO should not impose a maximum size limit for the recreational fishery. While few anglers actually catch large halibut, the opportunity to "catch a big one" is a strong motivator for many anglers to incur the expense of engaging in recreational halibut fishing. Indeed, many charter boat operators and lodges market halibut fishing based on the opportunity to catch a large fish and to deny anglers that opportunity would further undermine an economically important fishery.
4) DFO should seek amendments to section 13 and Schedule VIllI of the British Columbia Sport Fishing Regulations regarding total halibut possession limits. While the regulation currently allows anglers to possess three halibut, we recommend that that the regulation be amended to allow the Minister to establish possession limits on an annual basis and that the 2008 possession limit be reduced to two halibut. We understand that DFO is of the view that changing regulations is a lengthy process that often requires up to three years of consultation and background work. We think that most Canadians would find the suggestion that the Government of Canada cannot readily change regulations that are in the public interest to be patently absurd.
5) DFO should take steps to ensure that US-based charter operators do not continue to catch halibut in Canadian waters and assign that catch to the Canadian recreational fishery. The situation is now so intolerable, that Washington State charter boat
operators are advertising Canadian trips to their US customers and even going so far as to note that while Washington State fisheries are closed, harvesting our halibut and bottom fish is acceptable because "its OK, its Canadian" (please see
for examples of some of this outrageous advertising.)
6) DFO should reiterate that current daily and possession limits for halibut are the norm
and the reduced limits we are proposing are exceptional. We stress that in our view, the normal and appropriate limit on halibut possession should be two per day and three in total possession. The reduction to two in total possession is strictly an interim measure designed to deal with the extraordinary circumstances we face in 2008 and 2009.
7) In 2009, DFO should begin acquiring halibut quota to be transferred to the recreational sector. As will be recommended in the consensus document to be forwarded by Pacific Region, DFO should seek funding from Treasury Board to purchase quota sufficient to meet the requirements of the recreational sector, and then develop appropriate mechanisms for recovering those costs over time.
I must reiterate that our membership is deeply disappointed that you persist in endorsing the past Liberal government's halibut allocation policy. Quite frankly, we find this decision perplexing.
Moreover, we are truly offended that despite repeated assurances to the contrary, halibut is being treated as private property rather than as a common-property resource, and that as Canadian taxpayers, we are being asked to purchase something that we already own, especially when more than half of the halibut quota is now owned by people who do not fish, but simply lease this valuable commodity to others. We urge you to seriously consider overturning this indefensible policy .
In the interim, however, we hope that you will give serious consideration to our recommendations.
Sincerely,
Syd Pallister CA, CBV President
Sport Fishing Institute of British Columbia