October 10, 2017
An Open Letter to The Honourable Dominic LeBlanc, Minister of Fisheries and Oceans from the BC Wildlife Federation and the SFI
October 10, 2017
The Honourable Dominic LeBlanc, MP
Minister of Fisheries and Oceans and the Canadian Coast Guard
House of Commons
Parliament Buildings, Wellington Street
Ottawa, ON K1A 0A6
Dear Minister LeBlanc,
Re: An open letter seeking change to Pacific Halibut recreational fishery management
We write to you on behalf of the Board of Directors and members of the Sport Fishing Institute of BC and the BC Wildlife Federation (BCWF). Our two organizations represent the interests of the primary and secondary portions of the recreational fishing sector on BC’s coast. Members of the BCWF number over 50,000 and the SFI members serve many of the 300,000 anglers that acquire tidal water licences every year.
We are disappointed by DFO’s treatment of recreational opportunity and access to halibut on the Pacific coast during the 2017 season. The department’s decision to close the fishery on September 6, 2017, reflects the flawed management practices that have been in place since 2003 and the arbitrary allocation of 85 percent of Pacific halibut to commercial harvest without taking adequate account of the social and economic value of the recreational fishery.
The unsatisfactory allocation formula has required our sector to develop measures to ration and slow harvest to secure a reliable and full season. In a conscientious effort to stay within the 15 percent amount, daily and total possession limits have been cut, the maximum size of fish an angler could retain reduced dramatically, and an annual limit imposed. Until this year these measures were having the desired effect of providing a year-round fishery. As a result, the 2016 rules were rolled over into 2017 with the hope that they would continue to meet the need, but also with the expectation that if they proved inadequate the department would give the recreational sector the same consideration it accords commercial quota holders who can carry uncaught fish from year to year.
It now is clear that a couple of things changed in 2017. The average size of halibut increased, and with our support the department improved catch monitoring and put in place a more precautionary formula for assessing catch including an internet survey of anglers. However, when partial and questionable forecast numbers in August suggested that the recreational catch was likely to exceed the 15 percent allocation by the end of September, instead of providing flexibility based on the past surpluses, the September 6 closure was imposed with no apparent regard for the social and economic consequences.
It is our collective view that the decision to close the recreational fishery demonstrated how little regard the department seems to give to 300,000 tidal licence holders and the sector that accounts for fully half the economic value of all BC fisheries. The implications of the closure will extend well beyond the end of 2017 and impact opportunities for small coastal communities and local businesses for years to come.
Halibut in BC waters are not in a state of conservation concern, the stock is in an increasing cycle, and average sizes of halibut are increasing. The conservation risk of keeping the recreational fishery open with only the potential of being slightly over the recreational TAC is negligible and falls within the margin of error in any data set used.
The ill-considered decision has reignited anger about the underlying cause of this closure. How is it that government can allow 435 quota holders to possess, in advance of harvest, 85 percent of Pacific halibut available to Canada in circumstances where most of the quota holders do not fish but simply lease their harvest rights to the skippers of 140 or so remaining vessels, effectively creating a fleet of sharecroppers who, in turn need to reduce the margin available to their crews to pay for the quota they lease.
Anger has also resulted from the fact that the decision to close the public fishery was announced in a fishery notice that reminded anglers they could continue to access halibut by utilizing the so-called “Experimental Licence” (XRQ) program to lease quota. This program was designed by a previous Minister and drives a wedge between the angling public, who have a right of access to a public property resource, and opportunists who, without understanding the implications, are willing to pay to lease an opportunity to access the resource. We provided much comment and criticism during a RIAS of the XRQ proposal and have been waiting several years to see the results properly reported, and the XRQ dismissed as a failure. In the meantime, your Department saw fit to encourage its use despite disproportionate expense, a lack of enforcement and an inability to reliably track catch. The XRQ is not a solution to the inequity in the current formula nor is it a workable market based transfer mechanism between sectors.
The current circumstances present an opportunity for you and your department to make changes to provide the recreational sector with long term reliability and opportunity while still honouring conservation and sustainably based fishery principles. We would welcome the opportunity to work on options including increasing our allocation through a compensated transfer or allowing a reasonable degree of flexibility, recognizing catch variability year to year and performance over time.
We are committed to continued implementation of the Vision for Recreational Fishing in BC as developed and approved by Fisheries and Oceans Canada, the Province of BC, and the Sport Fishing Advisory Board. The Vision strives for a vibrant and sustainable recreational fishery and community in British Columbia, providing broad social and economic benefits through diverse opportunities that recognize and respect other users of the resource.
We respectfully request the opportunity to discuss these matters with you and your department.
Thank you for your consideration.
Sincerely,
BC WILDLIFE FEDERATION SPORT FISHING INSTITUTE OF BC
Harvey Andrusak, Robert Alcock,
President, BCWF President, SFI
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Until next time, tight lines,
The SFI Team
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