What We Heard
A Summary of Comments from Public Discussions on The Future of Canada’s Commercial Fisheries
The document entitled “What We Heard – A Summary of Comments from Public Discussions on The Future of Canada’s Commercial Fisheries” is an overview of the comments and questions received by the Department through the public engagement process on Fisheries Modernization between January and March 2012.
This document will inform our future discussions and actions as we continue to review our fisheries management-related regulations, policies and operations.
It is important to note that on September 21, 2012, Minister Ashfield affirmed that the fleet separation and owner operator policies in Atlantic Canada will remain intact.
Overview of the Engagement Process
In January 2012, Fisheries and Oceans Canada (DFO) began an engagement process with Canadians about the future of the fishery.
The intent was to engage many different people and groups invested in the future of the fishing industry—to hear views from the harvesting, processing, and recreational sectors, as well as Aboriginal groups, environmental non-governmental organizations, academics, economists, and other levels of government. To make the submission process more widely accessible, comments were also accepted through post, email, and fax.
As part of this process, DFO also mailed notices and the discussion document to approximately 350 First Nations and Aboriginal groups, encouraging their review and submissions through mail, email, or online.
Each one of DFO’s Regions held a one day session to discuss the improvement of commercial fisheries management, which included participants from various sectors. Table 1.0 provides a summary of the regional face-to-face meetings that were held.
|Date and Region or Group||Location|
|January 12, 2012
Newfoundland and Labrador Region
|St. John’s, NL|
|January 16, 2012
|January 17, 2012
|January 24, 2012
|Quebec City, QC|
|January 27, 2012
|February 21, 2012
Central and Arctic Region
|February 23, 2012
Central and Arctic Region
Each face-to-face meeting generally followed the same structure with a morning and afternoon session. The morning session focused on the drivers behind the need for improvement in commercial fisheries management and the developing policy direction. The afternoon session consisted of technical sessions on components of the Sustainable Fisheries Framework. Each session also included a roundtable discussion during which participants could share their views and ask questions.
Following these initial discussions, DFO met with specific groups to hear their unique perspectives. This included Aboriginal groups, working groups, industry associations, and environmental non-governmental organizations. These meetings allowed DFO to discuss specific issues relevant to these groups and open the floor to more in-depth discussion.
For the online component, email notifications were sent to stakeholders in the commercial and processing sectors, as well as Aboriginal groups, environmental non-governmental organizations, economists, academics, and industry associations in an attempt to engage a wide variety of views.
Summary of What We Heard
Based on discussions during face-to-face meetings and the many comments we received by email and online, it was evident that Canadians are committed to making the fishery a vibrant, prosperous, globally competitive industry.
Many harvesters, Aboriginal groups, and other stakeholders expressed a strong interest in changing fisheries management. Our questions concerning which rules and regulations should and should not be changed yielded many varied, creative, and insightful suggestions, though not always consensus. Within and across regions and groups there was significant disparity, even contradiction, as to which management practices best support the fisheries, and which inhibit its advancement.
The intention of this process was to provide an opportunity for Canadians to comment on the future of Canada’s commercial fisheries. There was no set agenda and all topics were open to comment. The following sections present major highlights from the thousands of submissions received during the consultations period through meetings, post, emails, fax, and online.
The general response to the principles was positive: the pillars of stability, economic prosperity, and sustainability are principles all people could support. However, the definitions of these terms were noted as unspecific. In particular, concerns were expressed over the term “economic prosperity”. A common concern expressed by Aboriginal groups was that they felt the consultation process did not meet the Government of Canada's duty to consult Aboriginal people and it may infringe on their rights. Many people expressed that it was unclear which level of industry was the primary target for a policy to improve economic prosperity, i.e. individual harvesters, enterprises, communities, etc.
During the course of these discussions, it became apparent that people across the fishing industry want to be more involved in and informed about the decision-making process. There was a strong sentiment among those who participated in face-to-face discussions and provided comments online that there is a disconnect between those in the industry and those deciding how the fisheries are managed.
There was also recognition that DFO plays an important role in the management of fisheries, especially in areas of co-management, and looking to the future, there was concern about how the shift in staff on a regional level would impact industry participation in decision-making processes.
Aboriginal groups expressed the desire for full and effective participation in the management of the fisheries, not just consultation, stating that DFO must continue to respect Aboriginal and treaty rights.
Role of Science
Many people expressed concerns about the use of multi-year science advice— namely how the shift in how science advice is provided—could potentially impact the sustainability of resources. Some indicated that without yearly science advice, stocks may be placed in jeopardy, especially in emerging fisheries where scientific data around stock levels is incomplete. The concerns were that a reduction in science advice would weaken the basis of important frameworks such as the Precautionary Approach.
Commercial harvesters and Aboriginal groups expressed their desire to be more involved in the collection of data and the provision of science advice. It was also stated that revenue is being lost due to the downloading of costs onto industry participants. Harvesters want to see these costs addressed, with no further implication to industry.
The Role of Government
Differing opinions were voiced concerning what DFO’s role should be in managing the fishery. Some felt DFO should be primarily concerned with distribution of the resource and controlling who can access it, while others stated the primary occupation of the department should be to provide a transparent, stable operating environment based on science.
Across the country, people often asked that attention be given to helping young people and new entrants access the fishery, and also improving long-term job prospects. Participants identified competition from industries such as mining and oil and gas as significant competition for labour; people said to attract a younger generation, the fishing industry needs to be able to compete with industries that can offer job stability and better wages.
The issue of allocations and sharing formulas was regularly raised both during the face-to-face meetings and online. Many used these public discussions to voice concerns about how resources are allotted in specific fisheries, demonstrating that additional consideration needs to be given to this issue.
Aboriginal groups also raised concerns about their share of allocations. Many Aboriginal groups specifically expressed the concern that current allocation formulas do not meet their needs or established Aboriginal or treaty rights. It was suggested that allocations need to be reconsidered to better address both food, social, and ceremonial rights and the commercial rights.
Streamlining the Complex Web of Rules
Significant feedback was received concerning which rules and regulations are impeding the ability of harvesters to compete on a global scale. Many differing opinions were expressed about which rules should be maintained, and which should be revised. Some of the more frequently raised issues included:
- Fishing arrangements: restrictions around “buddying-up”; partnership agreements;
- Trip limits and season length;
- Rules and regulations concerning vessels;
- Access to financing;
- Trap and quota splitting;
- Inability to transfer quota or fish multiple licenses; and
- Owner-operator and fleet separation policies.
Safety at sea was also an important concern noted at multiple regional meetings and it was strongly recommended that this be considered in regard to vessel regulations.
Some harvesters felt that current policies work to shorten the length of a fishing season. They stated this has an effect on the value of their landings. For example, the race-to-fish can result in lower quality and small catch size. Another concern was that these poor economic returns cannot sustain crews who increasingly seek work in other industries that provide more stable employment and competitive wages.
On a related topic, the issue of individual transferable quota was also raised with views both in favour and opposed to this form of fisheries management. Many people on the east coast stated they did not want this form of fisheries management implemented in their fisheries. Alternatively, some harvesters supported individual transferable quotas. Many also stated they thought some rules, such as vessel restrictions, have become redundant within this management structure and should be removed.
Owner-Operator and Fleet Separation Policies
DFO received a large volume of feedback on the owner-operator and fleet separation policies. As with all issues, conflicting views were heard.
For those who expressed a desire to maintain owner-operator and fleet separation policies, one of the biggest concerns expressed was that removing these policies would lead to a centralized, vertically integrated fishery. Many harvesters, Aboriginal groups, environmental non-governmental organizations, and others stated that these policies not only impact fishing, but the culture of communities as well. In the Atlantic, many people stated they did not want to see their fisheries managed like those in the Pacific region, while some in British Columbia stated they would like to see these policies implemented on the west coast.
Those who favoured the removal of owner-operator and fleet separation policies felt that these policies hindered the economic potential of many fishing enterprises. It was often noted that the idea of owner-operator does not align with how the policies are applied. Many stated that discrepancies in the application of the policies and regular circumvention were significant problems with the policies, causing inefficiencies in the management system and elevated costs. For these reasons, they stated, the policies were obsolete and should be removed. Many in the industry, both commercial harvesters and processors, linked the owner-operator policy with low incomes and said their businesses were impeded by these policies. Processors also wanted to be able to invest in harvesting enterprises. It was often cited that harvesters and processors were unable to engage in effective business planning because of restrictions associated with these policies.
Others did not definitively express a view of whether the policies should be removed or maintained, but mentioned other changes that could be made to how fisheries are managed. Often referring to the frequent circumvention of the policies, some impressed whatever the policy, it should be applied fairly and consistently. Harvesters advocated for flexibility and the ability to fish multiple licenses from a vessel, purchase licenses of others interested in leaving the industry, or manage their independent enterprises from shore when nearing retirement.
Comments on the Proposed Policies and Tools under the Sustainable Fisheries Framework
It was widely agreed that healthy aquatic ecosystems and sustainable resource use are the basis for economically prosperous fisheries. How this is best achieved, however, was a question open to many different points of view.
Common themes that emerged from comments on the Precautionary Approach Rebuilding Plan Guidelines (PA Guidelines), the Ecological Risk Analysis Framework, and the draft Policy Framework on Managing Bycatch and Discards focussed on the timeline for implementation. In many cases, people urged for the swift implementation of the tools or policies. However, others raised questions about the terms used within the documents and potential negative impacts on fisheries, making the suggestion for further analysis and discussion before implementation.
Most Aboriginal groups were generally supportive of the goals of the policy initiatives, however, it was noted that the implementation of the Sustainable Fisheries Framework policies through the proposed tools have implications not only for commercial fisheries but for food, social, and ceremonial fisheries. Many Aboriginal groups stated that the implementation of these policies and tools will need to take into account Aboriginal rights and interests by meeting the duty to consult.
Many people discussed the potential impacts of the released draft policies and tools and noted the challenges of applying management practices to achieve the overarching goals of sustainability in many unique species and fisheries. While the principle of sustainability was generally supported, as were the goals of the draft policy and tools, it was often mentioned that it would be difficult to know the full range of potential impacts until implementation.
Proposed Precautionary Approach Framework Rebuilding Plan Guidelines
The Fishery Decision-Making Framework Incorporating the Precautionary Approach (PA Policy Framework) published in 2009 calls for rebuilding plans to be in place for stocks whose status is in the critical zone. The draft Precautionary Approach Rebuilding Plan Guidelines (PA Guidelines) were developed to provide more direction on developing rebuilding plans. While the new draft guidelines were the focus of discussion, many comments were received concerning the PA Policy Framework itself.
Some stakeholders stated that the lack of data and information on species makes it difficult to understand how a stock can be placed in a particular stock status zone within the PA Policy Framework: healthy, cautious, or critical. Suggestions were offered on how this could be accommodated, including on how to determine and where to set reference points. A frequent comment concerning the PA Policy Framework was for its swift implementation—frustration was occasionally expressed for what was seen as a delay in firm action on the policy.
Concerning the specific stock rebuilding guidelines discussed during the consultation process, a main concern was how rebuilding plans would be established. The timelines for achieving the goals of rebuilding plans was a concern, as some wanted to see firm and enforceable timelines, while others felt these timelines would be counter-productive given large uncertainties with rebuilding stocks (e.g. environmental factors).
Developing rebuilding plans in consultation with harvesters, Aboriginal groups, and other stakeholders was stated as important. The commercial industry in particular had questions about the applicability of reference points in certain fisheries such as crab and lobster. Concern was also expressed in the North about the application of the PA Policy Framework; some people stated that information about stocks in the North is being accumulated, and the subsequent development of fisheries could, therefore, be impeded if the PA Policy Framework were applied without appropriate data.
In addition to science, it was also suggested that traditional knowledge, from both Aboriginal groups and harvesters, should have a greater role in forming rebuilding plans. Aboriginal groups also raised the concern that rebuilding plans may impact their established Aboriginal and treaty rights, specifically for food, social, and ceremonial fishing. While Aboriginal groups understood the importance of and likewise valued conservation, comments frequently referred to the importance of addressing their rights.
Proposed Ecological Risk Analysis Framework
The Policy for Managing Fishery Impacts on Benthic Habitat, Species and Communities (Sensitive Benthic Areas Policy), published in 2009, called for the development of an Ecological Risk Analysis Framework to analyse and assess the impacts of fishing activities on sensitive benthic areas. During the consultations, some questions were raised as to what specific management actions would result from this tool. While the Ecological Risk Analysis Framework is a tool for the assessment of ecological impacts, not mitigation, some questioned how the Ecological Risk Analysis Framework would link to decision-making.
Questions were also raised as to how the results of the Ecological Risk Analysis Framework would be considered in conjunction with socioeconomic factors in decision-making. In this regard, it was mentioned that harvesters, Aboriginal groups, environmental non-governmental organizations, and other stakeholders should be engaged and involved in providing relevant information to inform a final management decision.
Proposed Policy on Managing Bycatch and Discards
The draft policy was generally well received, although while some stated it provided adequate guidance on addressing this issue, others felt more details were required. Many also expressed that implementation would be the true test of its effectiveness.
It was frequently noted that discarding dead catch of non-target species was not a good environmental practice, and many wanted to see better mechanisms put in place to draw on the economic value of discards, without creating incentive to fish for bycatch. Particular challenges noted with the draft policy were the lack of a specific timeline for implementation and how to effectively enforce the policy.
There were differences of opinion concerning the data collection around bycatch and discards. Some stated that catch information was lacking for some fisheries, including recreational and food fisheries, and that the management of those stocks and any bycatch species in these fisheries is challenging, but needs to be considered within the policy. However, people within the recreational fishery in particular referred to selective harvesting practices in their fishery as a good practice to help reduce bycatch and discards, which they compared to other non-selective fishing practices in other fisheries.
Many raised concerns and frustration about incidental catch that would have value if landed, but harvesters were obligated to throw back due to regulations or license conditions. It was stated that this contributes to poor environmental and economic outcomes. Suggestions that were made to address these issues included:
- Longer seasons, which could also lower competition to land low-quality product quickly and increase value;
- Ability to fish multiple licenses;
- Transferability of quota;
- Gear modifications; and
- Dual fishing for commercial and food, social, and ceremonial fisheries.
It was stated that managing bycatch is a complex issue that needs to be considered from the perspectives of environmental sustainability and economic prosperity. Issues were raised about what factors should be taken into account when determining acceptable levels of bycatch including:
- Ecosystem factors, such as predatory species;
- Stock status of incidental catch; and
- Increasing the data collection on bycatch and discards.
While not a subject of the consultation process, multiple comments were received on the eco-certification of fisheries. In addition to supporting conservation, many across the industry felt the developing policies and tools under the Sustainable Fisheries Framework could support their objectives to achieve eco-certification, and thereby increase the economic viability of their enterprises by improving the access to markets and the demand for Canadian seafood products. However, a concern was noted about how competing certifications would be perceived by the marketplace and impact the reputation of Canadian fisheries.
- Date modified: