Prince Edward Island Fishermen's Assoc.

The following is the PEIFA responce to DFO's discussion document entitled, "The Future of the Commercial Fishery" in Canada.

February 29, 2012

PEIFA RESPONSE TO “THE FUTURE OF THE FISHERY”

The Prince Edward Island Fishermen’s Association (PEIFA) represents 1300 core fishers on Prince Edward Island, comprising the fishers from the local areas of the Western Gulf, Prince County, Central Northumberland Strait, Southern Kings and Queens, Eastern Kings, and the North Shore. The primary species for the member harvesters are lobster, tuna, herring, rock crab and groundfish. The PEI lobster fishery contributes over 30% of the total Canadian lobster harvest. This fishery has a positive economic impact to the provincial economy estimated conservatively at 250M in direct financial contribution, and 9000 industry related jobs; ranking third in the Province as an economic driver.

Considering the importance of this fishery, the PEIFA views the discussion paper “The Future of Canada’s Commercial Fisheries” as a starting point for dialogue, but much more input and discussion must take place with the Harvesting sector. To date we have found the process of this document review to be lacking in dialogue, with the specific details on the meeting being vague. There was minimal advance notice for the critical stakeholder meeting of 2011, especially given the pending holiday season (December 20th). A previous Gulf wide meeting on lobster provided numerous stakeholder seats at the table and ample accommodation for observers. For this important meeting, we were requested to restrict attendees to 2 representatives from 1300 core fishers, due to “space considerations”. Limiting access is not the way to conduct open and transparent consultations and it is critical that the Department of Fisheries and Oceans (DFO) improves this process moving forward.

In our response, we will address the three areas of focus, as outlined in the presentation in Moncton of January 17, 2012. These are 1) Conservation and Stability, 2) Stable Operating Environment, and 3) Economic Prosperity. These areas will all be addressed from the perspective of the Independent Core Sector Harvester.

Conservation and Stability:

PEI has been one of the lead provinces in terms of rationalization efforts and sustainability programs in the Gulf Region. There is significant interest from our next generation fishers that fishing continues to be a viable and honourable profession. This can only be achieved if the harvester receives an appropriate price for their product, and if catch quantities are sufficient to sustain a reasonable standard of living. Numerous species must be part of a viable fishery so that a harvester is not solely dependent on one or two species. The subsidization of fishing income with off Island employment is not a long term solution to solving our industry’s problems. The out of province migration of fishers on a seasonal basis has, in fact, delayed the critical analysis of fisheries issues and the focus required in seeking solutions.

One current concern is that some fishing areas are excluded from participating in any type of rationalization and conservation efforts. One example of this is the upcoming implementation of biodegradable twine and larger escape panels in lobster traps in some areas only. Resources may not be healthy enough to withstand sustained increased catches. An inconsistent conservation approach took place in the cod industry and it has never recovered from the decimation experienced in the 1970’s and 80’s. The exclusion of certain areas in conservation programs creates a two-tier system among fishers, and encourages other areas to defer or reject proposed conservation plans based on the fact that all areas are not required to adopt even basic measures. If some areas are not required to adopt conservation measures, this is counter -productive to the overall health and sustainability of the fishery, regardless of species.

The PEIFA support the continuation of controlled seasons, but would like a formal review process to be in place to address unique conditions that do occur. It is important for DFO to understand that lost fishing days have a very direct correlation on fisher income and that opportunities to make up these losses are limited. The current rigid policy of no season extensions creates economic hardship and also creates situations where harvester lives have unnecessarily been put at risk. A joint review of corporate fleet harvesting plans (CHP) should occur on an annual basis, as mid shore and inshore harvest many of the same stocks. The decline of current herring stocks is a prime example of how multiple fleets are affected. All primary fisheries will be decimated if this key resource is not protected and maintained.

Stable Operating Environment:

The PEIFA advocates for longer term management systems, but participation from the industry must be greater. Although species meetings do occur, many times the discussion material is first presented the day of the meeting and does not allow for meaningful and thorough analysis. Attendance restrictions are also placed on participants of the science reviews. It is important for DFO to appreciate that fishing organizations do not have numerous science people on staff. Additional attendees may be required for these sessions, so that data can be properly analyzed and discussed.

The pending cuts to Science and Research departments within DFO are a concern, as credible scientific data is required for meaningful analysis to take place. The use of the Precautionary Approach should prevent stocks from becoming depleted if accurate and current data is available. It is our concern that the lack of current data can skew results in either direction and create a vacuum, where poor decisions may be made.

One area that should be investigated is the preservation of bait stocks in Atlantic Canada. The United States is currently experiencing traditional bait shortages and this has resulted in many off shore bait options being used. The PEIFA is concerned about this trend; we must work together to prevent the introduction of both non-native species and possible pathogens to enter our ecosystem.

Economic Prosperity:

Appropriate and sustainable prices are a must for ongoing economic prosperity. Increases in items such as fuel must be accounted for in the marketplace, and the tendency to fish the stocks harder is not encouraged. Weak prices and escalating costs are systemic in many fisheries and must be part of the discussion moving forward. The outdated view that DFO species management, and return to the harvester, are not connected, must be changed.

The Independent Core Harvester lives and spends money in his or her local community. They support their local businesses and pay local municipal taxes. Sustaining the fishery is a key component in keeping rural Canada vibrant. Opening the fishery up to a more corporate approach will not keep our communities alive. The downsizing currently taking place in the processing sector is a prime example of how a few major players are closing out smaller locations and consolidating operations in urban centres. Some processing companies are looking at relocating their processing out of the country. We do not feel this is an inevitable or preferred outcome. The Independent Harvester brings a key component to this discussion; independence from shareholder interests and large financial institution influences. Many times the personal financial commitments of the harvesters far exceed the equivalent investment of corporate organizations.

One key factor that has been overlooked is that the independent harvester can, and should be, a cornerstone of a Canadian Food Security Policy. The Independent harvesters who live and fish in their local areas bring an in-depth and specific expertise that cannot be replicated. Many fishing operations are multi-generational which supports the deep commitment by these fishers. The trending towards increasing catches, so that cheap product can flow to an expanding marketplace is short sighted and wrong. Opening the harvesting sector to corporate interests opens the door for foreign control of an important food resource in Canada. The export of Canadian seafood is a major export industry in Canada, but can only continue if stocks are healthy and sustainable. Protecting the resource for the Canadian people should be paramount, and the continued viability of the Independent Core Sector Harvester is the key.

Recommendations of the PEIFA:

1) The PEIFA would like to see a task force set up so that these three key areas can be discussed in greater detail, and that fishers are being properly represented at the table. The Harvester representative(s) will be chosen by the individual certified fishing organizations (PEIFA). An advance meeting schedule should be drafted so that harvesters have ample time to plan and research the areas of focus being discussed, including prior distribution of key documents for discussion. This is currently being done by other government departments, such as, Transport Canada for bi annual CMAC meetings.

2) Sufficient time allotments for meetings will be determined by the Harvesters and DFO. The current practice of four hour reviews for a number of species is insufficient and smacks of a top down management approach to the fishery. Covering the agenda in these meetings becomes the focus rather than the focus being on a full and meaningful discussion of the agenda items. Extending discussions beyond 4:30pm does not seem to be an option for DFO.

3) A key goal of the Task Force groups must be the setting of Benchmarks and Measurable Metrics so that concrete goals are achieved. Too many initiatives have been discussed at length over many years and numerous timelines missed. This cannot continue. It is also not acceptable if the focus is too hurried moving forward so that fundamental changes are ill thought out and planned. The establishment of realistic timelines for reviewing policy and implementation must occur with both sides having input on these parameters.

4) A coordinated approach on topics, such as, eco-certification and traceability requires more direct input from the Independent Core Sector Harvesters. It is critical that Canada not be perceived as a fragmented supplier in this regard. The PEIFA will be participating in the pilot program for the development of a Canadian certification option for lobster. We hope this will be a viable certification option for our industry.

5) Electronic monitoring must also be reviewed in an open and transparent way as the current direction of this program is contrary to the last input sessions that harvesters attended. This type of directional change contributes to the mistrust that exists between harvesters and DFO.

6) The continued rationalization of many fishery sectors is still required. Specific industry input on how these programs can be funded is critical. This is another key area where multiparty consultation and the development of a long term approach is required.

7) The PEIFA concurs with DFO, that only certified and credible organizations that truly represent fishers are the ones at the industry table to discuss how the industry should be improved.

8) The Independent Core fishers of Atlantic Canada are to be treated as full partners in this process and treated accordingly. Many times the short notice for meetings (less than one week is common) is discourteous and disrespectful to the participating fishers and to the fishing organizations that represent the fishers.

In summation, the Prince Edward Island Fishermen’s Association is a progressive and transparent organization that is committed to making our fishery more sustainable and profitable for generations to come. The past cannot be changed. There does exist a feeling that the expertise and knowledge that the harvesting sector possesses has not been fully utilized or appreciated by the Department of Fisheries and Oceans in Canada. Open and productive dialogue regarding our recommendations will be a significant positive step forward. The harvesting sector must be included as full partners and be actively involved in any changes to our fishery that are being discussed. The PEIFA is ready and willing to participate in these discussions if both parties are committed to fundamental change and improvement. We await your timely written response to our document.