The PEIFA, with assistance from the PEIFA Tuna Advisory, submitted a workbook responce to the Species at Risk Act Program, DFO on the proposed listing of Bluefin Tuna. 

For a PDF copy of the submission, read below or click the following link:  userfiles/PROPOSED LISTING OF ATLANTIC BLUEFIN TUNA (1) final - PEIFA Submission - Dec 2012(1).pdf

For more info on the SARA listing process go to: http://www.registrelep-sararegistry.gc.ca/document/default_e.cfm?documentID=1748

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SUBMITTED TO:
The Department of Fisheries & Oceans
Gulf Region, Species at Risk Program
343 Universite Ave
Moncton, NB
E1C 9B6
EMAIL: GLF-SARA-LEP@dfo-mpo.gc.ca
TEL: 506-851-6253
FAX: 506-851-2620

PEIFA WORKBOOK SUBMISSION
ON PROPOSED LISTING OF ATLANTIC BLUEFIN TUNA

PRESENTED BY:
Prince Edward Island Fishermen’s Association
420 University Avenue, Suite 102
Charlottetown, PE
C1A 7Z5
TEL: 902-566-4050
FAX: 902-368-3748
Proposed Listing of Aquatic Species Questionnaire for Atlantic Bluefin Tuna (Thunnus thynnus)
Section A: This section asks your opinion of the importance of Atlantic Bluefin Tuna. For each question, please choose the response that best describes your opinion.
Disagree Don't Know Agree Comments
1. I believe that Atlantic Bluefin Tuna play a significant role in maintaining a healthy ecosystem. Agree • See comments attached
2. I believe that Atlantic Bluefin Tuna is an important Aboriginal food, social and ceremonial food source. Don’t Know • See comments attached
3. I believe that Atlantic Bluefin Tuna have economic value as a recreational fishery. Agree • See comments attached
4. I believe that Atlantic Bluefin Tuna have economic value as a commercial fishery. Agree • See comments attached
5. I believe that Atlantic Bluefin Tuna have economic value as an Aboriginal commercial communal fishery. Agree • See comments attached
6. Atlantic Bluefin Tuna provide additional job opportunities (e.g. tourism) to the local economy. Agree • See comments attached

Q 1 Agree
Comments: Any successful fishery is based on a healthy and diverse ecosystem that produces a variety of species and bluefin tuna is one of the species that has been found in Atlantic waters for generations.
Q 2 Don’t know
Comment: Bluefin tuna is not a direct part of food, social and ceremonial fisheries for aboriginal communities. However, it is a growing and important source of commercial activity for many First Nations and aboriginal communities in Atlantic Canada and through this commercial activity, communities may be able to address any of the FSC requirements that may be identified within the communities.
Q 3 Agree
Comment: Atlantic bluefin tuna has been fished recreationally for over 100 years in Atlantic Canada. The Sharp Cup is one of the oldest sporting trophies in North America. Over the decades significant recreational tuna fisheries have existed in PEI, Southwest Nova Scotia and Newfoundland. In recent years, Prince Edward Island has seen a renewal of the recreational tuna fishery as the number of charter vessels have increased steadily. The recreational tuna fishery brings added economic value to the industry and to local economies. Clients are mainly from out of province, many out of country, and the economic spinoff includes benefits to airlines, rental car companies, hotels, restaurants and most of the hospitality industry. The international exposure also brings added value to tourism overall. For example, this year, the Daily Sun in the UK ran a story, complete with photograph, of two UK residents who came to Atlantic Canada to fish bluefin tuna and hooked a 1000 lb fish. This type of publicity will not only enhance the recreational tuna fishery but tourism in general for Atlantic Canada. In addition to regular charters, there are also tuna tournaments that attract additional participants and, in some cases, are important revenue generators for local charities.
Q 4 Agree
Comment: The Atlantic bluefin tuna commercial fishery is an important part of the multi – species inshore fishery throughout Atlantic Canada. There are over 600 commercial licenses throughout the Atlantic Canada and Quebec. Over half, 360, of these licenses are held by core fishermen from Prince Edward Island. The overall direct economic value of the commercial tuna fishery varies depending on quotas and market price, but the industry generates $20 and $30 million to the Canadian economy. Around one third of this is contributed by PEI fishermen. In addition, there are indirect benefits to normal industry suppliers, truckers, airlines and others in the packing and transporting of the fresh product to market. On a normal commercial or charter vessel there is a captain and crew member. In PEI the commercial bluefin tuna fishery benefits in excess of 500 individual fish harvesters. The Atlantic Canada bluefin industry also enjoys a privileged position in the prime commercial market for tuna; Japan. This adds to the economic potential of the commercial fishery.
Q 5 Agree
Comment: In Atlantic Canada there are 60 communal commercial bluefin licenses that are held by First Nations and aboriginal communities. These licenses are a vital part of the commercial fisheries activity of the aboriginal fishermen and benefit the fishermen and their community. Like other commercial tuna fishermen, enterprises comprise of a captain and at least one crew. Aboriginal fishermen have also begun to exploit the recreational charter tuna fishery in recent years. In PEI there are 11 communal commercial tuna licenses.
Q 6 Agree
Comment: As noted in the above comments, the bluefin tuna fishery provides direct economic activity for over 500 fish harvesters and indirect benefits for a wide range of suppliers, fish buyers, transport workers and the hospitality industry. In PEI, the provincial government promotes recreational fishing charters as a part of its tourism publications and web site.

Section B: The next questions ask how the listing of Atlantic Bluefin Tuna under SARA may impact you or your activities.
Impact on Your Activities: Based on what you know about the Species at Risk Act and the potential management measures identified in this document, do you think adding Atlantic Bluefin Tuna to the SARA List would affect you or your activities?
Adding Atlantic bluefin tuna to the SARA list would have a significant negative impact on the fishing and tourism industry of both PEI and Atlantic Canada. In Atlantic Canada, listing of bluefin tuna would result in the loss of up to $30 million in direct economic activity in addition to the positive spin off from this direct activity. In PEI alone over 500 persons would be affected, including aboriginal fishermen. The listing may also affect the ability of these fishermen to quality for employment insurance. The emerging recreational fishery would lose its place in the international recreational market and re – attracting this international sector will become more difficult in future years. Likewise, a SARA listing would also mean that Atlantic Canada is removing itself from the world’s prime commercial market for tuna; Japan. Following a listing under SARA, the ability to re-establish in this prime high valued market will be many times more difficult and require additional investments in marketing. As well, the marketing expertise that Atlantic Canada has developed relative to these prime markets will disappear. This is an added overall loss for Canada.

Section C: This section seeks your opinion on the potential benefits of listing Atlantic Bluefin Tuna under the Species at Risk Act. This includes benefits that are economic (impact on employment or income), environmental (impact on the functioning of the ecosystem), or social/cultural (impact on society/community or groups within society/community)
1. Economic Benefits: Do you think that listing the Atlantic Bluefin Tuna would have economic benefits to you, your community, or your organization?
We believe that a SARA listing of Atlantic bluefin tuna will not have any economic benefits to communities in Atlantic Canada.
2. Environmental/Ecosystem Benefits: Do you think that listing the Atlantic Bluefin Tuna would have any benefits to the environment or ecosystem?
We believe that a SARA listing will not have any meaningful environmental/ecosystem benefits. It is noted in the COSEWIC assessment that Atlantic Canada is neither a spawning nor rearing area for bluefin tuna. It is simply a ranching area for a part of the season. Even the feeding and ranching benefits may be non- existent if fishermen, faced with a loss of revenue and income from closure of the bluefin fishery, are forced to re-direct effort toward smaller pelagic species that form a large part of the feeding and prey for bluefin tuna. In addition, listing of bluefin tuna will negate much of the valuable scientific data that is currently being collected by commercial, recreational and aboriginal fishermen. This information and data are important contributors to Canada’s research activities and they add value to the international assessment for this stock. Tuna fishermen have worked closely with scientists from Canada and other countries for decades and a listing will make this cooperation moot since fishermen will no longer be permitted to fish for bluefin tuna. In PEI the level of cooperation between fishermen and scientists has been significant in recent years. In 2010, the PEIFA worked in concert with DFO and university scientists to study the effects of catch and release on bluefin tuna. This unique project resulted in the tagging of 59 tuna over a 2 week period. The information collected is valuable to both Canada and the international community. The Head of the Canadian delegation to ICCAT said “... the research puts Canada in the forefront of developing responsible recreational fisheries by enduring that incidental mortality associated with catch and release activities is explicitly for in the management of the resource”. As well, PEI tuna fishermen have collected scientific data for years and, in 2012, they collected 132 otolith samples that are essential for scientists to determine both the age and the spawning origin of bluefin tuna.

3. Cultural/Social Benefits: Do you think that listing the Atlantic Bluefin Tuna would have cultural or social benefits for you, your community or your organization?
We cannot see any cultural/social benefits of a SARA listing that will accrue to our communities. If anything, the listing, and subsequent restriction of harvest, will result in lesser cultural/social attachment within our communities to the important role that bluefin tuna plays in our fisheries and the ecosystem and a reduced understanding of the science and the unique place within the oceans ecosystem that highly migratory species, such as tuna, maintain. For example, the bluefin tuna information and interpretation centre at the wharf in North Lake, PEI has taught and influenced hundreds of locals and tourists alike regarding the life history and significance of bluefin tuna in our coastal areas and the role that Canada plays within the international community that manages tuna species throughout the Atlantic Ocean. It is the bluefin tuna fishery which maintains this connection and a SARA listing that curtails harvest will result in the loss of this cultural attachment and educational opportunity.

Section D: This section seeks your opinion on the potential costs of listing the Atlantic Bluefin Tuna under the Species at Risk Act. This includes costs that are economic (impact on employment or income), environmental (impact on the functioning of the ecosystem), or social/cultural (impact on society/community or groups within society/community)
1. Economic Benefits: Do you think that listing the Atlantic Bluefin Tuna would have economic costs for you, your community, or your organization?
As described in Section A, there will be large economic costs to a SARA listing that declares bluefin tuna as endangered and curtail all harvest. Within Atlantic Canada, there are over 600 commercial licenses that are used by inshore fishermen that support their multi-species fishing enterprises. The landed value is annually between $20 and $30 million and hundreds of individuals participate in the fishery. In addition there are economic spin offs that affects various other industries (suppliers, hotels, restaurants and transporters) and a variety of charities that benefit from tuna tournaments each year. In PEI a listing will affect over 500 individuals who earn a part of their livelihood in the commercial, recreational charter or aboriginal fishing of bluefin tuna.
2. Environmental/Ecosystem Costs: Do you think that listing the Atlantic Bluefin Tuna would have any costs to the environment or ecosystem?
A listing of bluefin tuna as endangered under SARA and a curtailing of any harvest will have indirect costs to the environment and ecosystem. As described earlier, fishermen will be forced to try and replace the revenue that bluefin tuna contributes to their enterprises. This may include a re-direction of fishing effort on other fish species such as herring and mackerel which are prey for tuna. Any such re-direction of effort may have an effect on localized components of these small pelagic, particularly herring which are known to have defined spawning areas, and eventually on tuna feeding and migration.
In addition, there is significant cooperation between fishermen and scientists in data collection for bluefin tuna. These data include log books, tagging, oceanographic conditions and the retrieval of otoliths which are essential to determine the origin of tuna migrating into Atlantic Canada. As well, without a commercial fishery, the full extent of the migration range will be solely dependent upon whatever scientific tagging can be done in the future.
3. Cultural/Social Costs: Do you think that listing the Atlantic Bluefin Tuna would have cultural or social costs for you, your community or your organization?
As described in Section C above, we believe that a SARA listing as an endangered species and the subsequent curtailing of harvest will make it more difficult for future generations to understand the life history of this species and its connection to Atlantic Canada and PEI in particular. This loss of understanding has social and cultural effects in the long term. It is from use of natural resources that we learn to protect and respect both the ocean, its habitat and its species. This loss of stewardship is a real cost to society.

Section E: This section seeks your opinion on the proposed listing of Atlantic Bluefin Tuna under the Species at Risk Act.
Are you in favour of the Government of Canada listing the Atlantic Bluefin Tuna under the Species at Risk Act as Endangered?
The Prince Edward Island Fishermen’s Association is adamantly opposed to the listing of Atlantic bluefin tuna (western component) as endangered under SARA. We believe that the proposed listing is not warranted based on the current scientific advice or even based on the COSEWIC assessment itself. We hold this view strongly for a variety of reasons.
1. Current science advice.
The most recent scientific advice for the western component of northern Atlantic bluefin tuna is found in the report of the Standing Committee on Research and Statistics (SCRS), a scientific body within the International Commission for the Conservation of Atlantic Tunas (ICCAT). ICCAT is a Regional Fisheries Management Organization consisting of 48 members who hold responsibility for the overall conservation and management of tuna and tuna like species throughout the Atlantic Ocean. ICCAT held its annual meeting in November and the updated stock assessment for western bluefin was available in the SCRS report to ICCAT made available in October, 2012. The SCRS is comprised of scientists from ICCAT member states, non -governmental environmental organizations and others who met in September to finalize scientific advice for bluefin tuna and other ICCAT managed species.
The fishery indicators identified by SCRS show that since the ICCAT management decision in 1981 to differentiate between the western and eastern/Mediterranean stock components, catches have, because of the imposition of reduced quotas, been relatively stable. There are three main parties who fish on the western component; Canada, Japan and the United States. The Canadian and Japanese catches and have been stable over the past decade while the US catch has declined in certain areas. This decline may be more to do with mixing from the eastern component of the stock. As well catch indices for both Canada and Japan are either stable of show increasing trends. Some, such as the Gulf of St. Lawrence fishery are the highest in the times series considered for the assessment. The SCRS also identify that the 2003 recruitment is considered a strong year-class. The SCRS also notes that the average weight of catch has increased markedly over the past 30 years; from a low of 33 kg in the 1970`s to 93 kg since 1980.
ICCAT adopted a rebuilding plan for western bluefin in 1998 and since then the Spawning Stock Biomass (SSB) has increased by 19%. Indeed, the SCRS also calculated that the western bluefin population has grown by 13% since 2009. And the SCRS notes that the 2003 year-class, which is considered strong, has only begun to contribute to SSB in 2012.
The management advice provided by this august body of scientists is that maintaining catches at current levels, 1750t, is expected to allow the spawning biomass to increase. Indeed, under the low recruitment scenario, the rebuilding targets set by ICCAT could have been met with a catch level of 2000t. The advice was to follow the more conservative approach and set the TAC at 1750t. The SCRS noted that even under the high recruitment scenario, if correct, maintaining catch at 1750t would allow for additional increases in spawning biomass which, in turn, should result in higher recruitment. ICCAT adopted the scientific recommendation for the western component of Atlantic bluefin tuna.
Thus the current management approach, of which Canada is a party, adheres to the latest scientific advice, it allows for the rebuilding targets to be reached in the agreed to time frame. Even non-governmental groups like the PEW Environmental Group supports the management advice contained in the most recent SCRS assessment. A unilateral move by Canada, at this time, to list the western component of Atlantic bluefin as endangered is simply not warranted within the context of the most recent scientific advice.
2. Stock mixing
While ICCAT agreed to separate management components for the western and eastern stocks in 1981, there has, since then, been considerable discussion on the applicability of the management zones and possible inter-mixing between the two components. Archival tagging studies have been done for decades and have identified some interaction between the stock components. In recent years, micro-constituent analyses of tuna otoliths (earbones) have allowed scientists to identify, with greater certainity, stock fidelity. Otolith analysis shows that the vast majority of catches in the Gulf of St. Lawrence originate from the Gulf of Mexico spawning component. However, over 70% of the catch in the mid-Atlantic states of the United States (the Carolinas and Virginia) are tuna born, not in the Gulf of Mexico, but in the Mediterranean Sea. For the past decade, Canada and many others have argued that the TAC for the eastern and Mediterranean component has been set well above recommended scientific advice and that management control measures have been woefully inadequate. Indeed, the SCRS agreed with this in reviews beginning in 2007. It estimated that catches were double the established TACs and the TACs were double the recommended scientific advice. Needless to say, such callous overfishing lead to stock depletion. And the SCRS notes this in its 2009 report to ICCAT. ICCAT responded with greatly improved control and monitoring and reduced the TAC to the recommended scientific levels. The re-building plan for eastern bluefin is now a true rebuilding plan and the current assessment shows that stock benefits are already being realized.
However, the significant overfishing from 2002 to 2008 did have a detrimental effect on the stock and hence catches. During this period, one of the areas that had a marked decline in catches was the mid-Atlantic states of the US. This was also used to show the inherent weakness of the western component of Atlantic bluefin. And this was noted in the COSEWIC assessment that recommended the species be listed as endangered under SARA. As we now know, the US fishery in the mid-Atlantic states is comprised of over 70% eastern and Mediterranean origin bluefin. It is entirely probable that the decline in US catches had little to do with the health of the western stock and all to do with overfishing on the eastern component. ICCAT and its member states have now moved to maintain strict management regimes for the eastern stock and already rebuilding is noted in the recent science assessments. To now follow through on the COSEWIC assessment based, in part, on a flawed premise would ignore all of this information.
3. Overall impact on stock.
A move by Canada to declare western bluefin as endangered would lead to a cessation of commercial, recreational and aboriginal harvests and the establishment of a Recovery Strategy and Action Plan to allow for rebuilding of the stock. Canada is already a party to the rebuilding plan for western bluefin that has been in place since 1998. It has shown some success in that the SSB index has increased 19% during this period. As well, given that the eastern stock greatly affects catches in parts of the west and that management had been vastly improved in the eastern stock, the full benefits of the current rebuilding plans may now be evidenced in the next few years. It makes little sense for Canada to embark on its own unilateral process.
Further, the COSEWIC assessment identifies that Atlantic Canada contains no known spawning or rearing habitat for bluefin. So the overall effect of this listing may be relatively minor. In terms of overall catch, Canada represents only 20% of the western total and, thus, the overall impact on the stock may be relatively minor. The loss to Canada’s fishing indices may only serve to bring more uncertainty to future stock assessments. And unless all others nations involved in fishing the western stock follow the same process, the overall results and impact will be modest at best. Indeed, the US has already decided against listing western bluefin as endangered under it legislation. And we see no reason for Canada to make this move today.
4. Economic impact
As we identified throughout the above sections, listing western bluefin as endangered will affect hundreds of commercial, recreational and aboriginal fishermen across Atlantic Canada and particularly in PEI. The overall impact could be in the $30 million range and will impact many coastal communities where fishing is the only economic alternative. For this reason, we disagree with the listing proposal.
5. COSEWIC Assessment.
We also feel that the COSEWIC assessment is flawed. The COSEWIC technical summary identifies five criteria for assessment. The technical summary notes that only one of these five criteria is applicable. The overall decline in the numbers of mature individuals over the past 30 years is the only criterion that meets the threshold. Yet the summary notes that a related criteria, a small and decreasing number of mature individuals, is above the threshold and thus not applicable. Any decline in the overall range of the specie is also well within the assessment threshold. As well, a small and restricted population does not apply and a quantitative analysis was not done. And current science advice notes that the SSB index has increased 19% since the ICCAT rebuilding plan came into effect and it forecasts further increases in SSB. On this basis alone, we cannot endorse any move to list the species as endangered.
The technical summary and proposed listing document also makes mention of additional uncertainty surrounding the Deepwater Horizon oil spill in 2010. This is emphasized as an additional rationale for the listing. Yet, again, recent scientific advice seems to negate this rationale. As recent as this past April, a leading US government scientist, specializing in bluefin tuna, is quoted in US press (Washington Post) as saying “it appears that the impact (of the oil spill) on larval population is relatively small”. These comments are taken from an analysis of Atlantic Bluefin Tuna completed by the National Marine Fisheries Service and released in May, 2011. This would negate a further part of the rationale used to support the listing as proposed
Concluding Remarks
The above factors lead us to conclude that listing western bluefin tuna as endangered in not needed and not warranted at this time. We, the PEIFA, have not arrived at this conclusion simply because we are an organization that represents commercial fishermen. We have reviewed and analyzed the facts closely. No one has more to lose that the fishermen we represent if the western bluefin stock continues to decline. But we see the efforts already made by Canada and other ICCAT members as positive, substantive and in the right direction. We have made sacrifices to support the bluefin stock for decades and now we are starting to see some positive results. For these factors, The PEIFA adamantly disagree with the proposed listing and ask that you let the current measures protecting the bluefin to continue in effect.

Section F: The next questions ask for information about you. This section is optional.
1. In what capacity are you completing this questionnaire?
 Representative of a group
The Prince Edward Island Fishermen’s Association (PEIFA) represent all 1300 independent core fish harvesters on PEI of which 360 are licensed commercial tuna fishers. The primary species for our member harvesters include lobster and tuna as well as herring, crab and groundfish. There are six member locals of the PEIFA representing specific geographical areas of the Province and these include Western Gulf, Prince County, North Shore, Southern Kings & Queens, Eastern Kings and Central Northumberland Strait. Each local elects two members to the Board of Directors of the PEIFA as well as nominates members to sit on various PEIFA Advisory Committees. The PEIFA Tuna Advisory Committee meet often and play an important role in the development and planning of the annual conservation harvesting plan for PEI’s commercial and recreational tuna fishery.
2. Where do you live?
 Prince Edward Island

3. Which sector(s) do you represent? Please check all that apply.
 Commercial Fishing/Processing/Sales
 Recreational Fishing
 Stewardship group

Did this consultation workbook help you to:
a. Understand how the listing process under the SARA works?
Strongly Disagree Disagree Don't Know Agree *
(somewhat agree) Strongly Agree
b. Provide an effective way to communicate your views to DFO on the potential listing of Atlantic Bluefin Tuna?
Strongly Disagree Disagree * Don't Know Agree Strongly Agree

CONTACT INFORMATION:
Please feel free to contact the PEIFA at 902-566-4050 with any questions you may have on our submission and with any additional or updated information regarding this proposed listing.
Ian MacPherson
Executive Director, PEIFA
managerpeifa@pei.eastlink.ca

Laura Ramsay
Research & Liaison Officer, PEIFA
researchpeifa@pei.eastlink.ca

Ken Drake
Chair, PEIFA Tuna Advisory Committee
kendrake@pei.eastlink.ca

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