AREA C HARVEST COMMITTEE c/o c/o 250 627 8486 250 624 6048
May 30, 2016
Rebecca Reid
Regional Director General
Suite 200 401 Burrard Street
Vancouver, British ColumbiaV6C 3S4
By email:
Dear Ms Reid,
Re: Monitoring costs and the Transfer of Area C allocation to other fisheries
Area C Harvest Committee has two urgent concerns that the North Coast office cannot resolve:
Monitoring Costs: DFO has requirements for 20% monitoring of offloads from the gillnet fishery as well as 20% at-sea observer monitoring of any Skeena gillnet fishery and the gillnet Nass fishery after the Kwinageese closure.
The returns forecast for Skeena and Nass sockeye combined is 377,000 sockeyeof which the post-PICFI gillnet share is 243,000 pieces or 1,216,000 pounds. At a recommended cost charged to gillnets for the Catch Monitoring Program of 1.5 cents per pound, the revenue generated will be $18,300. This is not sufficient to fund the at-sea observer and dockside Monitoring Program to the same level as in the past.
In 2015, the Area 3 and 4 Monitoring Program cost $30,000. At 1.5 cent per pound, Area C fishermen paid $14,000, leaving a deficit of $16,000. If we had not had savings from the previous year, the Service Provider, Ecotrust Canada, would not have been paid for their services.
It will cost approximately $300 per fisherman to raise $30,000 in 2016. Added to the AMR log book charge of $400, the total cost of the DFO required monitoring program to a north coast gillnetter will be 14% of their average net income.
This is far too much.
We have been in discussions with DFO regarding various options, including a multi-year program where we could accumulate funds for 3 years and have a good program in the fourth year. For the three years, the dockside monitoring program could be replaced with an annual company audit – the fish slips collected by a packer should equal the packer delivery tally which should equal the dock tally. On the fourth year, dockside monitoring could be done.
The at-sea observing program provides relative CPUE by species and release survival rates. There is no evidence to show that the release survival rates vary from year to year and the CPUE calculations by species can be done annually by using Tyee test data on the Skeena, fishwheel data on the Nass, and by hail or fish slip/log book data. If required, on the fourth year, a well designed at-sea observer program could be instituted.
The other option discussed is that the MCC or other concerned parties contribute half of the costs of the Monitoring Program.
In 2009, North Coast DFO called a meeting to design a fish slip/log book program that would provide accurate and more timely data with which to run the Nass and Skeena fisheries. The seine and gillnet fleets and the processors supported the idea which would see fish buyers enter the catch and log book information directly into the DFO data base. Unfortunately this plan to replace the AMR logbook, reduce fishermen’s costs, and to provide better data faster seems to have stalled. We have $56,000 from the PST Northern Fund to help DFO and the Processors to cover pilot program costs in 2016 and we would appreciate your support in moving this project forward.
We do not see that it is unreasonable to ask DFO to assist fishermen to design Monitoring Programs that will deliver accurate information in a timely manner – that fishermen can afford.
Nass and Skeena gillnetters cannot afford an expensive Monitoring Program in 2016; accurate catch and release figures can be achieved in a more timely and less costly manner and annual monitoring could be replaced with a financially well supported quadrennial program. Can you please meet with the Area C Harvest Committee representatives (over the phone) to sort out these issues.
Transfer of Area C allocation to other fisheries: Area C Harvest Committee has given ‘advice’ to DFO for many years that it is unfair to allow individuals in an Area C regular fishery to declare their licenses to have an ITQ and transfer this ITQ out of the regular gillnet fishery to another fishery. Area C gillnet fisheries are the only regular fisheries where DFO permits this to happen.
PICFI has transferred 14% of the Area C allocation to First Nations’ Economic Fisheries and retired the same percentage of licenses. However, in addition to this PICFI allocation, ITQ leasing arrangements are increasing the inland allocation at the expense of active Area C fishermen. Half of Area C fishermen are indigenous. The Individual Transfer of Quota (by license leasing) out of the Area C fishery allocation into another fishery takes fish away from indigenous Area C gillnet fishers. Coastal gillnet fishermen, including aboriginal gillnet fishermen, are losing allocation and income.
In 2015, the peak number of fishermen on the north coast was 180 out of a possible 542. The reason the Area C fleet is so small is that the economic returns of the fishery are poor. If more allocation is leased out of the fishery by some of the 362 licenses that are not being fished, that means those who remain fishing become poorer or drop out entirely.
In 2012, the Lake Babine Nation leased gillnet licenses with the ‘attached quota’. They then re-leased this quota downstream to CFC which had over fished its seine sockeye ITQ in the Skeena. This means gillnet allocation was laundered through a First Nation to the seine fleet therefore transferring gillnet allocation to a seine ITQ.
If DFO allows Area C gillnet allocation to be moved to other fisheries, we no longer have stability and certainty for our fleet. We are asking DFO to amend the transfer rules so that individuals cannot lease Individual Quota out of a regular Area C fishery, thereby diminishing the fish allocation available to the remainder of the Area C fleet. If DFO chooses to buy further licences for permanent transfer in the PICFI program, then fair enough, but to permit ITQ style leases to inland First Nations, who are not fishing the licenses, but leasing quota, is just wrong.
Sincerely,
Area C Harvest Committee
Bob BurkoskyBarry Marcotte
Henry Clifton Mabel Mazurek
Don Ekroth Kim Olsen
Robbie Hughes Joy Thorkelson
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