To: The Honourable Joyce Murray
Minister of Fisheries, Oceans and the Canadian Coast Guard House of Commons
Ottawa, ON K1A 0A6
Dear Minister Murray,
The Public Fishery Alliance (PFA) represents marine and freshwater anglers and the businesses that rely on the public fishery in British Columbia. Our primary interest is the maintenance of well–managed, sustainable public salmon fisheries that contribute to the economic well-being of BC, and the preservation, conservation and restoration of salmon and their habitats. We are a BC registered not-for-profit society and totally self-funded.
To this end, we have provided support for salmon projects and for the development of new selective in-river fishing trap technologies. We have backed an affiliated angling group that raises additional Chinook smolts to increase the abundance of preferred food for Southern Resident Killer Whales. These activities have a connection to this letter, because they illustrate that we create funding for salmon recovery as opposed to consuming funding; as do the vast majority of anglers and angling organizations through numerous self-directed fundraising events and initiatives.
We would rather not be writing this letter. We believe all salmon stakeholders should be working together to bring about a comprehensive, supportable and effective recovery strategy for salmon and their dependent fisheries.
Unfortunately, the PFA Board of Directors and our membership believe the time has come to challenge certain Environmental Non-Government Organizations (ENGOs) who have gone public, in an effort to pressure you into rejecting proposed recreational pilot Mark Selective Fisheries for the coming fishing season, instead of working within the existing consultative system. They are within their right to do so. However, we do not believe they are entitled to misinform the public about the pilots’ risk and benefit analyses and the rationale for their implementation.
It is apparent to us that they are also using this coordinated anti-recreational fishing campaign as a funding vehicle. The difference between the recreational fishery and its numerous organizations, and ENGO’s is that the recreational fishery has a history of gum-boot volunteerism and fundraising for salmon restoration that pre-dates Romeo LeBlanc’s Public Involvement Program. This excludes the revenues that accrue to governments from taxes, licenses and dedicated stamp monies, and the economic benefits to large and small BC communities from angling business activities; while ENGO’s have a history as substantial consumers of funding, much of which is raised outside Canada.
There are a number of ENGOs involved in this campaign notably the David Suzuki Foundation, Watershed Watch and the Raincoast Conservation Foundation. Their approach is not new, but it has ramped up in recent years with the recreational salmon fishery becoming a major target.
The recreational fishery is willing to work with any organization to rebuild salmon and sustain fisheries. However, it is becoming more apparent that the goal of these organizations is to substantially weaken the fabric of recreational fishing. Fisheries management is not a popularity contest; not liking recreational angling is not a justification for getting rid of it.
Their statements are intended to convince you to reject the MSF pilot projects. Much of it is misleading or factually inaccurate. From other sources there might be room for some benefit of the doubt.
However, these groups are involved in the consultative process and know the details of these proposals and your department’s risk assessments of them.
According to their messaging the 2023 Marked Selective Fishing pilot proposals:
- Threaten Southern Resident Killer Whales;
- Threaten weak stocks of Fraser River Chinook;
- Circumvent the existing evidence-based processes;
- Are driven by a small group of commercial recreational interests, “along with their supporters within government”, without due process and review;
- May cause salmon release mortality rates as high as 50%;
- Recreational catches are not properly monitored or verified; and,
- Recreational catch data does not support the argument that recreational fisheries have been constrained where the mark selective fishing pilots are proposed.
The Public Fishery Alliance takes exception to these obvious misrepresentations and consider them purposefully deceptive.
The following explanations provide data-supported information to counter the claims of the ENGOs listed above:
- These Pilot Fisheries do not threaten Southern Resident Killer Whales
All new proposed pilot fisheries occur within the Salish Sea, their locations fall under existing speed and distance regulations specifically to protect SRKWs. The proposed pilot areas, except portions of Juan de Fuca Strait, have not been classified as important foraging or transiting habitats and, in some cases, are not utilized by SRKW’s when the pilots are in place. This is confirmed by ‘occurrence heat maps’ prepared by DFO science and by the Orca Behavior Institute in Washington State (See attachments 1 & 2). This also negates the claim that recreational fishing boats will disrupt feeding SRKWs.
Juan de Fuca Strait – Fisheries Management Area 20 is a known transiting region, where a lesser amount of opportunistic foraging occurs. However, it already has substantial no-fishing closures. There is a large offshore salmon fishing closure near Sooke (100+ sq. km), along with a larger closed area off San Juan Bay near Port Renfrew. Swiftsure Bank, FMA 121, has an extensive set of closed areas, plus reduced speed and distance protocols for SRKW’s. These closures have been imposed over important recreational angling waters.
Most important, the April and May proposed pilot Marked Selective Fishery in Haro and Juan de Fuca Straits occurs before SRKW historically return to Canadian waters for the summer.
- Do not unduly threaten weak stocks of Fraser River Chinook
These descriptions and assessments come directly from your own department’s risk assessment of the pilot Mark Selective Fisheries (Attached).
- Howe Sound- Area 28: April 1-May 31: 1 Chinook/day marked only > 62 cm maximum 80 cm. Less than 1% exploitation rate on stocks of concern. Recommended mitigation– Increase monitoring & sampling (Attachment # 3).
- Gulf Islands & Saanich Inlet-Portions of Areas 17-19: April 1-July 14: 1 Chinook/day marked only >62 cm. Very low impact on Fraser or local stocks of concern. Recommended mitigation-Increase bio-sampling from kept and released Chinook (Attachment # 4).
- Victoria-Sidney-Areas 19-1, 19-3 to 19-5: April 1 to April 30 possibly all of May: 1 Chinook/day marked only, >45 cm except 19-5 >62 cm. Low incremental impact to stocks of concern. >70% mark rate, >90% US Chinook. Recommended Mitigation-Increase monitoring and sampling (Attachment # 5).
- Juan de Fuca-Areas 20-1, 20-3 to 20-5: April 1 to April 30 possibly all of May: 1 Chinook/day marked only >45 cm. Prevalence of stocks of concern 2.9%, negligible in April but increases later in May > 68% mark rate. Recommended mitigation-Increase monitoring and sampling (Attachment # 6).
These proposals are the product of considerable work, fine tuning and review over multiple years based on the best DFO stock composition and run timing data available. However, recent ENGO comments lead readers to conclude these pilots are large open-ended unregulated fisheries that occur when SRKW’s and weak Chinook stocks are present. Part of your mandate is to provide data supported recreational fishing opportunities when and where they become available. These fisheries qualify. These pilots also acknowledge that First Nations’ Food Social Ceremonial retention fishing is permitted.
- Do not circumvent existing evidence-based processes
The recreational fishery fully participates in the existing Integrated Fisheries Management Process and has, through the Sport Fishing Advisory Board, consistently advised Ministers of Fisheries for over half a century.
- Are not driven by a small group of commercial recreational interests
Suggesting otherwise is nonsense, perhaps libelous nonsense. In our view it is designed to create a false impression within the public about how the recreational fishery process functions. These proposals have been developed with input from Sport Fishing Advisory Board local committees within affected regions, and then discussed at SFAB regional and full board meetings, where a protocol requires that anglers and non-business angling organizations hold the majority of seats. There is no cabal of powerful industry representatives with ‘government supporters’ in their pockets as suggested. Yes, governments have been lobbied when significant issues arise that could impact recreational fisheries, which is a right that belongs to all Canadians.
- Do not result in release mortality rates as high as 50%.
The public fishery has already been through this debate with ENGO’s who have used inflated recreational Fishery Related Incidental Mortality (FRIM) rates previously, including making public their own numerical mortality estimates for stocks of concern that required correction later. Our concerns are:
- The pre-mature release of questionable data creates unnecessary controversy and animosity between fishery stakeholder groups.
- Knowing the scientific basis for the assessment of post salmon release mortality comes with a substantial list of uncertainties, but not including these caveats in ENGO literature, is misleading.
- The damage has already been done by the initial release of questionable and/or incorrect data.
The assumptions that high release mortality rates are possible outcomes, should pilot marked selective fisheries proceed, has no useful purpose other than to prolong inter-stakeholder animosity and confuse the public.
While there may be recreational fisheries with very high release mortalities somewhere in the world. They do not apply in the pilot fishery areas. Trolling with downriggers using comparatively small barbless hooks on lures and baits is the dominant angling method. The salmon ‘strike’ overwhelmingly produces a hookup just outside of, on or near the interior of the jaw which means the hooking site is peripheral and shallow rather than deep and potentially damaging.
Their press releases also suggest that current catch and release mortality rate data are flawed. The existing mortality rates for recreationally caught salmon were conducted over a number of years by the Pacific Biological Station in Nanaimo. This work was reviewed by the Pacific Salmon Commission who increased the mortality rate to 20% providing a buffer for uncertainties.
Currently there is an on-water multi-year study underway at University of British Columbia to estimate total recreational fishing mortality rates. Preliminary information suggests low release mortalities. The public fishery supports this work. However, all user groups should wait for the results instead of throwing more gas on this fire.
- Recreational catch data is monitored and collected using best available protocols.
Recreational fishery monitoring and data collection is constantly evolving. This is a good thing with strong recreational fishery support. Currently ‘dockside creel surveys’, considered the gold standard for catch accounting of the public fisheries, are the principal tool for collecting data during the main fishing season in high fishing effort areas. In recent years additional data sources have evolved to back up the creel surveys and improve data recovery from low use areas. In 2022 there were 20,000 creel interviews. Back up data comes from iREC (random internet surveys) and guide logbook programs, both mandatory. Stock composition comes from 250 code wire tag head depots, and the Avid Angler program provides DNA data from kept and released salmon. These improving data sources suggest that ENGO’s have little practical knowledge of the recreational fishery.
- Recreational expectation and opportunity have been constrained by the current regulations
Again, this shows ENGO’s do not understand the requirements for a sustainable recreational fishery. They fail to take into account that recreational fishing is not driven by total catch, but by expectation and opportunity: Defined by the expectation of catch and the opportunity to realize that catch. It is exactly opposite from commercial fishing which is driven by maximizing catch in the shortest period of time. Attached photos # 1 and 2, taken in May 2018 without Chinook-non-retention, and May 2019 after the implementation of Chinook-non-retention, clearly illustrate the drop in fishing interest at a First Nations owned and operated marina near Sooke BC.
The Public Fishery Alliance stresses that we support and need wild salmon to recover and we are willing to work with any organization that embraces that goal, including the groups mentioned in this letter. However, that will be impossible if they continue to promote a divisive agenda based on inferences that recreational fisheries are unregulated, its businesses are only in it for the dollar, and anglers are not legitimate stakeholders.
Approving these pilot projects signals there is a place for recreational angling and its associated businesses in the future.
Yours in conservation,
1-DFO SRKW occurrence heat map.
2-OBI SRKW occurrence heat map.
3-Howe Sound Pilot MSF assessment with map.
4-Saanich Inlet-Gulf Islands Pilot MSF assessment with map.
5-Victoria-Sidney Pilot MSF assessment with map.
6-Juan de Fuca Pilot MSF assessment with map.
Photo # 1- Cheanuh Marina without Chinook-non-retention (May 2018).
Photo # 2- Cheanuh Marina with Chinook-non-retention (May 2019).