4RST Atlantic Halibut Review Written Submission by Prince Edward Island Fishermen s Association
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1 4RST Atlantic Halibut Review Written Submission by Prince Edward Island Fishermen s Association PRESENTED TO ERNST & YOUNG Prince Edward Island Fishermen s Association 420 University Avenue, Suite 102 Charlottetown, PE, C1A 7Z5 March 23 rd, 2012
2 1 The Prince Edward Island Fishermen s Association represents 1300 core fishers on Prince Edward Island. Eight hundred and seventy six (876) fishers possess Groundfish licenses that include the harvesting of halibut. These license totals represent 68% of the fishers on PEI. The groundfishery was always an important component for PEI and has provided a vital revenue stream for Island fishers. Although PEI holds 22% of fixed gear licenses, the PEI percentage at 1.46% of the Atlantic halibut quota is the lowest amongst the Atlantic Provinces and Quebec. The nominal allocation of quota currently available for PEI Fishers has set major limitations on our fishery. In 2011, we were limited to a 14-hour season including extremely restrictive parameters on the numbers of hooks to be used and number of overall participants. The increased abundance of halibut in the waters off PEI has added significant fisher interest in participating in this fishery. All issues relating to the PEI groundfishery are dealt with by our Groundfish Advisory Board. This Board is comprised of elected representatives from various geographical areas across Prince Edward Island. The Advisory Board and the PEIFA have been advocating for fair and equitable quota allocation in the in the halibut fishery since the allocation decision of Past History In terms of historical data, the following recommendations were made at the Consultative Meeting Geographical Fleet shares 4RST/3NO for Atlantic Halibut. This meeting was held on March 30 th, 2007 in Moncton, New Brunswick. Methodology that was under consideration was: 1) Use of Historical landing data 2) Provincial share allocation of 1/5 th share per province 3) Mediation 4) Suggested combinations of options 1, 2, and 3 As stated in the minutes of this meeting, the following 14 organizations in attendance suggested that methods other than solely using historical landings be used. The majority of organizations supported Provincial shares or some type of equal sharing arrangement. 1) Le Regroupement des Pecheurs Professionnels du Sud de la Gaspesie Inc. 2) Regroupement des Pecheurs Professionnels du Nord de la Gaspésie 3) Association des pecheurs des Illes-de-la-Madeleine 4) L Association des morutiers Gaspesiens et L Association Capitaines 5) L Association des morutiers traditionnels de la Gaspésie PEI Fishermen s Association 1
3 2 6) Regroupement des Associations de Pecheurs de la Basse Cote-Nord 7) Regroupement des Palangreiers at Petoneliers uniques Madelinots 8) Regroupement des pecheurs professionnels de la Haute et Moyenne Cote Nord 9) Union Pecheurs des Maritimes (Eastern NB) 10) North of Smokey Inverness South Fishermen s Association 11) Maritime Fishermen s Union 12) The Federation of Gulf NS Ground Fishermen and Inverness South Fishermen s Association 13) FFAW 14) Prince Edward Island Fishermen s Association There were also documented comments from six (6) of the attending organizations that the assessment dates should be revised so that information being used encompassed dates that were not affected by the cod moratorium. The cod moratorium was in place from 1992 until In addition, the Provinces of Nova Scotia, Newfoundland and Labrador, New Brunswick, Quebec and PEI were on record as supporting methods of allocation other than using historical data only. The above recommendations were largely mirrored by other 3 rd party assessments during that same time period such as the Independent Panel on Access Criteria (IPAC) and the Atlantic Fisheries Policy Review (AFPR) Our research shows that the recommendation from the Department of Fisheries and Oceans (DFO) in the Gulf and Maritime regions, recommended a combined equal share / historical model be used moving forward. Prior to 2007, the competitive halibut quota was set at 250MT, with 125T available until the end of June. The remaining 125MT was available starting the 15 th of July until the entire quota was caught. Due to the migration of the halibut, Newfoundland and Quebec were typically the first to begin fishing. Atlantic halibut were available in the northern Gulf earlier in the year. In many cases NL and Quebec would overrun the first 125MT available and without penalty. NL & Quebec were able to fish the resource ahead of the other provinces and considerably build their historical landings numbers at the expense of others. In , Newfoundland and Quebec exceeded the early quota, creating a large overrun of the first half of the competitive quota and consequently decreasing the available TAC for other major players including PEI, NB and NS. In fact, in 2006, due to such overruns, only 30MT remained for all southern Gulf fishermen. Overages were averaged among the eight (8) fleets as DFO did not have a penalty system in place. NFLD actually lobbied to have these years and history included in the new sharing arrangement of These fleets were rewarded for overrunning the allowable quota by building additional history and seriously limiting available access for the other fleets. PEI Fishermen s Association 2
4 3 This in turn created a two-fold problem: 1) The offending areas were not penalized to the full extent of their overages 2) In addition the offending areas built up a larger landing history than should have been allowed. This in essence rewarded areas for going over their quota on a year after year basis 2007 Decision The Federal Fisheries Minister at the time opted to go to an allocation that was based strictly on historical landings. The years used for assessment were from 1986 until As previously stated the cod moratorium included the years 1992 to 2004, affecting PEI, NS and NB who were not building landing history during these years. Impacts of the 2007 Allocation to Prince Edward Island The impacts on Prince Edward Island as a result of the 2007 decision were as follows: 1) Historical landing data for PEI was low as the cod moratorium was in place for 12 of the 18 assessment years 2) The current 1.46% quota allocation results in an miniscule 14 hour annual fishery 3) PEI has the lowest quota allocation percentage in spite of the large number of licenses. 4) Currently there are major limitations imposed in terms of number of hooks and number of participants in this heavily restricted fishery 5) There has been a serious loss of economic opportunity for our PEI fishers, their families and communities because of this decision 6) Currently PEI fishers are at a disadvantage with buyers as they are unable to produce fresh product for more than one day a year. This makes it difficult for fishers to convince buyers that they are able to supply them in a consistent and economically viable manner, resulting in lower prices paid to the fisher PEI Fishermen s Association 3
5 4 Figure 1: Percentage of Atlantic Halibut quota per province and respective number of groundfish fixed gear license holders (DFO Stats Feb, 2012) Recent History The Total Allowable Catch (TAC) has increased to 720 MT in 2011 and recently another formula (other than solely using historical landings) was used. In 2010, increased TAC was announced by the Federal Minister of Fisheries, and this new TAC was distributed equally amongst the fixed gear fleets. Although this was not equal provincial shares, this arrangement opened the door for southern Gulf halibut fishermen to access slightly more halibut. The abundance of the halibut stock has been trending in a positive direction over the past number of years as reported in the DFO Science Advisory Report 2011/12 on Atlantic Halibut in the Gulf of St. Lawrence. Indications are that this trend will continue with responsible management practices being followed. The increase in halibut populations in adjacent PEI waters has also been documented by local fishermen for many years as well. It is often difficult for appropriate data collection to be produced on PEI with such a limited fishery and with lack of funding devoted to halibut research in the Gulf. For example, at present, the collection of halibut data in the Sentinel Groundfish Surveys is at the discretion of the observer. DFO insist that halibut be released immediately in the water. Sometimes the observer will measure the weight and length of the catch, but this is not done on a consistent basis. It is critical that DFO recognize the importance of further scientific research on such an important species and the need to dedicate adequate funding towards research particularly in the Southern Gulf region. PEI Fishermen s Association 4
6 5 Recommendations: In summation; The PEIFA and the PEIFA Groundfish Advisory Board recommends the sharing arrangement that was agreed to prior to the 2007 decision be used. This involved a split of Provincial and Historical landing shares on the original 250MT. A 1/5 Provincial sharing arrangement was then to be applied to the remainder of the TAC. We feel this is the fairest and most equitable method of allocating this resource. We have clearly documented in this response the injustice of the 2007 decision on the allocation of halibut shares. We request that the decisions made in 2007 be re-visited and a more equitable process be put in place. These recommendations will reconcile past inequities and allow all Provinces to move forward on a fair and consistent basis. It is critical that fishers in all geographic areas of the Gulf of St. Lawrence be economically viable and benefit from the increasing availability of this key resource. We applaud Federal Fisheries Minister Ashfield for taking the initiative to engage Ernst and Young for the review of past allocation methods. PEI Fishermen s Association 5
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