I emailed the specific DFO address associated with the consultation, and a 2nd email to Fisheries Minister, shadow minister, and every MP in BC with a riding bordering the Pacific. Managed to finally get my local MP (Nanaimo, Tamara Kronis) to finally schedule me for an in person meeting after initially requesting in regards to the proposed SRKW closures. I intend to speak to her about both issues.
Is the commercial salmon fishery still viable?
- Thread starter searun
- Start date
searun
Well-Known Member
The more we dig into this, the more weird it gets in terms of the asks for even more subsidies from Canadian tax payer. I think its time for Canada to step up and offer a quality buy-out so the fleet can retire with dignity. Not exactly sure where the $ will come from for either a buy-out or continued subsidies - Canada is broke.
searun
Well-Known Member
The reason why all the MP's want to talk SRKW is the SAP hasn't yet hit the airwaves in Ottawa. They also don't know about just how nuclear (worse) these proposed amendments to the SAP are for the future of the recreational fishery. j
I’ve got an email drafted and waiting for my wife to edit…im told I can come across a little brash. One thing I’m highlighting is how much money our family spends annually on rec. fishing and boating.
I know the deadline for input is Jan 23, but has DFO said when they’ll have a decision on all this nonsense?
I know the deadline for input is Jan 23, but has DFO said when they’ll have a decision on all this nonsense?
Thank you
Met with MP Tamara Kronis (Nanaimo) today. Apparently I was the 2nd person in her office today talking to her about the proposed SAP changes. Whoever was there before me left her a full copy of the discussion paper, with relevant sections highlighted. She does not have a lot of experience with the complex topic of fisheries management, but seems to want to learn more and advocate. She told me the best thing would be if she received more constituents coming to meet her and talk about this, so she can better understand and take those concerns forward. Maybe blowing smoke but I don't think so - she did sponsor the petition about the SRKW closures. Apparently there is some sort of "salt water fishing caucus" she is chairing, or trying to anyway.
3-3188 Barons Road
Nanaimo, British Columbia
V9T 4B5
Telephone: 250-434-7110
Toll Free Number: 1-866-390-7550
Email
tamara.kronis@parl.gc.caConstituency Offices
Main office - Nanaimo3-3188 Barons Road
Nanaimo, British Columbia
V9T 4B5
Telephone: 250-434-7110
Toll Free Number: 1-866-390-7550
searun
Well-Known Member
A small sample of feedback being sent to the DFO Public Consultation.....If you value your recreational fishery please take a few minutes and write into DFO with your feedback. I have to split this into a few separate posts to share the most relevant elements.
Reconciliation and FN’s Allocations:
We fully support First Nations Section 35 rights to FSC, Treaty and Court defined commercial fisheries.
However, government’s reconciliation agenda must balance those equally against the rights and interests of the non-indigenous community. A modern SAP must not confer rights that cannot coexist with the rights and interests of non-Aboriginal Canadians.
To illustrate, we offer the perspective of the New Brunswick Court of Appeal case J.D. Irving, Limited et al. v. Wolastoqey Nation (Wolastoqey Nation), 2025. This case provides valuable perspectives that we believe also applies to how government must act in determining a fair approach for modernization of the SAP. Paragraph 175 of the judgment offers these principles:
"Part of reconciliation may include placing limits on Aboriginal rights. EMS quotes Delgamuukw, which emphasizes the words from R. v. Gladstone, 1996 CanLII 160 (SCC), [1996] 2 S.C.R. 723, [1996] S.C.J. No. 79 (QL): “Aboriginal rights are a necessary part of the reconciliation of aboriginal societies with the broader political community of which they are part; limits placed on those rights are, where the objectives furthered by those limits are of sufficient importance to the broader community as a whole, equally a necessary part of that reconciliation” (para. 73). Aboriginal rights are not absolute, and exist within Canadian society and Canada’s constitutional framework. EMS quotes Chippewas of Sarnia to underscore this point: “a court must take into account the perspective of the Aboriginal people claiming the right … while at the same time taking into account the perspective of the common law” such that “[t]rue reconciliation will, equally, place weight on each”. The accommodation is to be done in a manner that does not strain “the Canadian legal and constitutional structure”. The co-existence of Aboriginal title and fee simple title is not supported by Canada’s constitutional framework".
The courts have clearly stated that it is the government's responsibility to fully fund/implement fair and reasonable reconciliation efforts recognizing needs/interests of both communities (indigenous and non-indigenous) if they wish to pursue real meaningful reconciliation. This SAP review was initiated in response to the Ahousaht case - DFO and the Minister cannot ignore their duties to act reasonably, considering how they account for FN's rights and equally accounting for provisions to non-indigenous peoples contained within common law.
Reconciliation and FN’s Allocations:
We fully support First Nations Section 35 rights to FSC, Treaty and Court defined commercial fisheries.
However, government’s reconciliation agenda must balance those equally against the rights and interests of the non-indigenous community. A modern SAP must not confer rights that cannot coexist with the rights and interests of non-Aboriginal Canadians.
To illustrate, we offer the perspective of the New Brunswick Court of Appeal case J.D. Irving, Limited et al. v. Wolastoqey Nation (Wolastoqey Nation), 2025. This case provides valuable perspectives that we believe also applies to how government must act in determining a fair approach for modernization of the SAP. Paragraph 175 of the judgment offers these principles:
"Part of reconciliation may include placing limits on Aboriginal rights. EMS quotes Delgamuukw, which emphasizes the words from R. v. Gladstone, 1996 CanLII 160 (SCC), [1996] 2 S.C.R. 723, [1996] S.C.J. No. 79 (QL): “Aboriginal rights are a necessary part of the reconciliation of aboriginal societies with the broader political community of which they are part; limits placed on those rights are, where the objectives furthered by those limits are of sufficient importance to the broader community as a whole, equally a necessary part of that reconciliation” (para. 73). Aboriginal rights are not absolute, and exist within Canadian society and Canada’s constitutional framework. EMS quotes Chippewas of Sarnia to underscore this point: “a court must take into account the perspective of the Aboriginal people claiming the right … while at the same time taking into account the perspective of the common law” such that “[t]rue reconciliation will, equally, place weight on each”. The accommodation is to be done in a manner that does not strain “the Canadian legal and constitutional structure”. The co-existence of Aboriginal title and fee simple title is not supported by Canada’s constitutional framework".
The courts have clearly stated that it is the government's responsibility to fully fund/implement fair and reasonable reconciliation efforts recognizing needs/interests of both communities (indigenous and non-indigenous) if they wish to pursue real meaningful reconciliation. This SAP review was initiated in response to the Ahousaht case - DFO and the Minister cannot ignore their duties to act reasonably, considering how they account for FN's rights and equally accounting for provisions to non-indigenous peoples contained within common law.
searun
Well-Known Member
Next instalment ....
Salmon as Reconciliation Currency:
To cite a principle outlined by the New Brunswick Court of Appeal, the SAP approach "must not strain" our constitutional and legal foundations. For reconciliation to proceed successfully, government must find a delicate balance between meeting the rights and interests of FN’s, while ensuring non-Aboriginal rights and interests are equally and fairly treated. To do otherwise, creates disfunction and socio-economic harm to Canada and perversely sets meaningful reconciliation back 30 years.
It appears this government seeks to utilize salmon as reconciliation currency – this is a slippery slope and incredibly difficult to navigate. Clearly if government seeks to re-allocate salmon from non-Aboriginal Canadians to FN’s there will be winners and losers in that process. In our view, the interests of the majority of non-Aboriginal Canadians reside primarily within the Recreational fishery, where the public right to fish supports the greatest social and economic benefits. Going forward, we do not see a future for the Commercial Salmon fishery if government seeks to re-allocate salmon to FN’s from non-Aboriginal fisheries.
If that is the circumstance moving forward, then the wisest use of a limited common property salmon resource is best determined by allocation of those resources in a way that optimizes benefits to Canada in creation of jobs, GDP, social & cultural benefits.
Salmon as Reconciliation Currency:
To cite a principle outlined by the New Brunswick Court of Appeal, the SAP approach "must not strain" our constitutional and legal foundations. For reconciliation to proceed successfully, government must find a delicate balance between meeting the rights and interests of FN’s, while ensuring non-Aboriginal rights and interests are equally and fairly treated. To do otherwise, creates disfunction and socio-economic harm to Canada and perversely sets meaningful reconciliation back 30 years.
It appears this government seeks to utilize salmon as reconciliation currency – this is a slippery slope and incredibly difficult to navigate. Clearly if government seeks to re-allocate salmon from non-Aboriginal Canadians to FN’s there will be winners and losers in that process. In our view, the interests of the majority of non-Aboriginal Canadians reside primarily within the Recreational fishery, where the public right to fish supports the greatest social and economic benefits. Going forward, we do not see a future for the Commercial Salmon fishery if government seeks to re-allocate salmon to FN’s from non-Aboriginal fisheries.
If that is the circumstance moving forward, then the wisest use of a limited common property salmon resource is best determined by allocation of those resources in a way that optimizes benefits to Canada in creation of jobs, GDP, social & cultural benefits.
searun
Well-Known Member
Next instalment....
Recreational and Commercial Allocation Principles:
The 1999 SAP allocation between Recreational and Commercial should in our view continue as before. The 1999 SAP approach was fair to all concerned. Allocations between Recreational and Commercial should be guided by a principle of assessing which fishery delivers the optimal socio-economic benefits to Canada – a “wisest use” principle.
Commercial fishers despite Recreational priority for Chinook and Coho, landed more than 50% of the non-Aboriginal catch (51.2% Chinook, 57.4% Coho), and 95% of Sockeye, Chum and Pink. Despite this, the commercial salmon fishery is unable to remain economically viable given they receive the majority of all 5 salmon species under the 1999 SAP. DFO Economics Branch analysis clearly demonstrates the commercial fishery which requires industrial levels of access to salmon, is fundamentally a broken economic model. For example, the commercial salmon fishery generates average household incomes of $8,967 for 881 participants – clearly not a livable income, representing a lifestyle choice. In contrast, the recreational fishery generates 25x more GDP, and 9,110 jobs creating average annual household income of $66,167.
Further DFO Economics Branch analysis indicates that after expenses EBITDA earnings for the Commercial Salmon fleets respectively are:
Path Forward:
Proposals to remove recreational priority for Chinook and Coho, replacing that with a fixed share where most salmon would be re-allocated to the Commercial sector is nothing more than a subsidy. No amount of additional subsidization will make the commercial salmon fishery viable.
It seems to us that the wisest use principle applied to a modernized SAP would be to focus allocation priority on supporting the greatest social and economic benefits that will help drive Canada’s economy, creating optimal jobs and GDP. This supports holding the public fishery harmless in the SAP allocation amendment.
Therefore, a reasonable path forward for government would be to fully fund a fair compensation program to allow commercial salmon fishers to retire their salmon allocations through a fair one-time buy-back compensation process.
The New Brunswick Appeal Court espoused a compensation principle for government to address reconciliation in a land title case, which in our view also applies to SAP, J.D. Irving, Limited et al. v. Wolastoqey Nation (Wolastoqey Nation, paragraph 202:
“I endorse this commonsensical and reconciliation-friendly conclusion. In my view, remedial justice favours compensation from the Crown over dispossession of private fee simple ownership in all cases although, admittedly, that is especially the case “when the land has passed through numerous innocent hands”.
In our view using both title and fee simple title and public access and allocation of salmon as a reconciliation currency is not supported by Canada’s constitutional framework. We have an opportunity through the SAP to strike a reasonable balance – using fair compensation to retire commercial salmon allocations as a mechanism to support broad reconciliation between both indigenous and non-indigenous communities.
The Bottom Line:
Proposals from Commercial and First Nations stakeholders to amend the 1999 Allocation Policy would be a death knell to the public fishery resulting in significant social and economic harm. These proposals would replace the current system – where access is coordinated across fisheries – with a rigid percentage-based “share “model. Our immediate concern would be these proposals will drive irreparable harm to the public fishery, leading to:
Bottom line
Recreational and Commercial Allocation Principles:
The 1999 SAP allocation between Recreational and Commercial should in our view continue as before. The 1999 SAP approach was fair to all concerned. Allocations between Recreational and Commercial should be guided by a principle of assessing which fishery delivers the optimal socio-economic benefits to Canada – a “wisest use” principle.
Commercial fishers despite Recreational priority for Chinook and Coho, landed more than 50% of the non-Aboriginal catch (51.2% Chinook, 57.4% Coho), and 95% of Sockeye, Chum and Pink. Despite this, the commercial salmon fishery is unable to remain economically viable given they receive the majority of all 5 salmon species under the 1999 SAP. DFO Economics Branch analysis clearly demonstrates the commercial fishery which requires industrial levels of access to salmon, is fundamentally a broken economic model. For example, the commercial salmon fishery generates average household incomes of $8,967 for 881 participants – clearly not a livable income, representing a lifestyle choice. In contrast, the recreational fishery generates 25x more GDP, and 9,110 jobs creating average annual household income of $66,167.
Further DFO Economics Branch analysis indicates that after expenses EBITDA earnings for the Commercial Salmon fleets respectively are:
- Gillnet - $13,900 (loss)
- Seine - $25,700 (loss)
- Troll + $1,200 (very slim profit)
Path Forward:
Proposals to remove recreational priority for Chinook and Coho, replacing that with a fixed share where most salmon would be re-allocated to the Commercial sector is nothing more than a subsidy. No amount of additional subsidization will make the commercial salmon fishery viable.
It seems to us that the wisest use principle applied to a modernized SAP would be to focus allocation priority on supporting the greatest social and economic benefits that will help drive Canada’s economy, creating optimal jobs and GDP. This supports holding the public fishery harmless in the SAP allocation amendment.
Therefore, a reasonable path forward for government would be to fully fund a fair compensation program to allow commercial salmon fishers to retire their salmon allocations through a fair one-time buy-back compensation process.
The New Brunswick Appeal Court espoused a compensation principle for government to address reconciliation in a land title case, which in our view also applies to SAP, J.D. Irving, Limited et al. v. Wolastoqey Nation (Wolastoqey Nation, paragraph 202:
“I endorse this commonsensical and reconciliation-friendly conclusion. In my view, remedial justice favours compensation from the Crown over dispossession of private fee simple ownership in all cases although, admittedly, that is especially the case “when the land has passed through numerous innocent hands”.
In our view using both title and fee simple title and public access and allocation of salmon as a reconciliation currency is not supported by Canada’s constitutional framework. We have an opportunity through the SAP to strike a reasonable balance – using fair compensation to retire commercial salmon allocations as a mechanism to support broad reconciliation between both indigenous and non-indigenous communities.
The Bottom Line:
Proposals from Commercial and First Nations stakeholders to amend the 1999 Allocation Policy would be a death knell to the public fishery resulting in significant social and economic harm. These proposals would replace the current system – where access is coordinated across fisheries – with a rigid percentage-based “share “model. Our immediate concern would be these proposals will drive irreparable harm to the public fishery, leading to:
- Significantly reduced recreational fixed shares-based allocations – where the majority allocation would move to support commercial fishery subsidization.
- Insufficient stable, predictable access to salmon necessary to support guided fishery and lodges creating a “locals only” fishery – leading to adjusting recreational fishing regulations to create short seasons to spread out limited allocations that likely could close fishing with no notice making planning family vacations impossible – impacting tourism and local expenditures on fishing and fishing related goods and services.
- Requirement to severely restrict or eliminate non-resident recreational fishers given the limited salmon allocations available – with associated impacts to tourism revenues.
- Significant business failures in those businesses reliant upon the current recreational fishery – businesses such as tackle manufacturers & shops, marine suppliers, marine outboard and boat sales, hotels, airline travel, lodges, marinas, marine fuel suppliers, food services providers.
Bottom line
- No - to re-allocation of any Recreational salmon
- No - to Fixed Shares and Caps
- No - to gifting recreational salmon allocations to subsidize commercial fisheries to help make them economically viable
- No - to giving control over who determines salmon allocations to local sub-area salmon allocation boards that are controlled by stakeholder groups who have a vested interest as competing harvesters – this proposed concept will not ensure independent fairness in allocation decision-making. We must maintain coast-wide fishery planning through the DFO led IFMP process
- Yes – to maintaining Conservation and Common Property fishery management as a key objectives of the SAP
- Yes – to maintaining 1999 Recreational priority for Chinook & Coho
- Yes – to improving management practices for recreational access to Sockeye, Chum and Pink
- Yes – to fair support to FN’s FSC, Treaty and Court Defined commercial salmon fisheries
- Yes – to a fair one-time retirement buy-out for all remaining commercial salmon fishers (and commercial salmon allocations) with that salmon allocation being distributed to both Recreational and FN’s FSC
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