searun
Well-Known Member
DFO held public meetings - you may recall meetings in Victoria and Sooke? They have also held numerous meetings with local SFAC groups and the SFAB Conference Board. Additionally, the SFAB has been fully engaged in all the Technical Working Groups and Multi-party consultations.I did not see any meaningful consultation with the rec sector about the proposed measures. If DFO did the same with FN and called this joke "consultation" they'd be sued immediately.
The SFAB is the official advisory body to the Minister of Fisheries, and is a grass roots organization with 25 local Sport Fish Advisory Committees (SFAC) that any recreational angler can join and participate within. Each local SFAC can provide feedback in the form of motions up to Species Committees or in the case of SRKW, to the SRKW Working Group (WG). That WG in turn provides input to the SFAB Conference Board (SB), and any motions or advice that is supported at the CB becomes the official advice to the Minster of Fisheries. In the case of SRKW, the WG provided a full report with recommendations for alternative incremental measures. Those were adopted and forwarded to DFO as advice to the Minister in the last round of public consultations.
So, I would suggest meaningful and fulsome consultation has taken place.
Attached below is a summary section from the SFAB Advice to Minister document. The SFAB submission was 12 pages, which is too large to post here - Appendix A captures a brief summary of recommendations.
Appendix A
SFAB Recommendations
- DFO investigate transitioning SRKW management measures to an adaptive management approach as a response to government direction to the Emergency Order response requesting new incremental measures
- Given high spatial temporal variability of SRKW foraging behaviour, the SFAB recommends DFO transition to an adaptive management approach
- DFO incorporates a principle of applying analysis of how management measures achieve effective balance between those measures and ensuring social and economic benefits to Canada are optimized
- Proposed extensions to closure periods are held in abeyance pending a DFO review to develop clear objective science-based assessment of the benefit to SRKW prey availability directly related to implementation of these measures.
- Additionally, the Department undertakes an economic analysis of the impact of this proposal to inform decision makers seeking to assess the balance between what is to be gained and lost.
- To support implementation, the SFAB recommends DFO investigates the following issues:
- Total Chinook Abundance:
- Current status of chinook abundance in SRKW habitat during the time SRKW are present – aligned to areas currently part of fixed spatial-temporal fishery closures – establish a baseline to measure changes over time
- Analysis of prey availability within existing areas designated to assess effectiveness of management measures performance delivery (all prey made available for SRKW)
- Analysis of Fraser stream-type chinook made available through implementing existing measures – comparative analysis of Fraser to all other sources of chinook, chum, coho
- Analysis of the effect of prey competition from recreational fishing activity specifically within existing
Recovery Objectives, Measures and Targets:
- DFO undertake investigation and research to inform development of incremental measures, but those must be framed from a management focus that also achieves a balance with social and economic considerations as a key principle.
- Evaluation to identify objective metrics to measure fishery management measure performance
- DFO establish clear recovery objectives for all SRKW proposed measures to address Chinook abundance (prey availability & accessibility)
- DFO evaluate exemptions for commercial Whale Watching operations to determine if synchronization to a 400m avoidance zone standard is in the best interest of SRKW prey acquisition requirements to limit physical and acoustic disturbances from these vessels as an effective incremental measure to enhance SRKW prey acquisition success
- Department’s undertake comparative investigative analysis of the performance of existing fishery closures and static non-adaptive measures in delivering objective protection benefit outcomes for SRKW against adaptive management measures proposed by the SFAB
- The proposed chinook closure brings little if any meaningful benefit, and while it provides the appearance of implementing an incremental measure, it creates confusion, uncertainty and impedes the stable environment necessary to attract tourists to fishing dependent communities. For these reasons, we recommend this proposal does not advance.
- Before bringing this proposal forward in future, the Department complete a thorough analysis to determine the differential benefit of the Chinook Closure vs other measure such as non-retention or adaptive management options proposed by the SFAB.
- DFO Economics and Policy Branch complete an analysis to measure the benefit to SRKW management measures against the opportunity cost of Social and Economic benefits the recreational fishery provides to GDP and job creation
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