Cuba Libre
Well-Known Member
Part One:
March 1, 2010
Honourable Gail Shea,
Minister of Fisheries and Oceans
Parliament Buildings
Ottawa, On
K1A 0E6
by e-mail
Dear Minister;
On behalf of the executive members of the Sport Fishing Advisory Board, I have been
asked to respond to your recent media release on recreational halibut allocation.
You say in your February 15 statement that you understand the “value of the
recreational fishery to British Columbians and the economic opportunities it provides”.
Unfortunately, your actions suggest otherwise.
. If you understand that recreational fishing is the single largest component of
the fishery economy in British Columbia, at 40 percent of its total GDP value,
why do you continue to restrict and reduce its activity by imposing bag and
possession limits of 1 and 2 for halibut and making it impossible for anglers or
service providers to predict season length?
. If you understand that the economic value of the recreational halibut fishery
based on 12% of the catch is similar to the economic value of the commercial
fishery based on 88% why are you favouring the sector dominated by a quota
leasing market that according to recent academic analysis is “limiting
efficiency, stifling innovation, and causing financial hardship”.
You say that “a ministerial decision is required to move forward for the 2011 season”
but your “decision” was to do nothing. You have chosen to leave the 88/12 allocation
and last year’s possession limit unchanged. You have confirmed that for practical
purposes your authority under the Fisheries Act has been fettered by the 2003
decision of a Liberal predecessor to insist that any growth in the recreational share of
halibut can only take place by means of private financial transactions with quota
holders who have been given what amount to perpetual property rights.
Your media statement confirms that you have abdicated your statutory authority by
giving complete control over allocation to an unregulated private marketplace. It says
that future change can only take place:
. If the sectors develop an acceptable way “to transfer allocation between
them.”
. If recreational stakeholders „lease quota from “commercial harvesters”.
. If MP Randy Kamp can develop options that provide flexibility through “an
effective mechanism for transfers between the sectors”.
You say in your media statement that you have long held the belief “that those who
participate in and depend on a fishery to make their living need to be able to provide
input into how that fishery is managed.” Unfortunately, your actions suggest the
opposite. In British Columbia, participation in the fishery is not a requirement. In fact,
preference is given to non-fishing quota holders. One of the documents issued with
your statement asks the question “Is the Department concerned about commercial
licence holders leasing out their quota without actually fishing? Your answer is to
restrict recreational sector growth to use of an “experimental licence to lease quota”
which extends the right of non-fishing quota holders to not only take financial
advantage of active commercial harvesters but also to hold the recreational sector to
ransom if it wants to get out of the 88/12 prison. You have given the paid lobbyists for
the non-fishing quota holders and their private society, the PHMA, preferential
treatment by confirming that quota has become private property exempt from
ministerial change. By contrast you have ignored the SFAB’s input, presumably
because it represents only the public’s access rights and is required by its terms of
reference to give majority representation to people who do not benefit financially from
the fishery.
It is both ironic and troubling that the privileged treatment of west coast non-fishing
quota holders who “make their living” by leasing rather than fishing, is in stark
contrast to the government’s position on Atlantic Canada fisheries. When approving
“buddy-up” arrangements in 2009, you said that you supported the policy announced
in 2007 by your predecessor Loyola Hearn on behalf of the “New Government of
Canada”, which was “to support the owner-operator principle” and “end policies
that move the wealth generated from the fishery from those who actually fish."
On February 12, 2009 you said “I believe that the fishery resources in Newfoundland
and Labrador should benefit those with a direct investment in the industry. I remain
committed to fleet rationalization and the owner-operator principle.” It seems
obvious that just one year later, because your allocation authority has become
fettered by the quota system, you are taking a diametrically opposed position on the
Pacific coast.
We are troubled because the DFO national website tells us that in Atlantic Canada
the government is moving against people who have been “circumventing licence
policies” to the disadvantage of harvesters. By contrast, in BC your officials do not
hesitate to issue licenses and quota shares to fictitious vessels so that absentee
fishlords, or “slipper skippers” can profit from leasing a majority of the fish to actual
harvesters and now demand the same benefits from recreational anglers. It is
obvious that on Canada’s West coast the government has no objection to a system
driven by non-fishing speculators! Far from being concerned about commercial
licence holders leasing out their quota without actually fishing, the department
encourages and facilitates it.
Your press release bemoans the fact that “stakeholders have been unable to reach a
consensus”. What it fails to mention is that in 2008 there was a consensus between
representatives of the commercial, recreational and First Nations fisheries as well as
the provincial government. The report from Hugh Gordon proposed that the federal
government fund an allocation transfer, as it has been doing for First Nations, with the
difference that it would then recover the cost over time from recreational anglers. You
rejected this proposal as “not something DFO can support” and now criticize a lack of
consensus from the Stanyer participants despite the fact it was made clear
throughout the Stanyer process that the purpose was not to find consensus but to
evaluate alternative proposals. In any case, consensus could hardly be found once
the PHMA made clear in writing that it no longer favoured any allocation change,
whether compensated or not. This was understandable. Why should a private
society, which your department gifted with 10% of the commercial TAC prior to
Larocque, and which now has privileged status as the commercial sector
representative, explore alternatives. It knows that your authority has been fettered
since 2003 by a series of political guarantees that no change will ever take place
except through arms length transactions between private individuals in an
unregulated market controlled by the current quota holders!
March 1, 2010
Honourable Gail Shea,
Minister of Fisheries and Oceans
Parliament Buildings
Ottawa, On
K1A 0E6
by e-mail
Dear Minister;
On behalf of the executive members of the Sport Fishing Advisory Board, I have been
asked to respond to your recent media release on recreational halibut allocation.
You say in your February 15 statement that you understand the “value of the
recreational fishery to British Columbians and the economic opportunities it provides”.
Unfortunately, your actions suggest otherwise.
. If you understand that recreational fishing is the single largest component of
the fishery economy in British Columbia, at 40 percent of its total GDP value,
why do you continue to restrict and reduce its activity by imposing bag and
possession limits of 1 and 2 for halibut and making it impossible for anglers or
service providers to predict season length?
. If you understand that the economic value of the recreational halibut fishery
based on 12% of the catch is similar to the economic value of the commercial
fishery based on 88% why are you favouring the sector dominated by a quota
leasing market that according to recent academic analysis is “limiting
efficiency, stifling innovation, and causing financial hardship”.
You say that “a ministerial decision is required to move forward for the 2011 season”
but your “decision” was to do nothing. You have chosen to leave the 88/12 allocation
and last year’s possession limit unchanged. You have confirmed that for practical
purposes your authority under the Fisheries Act has been fettered by the 2003
decision of a Liberal predecessor to insist that any growth in the recreational share of
halibut can only take place by means of private financial transactions with quota
holders who have been given what amount to perpetual property rights.
Your media statement confirms that you have abdicated your statutory authority by
giving complete control over allocation to an unregulated private marketplace. It says
that future change can only take place:
. If the sectors develop an acceptable way “to transfer allocation between
them.”
. If recreational stakeholders „lease quota from “commercial harvesters”.
. If MP Randy Kamp can develop options that provide flexibility through “an
effective mechanism for transfers between the sectors”.
You say in your media statement that you have long held the belief “that those who
participate in and depend on a fishery to make their living need to be able to provide
input into how that fishery is managed.” Unfortunately, your actions suggest the
opposite. In British Columbia, participation in the fishery is not a requirement. In fact,
preference is given to non-fishing quota holders. One of the documents issued with
your statement asks the question “Is the Department concerned about commercial
licence holders leasing out their quota without actually fishing? Your answer is to
restrict recreational sector growth to use of an “experimental licence to lease quota”
which extends the right of non-fishing quota holders to not only take financial
advantage of active commercial harvesters but also to hold the recreational sector to
ransom if it wants to get out of the 88/12 prison. You have given the paid lobbyists for
the non-fishing quota holders and their private society, the PHMA, preferential
treatment by confirming that quota has become private property exempt from
ministerial change. By contrast you have ignored the SFAB’s input, presumably
because it represents only the public’s access rights and is required by its terms of
reference to give majority representation to people who do not benefit financially from
the fishery.
It is both ironic and troubling that the privileged treatment of west coast non-fishing
quota holders who “make their living” by leasing rather than fishing, is in stark
contrast to the government’s position on Atlantic Canada fisheries. When approving
“buddy-up” arrangements in 2009, you said that you supported the policy announced
in 2007 by your predecessor Loyola Hearn on behalf of the “New Government of
Canada”, which was “to support the owner-operator principle” and “end policies
that move the wealth generated from the fishery from those who actually fish."
On February 12, 2009 you said “I believe that the fishery resources in Newfoundland
and Labrador should benefit those with a direct investment in the industry. I remain
committed to fleet rationalization and the owner-operator principle.” It seems
obvious that just one year later, because your allocation authority has become
fettered by the quota system, you are taking a diametrically opposed position on the
Pacific coast.
We are troubled because the DFO national website tells us that in Atlantic Canada
the government is moving against people who have been “circumventing licence
policies” to the disadvantage of harvesters. By contrast, in BC your officials do not
hesitate to issue licenses and quota shares to fictitious vessels so that absentee
fishlords, or “slipper skippers” can profit from leasing a majority of the fish to actual
harvesters and now demand the same benefits from recreational anglers. It is
obvious that on Canada’s West coast the government has no objection to a system
driven by non-fishing speculators! Far from being concerned about commercial
licence holders leasing out their quota without actually fishing, the department
encourages and facilitates it.
Your press release bemoans the fact that “stakeholders have been unable to reach a
consensus”. What it fails to mention is that in 2008 there was a consensus between
representatives of the commercial, recreational and First Nations fisheries as well as
the provincial government. The report from Hugh Gordon proposed that the federal
government fund an allocation transfer, as it has been doing for First Nations, with the
difference that it would then recover the cost over time from recreational anglers. You
rejected this proposal as “not something DFO can support” and now criticize a lack of
consensus from the Stanyer participants despite the fact it was made clear
throughout the Stanyer process that the purpose was not to find consensus but to
evaluate alternative proposals. In any case, consensus could hardly be found once
the PHMA made clear in writing that it no longer favoured any allocation change,
whether compensated or not. This was understandable. Why should a private
society, which your department gifted with 10% of the commercial TAC prior to
Larocque, and which now has privileged status as the commercial sector
representative, explore alternatives. It knows that your authority has been fettered
since 2003 by a series of political guarantees that no change will ever take place
except through arms length transactions between private individuals in an
unregulated market controlled by the current quota holders!
