From the Gill netters association
Lots of questions about the PSSI Long-Term Salmon Closure Initiative. The gillnet representatives from all areas have been working all winter on trying to get more information. We have had mixed results. I was hoping to hold off on an update until we had more concrete and helpful information and advice, but I am going to post this update thread now, in case that time never comes. Thanks to Darrel, Joy, Bob, Mike, Mabel, Calvin, Barry, Dean and all the others who have been working hard to try and get more information.
I will split this post into two parts for easier reading. The parent post will be the questions and answers between the CSAB and the DFO. (See below)
After the PSSI group heard from the gillnet fleet that we did not want a reverse auction system buyback, they came back to us and asked what we wanted instead. We had an informal meeting between various area reps in the gillnet fleet, and came up with a letter as our response. That letter will be posted as the first comment to this post (see comments)
Here are some questions that were compiled by the commercial fleet to the DFO, with their answers included as well. (This is from the DFO)
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CSAB Questions and Answers on PSSI Longer-Term Closures and Licence Retirement Program
1. How many of the 796 A and AI licenses does the PSSI intend to retire?
• There are 804 A and AI gillnet licences. DFO is reviewing the CSAB’s request to provide more specific targets for licence retirement and the request to identify the total funding that will be available for the licence retirement (and licence alternation) program. It’s important to note however, that because this is a voluntary program, actual uptake on the program is uncertain.
2. How many of the 588 FAG and NAG licenses does the PSSI intend to alternate?
• The Alternation program is a completely voluntary program. As such we are uncertain as to the potential uptake at this time. Our hope is that a proportion of the FAG and NAG licenses will be alternated through the program, allowing for the diversification of the fleet and a reduction in the pressures on Pacific Salmon.
3. Will the allocation from the retired A and AI licenses be treated the same way as the allocation from the alternated FAG and NAG licenses, and what is the destination of the retired allocation from both the retired and alternated licenses?
• Commercial salmon shares (specified as a % allocation of the allowable commercial harvest) are assigned by species, fleet and fishery production area and outlined in the Northern and Southern BC IFMPs.
• In the recent PST Mitigation Program troll licence retirement, the fleet shares were not adjusted as licences were retired (i.e., allocation stayed with the remaining fleet). Shares were set for a 5 year period with a provision for a review after year 4 to determine if adjustments should be made to Area A-H sharing arrangements in subsequent years. An earlier review could be considered if circumstances warrant by majority agreement of the commercial advisory board.
• DFO will be reviewing the Salmon Allocation Policy with First Nations and stakeholders, which will be the forum for considering longer-term allocation arrangements or adjustments between sectors. Current commercial salmon allocation arrangements remain in effect and are outlined in the salmon IFMPs.
4. When and how will the DFO and PSSI mitigate the years long deficit of Area D Conuma Chinook allocation that was transferred from the Area D license holders to the Five Nations?
• The PSSI licence retirement program funding is not intended to be directly used for mitigation of the Five Nations First Nations fisheries allocations.
• The Department has indicated that this may be mitigated over time via other funding, and discussions are underway within DFO regarding this matter.
5. Were encounter numbers considered when identifying closures, or only mortality rates?
• The Department assessed fishery risks as ‘high’ based on known occurrence of stocks of conservation concern in the fishery which is informed by encounter information. We applied a qualitative approach using a consistent evaluation framework to the fisheries to identify fisheries of high conservation risk and formal quantitative risk assessments are not available (see challenges in 2nd bullet). The release mortality rate of the gear was considered in identifying potential mitigation measures. The criteria of >25% release mortality was based on our release mortality rates outlined in the IFMP.
• The CSAB has requested the Department conduct detailed quantitative analysis to base fishery risk on encounter rates * release mortality rates to determine mortalities of stocks of concern relative to thresholds. Due to several factors including limited data on encounters/release rates, unknown origins of stocks in releases, and lack of specific mortality thresholds for most stocks of concerns this approach was not used. The precautionary approach for stocks in the critical zone is to keep mortality at the lowest possible level.
6. How many steelhead were saved by the 2021 Chum closures in Johnstone Strait, Nitinat, and Fraser Rivers?
• DFO does not have quantitative estimates of how many of each stock of concern would be saved by closing fisheries. We applied a qualitative approach using a consistent evaluation framework to the fisheries to identify fisheries of high conservation risk. Determining quantitative encounters (or “savings”) of IFR Steelhead in fisheries are challenged by several factors: a) Limited data on encounter/release rates. b) Unknown origin of stocks in releases (e.g., Steelhead vs. Thompson/Chilcotin Steelhead). c) Uncertainty about total removals and run size makes it challenging to use fishery mortality rates to assess fisheries.
• Management measures for IFR Steelhead are based on timing and exposure of IFR Steelhead to fisheries. Given that Thompson and Chilcotin populations are at historical low levels, there is also a consideration for an extended window closure as per recommendations from the Province of BC.
7. What are the details of the Licence Retirement Program (LRP)?
• When will it start? o Consultations with stakeholders on the design and implementation of the Pacific Salmon Commercial Licence Retirement Program are currently ongoing and input from these sessions will inform the final design. It is anticipated that the program will launch in Spring 2022.
• What will be the initial prices offered for seine (SN) and gillnet (GN) licences?
o The value of licences submitted to the program will be guided by estimates of market value.
o The Department has heard from stakeholders that the value of salmon licences has been affected by the extensive conservation measures that have been put in place in recent years and suggestions have been made to consider licence values prior to the implementation of the 2021 closures to determine market value.
• Will there be more than one offering by the PSSI?
o The Department anticipates carrying out multiple rounds of licence retirements until 2025. The number of rounds to be used per year may be determined based on engagement with licence holders early in the program’s implementation.
• Will licence be able to be unstacked to be retired?
o Similar to past licence retirement programs, stacked salmon licences are eligible for retirement.
o Salmon vessel owners will have the option to separate stacked licence(s) and retain the area for the remaining licence(s).
o Salmon licences married to other licences that may be on a vessel can also be separated for the purposes of retirement.
• Will PSSI make the same offer to all three GN and two SN areas at the same time?
o The licence retirement program is voluntary, and the Department will review all submissions and will consider those applications with amounts that fall within estimates of market value.
o The Department has not yet identified additional criteria that would differentiate between bids (apart from proposed market value criteria) that are submitted and welcomes feedback on this.
• The Department values and welcomes any feedback you may have on the different elements of the licence retirement program including fair market price, timelines, etc.
8. We have heard about a gear buyback program – can you provide details?
• There are currently no plans to buyback vessels and gear. There will be opportunities to support the disposal / recycling of vessels and gear. More details on this program will be shared in the near future.
9. Will food, social, and ceremonial (FSC) and Economic Opportunity (EO) fisheries be subject to the same restrictions given that conservation is the first priority?
• Allocation decisions are made in accordance with An Allocation Policy for Pacific Salmon.
• After conservation, the first priority in salmon allocation is to address treaty rights for harvest opportunities for domestic purposes (consistent with Treaty Final Agreements) and for FSC harvest opportunities (under communal FSC licences issued to First Nations).
• EO fisheries (not including the Five Nations rights-based sale access) are managed under the same allocation guidelines as commercial fisheries.
• In 2021, there were economic opportunity fisheries using gill net gear that were closed along with commercial fisheries given conservation concerns (e.g., Fraser Chum fisheries). EO fisheries are being evaluated in the same manner as commercial fisheries in terms of potential longer-term closures for 2022 and beyond.
There will be other initiatives under the Harvest Transformation Pillar of the PSSI to be announced shortly.
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