For those interested, here is DFO's response to my comments on page 14:
Hello,
Thank you for your recent correspondence regarding Chinook conservation measures for 2019.
It is a difficult time for coastal communities that rely on the fishing industry, and Fisheries and Oceans Canada (DFO) acknowledges concerns regarding the economic and social impacts resulting from the reduced fishing opportunities for salmon. We have provided a broad overview of the background on Chinook fisheries management and related topics.
British Columbians have an enduring connection with Pacific salmon, which holds tremendous value for natural ecosystems, cultural and spiritual practices, jobs and income, and recreational enjoyment along the coast and inland watersheds of the Pacific Region. DFO is very concerned about the health of fish and our oceans.
Fraser River Chinook salmon in particular have experienced a dramatic decline in recent years. In November 2018, the Committee on the Status of Endangered Wildlife in Canada (COSEWIC) assessed seven Fraser River Chinook salmon populations as endangered, four as threatened, and one as a special concern. This assessment has implications for these stocks and for Southern Resident Killer Whales (SRKW), which are listed as endangered under the
Species at Risk Act (SARA) and which depend on Chinook salmon as their preferred prey.
DFO is guided by a strong framework of conservation policies including
Canada’s Policy for Conservation of Wild Pacific Salmon (Wild Salmon Policy), the
Sustainable Fisheries Framework and a
Fishery Decision-Making Framework Incorporating the Precautionary Approach. These important policies support the conservation and sustainable use of Canadian fisheries through monitoring and assessment, and they ensure that management relies on evidence-based and precautionary decision making.
The Department, along with others, urgently needs to address these declines and changes to marine life, freshwater habitat, and ecosystems that are affecting salmon and the communities that rely on them. Last year, new management measures were introduced to reduce fishery mortalities on Chinook populations of conservation concern in British Columbia (including Skeena, Nass, and Fraser River origin Chinook salmon) by 25 to 35 percent to limit pressure on these stocks. However, preliminary data indicates that the target reductions in 2018 were not achieved and Fraser River Chinook salmon in particular continued to decline. Despite DFO’s efforts, a broad pattern of decline has affected many Chinook salmon populations in southern BC, and these populations require bold action to prevent extinction.
Therefore, DFO introduced new management measures for Fraser River Chinook salmon in 2019. These measures build on the actions taken last year, introducing new constraints across all fisheries encountering Chinook. The 2019 goal is designed to allow as many endangered and threatened Fraser River Chinook salmon stocks to reach the spawning grounds as possible. Management actions seek to minimize fishery mortalities in commercial, recreational, and First Nations fisheries where these Chinook are encountered.
In all fisheries management decisions, conservation is the first and fundamental priority, followed by respect for Indigenous peoples’ constitutionally protected priority for food, social, and ceremonial (FSC) fisheries. DFO then considers allocation priorities and provides sustainable fisheries where possible.
First Nations are contending with new reductions to FSC fisheries as part of these actions. To support conservation outcomes, communal fisheries will not commence until July 15, 2019. Prior to July 15—consistent with the Government’s constitutional obligations to First Nations—DFO will provide First Nations with ceremonial access opportunities (e.g. funerals or first fish ceremonies) to harvest very limited numbers of Chinook.
The Department recognises the significance of Chinook to the recreational fishery and the role played by the recreational fishery as a source of food, income, and employment in many communities. A continued decline in Fraser River Chinook would harm species that depend on the survival of Chinook salmon, such as SRKW. A continued decline would also permanently affect the culture, heritage, and livelihoods of Indigenous communities and permanently eliminate many more jobs in the recreational and commercial fishing industries.
The Department sought input from, and carefully considered advice and recommendations provided by, Indigenous peoples and all stakeholders, including commercial and recreational harvesters, environmental organizations, and the public. Advice gathered from consultations led DFO to modify the original fishery proposals.
Fishery Notice 0377 contains details on 2019 Commercial, Recreational and Aboriginal Fraser River Chinook Conservation Measures and coast-wide recreational annual limits for Chinook salmon in tidal waters.
DFO Pacific Region Conservation and Protection comprises 180 fishery officer positions. Fishery officers conduct patrols by land, air, and water, in uniform or plain clothes, to monitor compliance of the
Fisheries Act and regulations.
Regarding Tidal Waters Sport Fishing Licences (TWSFLs), DFO does not issue refunds for the cost of annual TWSFLs or Salmon Conservation Stamps. TWSFLs provide access and opportunity to harvest fish other than Chinook salmon. As you may know, all revenues from the Salmon Conservation Stamp go to the Pacific Salmon Foundation to support projects that improve Pacific salmon habitat. For one-, three-, and five-day TWSFLs, requests for refunds may be directed to the Pacific Fishery Licensing Unit at <
Fishing-Peche.XNAT@dfo-mpo.gc.ca >. DFO will review requests on a case-by-case basis.
The Department does not provide compensation to recreational salmon licence holders or to businesses potentially affected by reductions in fisheries opportunities. Stock levels fluctuate every year, and fisheries closures for conservation are a regular occurrence and necessary for responsible management of the fisheries.
Fishery management measures alone will not restore salmon. The Department continues to work on a number of fronts to protect wild salmon, including rebuilding measures and habitat restoration. DFO’s
Protecting Canada’s wild salmon website provides information on the Government’s work on the
Wild Salmon Policy and its Implementation Plan; the International Year of the Salmon, SARA
: Pacific salmon; and the Salmonid Enhancement Program. The website also provides links to information on habitat restoration and the British Columbia Salmon Restoration and Innovation Fund, a collaborative initiative with the Province of BC.
In addition, to support salmon recovery, the Department is undertaking more science work, including research regarding climate change, as detailed on the
Scientific research and Pacific salmon website.
Understanding what is happening to our stocks and to our freshwater and marine environments is the key to ensuring that salmon and their habitats are managed sustainably. The Department’s work includes documenting assessment methods, improving databases, and better understanding a range of threats including habitat and water use impacts, disease, climate change, predator impacts, and other issues, and exploring mitigation options.
DFO recognizes the importance of Pacific salmon and salmon habitats from multiple perspectives—environmental, economic, and sociocultural. Given the complex life cycles of wild salmon, combined with the multiple jurisdictions and regulatory frameworks implicated, it is critical that all affected sectors and governments continue to work together on a holistic approach to salmon conservation. DFO is confident that by working together to conserve salmon, we will secure a brighter future for wild Pacific salmon in British Columbia.
The road to recovery requires a long-term view and the collaboration of all interested parties. To this end, DFO will be engaging with First Nations and stakeholders, including the Province of British Columbia and commercial and recreational harvesters, to explore establishing a process to address a broad range of issues impacting Chinook stocks. It is expected that this process will address issues including conservation, land and water use, fish habitat, role of hatcheries to support rebuilding and potential for marking selective fisheries, and impacts of seals and sea lions on Chinook salmon, among others. DFO’s hope is that this process will play a vital role in determining how best to steward the resource moving forward.
The Department understands that this is a challenging situation. Our immediate priority is conservation of Fraser River Chinook salmon and supporting their long-term recovery.
eman
LOL. 
