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ASF Submission to DFO Survey on Gulf Recreational Salmon Angling Management

ASF is sharing below its submission to DFO concerning the management of wild Atlantic salmon in the Gulf Region. We encourage people to submit their own responses by the deadline of Feb. 29.
The survey itself can be reached at:
http://www.glf.dfo-mpo.gc.ca/Gulf/FAM/Recreational-Fisheries/2016-atlantic-salmon-survey


ASF Response to DFO Survey on Management (PDF Format) 121.2KB


ASF Response to DFO Survey:

This document outlines the Atlantic Salmon Federation’s (ASF) responses to the consultation survey on the 2016 Atlantic salmon Recreational Fishing Plan in Recreational Fishing Areas 15, 16, and 18 in the southern Gulf of St. Lawrence.

ASF clearly recognizes that the problems facing wild Atlantic salmon are wide-ranging and go far beyond the recreational fishery, and that restrictions to the recreational fishery alone will not halt the long-term decline, nor be the sole reason for recovery.  Action is required on all 61 recommendations contained in the Ministerial Advisory Committee’s report, and it is important for all who value wild Atlantic salmon to communicate this need to our new federal government, as well as to our respective provincial agencies, to spark that action.    

While this process is underway, and until multi-year fishery management plans are implemented that incorporate the Precautionary Approach, it is very important for the recreational fishery to be managed in a fashion that will reduce and minimize mortality in our populations that have been struggling to meet even minimum spawning requirements (officially known as Conservation Limits).

The consultation survey provided to us by DFO requested our views on the management of the recreational Atlantic salmon fishery for the 2016 season.  Our response to each of the questions is provided below.


1. Do you agree with the use of catch and release (no retention of grilse) as a management measure in the Atlantic salmon recreational fishery (like in 2015)?

Yes


2. Do you agree it is appropriate to continue with catch and release in the Atlantic salmon recreational fishery in 2016?

Yes

3.    Do you agree that additional conservation measures are necessary to protect Atlantic salmon?

Yes  (See our additional comments provided below.)

4.    Overall, do you believe that DFO is devoting enough effort and resources to monitor and manage the Atlantic salmon population and fishery?

No

5.    Overall, do you believe that DFO is using adequate fish population monitoring programs and management measures to address the declining trend of the Atlantic salmon population?

No

6.    Additional comments

In these additional comments we:

1. Outline our reasons why we believe it is appropriate to continue with mandatory catch and release in the Atlantic salmon recreational fishery in 2016; and

2. Discuss additional conservation and management measures that we feel must be in place to ensure the sustainability of any future grilse harvest.

  1. The following points outline why we believe it is appropriate to continue with mandatory catch and release in Recreational Fishing Areas 15, 16, and 18 in the southern Gulf of St. Lawrence for the 2016 salmon fishing season.


  • The historical low runs of 2012-2014 of both large salmon and grilse on many rivers in the region prompted the formation of the DFO Ministerial Advisory Committee (MAC) to address what many people felt was a crisis. The MAC consulted widely throughout eastern Canada with many public and salmon interest groups and First Nations, and made 61 recommendations for actions to halt and reverse the decline. DFO, under the new government and Minister, is now assessing those recommendations and working on a strategy for implementation which is expected soon.

A list of the 61 MAC recommendations can be found here:

http://www.dfo-mpo.gc.ca/media/infocus-alaune/2015/salmon/MACAS-CCMSA-eng.htm#recommendations

  • The implementation of mandatory catch and release for 2015 came from recommendations put forward by many concerned organizations (including ASF) during the MAC consultations in early 2015. At that time the majority of angling and conservation groups suggested that it be implemented in 2015 as a precautionary measure, to ensure that the recreational fishery did not contribute to further declines, and to provide time to consider and implement other recommendations being developed by the MAC.

  • ASF believes that, given the information at hand about the long-term decline of salmon stocks, combined with three years of poor returns (2012-2014), implementing mandatory catch and release was the right decision.  Despite the low numbers, it allowed anglers to continue to enjoy accessing the resource and to be the eyes and ears of conservation, while minimizing their impacts on a stressed resource.  

  • These measures also contributed to positive movement in other critical areas of fisheries management.  It enabled Canada to report to the North Atlantic Salmon Conservation Organization (NASCO) that it has taken steps to reduce fishing mortality on a stressed resource.  This assisted in creating pressure on Greenland to move toward reducing and better managing their fishery. In 2014, Greenland had a reported catch of 58 tonnes; however, it was determined that there was a high degree of non-reporting, resulting in an underestimate of the total harvest.  The actual harvest by Greenland in 2014 was potentially as high as 96 tonnes. In 2015, Greenland agreed to cap their 2015-2017 annual catch at 45 tonnes and, to counteract high levels of unreported catch, implement significantly stronger monitoring, control and reporting measures to ensure that the actual catch is capped at 45 tonnes.   It is also our understanding that the catch and release regulation has been taken into account by some First Nation communities, and therefore may have played a contributing role in moving toward selective fisheries (i.e. where large spawners can be released for conservation reasons) in certain areas such as the Miramichi.

  • The question that is before us now is whether to continue the mandatory catch and release for 2016.  ASF believes that mandatory catch and release should be left in place for the 2016 season for the following reasons:

  • DFO is presently developing a multi-year recreational fisheries management plan that we have been told will be based on and built around the Precautionary Approach for the management of wild Atlantic salmon stocks and fisheries and which will incorporate some of the recommendations from the MAC.  We have been advised that this comprehensive management plan will not be ready in 2016. While this management plan is being developed, interim measures are needed that help conserve our stocks.

  • The 2015 catch and release measure was implemented at the request of a large number of angling and conservation groups at the four MAC hearings as a precautionary measure in the face of low returns and concern for the future of the resource and the fisheries it supports. Little has changed since mandatory catch and release was recommended and implemented a year ago, and significant concerns remain about the future of the resource. Although there seems to have been some improvement in returns in 2015 compared to the previous few years, we do not yet know the final numbers, but available information suggests that some rivers in the Miramichi and Restigouche systems probably did not meet their conservation limits despite the higher returns. We need to make decisions based on the best available science, not knee-jerk reactions to year-to-year variability: science tells us that populations are still near their historical lows and have a long way to go to be considered recovered.

  • Even if some rivers did meet their conservation limits in 2015, deciding on the coming year’s allowable harvest based on the previous year’s returns is not an adequate or scientifically acceptable form of management; our ability to predict the size of future returns based on past returns (or juvenile abundance) is poor, particularly with at-sea mortality being so high.  The only meaningful method for determining allowable harvest is to base it on the numbers of fish that have actually entered the river in that season, as determined by in-season counts. To date, however, in-season counts in support of in-season decision-making have not been implemented in the Gulf region (although experience elsewhere (e.g., Conne River and Harry’s River in Newfoundland and numerous rivers throughout the Gaspe region in Quebec) indicates that it is possible to do so).  Even if some rivers or tributaries could in theory support a small grilse harvest in the coming season, we do not know what that sustainable harvest is, and we currently have no way of limiting that harvest to sustainable levels on those tributaries/populations while preventing overharvest elsewhere. Given the low returns over the past few years and the uncertainty over what the returns will be in the 2016 season, being conservative and precautionary by continuing mandatory catch and release is the most sensible approach. Mandatory catch and release is the best way to signal that recreational anglers are doing everything possible to ensure that the recreational fishery does not contribute to future declines or impair future recovery.

  • And finally, it is important to recognize that mandatory catch and release is not the only step being taken to ensure the future of our salmon stocks. The 61 recommendations made by the Ministerial Advisory Committee contain significant measures to rebuild and sustainably manage Atlantic salmon stocks and the fisheries they support. Prioritizing and implementing all 61 MAC recommendations will take time. Collectively, we need to continue to advocate for the implementation of those recommendations, give the process time to work, and ensure that we do not make the situation worse in the meantime.  It is therefore incumbent on all of us who value wild Atlantic salmon to express to the federal government that these recommendations need action, and to show our commitment to conservation by supporting interim measures.
 
  • ASF recognizes and respects that people value Atlantic salmon and the recreational fisheries they support for many reasons, including for opportunities to harvest grilse for the dinner table. It is the desire of ASF to see salmon populations restored to their historic numbers wherever possible, supporting (and supported by) healthy and sustainable recreational fisheries that give people opportunities to enjoy the resource in ways consistent with their values. ASF also believes that if we are to get back to a point where grilse can be sustainably harvested, a number of important steps need to be taken, and we should be working towards these steps now.


The following points outline the conservation and management measures that ASF believes must be in place to ensure the sustainability of any future grilse harvest:

  • First, if we are to have a grilse harvest, we must have the information necessary to manage the fishery for sustainability. Currently, it would appear as though our approach to managing grilse is not working. On the Miramichi, where grilse are an important component of the stock, grilse returns have declined significantly since returns have been monitored. From 1971 to 1993, the average grilse run was approximately 65,000 per year (with a high of about 150,000 in 1992). From 1994 to 2011, the average grilse run was approximately 33,000. But from 2012 to 2014, the average grilse run was only approximately 9,000, with a low of 7,500 in 2014 (with only 1,200 estimated for the entire NW Miramichi system).  If this trend continues, there could be few grilse left on the Miramichi, let alone any that are available for harvest. Similar trends towards historical low abundance of grilse have been observed in Northumberland and Cape Breton rivers of Nova Scotia. Although other factors likely have had a larger impact on the decline of grilse runs than recreational fishing (e.g., low marine survival, predation, etc.), continuing to harvest grilse from such low population numbers without understanding the impact of that harvest on long-term sustainability would be a mistake. Currently, however, we do not have the information needed to understand what that impact is and what level of harvest would be sustainable in any given year.    

  • Consequently, more attention needs to be devoted to understanding the importance of grilse to the sustainability and resiliency of populations. Grilse are just one component of an age and size structured population that cannot be viewed or managed in isolation. On some rivers, such as the Southwest Miramichi, grilse have historically comprised the majority of returning adults, with the grilse to large salmon ratio being as high as 4 or 5 to 1 in some years. This river system simply would not consistently produce such high numbers of grilse if they were not important for the sustainability and resilience of the population. Although populations are managed based on egg deposition (which primarily come from large females), a sufficient number of males (which tend to be grilse) are needed to fertilize those eggs. Furthermore, grilse contribute to genetic diversity, and grilse that survive to spawn more than once will return to the rivers in subsequent years as larger spawners (both male and female).

  • Although we know that grilse are an important component of the population structure on most rivers, our understanding of this importance is limited. To ensure we can have a sustainable harvest, we need to know what the contribution of grilse is (both male and female), and therefore what the impact of removing grilse is, so that we are able to determine what level of harvest is sustainable in any given year.  An important question that must be considered with regard to sustainable grilse harvest is “what is a surplus”?  Any management decision made by DFO regarding the harvest of grilse by anglers must first take into consideration the right of First Nations communities to conduct their harvests for Food Social and Ceremonial purposes.  If there is a “surplus” of grilse after taking this harvest into consideration, combined with both egg deposition/fertilization and genetic contributions, then an angling harvest could be considered that would not compromise the abundance and/or diversity of future returns.

  • Second, when we are able to determine what level of grilse harvest is sustainable, we need a mechanism to ensure that our harvest is limited to that level each year and can be adjusted accordingly as returns vary, and appropriately distributed only to where it would be considered viable.

  • To do this, we need:

  • Harvest management that is done on a per-river, river classification, or stock-specific basis, taking into consideration the contribution of the grilse population to both spawning escapement and genetic diversity.
  • Determination of allowable annual harvest that is based on a reasonable, science-based expectation that the harvest will not compromise the stock’s ability to exceed its conservation limits after accounting for other removals (e.g., First Nation allocations). Returning adult counts, in-season reviews, and the ability to adjust harvest levels mid-season are preferred for stocks expected to be near or below their conservation limit.
  • A vastly improved catch reporting and enforcement system.

We believe that if DFO is committed to considering grilse harvests in the future, then they should be urgently working towards developing such a model and conducting the research to provide the necessary information to operationalize it. We note that the key components of this model (harvest based on abundance, river-by-river management, improved reporting and enforcement) are all contained in the 61recommendations of the MAC, and we hope that these will be incorporated into the forthcoming  multi-year management plan based on the Precautionary Approach.