Eastern New Brunswick Coastal and Inland Recreational Fisheries Advisory Committee Submitted By: Atlantic Salmon Federation Submitted To: Fisheries and Oceans Canada (Gulf Region) Date: 14 December 2017 RE: 2018 Atlantic Salmon and Striped Bass Recreational Fishery Management Plans The Atlantic Salmon Federation (ASF) thanks Fisheries and Oceans Canada (DFO) for the opportunity to participate in this meeting alongside other stakeholders and rights holders, and to have input into the process. The following information represents ASF s advice to DFO for the recreational fishing management plans for Atlantic salmon and striped bass in the coastal and inland waters of eastern New Brunswick (Gulf Region). Guiding principles for ASF s submission include: Atlantic salmon a. Conservation is the overriding priority b. Respect for First Nations rights to the resource after conservation priorities c. River specific and science/evidence-based management is necessary d. Public engagement in Atlantic salmon fisheries is beneficial for conservation e. Adequate enforcement is essential i. Increase in number of officers ii. More effective collaboration between DFO and the Province, and with First Nation / aboriginal guardian programs. 1. Last year, ASF s advice for the 2017 season was to implement an effective and sound sciencebased management plan for all wild Atlantic salmon fisheries to ensure conservation requirements are not compromised, with a reference to the Ministerial Advisory Committee s (MAC) recommendation 2.1 and DFO s Forward Plan on implementing the Precautionary Approach (PA) (see Appendix A for references to MAC recommendations and Forward Plan). Currently, ASF is very encouraged and pleased to see progress on this advice, with DFO moving aggressively toward implementing the PA framework for management of all salmon fisheries throughout the Gulf Region. We are equally pleased to see the parallel process of establishing river by river management under the NB Recreational Salmon Management Transformation Project, with a pilot project for the Miramichi system in the planning stage. The emphasis now needs to be on getting it right: developing an effective, adequately funded system, implemented in a timely manner.
River specific management and harvest levels established based on the PA are what ASF has been requesting in wild Atlantic salmon management for years and it is now becoming a reality. We will continue to assist DFO in these processes for a smooth and timely implementation, beginning with the pilot project, and following with rivers in the rest of the Gulf Region. We are confident that the PA model will enable DFO to sustainably manage the Atlantic salmon resource by determining science-based harvest levels for all salmon fisheries on a river specific scale. From a broader perspective, the move to a PA model and river-by-river management is consistent with Canada s international agreements under NASCO surrounding the Precautionary Approach and Guidelines for the Management of Salmon Fisheries, against which Canada must report progress to NASCO on an annual basis. Canada s ability to demonstrate adherence to these agreements strengthens our position in international negotiations regarding harvest of Atlantic salmon in marine mixed stock fisheries because we can demonstrate harvesting from only the healthiest stocks in a sustainable, controlled, and accountable manner. 2. With regards to implementing the PA and river by river management, over the coming months we would specifically like to see progress on: a. LRPs and USRPs need to be finalized for NB Gulf Region rivers, and definition is needed around the scale at which rivers will be managed (e.g., will smaller rivers be managed as assemblages; will the Restigouche be managed as one system or tributaries managed separately?). b. Defining harvest decision rules for all Atlantic salmon fisheries in the critical, cautious and healthy zones of the PA model (DFO Forward Plan 2.1 goal 2017/2018). Decision rules need to be focused on growing the stock toward the USRP and well into the healthy zone; they should not be focused on managing around the LRP. c. It is important for DFO to communicate to the public that for most Gulf rivers the LRP is taking a downward shift from the existing conservation limit as we know it. We are concerned that the expectations around conservation may also shift downward. An effective communications plan from DFO, with emphasis on the goal being to manage toward achieving the upper target (USRP), will prevent this perception from developing. d. DFO should present analysis on current stock status of rivers in relation to the existing conservation limit and the new LRP and USRP (when developed). This will provide important context to stakeholders, First Nations and the public when discussing the management of Atlantic salmon fisheries. e. Criteria need to be defined for use in mid-season assessments to adjust harvest levels using existing infrastructure (barriers, trapnets, counting fences, cameras), swim through assessments where water clarity permits, and transition to new technology, such as ARIS sonar cameras, or the addition of new counting facilities where gaps exist. To fill data gaps, DFO should start making a long-term plan now for expanding counting facilities/exercises.
3. ASF is participating in the recreational fishery transformation project and we are providing detailed input through that process for a refined management system that will be based on the Precautionary Approach. 4. For 2018, recognizing that DFO and the Province are putting significant resources toward developing the PA and the NB recreational fishery transformation project, we do not consider it to be practical to implement an interim system for managing the recreational salmon fishery on those other rivers that are not included in the pilot transformation project. As such, and given the state of the stocks, our advice for managing the recreational fishery on those rivers is to continue with live release until the PA and river by river management can be implemented confidently. A system that works well must first be developed for the pilot project, and then be expanded to all other NB Gulf rivers with required adjustments. 5. We recommend working with the Province, anglers and First Nations to significantly improve catch, harvest and live release reporting and statistics. NB is regularly singled out as having poor performance in this area. MAC recommendations 11.1-11.4 describe the need for improved statistics. Reporting is a critical component of establishing an effective management system. 6. An education and a communications strategy around the PA and the new recreational angling system will be key for public buy-in. Information around a new and improved recreational salmon fishery coming soon will encourage optimism within the angling and conservation community, important for maintaining engagement in the fishery. Striped Bass ASF s advice for the 2018 striped bass recreational fishery management plan is provided in detail as follows: 1. ASF proposes that DFO continue to manage the striped bass population using an adaptive management strategy, whereby harvest opportunities increase as population increases. Management needs to focus on achieving conservation goals and sustainability of both striped bass and wild Atlantic salmon, as well as gaspereau, smelt, and other anadromous fish populations. We suggest an increase in focus on achieving a balanced ecosystem for the benefit of all species. 2. DFO should establish a PA model for the management of the southern Gulf striped bass population so that the limit reference point and upper stock reference point are clearly defined and appropriate harvest levels be established based on stock health. 3. Given that the 2016 estimate of 318,000 spawners was more than 10 times greater than the recovery target of 31,200 spawners in 3 of 6 years necessary to open a directed fishery (DFO website FAQ section on striped bass), and indications of a continued growth trend in the
population, and given that DFO has recognized the importance of maximizing socio-economic benefits associated with Canada s fisheries, we propose that increased recreational harvest opportunities be incorporated into the 2018 management plan (see recommendation 5). 4. ASF questions the necessity of DFO s 2017 significant fishery management change to close ~10 km of the NW Miramichi estuary to all angling during the spawning period. There does not appear to be a conservation concern for striped bass by allowing angling in the spawning area, as evidenced by the continuous growth and abundance of the stock while angling was permitted in this reach prior to 2017. Also, this management measure on a healthy stock does not appear to be consistent with the way DFO manages other striped bass stocks (e.g., Bay of Fundy). 5. Using the same format of an effort-based management plan that is currently in place, ASF specifically proposes that DFO: a. De-couple possession limit from daily bag limit in the current legislation, so that they do not have to be equal, and can be varied separately. b. Increase possession limit to be double the daily bag limit. c. Increase recreational harvest opportunities from the status quo to a level that is consistent with meeting conservation targets and achieving ecosystem balance. d. In tidal water, eliminate slot size maximum, but retain minimum size limit of 50 cm to allow bass to spawn at least once before being susceptible to harvest. e. In inland waters (i.e., scheduled salmon waters), eliminate slot size minimum and maximum, and harmonize the daily and possession bag limits with tidal water regulations. Liberalizing recreational harvest opportunities in inland waters will alleviate potential impacts on juvenile Atlantic salmon and other species. Only a small proportion of the striped bass population is choosing to spend the summer feeding in freshwater rather than in coastal areas and based on reports, we are concerned this relatively small portion of the bass are having an impact on juvenile Atlantic salmon in freshwater. Such liberalization is appropriate because it will have negligible impacts to the striped bass population as a whole, but may provide meaningful protection for juvenile wild Atlantic salmon. In the medium term (2-5 years), we recommend that studies be undertaken to quantify impacts of striped bass on juvenile Atlantic salmon in freshwater. f. Season length in tidal waters: April 15 October 31 status quo. g. Striped bass recreational fishery in inland waters (above head of tide) to close at the same time as Atlantic salmon season according to location (e.g., September 30, October 15, or October 31) status quo. h. Gear type: no change. i. Improve harvest and fishing effort data - DFO should conduct creel surveys and angler effort surveys throughout Southern Gulf range (necessary for establishing a comprehensive management plan). j. Improve population monitoring and estimates of spawner abundance (also necessary for a sound management plan).
k. Enforcement: increase staffing and incorporate a creel census into patrols (additional staffing resources will benefit Atlantic salmon enforcement effort as well). 6. ASF is pleased that DFO is working with First Nations to develop a sustainable commercial fishery for striped bass. We emphasize that DFO should treat the establishment of this commercial fishery as a priority. Once again, thank you for the opportunity to provide input, we trust you will find our advice helpful in the development of recreational fishing management plans for Atlantic salmon and striped bass. Respectfully Submitted, Nathan Wilbur, P.Eng. Director, New Brunswick Programs Atlantic Salmon Federation
Appendix A Reference: MAC Recommendations and DFO Forward Plan (Section 2. Fishing Mortality) Recommendation 2.1 - Harvest levels for salmon in Atlantic Canada should be set using the precautionary approach framework that is presently being developed for Atlantic salmon. The limit reference point (LRP) should be the benchmark to determine if there will be any directed retention in FSC and recreational fisheries. When the abundance of salmon is above the LRP, DFO should consult with First Nations and Aboriginal partners as well as with recreational fishery interests to define the appropriate levels and sharing of directed retention salmon fisheries. DFO should network with First Nations and Aboriginal groups as well as recreational angling interests to set appropriate daily and seasonal bag limits including consideration of grilse and large salmon retention limits in accordance with the principles of the precautionary approach and status of the stocks. Analysis - DFO remains committed to implementing the Precautionary Approach (PA) for all fish stocks, and establishes Limit Reference points for various salmon stocks, based on scientific advice. For instance, DFO Maritimes Regions has adopted a 2.4 eggs/m2 as the LRP. Furthermore, given that all salmon populations are currently below this, there has been no recreational retention in that Region since 1998, and only limited FSC allocations. Implementation of the PA will consider scientific advice and consultations with indigenous groups and other stakeholders to establish appropriate rules. Forward Plan - Over the next 3-5 years, the Department will work to fully implement the PA. The Gulf Region, for example, is currently planning to establish the LRP for key index rivers in the Southern Gulf of St. Lawrence (Restigouche, Miramichi, and Margaree rivers) and to develop harvesting rules by 2017-18. Other regions are similarly working towards development of the PA framework. Reference regarding improved reporting: MAC Recommendations and DFO Forward Plan (Section 11. Data) Recommendation 11.1 - Work with provincial partners in NS, NB and NL to improve the licence return rates from the recreational fisheries. Collaborate on the development of a user-friendly electronic on-line reporting system that would be available for reporting on a daily basis. Establish a deterrent or incentive process/program to encourage reporting there must be some consequences for not reporting. Analysis - Some provinces have already instituted procedures to increase the returns of report cards from the recreational fishery. For instance in Nova Scotia and in Newfoundland, post-season reminder letters and telephone surveys are used to increase returns. And some groups, especially in the Pacific region, are investigating the use of fisher app smartphone applications.
Forward Plan - DFO will implement this recommendation by engaging provincial governments to continue exploring the use of innovative techniques to improve the return rates of licence report cards and data capture in general for all salmon fisheries. Reference regarding striped bass and FSC fisheries: MAC Recommendations and DFO Forward Plan (Section 2. Fishing Mortality) Recommendation 2.10 - Explore options to replace salmon with other FSC species (e.g., striped bass in Miramichi). Analysis - Most FSC licences are multi-species in nature and already have allocations for striped bass. In some cases, in the Gulf Region for example, striped bass and other species allocations have been increased due to conservation concerns for Atlantic salmon. Forward Plan - The Department will consult and work with Aboriginal partners to determine if there are FSC fisheries where options other than salmon can be considered within the existing FSC requirements.