Thank you very much, everyone. We really appreciate the chance to be here. I'm going to start and then Chris is going to follow.
I'm here for the B.C. Seafood Alliance. That's the most representative fishing organization on the west coast, mainly representing commercial fishermen up and down the coast in virtually every major fishery on this coast. Chris is here for the Seafood Producers Association of B.C. That's the largest processor organization on the west coast. His members are big players in salmon, herring, groundfish, and many specialty products. If you like, we're two sides of the same coin. Our members are the people who bring food to Canadians and to the world.
We are broadly supportive of the habitat provisions. These were subject to very thorough consultation. We have four points we would like to make about the non-habitat provisions. We want to propose an amendment to the “Purpose” section. We want to make some comments on changes to indigenous participation and co-management. We want to make some comments on the confidentiality of traditional knowledge, and we want to close by emphasizing that stability and predictability in licensing policy and the management framework are essential to all participants in the industry, including indigenous peoples.
In terms of amending the purpose, in our view the current text does not provide a purpose. It only provides tools. The purpose itself needs to be defined as it is in, say, the New Zealand Fisheries Act and in other common property jurisdictions. We propose that proposed section 2.1 should read, “the conservation and sustainable use of fish and fishery resources through the proper control and management of fisheries and the conservation and protection of fish habitat, including preventing pollution.”
Moving on to indigenous participation and co-management, the right to manage fisheries resides in the minister and cannot be downloaded to others except in very clearly defined ways. Parliament should be careful that it is not giving unconstitutional powers to the minister to delegate management to indigenous organizations. A patchwork of separate management authorities for fisheries on the west coast would be disastrous for conservation and the use of the resource by all Canadians. There must be a single manager.
Further to that point, the recent Ahousaht et al decision on the west coast confirms that while the nations have a right to fish and to sell fish, that right applies only in a very narrow area and is not unrestricted, not exclusive, not industrial, and it does not provide a guaranteed economic baseline. The judgment also says that bilateral negotiations of what the right means in practice are unacceptable. That's because DFO does not represent the interests of the other sectors such as commercial and recreational fisheries, and those interests must be included.
The judgment also says that voluntary relinquishment—that's willing buyer, willing seller transfer of licences—is the best means towards reconciliation in the fishery, and it stresses that reconciliation is a national endeavour, not only to be borne by the commercial fishing families, and that it cannot be achieved without the involvement of all interested parties.
Indigenous participation in the west coast fishery is already strong. We expect it to grow, and that's a good thing. Roughly one-third of all licences are held by indigenous individuals or organizations so any changes to fisheries management or licensing policy will affect them as well as others.
We do have concerns about the confidentiality of any traditional knowledge. We believe this needs to be narrowed, especially in the light of the Ahousaht et al decision. The recent decision by the minister, based on confidential bilateral negotiations to suspend the central coast herring fishery in the interest of reconciliation, despite the recommendations of peer-reviewed science, cost communities up and down the coast about $12 million for what would have been a two-day fishery.
Lastly, with regard to stability and predictability, the tabling of enabling provisions regarding licensing policy and social policy has already been destabilizing with millions of dollars of investment on hold on both coasts. It's scaring young people out of the industry or making them question whether they want to enter.
Without secure access, there is no incentive to invest in new vessels, new gear, new markets, or new products. Worse, there is no incentive to invest in the resource, and many of our fisheries contribute $1 million or more, for each fishery, to DFO science every year.
Unlike the habitat provisions, these changes to the act were made with minimal consultation, and in our view, have been rushed through with little opportunity for input.
I will just close by saying that fishing interests must be fully and comprehensively engaged in the development of regulations.
I'll pass it over to Chris.