Thank you, Mr. Chair and members of the standing committee.
My name is Merv Wiseman, and I have had a 35-year career with the Canadian Coast Guard. I'm retired now, of course. My first 16 years were served as a vessel traffic services officer in various locations in Newfoundland and Labrador and the Arctic. My final 19 years were served as a maritime search and rescue coordinator at the Maritime Rescue Sub-Centre in St. John's. During this period I co-authored a fishing vessel safety report for the Canadian Coast Guard search and rescue branch and subsequently assisted in the implementation of a safety program for fish harvesters in Newfoundland and Labrador. I later served on an assignment with Transport Canada to implement a similar program for fish harvesters in other parts of Canada.
I have a background study in nautical science and am a certified ship's officer in domestic and foreign waters. I have had some fishing vessel experience, and I have skippered a 50-foot longliner in the groundfishery for one season in the early 1970s.
It is my pleasure to present a brief in collaboration with FISH-NL on the important issue of vessel length and licensing policy in Atlantic Canada. The focus of my brief is to bring attention to the impact of vessel length restrictions on fishing vessel safety, which continues to have disturbing consequences, perhaps unintended, for those affected by it.
Fish harvesting is known to be the most dangerous commercial activity in Canada and globally. Transport Canada safety board marine, which is the agency responsible for investigations and recommendations into vessel accidents and fatalities in Canada, has elevated fishing vessel safety to its watch list, making it one of the two significant vessel safety issues in Canada that need continued attention for safety improvements. Despite numerous recommendations to Transport Canada to exercise its statutory mandate to provide solutions, an unacceptable level of accidents and fatalities continue to prevail.
During my time as a search and rescue coordinator at the Maritime Rescue Sub-Centre in St. John's, I was designated lead on the fishing vessel safety file for the Newfoundland region. After responding to a disturbing number of SAR incidents related to commercial fishing activity in the Newfoundland and Labrador region in the 1990s, the Canadian Coast Guard Maritime Rescue Sub-Centre undertook a review to try to understand the various safety dynamics related to these incidents. I co-authored a report entitled, “Fishing Vessel Safety Review (less than 65 feet)”. Unfortunately, the findings of the study and its report are as applicable today as they were almost 20 years ago.
The study found that 70% of all SAR incidents in the Newfoundland region occurred in the fishing industry. Moreover, the highest incident rate occurred in the small vessel category of the less than 34 feet 11 inches. The report also cited an Irish study undertaken in 1996, which established “the smaller the vessel involved in accidents, the more likely the accident resulted in fatalities”. Considering that almost 90% of this small vessel fleet type in Canada operates in waters adjacent to the Newfoundland and Labrador region, this continues to represent a deeply concerning problem. While the report identified a wide array of causes for these incidents and fatalities, one of the most dominant features was related to vessel modifications and the effect on stability.
The attempt by fish harvesters to adjust to new realities in the fishery after the 1992 cod moratorium by moving to alternative species, which in many cases were farther offshore, was a driving force behind the modifications. Furthermore, the DFO fish management restrictions leading to the inability of harvesters to fish in a vessel length category more conducive to the new operating environment forced harvesters into modifications that simply did not fit the vessel beneath them.
These conditions and restrictions still prevail. With an emerging cod fishery on the radar, one has to be concerned about a similar spike in incidents related to yet another adjustment in the operating environment for fish harvesters and the vessels they operate. Another layer of complexity may be arising with the new Transport Canada regulations requiring mandatory stability testing for all small fishing vessels. Aside from significant costs for testing, additional boat construction remediation required to offset the stability effects of vessel modifications due to the current length restrictions could create insurmountable financial barriers for affected harvesters.
In a recent hearing session of the current standing committee, Ms. Jacqueline Perry, acting regional director general for the Atlantic region of DFO, gave rationalization for the DFO vessel length restriction policy. The prevailing rationale appears to be rooted in achieving conservation objectives by controlling fishing capacity through vessel length restrictions. As members of this standing committee have questioned, the fact that capacity is controlled almost exclusively by IQs and other disciplinary management measures makes the policy seem uselessly redundant.
Aside from the unintended consequence for fish harvesters, the policy is made to look even more vacuous by the fact there is no standard correlation between vessel length and carrying capacity. For example, it is not uncommon for a 34 feet 11 inch fishing vessel to be designed to carry much more than the next category of vessel length, 44 feet 11 inches, and so on through the categories of vessel length.
While it would not be accurate to pin all the fishing vessel safety issues on fish management policies, there is no denying the underlying safety problems associated with vessel length restrictions. There are significant negative effects on stability related to the vessel modifications.
Fish management policy, which forces harvesters to undertake dangerous modification contortions in order to fit its designated length category, is effectively rolling the dice against the lives of the harvesters who have to fish in some of the most dangerous waters in the world. In recent years, stakeholders in the fishing industry, including fish harvesters, have made important adjustments against the backdrop of fishing vessel safety incidents and fatalities. This includes training, prevention, safety awareness, carriage of safety equipment, and significant regulatory revisions designed to ensure compliance with safety-at-sea operatives.
In recognition of the influence of fish management measures on fishing vessel safety, DFO has made some changes in its policy protocols. Unfortunately, the vessel length and licensing policy, which were designed to meet the needs of a 1970s fishery, have not fundamentally adapted to the realities of the current operating environment. However, there is a sense of optimism from grassroots fish harvesters that long overdue changes are about to occur.
It is with great hope and encouragement that the work of the current standing committee on vessel length and licensing will be the instrument needed to move the change over the top.
I sincerely wish you well.