Thank you, Mr. Chair.
Good afternoon, fisheries standing committee members.
My name is Mike Atkins. I'm the executive director of the Pacific Prawn Fishermen's Association. The PPFA is a non-profit organization with an elected board that represents the 245 commercial prawn licence-holders, 25% of which are first nations.
I am here today to inform you of a drastic reinterpretation of the fishery general regulations by some DFO Pacific region staff, and we are urging you to recommend to the Department of Fisheries and Oceans that the reinterpretation is flawed.
The issue is these tubs right here: one pound of tails in a plastic tub. The DFO Pacific region has recently deemed that the freezing of prawns in a one-pound tub is no longer compliant with subsection 36(2), which states:
No person who catches and retains a fish under the authority of a licence issued for the purpose of commercial fishing shall have...fish in possession if the fish is skinned, cut, packed or otherwise dealt with in such a manner that...
(d) where size limits are applicable, the size of the fish cannot be readily determined.
The PPFA, based on legal advice—which I have attached—is of the view that the size of prawns packaged in tubs can be readily determined. Upon immediate inspection of the tub, many of the prawns can be measured in their frozen state, and the remainder can be easily thawed in less than two minutes and 30 seconds, thus meeting the requirement of “readily determined”.
I tried to share a video and was told that it wasn't possible, but the video is titled, “Thawing frozen prawn tails with a deck hose”. It can be found on YouTube, and it shows us doing just that, thawing a full tub of prawns in less than two minutes and 30 seconds.
The practice of freezing prawn tails in tubs of seawater has been employed for 50 years, and it was endorsed by the DFO at the time of its introduction. The prawn fishery lands approximately $45 million worth of product each year and provides hundreds of well-paying jobs. The inability to freeze prawns in tubs would have serious economic consequences to the fishery. The harvest of undersized prawns is not a conservation issue, and this is supported by a peer-reviewed science paper by DFO staff. The minimum size is in place for economic reasons, which is why there is no size limit in the recreational prawn fishery, only in the commercial fishery. Again, I've attached supporting documents for your reference.
The PPFA is working co-operatively with the DFO Pacific region to resolve this issue. The PPFA has developed a set of industry protocols—once again attached—that will allow the practice of tubbing to continue for this year. However, we have been told that it is not a long-term solution. The practice of tubbing is key to market demand and the financial sustainability of the fishery, and there is no appetite from industry to discontinue the practice.
Thank you for your time, and we hope that you share our interpretation and the previous DFO interpretation that freezing prawns in tubs does meet the definition of “readily determined”.
Thank you.