Thank you very much.
Good afternoon, and thank you for the invitation to appear before you today. I apologize for not being there in person, but I had a prior commitment that has to be in person.
As many of you know, the Fisheries Council of Canada is the national association representing wild capture processors across the country, all of whom also harvest.
I wish to applaud the committee for undertaking such an important study. Canada has a robust fisheries management regulatory regime that is supposed to maintain sustainable commercial fisheries. Having the understanding of the interrelationship between fish stocks and seals needs to be an integral part of the process.
FCC is in general agreement with the science recommendations of the Atlantic seal science task team. In its report, the task team highlighted the data available on the food, feeding and migration of seals to be woefully lacking and, in some regions, not studied at all. Not having this information causes a serious issue when trying to develop management plans for fish stocks and the rebuilding plans for fish stocks listed in the cautious or critical zone. In particular, FCC supports recommendations 1 to 3 in the seal science task team report as they address the need for more science to fill in the gaps of the existing scientific body of knowledge.
I am pleased that the scope of this study includes both the east and west coasts. Most of the focus until now, including the task team, as per its terms of reference, has been only on Atlantic Canada. It is important to acknowledge and better understand the extent of the overpopulation of seals and sea lions and their subsequent impact on the marine ecosystem on all Canadian coasts. When you make recommendations to the government, I would urge you to be inclusive of all three of Canada’s coasts.
It is also important to note that it is not just the direct impact seals have on their prey species that needs to be studied but also the indirect impact they may have on the entirety of the marine food chain and ecosystem. An example of this would be the impact that seals and sea lions have on chinook salmon and, as a result, the impact on the southern resident killer whales.
While the need to gather more science on the impact of seals is greatly important, FCC stresses that it should not be at the expense of core fisheries science. We understand that DFO has a finite amount of resources; however, fisheries science and management are paramount to Canada's maintaining a sustainable resource. FCC is hopeful that the call for proposals announced at the end of the seal summit will fill some of the science gaps. Beyond that, DFO should consider external and in-house options over the longer-term science need, particularly so core fisheries science work is not undermined.
My last and perhaps most important comment relates to seafood markets. There are two aspects to this: market access as defined by government regulations in the destination jurisdiction and market acceptance, which is the private sector's willingness to buy our products. It is immensely important that, as the government considers potential steps moving forward, its actions do not disrupt either the market access or acceptance of Canadian fish and seafood products both internationally and domestically. I cannot stress this enough. This could have serious impacts on coastal communities that depend on our sector.
Foreign jurisdictions to which Canada exports have regulations that could impede our sector’s market access. Most notably, both the U.S. and the EU currently have near if not complete bans on importing seal products. They also have very strict rules regarding the harming of marine mammals that, if deemed violated, could limit or eliminate the market access of our fish and seafood products. For the U.S., NOAA is still reviewing Canada’s submissions for comparability findings for our fisheries under its Marine Mammal Protection Act. NOAA is scheduled to release its findings by the end of this year.
In terms of market acceptance, some importers and domestic buyers do not want to be linked with companies and/or countries associated with the sealing industry, so there must be extreme caution by the government to not jeopardize existing customers of Canadian seafood companies. We are working hard to improve the public trust of our sector and strengthen our market brand. These efforts could easily be undermined by government actions that are not well informed and communicated.
Thank you for your attention, and I look forward to your questions.