Thank you, Chair.
On behalf of the 13,000 Fish, Food and Allied Workers Union members in Newfoundland and Labrador, thank you for the opportunity for our union to address the members today with respect to your study on ecosystem impacts and management of pinniped populations.
For those of you who are unfamiliar with the FFAW, the FFAW represents fish harvesters all around the island of Newfoundland and in southern Labrador. Our membership encompasses approximately 3,000 owner-operator enterprises and their more than 7,000 crew members. Our membership also includes thousands of workers in fish processing plants, marine transportation, metal fabrication, hospitality and more sectors across the province.
As the union representing fish harvesters and processing workers, FFAW is an advocate for economic and social growth and the sustainability of coastal communities throughout the province. Those coastal communities, vibrant coastal communities, depend on sustainable and healthy fisheries and fish stocks. That's what I will talk about a bit today.
That's an overview of the union broadly, but I also want to talk about our science department. Some folks may not know that the FFAW has a science department. Our science department began with our cod sentinel program in 1994. One of the goals of the sentinel program, and it's been one of our main goals since then, has been to bring harvesters and their observations and knowledge to the assessment and management table so that they are part of the management of fished ecosystems and fisheries. We have programs on every commercially fished stock in Newfoundland and Labrador, plus many other programs. In all of the programs we do, harvesters bring their observations, knowledge and fishing expertise to the table and to the projects.
Before I get into my comments—this relates to my comments on seals—documenting harvesters' observations and knowledge remains an important priority for FFAW. I note here that, as part of your study, this committee has heard from harvesters and sealers in Newfoundland and Labrador and other regions. Included in that are some long-time harvesters I know well, Mr. Trevor Jones and Mr. Eldred Woodford, who reported on their observations and knowledge of changes in their fish environments. Specifically, I expect that they would have talked about changes in the abundance, distribution and impacts of seal populations in Newfoundland and Labrador.
As you've probably heard, because we certainly have, FFAW has repeatedly highlighted harvesters' frustration regarding the lack of commitment to understanding the impact of seal predation on important species like capelin, Atlantic cod, mackerel, herring, crab and the list goes on. In addition to logged reports of massive seal herds, harvesters have also presented, often directly to DFO, photos and videos of seal depredation. For years our membership has been calling for DFO to collect information on the current distribution and abundance of populations around Newfoundland and Labrador that are impacting our fishery species.
I think it's more than just calling on DFO to document. It's also calling on DFO to prioritize collaborative research on seal impacts, research that builds on the observations and knowledge of people on the water. As I'm sure you know by this point in your study, there has been a huge gap between harvesters' observations and DFO's assessments of ecosystem impacts from seals. I'm going to walk you through one specific example that I was a part of and just use it to illustrate some of the points I wanted to talk about. This example comes from a 3Ps cod assessment and rebuilding plan processes. Then I'll recommend potential ways to bridge that huge gap that we have between harvesters' and DFO scientists' assessments of impacts.
First, 3Ps cod is one of three cod stocks in Newfoundland and Labrador. It is the stock that is located on the south coast of the island of Newfoundland. It goes from Placentia Bay in the east to Burgeo in the west. Currently, 3Ps cod is assessed as being in the critical zone, which means that we must put a rebuilding plan in place. Like cod stocks in the southern gulf, the assessment for 3Ps cod shows that fishing levels are not driving the trajectory of the stock. In fact, model outputs show that natural mortality is estimated to be 10 times that of fishing mortality—10 times.
The most recent stock assessment that is available online states, “Only a very small proportion of the Grey Seal...population...utilizes Subdiv. 3Ps”. It then cites a tagging review that was published five years ago. However, that review, and, importantly, the satellite tagging data the review is based on, is at least 13 to 15 years old.
We're making a statement about what's happening on our south coast right now, and we're trying to build a plan for how to rebuild a really important cod stock, and we're using data that's 15 years old. We're saying there is a very small population on the south coast. This is why people are frustrated. This is an example of why people are frustrated, and how big that gap can be.
To be fair, I brought this up at the rebuilding plan working group, which is a small task group of DFO scientists and managers, industry and indigenous groups. When I highlighted the problem of using historical data to infer current status, because you cannot infer current status and current impacts from data that is 15 years old—