Thank you, Chair.
The Canadian Association of Prawn Producers represents offshore licence-holders in eastern Canada's northern shrimp fishery. Some 65% of these licence-holders are enterprises owned by indigenous groups and inshore fishers, and the remainder are typified by family businesses. This sector represents, in our view, a successful blend of indigenous and non-indigenous communities in the area.
FOPO's review of the Fisheries Act comes at a time of great economic uncertainty for Canada's fisheries. Our own sector is virtually entirely export-oriented. It's vulnerable to unsecured access to our primary market, which is China.
The cold-water shrimp resource and its fishery are also vulnerable to fluctuating environmental and ecosystem conditions. The threat is extremely serious in the form of reduced TACs and quotas, but it's existential if the average catch rate diminishes significantly.
As we continue to navigate these troubled waters, we desperately need greater stability from the Government of Canada. The current Fisheries Act, in our view, provides the minister with both the direction and the discretion necessary to deliver its mandate for the well-being of the resource as well as the fishery. It is not the time for legislative changes that handcuff our collective ability to adapt to these challenges.
We are extremely concerned about recent calls from environmental groups to amend the act that would limit commercial harvest stocks solely in the “healthy zone”. Sustainable harvests at lower levels would be closed unnecessarily. Any suggestion that the trajectory of fish stocks is determined exclusively, or even in some cases primarily, by harvest rates is outdated.
DFO should continue to be focused on promoting growth and mitigating decline through responsible harvest rates, with fisheries to be closed only when they are in the critical zone, and only if there are no alternative conservation measures.
Over the past couple of decades, DFO science has shifted spending towards oceans and ecosystem research. We believe DFO expenditures should be prioritized for applied science that should focus on sustainable utilization. We are asking DFO in this hard time to improve its stock assessment capacity and, if necessary, to finance that improvement through redirection of funds from other science programs. None of this requires a change in the Fisheries Act.
The review of the Fisheries Act also creates occasion for some interest groups to lobby for a change in quota allocations. The two most referenced allocation criteria are adjacency and historic dependence. FOPO has received presentations from some groups about their relatively low share of adjacent resource. At the core of that issue, the Independent Panel on Access Criteria concluded that, in the case of inshore fisheries, the application of adjacency is compelling. However, as the fishery becomes midshore and offshore fisheries, it's harder to justify, in particular when historic dependence is based on the premise that fishers who have historically fished a particular stock should enjoy continued access to that resource as well as that of the coastal communities from which they come.
To explain this more fully, each of the 17 offshore northern shrimp licences have been allocated an equal share of the quotas in each of the respective shrimp areas. The model was explicitly designed to achieve an economically viable year-round offshore shrimp fishery in areas mostly far away from local ports, facing seasonal ice coverage to a greater or lesser extent. Clearly, imposing adjacency on this model will render the model unviable.
The combination of allocation decisions and buyer-seller transactions over the past 30 years has, though, resulted in quota shares of indigenous and northern communities increasing from 27% to 77% of this northern shrimp complex.
Proponents who are advocating to include adjacency under the amended Fisheries Act have stated their interest to have quota shares that are comparable with the rest of eastern Canada.
Quota holders, though, based in the territory of Nunavut and the province of Newfoundland and Labrador, where these proponents come from, hold the highest percentage of share of quotas that are adjacent to their respective provinces, fully 75% to 80% of all species and sectors combined. Increases in quota shares for some participants are only achievable at the expense of other Canadians who also depend on the fishery, and in the case of the offshore shrimp fishery, at the expense of enterprises owned primarily by indigenous groups and inshore fishers.
We're facing reduced quotas, we're facing weakening catch rates and we're facing uncertain market access. Continued reinvestment in this fishery is at serious risk without a clear signal from government that quota shares are secure. This, too, does not require an amendment to the act.
Thank you.