CP32-93-2012-3-eng.pdf

Cohen Commission of Inquiry into the Decline of Sockeye Salmon in the Fraser River • Volume 3
four edits, twice regionally and twice in Ottawa.
After the minister approves the IFMP, DFO provides
no explanation about this decision-making process
and the basis for the minister’s final decision
regarding the IFMP.
I can understand the frustration felt by stakeholders
and First Nations, including those involved
in the IHPC. They accept that DFO’s consultation on
the IFMP is only an advisory process, but they often
have invested much time and energy into reviewing
and commenting on the IFMP. If their suggestions
are not acceptable to DFO, they would like to
understand why. At the same time, I understand the
time constraints DFO is under to receive ministerial
approval of the IFMP before the fishing season
begins. It would not be realistic to expect DFO to
report back to the IHPC, stakeholders, and First
Nations at each stage leading up to the minister’s
final approval.
I do not question either the minister’s authority
to make final decisions on the Integrated Fisheries
Management Plan or the fact that the minister will
properly rely on advice from within the department
in doing so. However, I think it only fair that DFO be
accountable to the stakeholders and First Nations
and provide a basis for its decision making.
Integrated Fisheries Management Plan
25 Within 30 days of the minister of fisheries and
oceans approving the Integrated Fisheries
Management Plan (IFMP), the Department
of Fisheries and Oceans should make public
the rationale for the harvest rules set out in
the Fraser River Sockeye Decision Guidelines
section of the IFMP.
Escapement target planning
Between 2002 and 2006, DFO developed the Fraser
River Sockeye Spawning Initiative (FRSSI), described
as a “quantitative modeling tool for assessing harvest
rules for Fraser River sockeye salmon given conservation
needs and other management objectives.” 100
Escapement strategies in the FRSSI model are
defined as a total allowable mortality (TAM) rule
that specifies the total allowable mortality rate
for Fraser River sockeye at different run sizes. The
escapement strategies are designed around three
fundamental considerations:
• no fishing at very low run sizes, except for
test fishing;
• fixed escapement at low run sizes to protect the
stocks and reduce process-related challenges at
this critical stage; and
• a fixed total allowable mortality rate at larger
run sizes. Currently, TAM is set at 60 percent,
which includes the total number of fish that are
caught in the fisheries or that die en route to the
spawning grounds.
Fisheries are managed according to the Early
Stuart, Early Summer, Summer, and Late-run timing
groups (based on the historic timing of the migration
to their spawning grounds). Any run-timing
group may contain a mix of Conservation Units that
are relatively weaker or stronger in terms of productivity.*
Accordingly, DFO recognizes a need for
precaution in setting the maximum mortality rate. 101
DFO includes options for escapement strategies in
its draft IFMP, which is presented to and discussed
by the IHPC. As described above, the draft IFMP is
provided to, and reviewed by, the harvest sectors
outside the IHPC process as well.
Al Cass, DFO scientist and one of the creators of
the FRSSI model, testified that the model itself does
not allocate harvest. Rather, it determines the TAM
rules, after which DFO managers allocate harvest
(mortality) among the commercial, recreational,
and Aboriginal fisheries and account for mortality
through other causes. 102
The FRSSI model has been the subject of
criticism. For some, the 60 percent TAM ceiling is
too high. For others, it is too low, allowing too many
fish to escape to the spawning grounds and resulting
in forgone catch. Rob Morley, vice-president of the
Canadian Fishing Company and a member of the
Fraser River Panel, expressed concern that DFO does
not consider economic trade-offs that must be made
in setting total allowable mortality / escapement. He
suggested that, when presenting the four optional
escapement targets in a given year for a given run,
DFO should conduct an economic evaluation of
the harvest rates before choosing a model. 103 Other
* Productivity is the number of recruits returning per spawner.
30