Julie Diamond
A/Director, Resource Management
Fisheries and Oceans Canada
Newfoundland and Labrador Region
February 27, 2024
Dear Julie,
FFAW-Unifor’s position on access and allocation for 2J3KL cod remains the same as historically recorded, with the first 115,000t being allocated to the Inshore Sector and Indigenous Groups. The Union representing all 2J3KL cod harvesters will under no circumstances support DFO reneging on this longstanding commitment.
Not only is this the FFAW’s position, but this has also been the documented position of the Federal Government for decades, most recently in 2021 within the Department’s Integrated Fisheries Management Plan:
“When a total allowable catch (TAC) for Northern (2J3KL) cod is established, the first 115,000 t of directed Canadian access will be allocated to the inshore sector and Indigenous groups in Newfoundland and Labrador. At a TAC level less than or equal to 115,000 t, directed fishing activity will be limited to inshore harvesters and Indigenous groups in Newfoundland and Labrador.”
The concept of first priority in allocation of the TAC to the inshore sector was repeatedly stated in 1977 to 1980 by then Minister Romeo LeBlanc:
“I have a bias for the inshore fisherman not because of some romantic regard, not because of the picture on the calendars, but because he cannot travel far after fish, because he depends on fishing for his income, because his community in turn depends on his fishery being protected.”
At the Special Government Industry Seminar on the management and allocation of Northern Cod in Corner Brook in August of 1979, then Minister of Fisheries and Oceans, the Honorable James McGrath stated:
“The Northern Cod were the staff of life to the people of Northeast Newfoundland and Labrador... that the policy of the government was that the inshore fisherman had first call on this resource” (Lear and Parsons, 1993).
As you can see in the attached quota tables, from 1982 to the time the moratorium was called, the inshore 2J3KL fixed gear fleet was allocated a percentage of the TAC that equated to 115,000 t. It is quite clear that from 1982 onwards, the inshore sector had priority access to the first 115,000 t – and that is documented in quota tables pre-moratorium and in the Department’s own approach to fisheries management in the time since.
This is more than a political commitment from the Minister-of-the-day. It is a more than 40-year commitment that speaks to the department’s recognition that the inshore sector in this province has a reliance upon and a commitment to the Northern Cod fishery.
Moreover, may we kindly remind you of modernizations to the Fisheries Act made in 2019, which prioritizes the owner-operator fishery and socioeconomic considerations of adjacent communities. While were certainly dismayed to see decisions made contrary to this Act in the recent Unit 1 Redfish allocations, we are hopeful the right decision will be made with Northern Cod.
Since the stewardship fishery began in 2006, inshore harvesters have been and continue to be stewards of the Northern Cod resource, taking the care to grow this stock out of the critical zone and into the cautious zone. They’ve invested time and money in sustainable fishing gear and technology, and in quality handling techniques to ensure that the cod fishery of today is not the cod fishery of our past.
Moreover, the Fishery Improvement Project for Northern Cod just received an “A” rating from international NGOs. This means inshore harvesters have demonstrated an ongoing and continued commitment to improving the sustainability of this stock. This ranking also recognizes on-the-water, regulatory and research commitments.
Introducing offshore draggers at this important period of continued growth would not be beneficial for the stock’s continued recovery. Based on historical data, Northern Cod are highly aggregated along the shelf edge in January and February, which is why the offshore fleets targeted these dense overwintering and pre-spawning aggregations prior to the cod collapse. These fish are tightly packed and extremely vulnerable. Historically, researchers used a lower catch rate limit of 1.5 tonnes per hour to identify commercially significant concentrations. These catch rates show how densely packed and vulnerable cod are at this time of year and that is something that must not be targeted during the rebuilding period.
The inshore fleet has tremendous capacity to land fish, and we do not need to introduce new capacity to this fishery. In 2023, the MAH for the 2J3KL stewardship fishery was 12,999t. In just four weeks (three summer, one fall), inshore harvesters landed 9,114t or 70% of the MAH, with the remainder spread out over seven additional weeks. That’s an incredible capacity to land fish, especially considering the crab fishery was still open during three of those four weeks and harvesters were restricted by a weekly landing limit as part of the Conservation Harvesting Plan.
Further, catch rates were so good that harvesters were fishing much fewer than their maximum number of nets. For example, inshore harvesters were allowed between nine and 15 nets for most of the season in 3KL, yet most fished just three to five nets and still managed to land over 9,000t within four weeks.
2023 was not an anomaly. The stewardship fishery in 2022 brought similar results, with 70% of the 2J3KL quota landed in a four-week period. The capacity to catch fish within the inshore sector in Newfoundland and Labrador is enormous and offers great potential for the economic future of coastal communities in the province.
Harvesters have been devastated by the downturn in multiple fisheries in recent years and rightfully see cod as an opportunity to diversify their enterprises and make a living fishing a longer season. Our harvesters now have vessels in a variety of sizes and capabilities, some of which will benefit from the closeness of the stock within the summer months, while many others have ample capability to fish further offshore during the fall season. NL harvesters have the ability to have a lengthy fishery, making frozen product available all year round, without the need to target spawning and pre-spawning aggregations.
Newfoundland and Labrador has a 500-year history of commercially harvesting Northern Cod, and the fishery continues to be critically important to inshore fish harvesters and processing plant workers in our province. There is a vast amount of economic development that is happening in our small coastal communities with inshore fisheries, and as we continue working for rural economic sustainability, the value of these fisheries and their capacity to directly employ tens of thousands of people should not be understated.
Now is also the time to step up monitoring and enforcement of the so-called recreational fishery. On average, landed recreational fish are 50 or 60 cm in length - which is notably longer than what commercial harvesters record during cod tagging by our at-sea technicians. This is clear evidence of high-grading happening at-sea.
We are in support of a provincial food fishery, however many recreational fishers are doing so to create a black-market local fishery, with limited enforcement and monitoring to deter. FFAW-Unifor does not support the current petition to the House of Commons to expand the recreational fishery. What we are adamantly against, is unregulated removals and a semi-commercial fishery by unlicensed harvesters. Landings from the food fishery must be monitored and enforced.
FFAW is also of the stance that current by-catch limitations on Northern Cod should remain the same, as increasing by-catch limitations puts more unnecessary pressure on the stock. Any harvester or group should be focused on targeting their directed species.
In closing, we are reiterating the importance of the commitment for the 115,000t to the inshore sector. Our Union vehemently rejects any attempts to undermine this commitment. The historic paper trail backed by our commitment to a sustainable fishery and capacity to harvest at significantly higher levels leaves no room for debate.
Sincerely,
Greg Pretty
President, FFAW-Unifor
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