Harvester Concerns with the Proposed Precautionary Approach Framework for Snow Crab

This article was originally published in the Winter 2018/19 edition of the Union Forum magazine

Harvester Concerns with the Proposed Precautionary Approach Framework for Snow Crab

Our fisheries are rapidly changing. The biomass of snow crab has declined in recent years. Harvesters have already experienced significant quota cuts and expect another difficult year ahead. The sustainability of the snow crab fishery is a key priority for harvesters. Through shared-stewardship, harvesters can work with DFO to establish an approach to this fishery that is sustainable and accurately reflects that differences in the stock and the fishery in distinct areas.

Is the snow crab precautionary approach framework a good idea?

PA frameworks include a limit reference point, which identifies when a stock is in trouble or as DFO says, “when productivity is sufficiently impaired to cause serious harm to the resource”. For multiple stocks in the NL region the proposed PA doesn’t make sense nor match fish harvesters experience. In theory, having an LRP or an “oh crap line” is not a bad idea. In the case of this recently proposed PA framework for snow crab, harvesters have identified serious flaws that make the framework unworkable.

Does this proposed snow crab PA framework make sense?

• The Problem with PA Areas

Throughout the preliminary consultations that took place in the past week, many harvesters expressed concern about the conservation implications of lumping different areas together. While the assessment has been at a large scale (e.g. all of 3L inshore or all of 3K), management was worked out at the Crab Management Area (CMA) level, based on what was happening in that CMA and in adjacent areas. Under the new PA framework, management will be dictated based on what is happening across the larger DFO category (e.g. all of 3L inshore or all of 3K), regardless of whether other CMAs in the category are adjacent and regardless of whether other CMAs have the same levels of crab.

• 3K Never in the Healthy Zone

Using the proposed criteria, most areas will never be considered healthy, even at the height of the fishery. Based on the PA approach presented by DFO, 3K has never been categorized in the healthy zone. Kilograms per trap never exceeded the Upper Stock Reference, even during the best years of the fishery.

Can the objectives of the proposed snow crab PA framework be achieved? Can they be achieved under this assessment structure?

The proposed PA Framework for snow crab is based on 3 criteria: kilos/trap, discards and egg clutch.  The discards criteria includes the amount of soft shell crab discarded from eth fishery – a shared concern by both harvesters and DFO.  However, the current management approach depends on getting discard data from onboard observers.  That program was gutted by DFO several years ago.  Consultations with fish harvesters would have identified this problem – the lack of a key tool.

Harvesters are extremely frustrated that years of co-management is being set aside. These preliminary consultation meetings were a total reversal from the sentiment that “this is your bay and you need to protect it.” DFO says there is movement among CMAs and across the entire management region but the amount of movement likely varies across the entire management region and likely does not reflect the grouping in the DFO categories that have been put forward.

Shared stewardship of our fisheries is key to managing the transition in our ecosystem. Meaningful and deliberate consultation with fish harvesters must take place at every step of the process whether it’s in stock assessment or management of the fishery.

Fish harvesters do not accept this precautionary approach framework for snow crab. More consultation is necessary in order to address the serious flaws in the framework and to ensure vital information provided by fish harvesters is reflected in a new approach.