Editor’s note: The following letter was sent to Minister of Fisheries and Oceans Bernadette Jordan on May 25, 2021.
I write regarding the recent decision by Fisheries and Oceans Canada to institute a year-over-year limit of 15 per cent on increases to the total allowable catch (TAC) in shrimp fishing area (SFA) 6 off southern Labrador and northeastern Newfoundland.
There is no mention in DFO’s Integrated Fisheries Management Plan (IFMP) for Northern shrimp of such a year-over-year limit on quota increases when a SFA — such as Area 6 — is in the critical zone of DFO’s precautionary approach management framework.
Inshore harvesters — who fish almost exclusively in SFA 6 — request that the 2021 quota be revisited to fall in line with the more than 40 per cent increase in the stock recorded between 2020/2021.
While the IFMP highlights that it is not a legally binding instrument that can form the basis of a legal challenge, the document does outline an understanding of the basic rules for the management of the shrimp stock.
When those rules aren’t followed, it leads to uncertainty, instability and frustration in the fishing industry, particularly, in this case, amongst the province’s inshore shrimp fleet.
The harvest decision rules (HDRs) in the IFMP clearly outline what happens when the spawning stock biomass (SSB) is in the healthy zone or above the upper stock reference (USR): “Changes in the TAC should generally not exceed 15 per cent of the previous TAC, unless the stock is declining precipitously.”
Likewise, the HDRs also outline that when the SSB is between the limit reference point (LRP) and the USR (the so-called cautious zone): “Changes in the TAC should generally not exceed 15 per cent of the previous TAC, unless the stock is declining precipitously.”
However, when the SSB is below the LRP (a.k.a. the critical zone) — which has been the case for a number of years in SFA 6 — the HDRs make no mention of changes in the TAC not exceeding 15 per cent of the previous TAC.
But that’s exactly what happened with the 2021 quota in SFA 6, which has been set at 9,534 tonnes (a 15 per cent increase from 2020) instead of a 42 per cent increase that would have reflected the year-over-year growth in that shrimp stock.
The difference in shrimp quota between a 15–40 per cent increase in TAC for Area 6 amounts to 2,072 tonnes or 4.6 million/pounds to Newfoundland and Labrador’s inshore fleet, which has struggled in recent years as the result of severe quota cuts.
DFO clearly went outside its rule book in reducing the expected shrimp quota increase in SFA 6 to 15 from 40 per cent and inshore harvesters feel they’re being punished for their sacrifices and Mother Nature’s turnaround.
On behalf of inshore harvesters who fish in SFA 6, I respectfully request that you immediately revisit the decision to limit the quota increase to 15 per cent.
Ryan Cleary, Executive Director (Interim)
Seaward Enterprises Association, Newfoundland Labrador (SEA-NL)