Here's what that means for members of the BC Federation of Fly Fishers
A new Salmon Allocation Policy is currently being developed, with significant implications for members of the BC Federation of Fly Fishers. Since the 1999 Salmon Allocation Policy was first adopted, salmon populations have faced substantial challenges, including declining ocean survival, an increase in stocks of concern, and mostly unfavourable changes to our climate.
Management regimes have also evolved. Notably, the 2018 BC Supreme Court ruling in Ahousaht Indian Band and Nation v. Canada required changes to Pacific salmon management to restore the commercial fishing rights of five First Nations on B.C.’s West Coast. In response, then-Fisheries Minister Dominic LeBlanc directed Fisheries and Oceans Canada (DFO) to review the existing allocation policy. You can read the Discussion Paper:Perspectives and Recommendations from the Review of the 1999 Allocation Policy for Pacific Salmon in British Columbia here. This mediated review has been underway for several years, and DFO recently released preliminary results for discussion. While there is consensus that a new policy must align with case law and constitutional requirements, disagreements persist regarding the specific allocation structure.
This post outlines perspectives and recommendations currently under consideration towards a new policy and provides feedback from the BCFFF.
The role of the BCFFF in Salmon Allocation Policy Discussions
The BC Federation of Fly Fishers is a ‘primary user’ representative of anglers at the Sport Fishing Advisory Board. Primary users are the vast majority of the angling public who do not have vested commercial interests or earn income directly from angling. The Sport Fishing Advisory Board (SFAB) also represents commercial sport fishers. Alongside the Commercial Salmon Advisory Board (CSAB), participating First Nations, and DFO, the Sport Fishing Advisory Board is a stakeholder in the review of the Salmon Allocation Policy. Via the SFAB, the BCFFF is able to communicate our perspectives during this review process.
The BCFFF also has its own perspectives on the Salmon Allocation Policy, and the purpose of this post is to share them. As a member of the BCFFF, you are welcome to share your perspectives with us by writing to us at info@flyfishers.ca. You are also welcome to share your perspectives on the Salmon Allocation Policy and the discussion paper directly by email to DFO. To help, here is some background.
The 1999 Salmon Allocation Policy
The 1999 Salmon Allocation Policy outlines seven core principles designed to ‘provide a transparent, fair, and predictable framework for managing Pacific salmon.’ These principles establish a hierarchy for resource use, prioritizing conservation and First Nations’ food, social and ceremonial rights while balancing the needs of the recreational and commercial sectors. They are as follows:
Conservation
The conservation of Pacific salmon stocks is the primary objective of this policy and takes absolute precedence in managing the resource. All management decisions are guided by a precautionary, risk-averse approach to ensure that fish and their habitats are protected from irreversible depletion. The policy emphasizes that the long-term productivity of the resource will not be compromised for short-term harvest benefits.
First Nations
After conservation requirements are met, the highest priority is given to First Nations’ food, social, and ceremonial (FSC) requirements, as well as any rights defined in modern treaties. This principle ensures that Aboriginal fishing obligations are addressed before harvestable surpluses are allocated to other user groups. While the policy acknowledges these priorities, it does not attempt to define the specific nature or scope of treaty negotiations.
Common Property Resource
This principle confirms that Pacific salmon are a common property resource belonging to all the people of Canada. Because the resource is managed by the government for the benefit of present and future generations, the government does not grant proprietary interests or guarantee fixed catch shares. This approach avoids open-ended financial burdens on taxpayers that would arise if compensation were required for every shift in allocation.
Recreational Allocation
Following First Nations’ priorities, the recreational sector is given priority access to Chinook and Coho salmon, which are considered the mainstay of this fishery. For other species like sockeye, pink, and chum, the recreational sector is provided with predictable fishing opportunities, though their harvest is limited to a maximum annual average of 5% of the total combined recreational and commercial catch. The primary goal for this sector is protecting fishing time and opportunity rather than ensuring an explicit quantity of fish.
Commercial Allocation
After conservation and higher-priority needs are addressed, the commercial sector is allocated at least 95% of the combined commercial and recreational harvest for sockeye, pink, and chum salmon. For Chinook and Coho, commercial harvest is only permitted when abundance levels are high enough to satisfy all other priorities. This allocation supports the viability of the commercial industry while ensuring it can still prosecute directed fisheries on its target species.
Selective Fishing
To encourage the transition to more sustainable practices, a portion of the total commercial catch is set aside for licence holders to test alternative, more selective gear and technology. The policy intends to move all Pacific fisheries toward higher selectivity to maximize the harvest of target stocks while minimizing by-catch. Over time, commercial allocations will be adjusted to favour fishers who demonstrate they can fish most selectively.
Gear Allocations
Target allocations for the commercial sector are established on a coast-wide basis for the three primary gear types: gillnet, seine, and troll. These targets are not guaranteed and may be adjusted to account for conservation needs, changes in the fleet resulting from voluntary licence retirement programs, and the priority of selective fishing. The policy uses a planning schedule to review results annually and translate these targets into specific fishing plans.
What has the Salmon Allocation Policy review yielded?
Since 2023, Fisheries and Oceans Canada has been working with First Nation representatives, as well as representatives from the Commercial Salmon Advisory Board and the Sport Fishing Advisory Board, to review the 1999 Salmon Allocation Policy and develop recommendations for a renewed policy that would apply to British Columbia. While there is unanimous agreement that salmon must not be privatized, and that after conservation the first allocation priority is for food, social, and ceremonial needs, common ground has not been established on how to further share and define the resource. As we understand it, this is where the parties are currently at:
1. There is agreement over the prioritization of conservation and Indigenous rights, but not on prioritization after those rights are accounted for.
Highest Priority: The policy maintains that conservation of salmon stocks and First Nation Food, Social, and Ceremonial (FSC) fisheries must retain the highest priority.
Rights-Based Fisheries: Following FSC needs, priority is recommended for treaty and court-defined rights-based sale fisheries (sanctioned Indigenous commercial fisheries).
Formal Rights Recognition: First Nation representatives recommended that the policy formally recognize First Nation commercial fishing rights, outside of existing court decisions and treaties.
2. There is disagreement over allocation structure.
Ending Recreational Priority: A major proposed change, put forward by representatives from the Commercial Salmon Advisory Board and First Nations, is to remove the existing recreational priority for Chinook and Coho salmon and replace it with with a harvest system based on a fixed number of fish or shares for each species and sector (Commercial, Recreational, and Indigenous Rights-Based Commercial), similar to the management model for halibut.
Recreational Counter-Proposal: The Sport Fishing Advisory Board strongly recommends maintaining the existing recreational priority for Chinook and Coho due to the significantly higher economic value and social benefits generated by the recreational sector per salmon caught.
Commercial License Buyouts: The SFAB recommends that as commercial fishing licences are retired through government buyouts, the commercial allocation should be reduced commensurately to reflect the intended harvest transformation.
3. Everyone agrees monitoring should be improved but …
Recommendations call for catch monitoring for all partners to be accountable, science-based (including Indigenous knowledge), transparent, standardized, and verifiable.
First Nations and CSAB representatives raised concerns about by-catch in other fisheries and recommended that the management rates for by-catch and incidental mortality be updated based on sound data and in collaboration with academia.
First Nations and CSAB representatives recommended creating a separate licensing category (and associated fees) for recreational fishing businesses, such as lodges, guides, and outfitters.
The position of the BC Federation of Fly Fishers
The BC Federation of Fly Fishers believes that after conservation requirements and food, social, and ceremonial needs have been met, allocation should be determined in a manner that serves the Public Interest. In this regard, the term “Common Property” is unhelpful and should be replaced. We propose that Principle 3 be retained but rewritten to confirm that Pacific salmon are integral to all people – indigenous and non-indigenous and to the ecosystems of British Columbia today, and into the future. Because the resource is managed by the government for the benefit of present and future generations, the government should not grant proprietary interest or guarantee fixed catch shares. Instead, the government should direct allocation to salmon fisheries in a manner consistent with the law, that benefits society, and protects the benefits provided to all when salmon are not harvested.
To us, managing allocation to fisheries in the public interest means the following:
Salmon stock assessment is comprehensive and up to date, so that the health of salmon populations are understood and properly communicated.
All marine mixed-stock fisheries are adequately and independently monitored so the status and natal origin of salmon encountered in fisheries are known through the use of reference fisheries.
All in-river fisheries are adequately and independently monitored.
All fishing related mortalities are accounted for, correctly assigned to their respective fisheries, are included in the assessment of allocation, and publicly reported.
Allocation shifts away from marine mixed-stock fisheries that are non-selective, towards fisheries selectively harvesting salmon from known populations in a sustainable manner.
Protecting recreational access to Chinook and Coho
The BC Federation of Fly Fishers does not support the re-allocation of Chinook and Coho from primary users of recreational fisheries to the commercial sector; however, we do believe that sport fishing charter operators should become licensed, the number of licences in the commercial recreational fishery should be limited, and that commercial sport fishing allocations should be transferable.
Over to you
It’s clear a new framework for salmon allocation is required. The Salmon Allocation Policy predates Canada’s Wild Salmon Policy, the 2019 Pacific Salmon Treaty, and recent court decisions which grant commercial fishing rights to a very small number of Indigenous fishing communities. It uses unhelpful and outdated language that creates unnecessary division, and has not lived up to its intention to prioritize conservation or encourage the transition to selective fishing for all sectors.
DFO is accepting feedback on its published proposed recommendations until January 23rd. We encourage you to review the proposed recommendations and email your feedback to DFO.SAPReviewBC-PASRevueBC.MPO@dfo-mpo.gc.ca.