Province of Nova Scotia Department of Fisheries and Aquaculture

Fisheries and Aquaculture
PO Box 2223
Halifax, Nova Scotia
B3J 3(4
March 23, 2012
Ernst and Young
Gulf Atlantic Halibut Regional Shares Review
[email protected]
Dear Ernst and Young:
Thank you for the opportunity to submit the Province of Nova Scotia's position regarding your current review of
regional shares of Atlantic halibut in the Gulf of St. Lawrence, as initiated by Minister Ashfield, Fisheries and
Oceans Canada.
As stated at your stakeholder consultation meeting held in Moncton, New Brunswick on March 5, 2012, the Nova
Scotia Department of Fisheries and Aquaculture (NSDFA) supports the positions as submitted by Ocean IQ
Management Services Inc. on behalf of the affected Nova Scotia fleet.
The Province, in conjunction with our
industry representatives, contend that the original methodology in reaching the final sharing arrangements was
flawed, and that DFO has not been consistent in its application of sharing formula criteria to other sectors which
have undergone similar changes in management.
NSDFA understood and appreciated the desire of DFO to move from competitive, hard to manage fisheries, to a
regime that is more conducive to orderly harvest and conservation. In fact, we supported this initiative for these
reasons. However, what should and could have been a reasonably positive initiative, has ended up causing more
disillusion and hardship to hard pressed sectors of our industry in Nova Scotia. As a province, we had proposed a
reasonable position of allowing long term historical landings, as suggested by DFO, to be the major factor in
determining shares. However, where long standing fishing involvement of a species was evident, we proposed
that strong consideration be given to providing a modest base amount to allow operational viability and
continuation of the traditional participation. In this instance, we felt it was entirely possible that this could be a
necessary proposition, especially given the substantial increase in TAC that is occurring for Halibut in 4RST in the
Gulf, and the allocation differential in the existing stakeholders.
DFO clearly stated at the outset that historical catch history would be a major parameter used in this exercise.
However, through the process of several meetings sponsored by DFO, at which considerable time, travel, cost and
discussion was expended by industry to prepare positions, a base share concept was continually entertained as a
real possibility. The issue of historical habitual overruns in quota by Quebec and Newfoundland was also raised
repeatedly by many interests. Industry strongly believes that this has resulted in exclusion of access and reduced
catch history for Maritime-based harvesters, and the overrun abuses should have been taken into account. The
final decision to utilize the initial catch history table without any consideration of these important factors adds to
the inherent unfairness of this decision.
Adjustments to sharing made subsequent to 2007, related to TAC increases and mobile gear bycatch quota, have
mitigated the impact on our fleet to some degree. However, any return to the 2007 sharing formula would be
unreasonable and unfair. In fact, given the increased TAC, and the large shares enjoyed by Newfoundland and
Quebec, the process which promised a fairer approach will once again discriminated against Nova Scotia
NSDFA also questions the consistency in which DFO has applied criteria around formulating sharing arrangements,
as in the case of dividing the 3NO halibut stock into regional allocations. Although the Maritimes fleet held a
majority (75-80%) of the historical harvesting for this stock, adjacency appears to have played a large part in the
shares equation, with the Newfoundland fleet receiving forty eight percent of the quota, and the Maritimes fleet
receiving fifty two percent. Rather than consistent application of resource allocations, it appears that politically­
based decisions are made, and various principles of historic shares, adjacency or historical dependence are then
applied to justify the decision.
Nova Scotia has as many rural economic challenges as any other Atlantic coastal province, and has a long history,
tradition and dependence on fish resources. We have communities that are dying. We do not have the capacity
and should not have to continually accept reduced shares to the benefit of others at our expense. We are
becoming tired of being involved in long drawn-out processes and debates that promise improvement and
equitable treatment, only to be ignored at the end of the process.
In regards to Ernst and Young's mandate in this matter, NSDFA would hope that along with our stakeholder's views
on DFO's past methodology, Ernst and Young will capture and forward their recommendations on how to rectify
this imbalance, including their position on how future increases in 4RST halibut quota allocations should be
Again, thank you for the opportunity to share our support for our industry on this matter. We look forward to a
timely and fair resolution of this issue.
Greg Roach
Associate Deputy Minister
Nova Scotia Department of Fisheries and Aquaculture