Thank you, Mr. Chairman.

First I want to thank the committee for this opportunity to appear before you to address Bill C-555. I am here representing the Seals and Sealing Network, which is a national non-profit organization promoting sustainable and wise use principles.

The network is made up of sealer associations, Inuit, processors, manufacturers and traders, veterinarians, provincial and territorial governments, among others.

Rather than just rely on my representation, I'd like to draw attention to the testimonials that are in the backgrounder, which we will leave behind. Those are testimonials by sealers related to interference they have experienced due to the observation regime we currently have.

The purpose of our presentation today is to provide you with our perspective on Bill C-555, and our recommendations for achieving the objectives that both the sealing sector and the government share. These shared objectives centre around worker health and safety, animal welfare, validation and enforcement to demonstrate the integrity of the industry, continuous improvement in management practices based on best science and experience. Bill C-555, which we support in principle, also provides the opportunity to revisit the rules and regulations related to Canadian seal hunt observers.

In its current form the bill proposes a change to the marine mammal regulations that would alter the minimum distance from one-half nautical mile to one nautical mile for unlicensed observers. The Seals and Sealing Network strongly believes that Bill C-555 is not addressing the real problem. It is important for the committee to know that unlicensed observers are not the primary concern of the sector. Difficulties lie with the licensed observers. Our preferred recommendation is to change the regulations to apply to all observers.

We have provided you with a fuller description of our proposals, but I will describe them briefly in my presentation today. We have three recommendations.

Recommendation one is to establish a mechanism for developing and deploying a verified assurance program for the east coast Canadian seal hunt. This assurance program is to be conducted by objective third party qualified experts and to have such a program recognized under the marine mammal regulations.

Recommendation two is to eliminate the licensed observer category under proposed subsection 33(1) and apply the one nautical mile buffer zone to all observers unless otherwise directed by the minister, or failing that, extend the observation for licensed observers to a minimum of 500 metres, and that observers meet the same requirement as seal hunters and be required to carry an electronic locator, GPS, or DFO enforcement officer or recognized at-sea observer for the purpose of distance and activity enforcement.

Recommendation three is to update the regulation to clearly state that it applies to both a person fishing for seals as well as sealing vessels travelling to and from and at the seal harvest site, and that it apply to marine vessels and aircraft, including drones.

I would like to briefly explain each recommendation. I ask that you refer to the discussion paper for a complete description.

On recommendation one, a verified assurance program, the sealing sector has become highly regulated and is conducted in a responsible manner by sealers who are trained to operate under the highest standards of humane harvest and handling. The next step is to demonstrate that this high level of hunting is conducted by providing objective and fact-based data rather than the distorted misinformation campaigns of anti-seal hunt protesters.

The sealing community believes there is both a need and a demand to create a third party assurance program for sealing. This would be similar to programs in other animal use sectors. It would revolve around a third party audit and validation system performed by qualified independent validators. A transparent assurance program would satisfy the need for public accountability and would help to offset one-sided reporting by biased observers such as anti-sealing groups that do not prescribe to the basic principles of sustainable use of wildlife.

Such a program would also support regulatory responsibility, that the best practices are being followed by the sealing sector, and where necessary that corrective measures are identified and implemented. It would also provide quantifiable data and would identify needs and opportunities within the sealing sector.

It would provide market assurances for buyers of our seal products. The need for independent evaluation was identified by the European Food Safety Authority in its 2007 report to the Scientific Panel on Animal Health and Welfare related to the Canadian seal hunt. Such an assurance program would be tied to other ongoing activities by the sector, such as training and education, codes of practice, and best management practices.

Recommendation two is to change the observer licence.

Option A: The Seals and Sealing Network strongly believes that Bill C-555 is not addressing the real problem. The concerns revolve around the violations by observers under their licence. Such violations create risks to human safety, animal welfare, and the lawful right to conduct business unfettered. The sealing community submits that with the development of a verified assurance program, the public's interest can be realized and would eliminate the justification for close proximity observation. Sealers report that close proximity allowed under the licensed observer permit can interfere with their ability to conduct their work, including the need to dispatch animals as quickly and humanely as possible. It also poses a safety risk to sealers, enforcement personnel, and the observers themselves.

Furthermore, with today's advanced photographic and satellite capabilities, there is no longer a need for close proximity observations. Applying the proposed amendment to one nautical mile for all observers would still afford observers the ability to conduct their surveillance without impeding on the sealers' workplace.

Option B: Should licensed observers' permits be maintained, then the sealing community believes that the current regulated observation distance must be extended. The current distance of 10 metres, only 32 feet, does not provide adequate safety or security for sealers, observers, or enforcement officers.

In his testimony to the committee on June 11, 2014, Jean-François Sylvestre, chief of conservation and protection with DFO, confirmed that the current 10-metre observation limit is insufficient. He said:

There can be some confrontations between hunters and people with observer permits within 10 metres.

Actually, this prevents the hunters from doing their job. They cannot work as well when they have a camera filming them 10 metres ahead or next to them compared with when they are alone on the ice. This is supported by Yves Richard, chief of regulations for Quebec, Department of Fisheries and Oceans, in his testimony to this committee. He said:

Having someone filming them with a camera can lead to additional stress for hunters.

Our own research at the Seals and Sealing Network has also found that from a safety aspect, the 10-metre limit is arbitrary and is inconsistent with limits set for other forms of hunting involving firearms. A cross-country analysis of municipal firearms discharge laws showed that 10 metres is insufficient for public safety when a firearm is used on stable land and even more so in an unstable sea and ice environment

For enforcement purposes, we also ask that these observers be required to be equipped with an electronic locator, GPS, as is required for the licensed hunters, in order for enforcement personnel to monitor their movements and locations.

Recommendation three is to clarify the regulations.

For better clarity, extending the observation distance one nautical mile should also state in regulations to apply to both a person fishing for seals as well as sealing vessels travelling to and from and at the seal harvest site. The extended observation distance should also be clearly stated in the regulation to apply to marine vessels, aircraft, and drones.

As I mentioned, there is a detailed brief on our recommendations and supporting evidence for the committee to consider.

In closing, I would like to thank the committee for considering our recommendations. I would be happy to answer any questions.

For further information we do have a website: www.sealsandsealing.net.

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