Thanks very much.

It's just Ian MacPherson here this afternoon. Captain Jenkins had to leave when our plans changed on the video conference. He sends his apologies.

Good afternoon, Mr. Chair, and members of the Standing Committee on Fisheries and Oceans.

My name is Ian MacPherson, and I am the Executive Director of the Prince Edward Island Fishermen's Association. We are here today to discuss the very important topic of the adequacy of enforcement and penalties for infractions of the Fisheries Act.

The Prince Edward Island Fishermen's Association represents approximately 1,300 core fishers from six local island-based organizations. Our members fish tuna, lobster, herring, raw crab, scallops, mackerel and groundfish in addition to estuarial species such as eel, silversides and smelt.

We contribute 30% of the overall Canadian lobster harvest, with a direct financial contribution of $250 million. Our sector provides close to 9,000 industry-related jobs. The fishing contribution to the provincial GDP is the highest percentage in Canada.

Needless to say, the fishery is not only a significant economic driver but its sustainability is also vital to the future of Prince Edward Island. The PEIFA prides itself in effecting rationalization projects for various species in both the past and present. These initiatives retire licences permanently and reduce traps and gear in the water.

For example, rationalization of lobster licences that began in 2010 and continued until 2013 in LFAs 25 and 26A took over 44,000 traps out of the water on Prince Edward Island. We do not want to see these significant efforts backslide due to illegal activity.

In our submission to Fisheries and Oceans Canada dated July 31, 2018, the PEIFA cited violations such as fishing in closed waters, fishing during a closed time, fishing with prohibited gear and recreational fishing for groundfish during a closed time. Input was requested on the suggested fine amount of $500 per infraction. The association's position is that these fines are insufficient to deter this type of infraction.

It is also the association's position that commercial and recreational fishers should be fined the same amounts for a violation, as illegal activities impact the resource as a whole.

We also suggest an increase of fines for repeat offenders. In the past five years, there have been steady price increases in most species. Operating costs have escalated, but a portion of these price increases have been related to expanding marketing efforts that have assisted in increasing demand. Canadian seafood enjoys a strong positive image in the worldwide marketplace. Unfortunately, these increases in value can also lead to more illegal activity. As some of these illegal activities are market-driven, it is important that enforcement priorities and deterrents be reviewed on an ongoing basis.

Illegal fishing is a worldwide problem, and many efforts are being put in place to plug the gaps in international export channels that allow illegal product to be bought and sold. At the local level, we must ensure that our stocks are preserved for future generations.

In addition, certain international certifications, such as Marine Stewardship Council, or MSC, may be impacted if stocks of primary or bycatch species decline. One area of current concern is the declining availability of certain lobster baits, the lack of commercial alternatives and the pressure to reduce bait costs through additional bait harvesting. In addition, it is important that only approved baits be available, as many bait alternatives are being sought both locally and internationally.

A significant concern revolves around rock crab, as this is the primary diet of our Atlantic lobster. Any serious depletion of the rock crab stocks could result in significant damage to the lobster industry. The PEIFA has been, and continues to be, an advocate for more enforcement resources to be devoted to the field. Any new processes put in place should have a primary focus of allowing conservation and protection officers to spend more time on the water for investigative work.

Over the past three years, the PEIFA has submitted numerous victim impact statements when requested by conservation and protection officers.

These impact statements are used in court proceedings. These letters address the concerns surrounding the impact on the overall resource or other potential negative impacts to the species.

The PEIFA has recently noticed an increase in fines for some local infractions, and in some cases a suspension of eligible fishing days. The suspensions have been applied to upcoming seasons if the current season has concluded. We feel these types of penalties are steps in the right direction.

It is the association's position to identify the areas of concern, but we do not feel it is our mandate to suggest specific fine amounts or remedies. We want to underscore our concern that fines or other remedies for committing an illegal activity not be viewed as a cost of doing business.

In conclusion, our recommendations are as follows.

Number one, $500 fines are insufficient for fishing in closed waters, fishing in closed times, fishing with prohibited gear, and recreational fishing during a closed time.

Number two, we advocate that the fines to the commercial and recreational fishers should be the same.

Number three, we suggest that fines escalate for repeat offenders.

Number four, we request that additional resources be supplied to DFO conservation and protection units.

Number five, rock crab violations should be a priority for enforcement, and attention should be paid to other bait fisheries.

Number six, we suggest that priorities of enforcement be reviewed as market conditions change.

Number seven, penalties should be reviewed along with a five-year review of the act.

Protection of our valuable marine resources is the responsibility of harvesters, regulators, the criminal justice system and parliamentarians. By working together, we can stem the tide on illegal fishing activity and the damage it does to our valuable seafood resources in Canada.

Added to our presentation today is our response letter, dated January 31, 2018.

When appropriate, I would be pleased to address any questions you may have.

Thank you.

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