ARCTIC FISHERY ALLIANCE L.P.

Background Information on

AFA Conservation Concerns

Regarding the Harvest of

Small Immature Turbot

Iqaluit, Nunavut

November, 2012

AFA Conservation Concerns

AFA is deeply concerned about the sustainability of the Greenland halibut resource in

the waters adjacent to Nunavut. Because of its role of making recommendations to the

Federal Minister of Fisheries and Oceans on the management and allocation of

Nunavut quotas the NWMB should be aware of and acting upon issues related to the

long term health of these important fish stocks.

Since AFA's initial entry into the commercial fishery, its predecessor quota holder

Nattivak HTA has been concerned about the large amount of small immature turbot

being harvested by mobile trawl gear vessels. It was this concern that in part led to its

withdrawal from BFC and ended its relationship with Clearwater as they primarily

employ trawl gear to harvest northern turbot. Nattivak came to the conclusion that this

was a serious conservation issue and hence decided to harvest its quotas whenever

possible with fixed gear vessels. It is for this reason that AFA decided when purchasing

our own vessel to purchase a gillnet/longline vessel as it is much more selective in

catching larger more mature fish.

Of the four Nunavut quota holders, AFA is the only enterprise that is exclusively

dependent on the turbot fishery for its income in Nunavut waters and as a consequence

its Inuit owners wish to ensure the turbot resource is sustainably managed and

harvested. AFA does not believe this is the case now as well over 50% of the subarea 0

turbot resource is caught by trawlers as shown on the attached graph.

Furthermore, DFO have expressed concerns in the 2006-2008 Greenland Halibut

Fishery Management Plan for NAFO Subarea 0 as they note that one of its main

objectives is to minimize the harvest of small fish. It states in the plan that "In order to

address concerns regarding small fish in Division 0A, the overall total allowable catch in

Division 0A will remain conservative and the use of long-line vessels will be encouraged

....." Yet DFO have not taken any meaningful steps to reduce the catch of small fish.

When one considers this situation it should not be surprising that NAFO scientists are

not recommending an increase in the Division 0A TAC.

When AFA was being consulted on the NWMB's Allocation Policy for Commercial

Marine Fisheries it was made very clear to all quota holders that we were expected to

meet NWMB's Requirements for Responsible Stewardship as "The conservation of

Nunavut's fisheries resources and habitat is NWMB's chief fisheries management

priority." Furthermore, the compliance with responsible fishing practices and gear use

guideline states in part "Each allocation holder must use fishing gear that minimizes

......the harvest of juvenile fish." AFA has not seen any concrete steps taken by NWMB

to deal with this issue.

As a quota holder that is using exclusively fixed gear we feel it is important to bring to

the attention of NWMB these important conservation concerns. AFA has requested that

NWMB address this issue now to ensure the sustainability of Nunavut's turbot

resources. AFA's Inuit owners can not rest until this matter is satisfactorily addressed

and appropriate management measures enacted.