September 24, 2018

Hon. Catherine McKenna
Minister, Environment and Climate Change
House of Commons
Ottawa, ON K1A 0A6

Dear Minister McKenna,

Re: Point Pelee National Park region National Marine Conservation Area (NMCA) feasibility study

The Canadian Sportfishing Industry Association (CSIA) represents the manufacturers, distributors, retailers and sales agencies which serve the 8 million Canadians who fish as an outdoor heritage activity. According to federal government figures our industry currently generates an annual national economy of over $8.6 billion dollars. In tandem with hunting our customers support over 100,000 jobs in all regions of the country. More Canadians fish for recreation than play golf and hockey combined. Sportfishing in all of the Great Lakes is some of the best in the world and generates a significant economy in Canada and the U.S.

We write in support of the Ontario Commercial Fisheries Association (OCFA) position opposing the concept of a feasibility study by Parks Canada to create a NMCA around Point Pelee National Park, Pelee Island and all of Pigeon Bay. The OCFA Executive Director explained their opposition in their letter to you of September 17, 2018 (attached). Our information is a motion proposing such a feasibility study will soon be tabled in the House of Commons, directed to you and the CEO of Parks Canada. This Lake Erie region is very popular with anglers and the fishery for multiple species is very healthy and sustainable under current policy and regulation.

CSIA is also opposed to any initiative by ECCC or Parks Canada to establish a policy or legislative foundation for eventual permanent / severely restrictive access closures for recreational anglers in Lake Erie or any of the Great Lakes without a credible basis in independently peer reviewed site-specific scientific research and industry consultation. There are no documented threats of significance to water quality, fish populations, habitat or ecology which would justify additional ‘protection zoning’ in the Point Pelee region. The creation of an NMCA clearly creates the basis for a minister to unjustifiably restrict or ban recreational (and commercial) fishing at some future point.

We are aware of the ongoing efforts behind closed doors at your ministry, Parks Canada and Fisheries and Oceans Canada to arbitrarily designate significant percentages of vast coastal and inland regions of public lands and waters nationwide as severely restricted / permanently closed to all extractive sustainable use of natural resources, including recreational fishing. There has been no public transparency, consultation or inclusion of CSIA in developing these federal agency access closure agendas, beginning with the seriously flawed Pacific North Coast Integrated Management Area (PNCIMA) process affecting over 100,000 sq. km. of coastal and inland tributaries in B.C.

According to DFO, the PNCIMA process is the national template for the comprehensive federal agency direction including ECCC, to create large permanent access closures on public waters and lands, including the Great Lakes, ostensibly to ‘protect’ them where no credible threats exist. The mandate letters from the Prime Minister to you and the DFO Minister reflect this same direction, as do the 2017 Parks Canada access zoning / NMCA plan map which we have discovered.

In addition to the absence of ECCC and DFO consultation and transparency with our industry and other affected economies, we have grave concerns with the well documented federal and provincial PNCIMA process funding stream from U.S. anti-sustainable use organizations and foundations who are no friend to fishing. When these various examples are viewed in combination as a national process precedent, one can fairly conclude the federal multi-agency process directed at the permanent closure of public access to vast areas of public lands and coastal and inland waters across Canada is being determined by U.S. groups with very questionable agendas. The severe impact on Canadian jobs and related economies is being ignored.

CSIA steadfastly maintains the environmentally sustainable use and conservation of all of Canada’s natural resources, including fish and wildlife, can only be managed responsibly through credible science and proven professional natural resource management standards on behalf of people who simply want to take their kids fishing. (Please see 2nd attachment for CSIA position statement).

Enclosed for your information related to these critical issues please find copies (English and French) of the CSIA position paper, “Elevating Recreational Fishing to a National Priority – A Vision for a Federal Course Correction”. The millions of Canadians – our customers – who fish for fun and food as part of our great outdoor heritage deserve a fair, open and unprejudiced honest policy process from their federal government agencies. Anything less is completely unacceptable.

 

Yours truly,

Kim Rhodes

President

Encl.