MCC submits comments to DFO on the Salmon Allocation Policy

The Pacific Marine Conservation Caucus (MCC) views the Salmon Allocation Policy (SAP) as a central instrument for conserving and recovering wild Pacific salmon, not merely a framework for allocating harvest among user groups. We believe salmon must be managed in the broad public interest, while equally upholding Indigenous rights.

Overview
The current SAP (1999) predates the Wild Salmon Policy, modern treaties, evolving case law, climate change impacts on productivity, and new knowledge in fisheries science—particularly the extent of mortality of salmon who encounter fisheries but are not retained as catch. The updated SAP must include these components and reaffirm conservation as the highest priority. This includes aligning its definition of conservation with the Wild Salmon Policy and requiring all fisheries to meet conservation and recovery objectives at the scale of Conservation Units.

To achieve this, allocation decisions must prioritize fisheries that demonstrate high selectivity, target known stocks, incorporate and account for fishing related incidental mortality (FRIM). Allocation should support transitions away from mixed-stock fisheries toward more selective, terminal, and known-stock fisheries where risks to at-risk populations are minimized and management efficiency improved. FRIM must be consistently defined and incorporated into allocation decisions using best available science and verified through independent monitoring. Fisheries lacking the capacity to accurately measure retained catch, discards, compliance, and total mortality cannot be considered consistent with conservation or the broader public interest.

Finally, the revised SAP should remain flexible rather than entrench fixed sector-wide allocations, support localized co-management with First Nations, recognize FSC and rights-based fisheries as second only to conservation, and acknowledge that wild salmon are a public resource whose stewardship obligations extend beyond harvesters—even where that entails higher costs for access and use.

Read the letter