Consultation Statement Regarding:
Canada Gazette, Part I, Volume 158, Number 51: Order Designating the Sarvarjuaq Marine Protected Area
Oceans North Kalaallit Nunaat (ONKN) appreciates the opportunity to provide input on the proposed Sarvarjuaq Marine Protected Area (MPA) published in the Canada Gazette, Part I, Volume 158, Number 51, submitted by the Department of Fisheries and Oceans (DFO) on December 21, 2024, with a consultation deadline of January 20, 2025.
We would like to clarify that ONKN is a Greenlandic non-governmental organization (NGO) and non-profit charitable organization, and our consultation statement on this hearing is not coordinated with the Inuit Circumpolar Council (ICC) nor the Government of Greenland.
ONKN is dedicated to the health of Arctic marine ecosystems and the sustainable use of marine living resources. Our mission is to support local communities through sustainable coastal fisheries management that ensures long-term environmental, economic, and social viability. As a guiding principle, ONKN advocates for conservation efforts grounded in scientific knowledge and complemented by Inuit knowledge.
General Comments
ONKN compliment the Government of Canada, the Government of Nunavut, and the Qikiqtani Inuit Association (QIA) for their leadership and collaboration in proposing the Sarvarjuaq Marine Protected Area (MPA) under the Oceans Act. This initiative marks a significant step toward preserving the ecological integrity of Sarvarjuaq, the portion of the Pikialasorsuaq located on the Canadian side.
Pikialasorsuaq is one of the most biologically productive and culturally significant polynyas in the Arctic, home to diverse species such as narwhals, belugas, walruses, polar bears, seals, seabirds, fish, and plankton that sustain the Arctic marine ecosystem. It also holds deep cultural and spiritual significance for Inuit communities on both sides of the Baffin Bay, providing essential resources for subsistence hunting and supporting Inuit traditions and livelihoods for generations.
ONKN supports Fisheries and Oceans Canada’s (DFO) work collaborating with the Government of Nunavut (GN) and the Qikiqtani Inuit Association (QIA) to ensure the protection of the Sarvarjuaq Study Area and evaluate long-term protection options, including the establishment of an Inuit Protected and Conserved Area (IPCA). However, ONKN also urges DFO and its partners to remain committed to the regional aspirations of Inuit as expressed in the consultations that informed the Pikialasorsuaq Commission’s recommendations. Specifically, ONKN urges ongoing efforts (both in Greenland and Canada) to harmonize conservation between national jurisdictions. ONKN thus encourages DFO to continue to enhance collaboration with the Government of Greenland.
The Pikialasorsuaq Commission, initiated by the ICC, recommended the establishment of a steering committee. This committee would determine the most suitable form of protection for the Pikialasorsuaq region. Its purpose was to ensure that Inuit communities in the area have a voice in deciding the type(-s) of protected area(-s) that Pikialasorsuaq should be. Additionally, it aimed to preserve their rights to harvesting and subsistence activities, while facilitating collaboration between both countries on the management of the Marine Protected Area (MPA) for Pikialasorsuaq. The first step of realizing this recommendation was through the Letter of Intent signed by the Government of Canada and the Government of Greenland in Reykjavik in 2023.
ONKN hopes that DFO’s MPA designation for Sarvarjuaq is not considered as the endpoint to this initiative and that the existing bilateral agreement between Canada and Greenland (Letter of Intent signed in 2023 in Reykjavik) is taken into account, reinforcing the need for ongoing cross-border cooperation. Pikialasorsuaq should be regarded as a cohesive ecosystem and managed in a holistic manner. Coordination by DFO with Greenland and Inuit communities on both sides of the polynya is essential to ensure that Indigenous rights, including the right to Free, Prior, and Informed Consent (FPIC), are respected.
Specific comments
Comments under the Background:
Leverage Scientific and Inuit knowledge
Conservation efforts should be primarily guided by robust scientific research, and complemented by Inuit knowledge/Indigenous knowledge, which reflects generations of stewardship and lived experience.
Comments under the Description:
Prohibit Bottom Trawl Fishing in Pikialasorsuaq
ONKN recommends emphasizing the urgency and necessity of banning bottom trawling in the area entirely, rather than merely freezing its footprint.
Given that bottom trawling is one of the most destructive fishing practices, inflicting severe ecological damage, ONKN advocates for a complete ban on this practice. Allowing bottom trawling to continue, even with restrictions, risks perpetuating the environmental harm caused by previous activities in the area. A proactive approach is essential to protect marine ecosystems and ensure sustainable fishing practices for the future.
Comments under the Community consultations:
Engage Inuit-Led Governance
ONKN supports and appreciates the strong community involvement in the Sarvarjuaq MPA, including collaboration with Inuit organizations such as the QIA and the ICC. However, it is important to view Pikialasorsuaq as one region and one ecosystem. The Inuit communities consulted by the Pikialasorsuaq Commission in 2016 should continue to play a central role in governance and decision-making for the region. We recommend that the DFO involve the following Canadian communities: Grise Fiord (Aujuittuq), Resolute (Qausuittuq), Arctic Bay (Ikpiarjuk), Pond Inlet (Mittimatalik) and Clyde River (Kangiqtugaapik). In Northern Greenland, the following communities should also be involved: Siorapaluk, Qaanaaq, Savissivik, Kullorsuaq, Nuussuaq and Upernavik. In communities without formal organizations, hunters’ and trappers’ organizations could serve as key representative bodies to ensure effective local participation.
Recommendations
In summary, ONKN suggests the following recommendations:
- Recognize Pikialasorsuaq as One Ecosystem
ONKN will continue to recommend to all parties that Pikialasorsuaq be approached a single, interconnected ecosystem and that an ultimate conservation goal is for Canada and Greenland to approach this ecosystem as a unified area. The biodiversity and migratory species in this region transcend political boundaries, highlighting the need for bilateral cooperation. International standards for managing species and areas are currently being developed within the Arctic Council to align with an ecosystem-based approach. Recognizing Pikialasorsuaq as one ecosystem presents an ideal opportunity to implement this approach through collaborative management between Canada and Greenland.
- Support the Pikialasorsuaq Commission’s Recommendations
ONKN strongly endorses the Pikialasorsuaq Commission’s recommendation to establish a steering committee composed of representatives from both countries. It is essential that the steering committee make recommendations regarding the types of protections to be implemented for the Pikialasorsuaq as a whole. This committee must assess and determine the necessary safeguards to ensure the preservation of Inuit rights to subsistence, hunting, and cultural practices throughout the region.
- Create an MPA for the Entire Pikialasorsuaq Region
ONKN advocates for the establishment of an MPA encompassing the entire Pikialasorsuaq region to safeguard its ecological integrity – not just Sarvarjuaq. We therefore urge the Government of Canada to collaborate with the Government of Greenland to develop a formal proposal for a harmonized MPA that includes the Greenlandic part of the Pikialasorsuaq polynya, complementing domestic efforts in Canada. To achieve this, ONKN calls on the Governments of Canada and Greenland to activate the joint steering committee, set concrete goals, and establish a timeline for implementing the Pikialasorsuaq Commission’s recommendations for Inuit-led management and protection.
- Strengthen Cross-Border Collaboration
The joint steering committee for Pikialasorsuaq should prioritize maintaining the ecological health of the region as a unified ecosystem while upholding Inuit rights and cultural practices, in line with the Letter of Intent signed by both parties. Cross-border collaboration will be essential to ensure the long-term sustainability of this critical region.
- Respect Indigenous Rights and Place Names
Ellesmere Island (Umimmaat Nunaat) is a traditional hunting ground for the Inughuit from Qaanaaq. The DFO should work with these communities to document traditional place names and explore opportunities to reinstate cross-border subsistence hunting rights.
- Include Inuit knowledge
Conservation efforts should include Inuit Knowledge (also referred to as Indigenous knowledge and local knowledge), which reflects generations of stewardship and lived experience. This invaluable knowledge should complement robust scientific research efforts to create well-rounded and effective conservation strategies. - Prohibit Bottom Trawl Fishing in Pikialasorsuaq
Given the severe ecological consequences of bottom trawling, ONKN recommends the adoption of a clear prohibition on bottom trawl fishing in any proposed MPA for Pikialasorsuaq. A definitive ban is essential to protect the ecosystem.
Closing Remarks
The proposed Sarvarjuaq MPA serves as a vital precedent for conservation efforts that respect Inuit knowledge, rights, and leadership. ONKN strongly supports this initiative and encourages the Government of Canada to work collaboratively with the Government of Greenland to protect the entire Pikialasorsuaq region. By doing so, Greenland and Canada can demonstrate global leadership in Arctic conservation, safeguarding biodiversity, ecosystem-based approach, and cultural heritage for future generations.
We look forward to continued collaboration to promote sustainable management of our shared marine ecosystems.
Best regards,
Jenseeraq Poulsen
Executive Director, ONKN
e-mail: jenseeraq@oceansnorth.gl
