A Response from the Minister of Fisheries!

A few months ago I wrote a letter to the Minister of Fisheries addressing a few key issues concerning Canada's oceans, as part of the social action section for a course my friend was teaching on social justice.  The issues addressed included the implementation of the Precautionary Approach for protecting Canadian fish stocks; the appalling lack of information given to consumers about the fish they consume; the lack of regulation in marine protected areas, and the paucity of such areas; and the insanity of determining an stock's endangered status based on socioeconomic considerations.  Considering that it was election time, I did not really expect a response, and so I was delighted to find a three-page letter from Senior Assistant Deputy Minister David Balfour of Ecosystems and Fisheries Management waiting for me in my mail when I returned from my trip out east.

It was a surprisingly candid and lengthy response to each of the issues I brought up.  Since we are talking about the Canadian government, there is much emphasis on what has been done and little about the criticisms.  But at least I now know that they know that there is at least one concerned Canadian out there.  For me, the most surprising admission in the letter is towards the end, in reference to the classification of endangered species in Canada.  It is somewhat shocking - see if you can spot it!


Click the link above to take you the the original letter.  Below is the response:

June 27 2011

Dear Mr. Morris:

Thank you for your correspondence of April 7, 2011, addressed to the Minister of Fisheries and Oceans, regarding your concern for the management and future of Canada's fish stocks.  I have been asked to respond on the Minister's behalf.

To first address your comment about the Precautionary Approach, Fisheries and Oceans Canada (DFO) published A Fishery Decision-Making Framework Incorporating the Precautionary Approach (Precautionary Approach Framework) in 2009, under the auspices of the Sustainable Fisheries Framework.  Since adopting this policy, significant progress has been made in incorporating the Precautionary Approach into major Canadian fisheries, and significant resources have already been dedicated to meeting the requirements of the framework, with more to follow.

Reference points have been identified for such stocks as snow crab and northern shrimp, while others are in development for stocks such as Atlantic cod and American plaice.  In addition, efforts are underway to develop reference points for species that are managed by input-control fisheries measures (e.g., American lobster).  Given that reference points are now established for some stocks, efforts are underway to develop harvest decision rules in cooperation with stakeholders.  In addition, given the need for broad-based support for such rules, such processes will often require sufficient timeframes.

Furthermore, one of the requirements of the Department's Precautionary Approach Framework is the establishment of rebuilding plans for fish stocks managed under the framework that are depleted to the point where they are below their limit reference point.  A rebuilding plan will necessarily include consideration of the timeline for rebuilding that takes into account both biological and socioeconomic objectives.  Rebuilding plans will be linked to the Integrated Fisheries Management Plan (IFMP).  The IFMP framework was recently updated and can be viewed online at <http://www.dfo-mpo.gc.ca/fm-gp/peches-fisheries/ifmp-gmp/index-eng.htm>.

Next, to address your comment about the Marine Stewardship Council (MSC) certification, the MSC does indeed have an active fisheries ecocertification program.  Ecocertification is a voluntary, market-based procedure by which a third party, such as the MSC, gives assurances to markets and consumers, through the use of an eco-logo, that a fishery product meets the sustainability requirements and standards of the third party's program.  Fifteen Canadian fisheries have obtained MSC certification, and an additional nine are currently under MSC assessment.  The Department is supportive of any Canadian fishery that chooses to seek ecocertification, under the MSC or other programs, in order to meet requirements established by their buyers.  As this pertains to the labelling of marine food products, you may wish to raise this matter further with the Canadian Food Inspection Agency (CFIA), as they are the federal department with jurisdiction on the issue of food labelling.  CFIA's comment information and feedback form can be found online at <http://www.inspection.gc.ca/english/util/contact/commene.shtml>.

Regarding marine protected areas, the Government of Canada recognizes the importance of Canada's unique and biologically diverse marine ecosystems, and is committed, both domestically and internationally, to protecting our oceans.

In 2007, the Government of Canada announced the Health of the Oceans initiative in which $61.5 million was invested over five years.  Details of the initiative can be found on DFO's website at <www.dfo-mpo.gc.ca/oceans/management-gestion/healthyoceans-santedesoceans/index-eng.htm>.

Three federal authorities have mandated responsibilities under their respective legislation to establish and manage marine protected areas in Canada.  DFO can establish Oceans Act Marine Protected Areas; Environment Canada can establish National Wildlife Areas and Migratory Bird Sanctuaries; and Parks Canada can establish National Marine Conservation Areas and National Parks.  Provincial authorities in Canada, such as the British Columbia Ministry of Environment, are also mandated to establish and manage marine protected areas.

On World Oceans Day, June 8, 2010, the Spotlight on Marine Protected Areas in Canada report, which is based on a comprehensive national inventory of marine protected areas, was released.  At the time of publication, there was a total of 182 marine protected areas in British Columbia, which included 9 federal and 173 provincial protected areas with marine components.  Since the time of publication, Gwaii Haanas National Park Reserve and Haida Heritage Site has also been designated.  It is estimated that approximately 2.8 percent of the marine area in the Pacific Region out of the 200-nautical mile limit is under some level of enhanced protection.  Once the area protected by other types of integrated management tools such as spatially defined fisheries closures is included, it is anticipated that the extent of conserved ocean area will be significantly higher.

Having different federal and provincial/territorial agencies capable of establishing marine protected areas facilitates protection for different aspects of the marine environment.  Federal authorities, together with provincial/territorial colleagues, are developing a National Framework for Canada's Network of Marine Protected Areas to guide the establishment of a national marine protected area network.

The process of adding a species to the federal Species at Risk Act is a responsibility that DFO takes very seriously.  I wish to assure you that all decisions in this regard are undertaken based on peer-reviewed scientific information and following extensive consultations with Canadians.  In some cases, socio-economic factors can be an important consideration in the decision regarding the listing of a species.  At this time, there are 97 aquatic species listed pursuant to the federal Species at Risk Act, with more anticipated to be added in the immediate future.

The Government of Canada is committed to the survival and recovery of all species assessed by the Committee on the Status of Endangered Wildlife in Canada regardless of whether or not they are managed pursuant to the Species at Risk Act or the federal Fisheries Act.  In the case of the Porbeagle shark, it was determined that the proper management of this species could be undertaken pursuant to the Fisheries Act, given the extent of the species' global range occurring in Canadian waters and the challenges facing its recovery.  As you indicate in your letter, the decision with respect to the Porbeagle shark was not an economic one as the species is of little economic value to Canadian fisheries.  Rather, the decision to not list the Porbeagle shark was based solely on the needs of the species and the mechanisms available to the Department to facilitate its recovery.  To that end, a Conservation Strategy has been developed for the species under the Fisheries Act to facilitate its management.  The Strategy implements a reduced total allowable catch for bycatch in other fisheries, and promotes greater emphasis and resourcing to the collection and assessment of scientific survey data to better determine the steps required to promote the recovery of the species.

Thank you for taking the time to write.

Yours sincerely,

Mr. David Balfour (with a real signature!)
Senior Assistant Deputy Minister
Ecosystems and Fisheries Management

I'll probably have more to say about this in the future, but for now I call BS on the response about the Porbeagle shark.  The Canadian government certainly felt it was valuable enough to do an economic evaluation of the shark when it came to designating it as endangered or not.  It even published, on the DFO website, a paper entitled Potential Socio-Economic Implications of Adding Porbeagle Shark to the List of Wildlife Species at Risk in the Species at Risk Act.  This report does show that the Porbeagle is not of incredible valuable on a national level, but does conclude that the entire issue is complicated by the fact that it is of remarkable importance to one Maritime community, the town of Sambro.  In fact, one of the authors of this paper, Dr. Murray Reid, was concerned enough to write Environment Canada when the government rejected the Porbeagle's endangered status.  Dr. Reid felt that his report showed the relative unimportance of the Porbeagle commercially, and was concerned when the Minister of the Environment cited socioeconomic factors as one of the reasons for not declaring it endangered.  It is an excellent letter, found here.  

The quote from the Minister of the Environment is as follows:

"…the Minister is proposing not to add the Porbeagle Shark to Schedule 1, because in the absence of a provision for the possession and sale of listed species, listing the porbeagle would eliminate the directed and bycatch fisheries and result in economic losses for some fishers and associated industries in coastal communities and loss of industry-based sources of information on the species."

So when the government tells me that economics played no role in the refusal to designate the Porbeagle as endangered, that is either misinformation or an outright lie.  But a lie is still an answer, I guess.