Herring Report

2023 – 2024 Pacific Herring IFMP

SIPS Submission Letter

Dear Minister Lebouthillier,

Please read the attached submission from our society concerning your Department's draft plan for Herring Fisheries in the Strait of Georgia. Interested parties are asked to consider a number of alternatives all of which, except one, would permit fishing in areas 14 and 17 of the Strait of Georgia. As the southern Strait of Georgia, including Saanich Inlet, has experienced an almost complete lack of herring spawn for several decades, and the only hope of restoration of our herring populations is migration from areas 14 and 17, we can only support option 1 which is no commercial fishing, FSC access only.

We especially bring to your attention that the draft plan fails to follow the DFO policies of respecting the Precautionary Approach and of respecting Ecosystem Management. It also fails to respond to species at risk designations under the SARA for Southern Resident Killer Whales, Chinook Salmon and six species of birds.

Thank you for the opportunity to review and comment on the draft plan.

Sincerely

Michael Simmons
Vice President, Saanich Inlet Protection Society

SIPS Submission to DFO

The draft plan offers options to reopen areas for fisheries that are presently closed. For the Strait of Georgia, the only area presently open for commercial fisheries, options are offered to increase commercial fisheries.

Saanich Inlet Protection Society (SIPS) is mainly interested in the Strait of Georgia herring fisheries on which we focus our recommendations to DFO.

The southern Strait of Georgia has experienced a progressive loss of herring and herring spawn from south to north stretching back more than 50 years1. The south to north trend continues with recent closure of fisheries north of Dodds Narrows as far north as Lantzville2. The drivers of this loss of spawning habitat have not been identified.

Accompanying this south to north loss of herring populations has been a narrowing of timing of spawning from historically up to five months to now only a few weeks. This probably means that local resident herring populations have been lost or, at best, greatly reduced. Together these trends represent a loss of genetic variety.

Significant spawning only continues to occur north of Nanaimo, in Area 14. Tagging studies indicate that 30%, or so, of spawning herring will stray from their natal territory when spawning. This makes repopulation in other areas of the Strait of Georgia possible if remaining herring populations north of Nanaimo are allowed to prosper.

DFO is obligated to include ecosystem considerations in managing fisheries and is also obligated to use a precautionary approach to conserve fish populations

SIPS therefore recommends that DFO do everything possible to conserve the remaining herring populations north of Nanaimo, by pausing commercial herring fisheries in area 14. SIPS also recommends that DFO create a herring population recovery plan for the southern Strait of Georgia.

1 Submission from MCC to DFO on Food and Bait Draft Plan 2023-24, dated November 13 2023.
2 Note that references to DFO data, reports, and publications are so numerous that they are not specifically cited.

Context

The draft plan optimistically offers options for re opening commercial fisheries in all closed areas of coastal BC except Haida Gwaii. For the Central Coast, only FSC and Spawn on Kelp fisheries would be available. The table below summarises the status of herring populations in the draft plan and proposals offered in the draft plan for reopening fisheries.

Area Biomass Change Status Proposed
Haida Gwaii Low Low Closed Closed
Prince Rupert Low Steady Closed Open FSC/Comm
Central Coast Low Decrease Closed Open FSC/SOK Only
Strait of Georgia Low Increase Open Open FSC/Comm
West Coast VI Low Slow Closed Open FSC/Comm

Source: DFO IFMP Herring 2023-24 Pages 76-78

Most of the remaining herring that now spawn in the Strait of Georgia are migratory. These fish spend the warmer months off the west coast of Vancouver Island. Therefore, conservation of herring populations off the west coast is strongly linked to conservation in the Strait. SIPS is concerned that if the WCVI herring fishery is re-opened pressure on Strait of Georgia populations will further increase.

We focus on four problems with the IFMP for Pacific Herring. They are:

  1. Failure of mathematical models used by DFO to adequately assess and forecast the status of Pacific Herring, a failure to properly incorporate DFO’s Precautionary Approach to DFO’s conclusions on maximum total available catch, and failure to incorporate ecosystem knowledge into these calculations.
  2. Failure of DFO to recognise and incorporate the revised assessment of the risk of overfishing from moderate to high for all herring fisheries except spawn on kelp.
  3. The consequent failure to protect Species at Risk (marine and shore birds), as well as the failure to protect globally and continentally significant aggregations of birds that are dependent on herring and herring spawn, and the inadequate assessment of these species in previous IFMPs for Pacific Herring.
  4. The absence of recovery plans for areas in which herring populations have been extirpated, and areas where population collapse is imminent, in the Strait of Georgia.

Saanich Inlet Protection Society wishes it to be known that recommendations in this submission are NOT intended to apply to Food, Social and Ceremonial Fisheries conducted by Indigenous People.

Saanich Inlet

We start with a synopsis of the current situation in Saanich Inlet

Once upon a time, Saanich Inlet was one of the most productive areas on the BC coast. Fisherfolk came from around the world. Heads of State, famous entertainers, nobility, and ordinary people by the hundreds joined the Indigenous residents every year to fish for salmon, rockfish, prawns … and herring.

Herring Spawn in Saanich Inlet

Herring have historically used Saanich Inlet for two purposes: spawning and pre-spawning aggregation. The former involved only Saanich Inlet resident stocks, while the latter also involved stocks from all over the southern Strait of Georgia. Spawning was documented along 35 km of the inlet shoreline, with a cumulative spawn area of 123 ha., as shown on the map at left. The average spawning date was March 28. Eelgrass was the preferred spawning substrate in Saanich Inlet.

You will note the use of the past tense in the preceding paragraphs. Even though a few herring are still seen in Saanich Inlet, there has been no observable spawn event since 2009.

There is no evidence that pre-spawning habitat nor oceanic conditions have deteriorated to an extent that would have wiped out herring in the Inlet. According to the 1996 Saanich Inlet Study, the use of Saanich Inlet as a pre-spawning habitat aggregation area appears to be sustainable. The study reported almost 30 years ago, in 1996,

“Herring spawning events in Saanich Inlet have decreased dramatically in the last quartercentury. There has been only one herring spawn recorded in Saanich Inlet since 1972. From 1931 to 1972, spawning occurred in pulses of six to ten years with, at most, eight years separating pulses. No one can remember a gap between spawning pulses comparable to the 20-year gap observed between 1973 and 1993. Furthermore, only minimal spawning was observed in 1993 and the pulse failed to continue to 1994. A concomitant decline in the abundance of juvenile herring, which serve as a food source for rearing salmonids, has also been observed within the inlet (Gilbert, pers. comm. 1995). Saanich Inlet herring
production is not currently sustainable.”

Within living memory herring spawn has taken place at numerous sites within Saanich Inlet, including Goldstream, Tod Inlet, Brentwood Bay, Coles Bay, Pat Bay, and Deep Cove, as shown on the map above. The last recorded herring spawn occurred in 2012 at Deep Cove and the last spawn recorded at multiple locations was in 2009. Indigenous people used cedar branches to collect roe in Tod Inlet up to 1972 when the last recorded spawn occurred there.

What has caused the decline? We don’t know. What we do know is that herring have declined precipitously in the Southern Strait of Georgia in recent years. While herring stocks in the Strait of Georgia were considered healthy at the turn of the century, the southern Gulf Island stocks were in serious decline at that time and have been since then.

If the herring stocks in Saanich Inlet are ever to return to their previous abundance, or even an approximation of that abundance, migration of herring from adjacent areas needs to be allowed to happen. As we will show there now is almost no herring spawning south of Dodds Narrows. The external migrants can only come from the one significant remaining spawn area which is between Nanaimo and Comox. Recovery of southern Strait of Georgia herring populations can only happen if the populations north of Nanaimo are allowed to recover and prosper.

The Saanich Inlet Protection Society urges you to allow that to happen. Recovery plans are needed for the entire southern Strait of Georgia. All areas from which herring are now virtually extirpated need recovery of their herring populations, including Saanich Inlet3. We attach in Appendix 1 a letter of support for these recommendations from MLA for Saanich North and the Islands, Adam Olsen.

3 Saanich Inlet Protection Society wishes to acknowledge the assistance of Jim Shortreed, Herring Advocate, Dr John Driscoll, Fisheries Science and Policy Analyst at David Suzuki Foundation, and David Fraser, former member of COSEWIC, in providing information for this submission.

Status of Pacific Herring in Southern Strait of Georgia4

Herring Spawn Surveys

In the latest 2023 DFO herring spawn surveys, after calculation of the DFO spawn index, only one spawn location was found south of Nanaimo, as shown in the map at left. Note that this location is at the lowest DFO spawn index category. The spawn that occurred in Esquimalt the previous year did not recur in 2023. This precipitous decline throughout the southern Gulf Islands, around Victoria and along the southeast coast of Vancouver Island needs to be urgently addressed by DFO. It has been shown that spawning in the Strait of Georgia has been lost over the last 50 years in a generally south to north direction. Early losses of spawn were recorded in Victoria and Esquimalt, then in Satellite Channel and Saanich Inlet, then round Salt Spring Island, then north of Dodds Narrows and now Lantzville5.

The graph on the next page shows the dramatic declines in number of spawning locations in the Strait of Georgia. Note since 2015 there have been more spawn events in area 14 than all the remaining areas combined.

4 All Data, Graphs, Maps and Quotations are from the DFO IFMP Pacific Herring Nov 2023 – Nov 2024, the Data Summary for Strait of Georgia 2023, and related documents.
5 David Suzuki Foundation, MCC Response to 2023/24 Pacific Herring Fishing Plans, November 13 2024

Spawning Events

Impact of the Food and Bait Fishery

The Food and Bait fishery, which happens in the months preceding spawning, appears to be exacerbating the south to north loss of spawning. DFO data shows that the Food and Bait fishery operated south of Nanaimo until the fishery was closed for lack of spawning herring in 2020. Since 2020 the Food and Bait Fishery has operated north of Nanaimo and now there is no spawn in those areas.

This fishery is roundly condemned by both the David Suzuki Foundation and UBC. Amongst other reasons there is evidence from SFU and the State of Washington that there are resident herring that do not migrate offshore. Everywhere the Food and Bait Fishery has been permitted is now lacking spawn. The conclusion seems to be that the Food and Bait fishery, while taking fewer fish than the roe fishery, is in fact having a very significant impact on local resident populations.

Recent Herring Catch in the Strait of Georgia

The graph below shows the total actual catch in the Strait of Georgia. The regression analysis shows a persistent decline that will soon approach zero.

Strait of Georgia Herring Catch

The food and bait and roe fisheries in the Strait of Georgia are now fishing the last remaining stocks of herring. If the food and bait and roe fisheries continue, we can expect the same loss of stocks that has occurred in Haida Gwaii.

Calculation of the Herring Quota for Strait of Georgia

Dr John Driscoll, Fisheries Science and Policy Analyst at the David Suzuki Foundation (DSF) and Marine Conservation Caucus (MCC) representative to the IHHPC, has provided SIPS with a synopsis of the MCC submission for 2022 – 23. For that year MCC suggested a maximum 4% harvest rate. Dr Driscoll explained that this rate was determined by,

“applying the MCC’s preferred harvest control rule to the estimated biomass. This information can be found in Table 32 of last year’s stock status update: https://waves-vagues.dfo-mpo.gc.ca/library-bibliotheque/41092703.pdf - the harvest control rule that the MCC has consistently proposed is “HS30-60_HR10” (which means a hockey stick-shaped harvest control rule where the harvest rate is 0 when biomass reaches 30% of unfished levels, increasing to a maximum of 10% when biomass is greater than 60% of unfished levels). If you follow the information for this harvest control rule across the table, the last column (“HR”) shows the harvest rate of 0.04.”

Dr Driscoll also pointed out while DFO claimed in the Management Plan for 2022-23, that even with harvest rates of 10% and 15% the conservation objectives were still met, this statement is in fact incorrect. In his words,

“The draft IFMP appears to contain a factual mistake in this regard, as the following statement appears to not be true: “For the SOG, in the most recent evaluations which included data from 1951-2021, MPs with a 10 and 15% harvest rate met the conservation objective with the minimum 75% probability over both natural mortality scenarios.” Again, we emphasize that only HS30-60_HR10 does this.”

Despite having to follow a Precautionary Approach as prescribed by the Minister, DFO decided that a 10% quota would be used rather than the 4% produced by DFO’s own model.

Similar claims are made in the draft 2023-24 plan. Six options are offered by the draft plan based on 60% of biomass with harvest rates of 10, 15 and 20%. A minimum harvest of 5,908 tons would be allowed to a maximum of 16,083 tons. We are concerned with the huge margins of error in the calculated biomass which are upper margin 65,739 tons (81%) and lower margin 36,842 tons (46%). Small differences in biomass estimates can make a large change in TAC.
It seems:

  1. the Minister’s direction of 10% has been ignored, and thus the precautionary approach is ignored,
  2. mistakes in calculating achievement of the conservation objective made in the previous plan are reiterated in this year’s draft plan,
  3. the huge margins of error in estimations of mature herring biomass render the seeming accuracy of the calculations suspect, and
  4. ecosystem considerations are not included because DFO could not assign numerical values to them.

We elaborate these critical omissions in the text that follows. We next refer to the failure of DFO to apply a Precautionary Approach.

Precautionary Approach PA and the Assessment of Risk of Over Harvest

DFO states, “the PA in general is about being cautious when scientific information is uncertain, unreliable or inadequate and not using the absence of adequate scientific information as a reason to postpone or fail to take action to avoid serious harm to the resource”.

“Both scientific uncertainty and uncertainty related to the implementation of a management approach must be explicitly considered and the management decisions taken must be tempered when necessary to give effect to the PA”.

The IHFMP 2023-24 in Appendix 13 dealing with Ecosystem Risk Assessment from the Food and Bait seine fishery, states, “Further analysis of additional resource management issues not incorporated into the preliminary risk calculations indicate there is a moderate to high potential to over harvest in this fishery, which may pose a risk to the stocks. To account for this additional issue, the overall risk that the fishery poses to the stocks was changed to high.

The exact same revision of risk of over fishing of the stocks to high risk is found for the Roe herring fishery Seine , and for the Roe Herring Gillnet fishery. The spawn on kelp fishery risk remains low.

There is no indication in the draft plan that the high risk of over-fishing to the stocks is taken into account in applying the precautionary principle to the allowable catches for these fisheries.

Ecological Significance of Pacific Herring

The draft IFMP for 2023-24 states,

“Herring plays a critical, foundational role in the ecosystem, supporting numerous economically, ecologically, and culturally significant species. These species include seabirds, especially diving birds such as cormorants and murres, fish, including salmon, perch, and hake, and several marine mammals”.

The most draft IFMP for 2023 – 2024 includes this description of the ecological significance of Pacific Herring:

“Herring are the foundation of the marine ecosystem which coastal Indigenous people have respected and honoured since time immemorial. This is illustrated by the significant role that herring play in the culture and society of coastal communities. Traditional Ecological Knowledge (TEK) shared by elders indicates that as children they were taught to have the deepest respect for herring because it was a “gift from the creator”. “Herring is the basis of the food chain. If we kill all of the herring we kill all of the salmon, we kill all of the halibut, and we kill all of the whales and so on.” The value of herring for Indigenous people goes much deeper than an economic or monetary value, instead the value of herring is looked at as a part of a much larger picture in which “everything is one and connected”. This is the earliest form of what is referred to today as, Ecosystem Based Management.”

The draft plan states, “Harvest rates are based on mature spawning biomass forecasts, with the intention of leaving juvenile fish and a significant proportion of the adult population available to support ecosystem processes”. The intention is praiseworthy, but the implementation is sadly lacking.

Schweigert attempted to quantify the role of herring as prey (for higher order animals) but found the ecosystem relationships too difficult to quantify. He also concluded (2009), “herring are the most important fish prey species for seabirds in the Salish Sea …. temporal and distributional changes may have affected seabirds and other predators during the spawning period … the causes of the apparent cohort failures of 2005 and 2007 are not understood but the effect on seabirds may have been substantial”.

While the current and recent Integrated Herring Harvest Management Plans refer to Ecosystem Interactions and to species at risk, we read from the October 5 2023 minutes of the DFO-IHHPC Pre-Season Herring Meeting,

“Ecosystem Approach to Fisheries Management … there has not been designated funding to implement this work”

and comments from members,

“it (ecosystem management) will not radically alter how fisheries are managed and will be incorporated into stock assessment”

and

“Would take enormous amounts of funding for ecosystem studies to be done and would be more restrictions for industry”.

The comments above demonstrate ignorance of huge volumes of work done not only by DFO scientists but of research from other areas around the Worlds.

While the concept of ecosystem management is mentioned in the plan document, NOTHING has been done to implement it. Consequently, it is completely missing from the plans presented. Ecosystem knowledge from other areas with herring fisheries are not referenced. Given that DFO acknowledges the critical importance of forage fish and especially herring to the marine ecosystem, plans for herring fisheries should not be approved until ecosystem management is explicitly included in quota calculations.

Herring Fishery in the Strait of Georgia and Birds

The current IFMP for Pacific Herring barely mentions birds. Reference is made to the Species at Risk Act but the connection between food availability for marine birds and herring is never mentioned, neither explicitly nor by inference. The plentiful and nutritious food provided by herring spawn allows birds to fatten up before beginning the most arduous time of their life cycle - migration and breeding.

It is well known to ornithologists that the timing of herring spawn and bird migration is crucial. Seabirds are a diverse group of species and include not just cormorants and murres, as briefly referenced in the IFMP, but also albatrosses, shearwaters, petrels, grebes, mergansers, auklets, murrelets, guillemots, sea ducks (goldeneye, long-tailed duck, bufflehead, etc.) and phalaropes. Migrating shorebirds and others also depend on herring spawn and they include sandpipers, godwits, curlews, yellowlegs, plovers, as well as gulls and geese including especially Brant.

A DFO paper published in 2009 states, “In terms of abundance, widespread distribution and accessibility, herring arguably are the most important fish prey species for many seabirds in the Salish Sea. The two key stages of herring life history, relative to their accessibility as food for seabirds, are the spawning period and the juvenile stage (two years and less).”
The relationship between prey abundance and breeding success has been understood for many years and has been substantiated World-wide. A 2011 paper identified,

Seabird Graph

“a threshold in forage fish abundance below which seabirds experience consistently reduced and more variable productivity … the threshold approximated one third of the maximum prey biomass observed in long term studies. This provides an indicator of the minimal forage fish biomass needed to sustain seabird productivity over the long term”6

The DFO paper also reveals that spawning timing has changed in the last 40 years. Before 1980 spawning occurred from early January to May. More recently most spawning happens only in March and into April. The authors conclude, “There has been a decrease in relative frequency and of early and late spawn since 1980.”

6 Global Seabird Response to Forage Fish Depletion – One Third for the Birds, Cury PM et all, Science, Vol 334, Issue 6063, pp 1703 -1706. DOI 10.11261/science 1212928

Herring as prey for seabirds are “abundant, occur in dense concentrations, are vulnerable and rich in protein and fats”. But in recent decades herring have declined in size by age, meaning that, “the energy return for seabirds per unit of energy expended is reduced.”

Variation in weight-at-age (1970-2008) for four age groups (ages 3 – 6).

This decline in weight at age is not trivial. For a four-year-old fish the weight in 40 years has declined by about 30%.

When herring spawn and spawn is floating in shallow water, exposed by the tides, or blown onshore by the wind, the congregations of birds are exceptional. One of the few places where this spectacle still occurs is from Parksville and Qualicum to Comox. Last winter (2022 -2023) the spawn did not occur, and the birds had to try to find alternative sources of food to fatten up for the northward migration and breeding.

In summary seabirds are facing:

  • A. huge declines in the total number of prey fish available,
  • B. dramatic shortening of the time through which herring spawn is available, and
  • C. diving birds are also catching fish that are significantly smaller.

It is quite clear that herring biomass in the Strait of Georgia is now far less than one third of the long term maximum biomass, which is recognised as the threshold below which seabird productivity declines precipitously.
On the next page species listed as at risk under SARA, that depend at some stage of their life cycle on herring and/or herring spawn, are documented.

The Species at Risk Act SARA Birds

The following are species at risk that are (or were) common in significant numbers in the Strait of Georgia, and depend at some stage of their life cycle on herring spawn, and are currently listed under the SARA Act:

  Location First Listed Last Review
Threatened      
Marbeled Murrelet BC 1990 2012
Special Concern      
Cassin’s Auklet BC, Pacific Ocean   2014
Horned Grebe (western) BC   2009
Western Grebe BC   2014
Ancient Murrelet BC, Pacific Ocean 1993 2014
Red-necked Phalarope BC   2014
Candidate Species of Birds for Assessment (November 2, 2023)      
Marbled Godwit      
Greater Yellowlegs      

Western Grebes, formerly present in thousands during winter on coastal waters in the Strait are now largely absent. Now they winter in California where anchovy is abundant. It is thought that the shift is due to the absence of herring in the Strait. Similarly Red-necked Phalarope that were abundant before the 1960s collapse of herring populations no longer occur in the Strait.

For all birds, including those listed as Species at Risk, the lack of food prior to migration and breeding may significantly reduce migratory and breeding success. Food provided by abundant herring spawn, a subject not mentioned in the IFMP, is more important than the risk of entanglement with fishing gear, which is referenced in the IFMP. Geographic areas of importance to birds are identified by international agreement and we next discuss them.

Important Bird and Biodiversity Areas (IBAs)

The Plan makes no mention of pelagic birds, nor of shorebirds, nor of species that prey on these birds. There is an additional section that deals with geographic defined areas and a map that shows Federal Marine Conservation Initiatives. Important Bird Areas IBAs are not shown. No mention is made of the 6 SARA listed bird species all of which, at critical stages in their life cycle, depend on herring and/or herring spawn. This is a statutory obligation that must be respected by all Federal government Departments including DFO.

In 2007 the Canada Wildlife Service created and published an inventory of Migratory Bird Areas of Interest (MBAOI), Technical Report 479. The purpose of the MBAOI report is to introduce marine planners to a comprehensive database describing marine areas with a heightened ecological value for migratory birds…The report defines an MBAOI as an area warranting special attention during marine planning processes, due to an underlying ecological value of the area with respect to marine birds.

Ecological value is defined as:

  1. an area where an observation of large numbers of marine birds have been recorded,
  2. an area where congregations of marine birds, regardless of species, are likely to occur based on identified habitat characteristics,
  3. areas adjacent to known marine bird breeding locations, or
  4. areas having high bird species diversity relative to other areas within the marine environment.

This work has since been refined and is now referred to as Important Bird and Biodiversity Areas.

Two large IBAs are within the area 14 for which both the herring roe fishery and the food and bait fishery are proposed in 2023 – 24.

1. K’omoks BC 272 which extends from Bates Beach south to Deep Bay including all of Hornby and Denman Islands and the coastal waters.

K'omoks

Part of the justification of BC 272 reads, “Birds concentrate in the Lambert Channel to take advantage of spawning herring in March … with globally significant numbers of Surf Scoter, Western Grebe, Black Oystercatcher, Glaucous-winged and Thayer’s Gulls.

There are also, “Continentally significant numbers of Short-billed Gull White-winged Scoter, and Red-necked Grebe. In some years there are also continentally significant numbers of Long-tailed Duck and Black Brant during spring migration. Aggregations of Harlequin Duck off NE Hornby Island during herring spawning can include 50% - 80% of the population of northern Strait of Georgia. Numbers have declined in recent years especially for Western Grebe and Harlequin Duck.

Other SARA listed species present are: Marbled Murrelet and Peregrine Falcon.

2. Little Qualicum Estuary to Nanoose Bay BC 56 which extends from north of the Little Qualicum Estuary to Lantzville including all the coastal waters.

Thayer’s and Short-billed Gull are common to abundant from Late fall to mid Spring with maximum abundance during the herring run. Numbers suggest a very significant proportion of the global population of Thayer’s Gull pass through.

“Very large congregations of birds (up to one million) are on the water in the second half of April. These include Surf, White-winged and Black Scoter; Long-tailed Duck and Common Loon. Other species present include Black Turnstone, Black-bellied Plover, and Dunlin; also Bufflehead, Greater Scaup and Harlequin Duck.”

In summary birds that congregate in large numbers in these two IBAs include

IBA Globally Significant Continentally Significant
   
K’omoks Surf Scoter Short-billed Gull
  Western Grebe White-winged Scoter
  Black Oyster Catcher Red-necked Grebe
  Glaucous-winged Gull Black Brant
  Thayer’s Gull Long-tailed Duck
Little Qualicum Thayer’s Gull Black Brant

References to Birds in the IFMP

The only references to birds in the draft IFMP for Herring are minimal and largely miss the point:

“The harvest rates are based on mature spawning biomass forecasts, leaving juvenile fish and a significant proportion of the adult population available to support ecosystem processes.”
Comment: The statement is not correct. The analysis does not take into account how the progressive reduction in herring and herring spawn in areas critical for birds has harmed those birds. There are no juvenile fish and no spawn in large areas of the SOG where they formerly existed. Herring biomass is significantly less than the threshold of one third of maximum long-term biomass below which seabird productivity declines precipitously.

“Encounters with SARA-listed species (e.g. Steller Sea Lion) and other marine mammals and seabirds may occur in herring fisheries. The Department and the fishing industry collect information on these encounters on behalf of the Species at Risk program and Marine Mammal Unit of DFO and Canadian Wildlife Service of Environment Canada”.
Comment: These reports are inadequate for protection of all species of birds and SARA listed species at risk. Nothing is done to reduce encounters with seabirds.

“Food and Bait Fishery SOG: Fishers shall take precautions to avoid fishing among seabirds. Fishers are requested to retain all dead birds which are entangled and to release live and unharmed birds by placing them in the water”.
Comment: Avoidance of birds is unavoidable as they are strong indicators of where there are herring and spawn. This advice is inadequate.

While the first statement quoted seeks to provide assurances that “harvest rates will leave sufficient fish to support ecosystem services”, this is an aspirational assumption not supported by any empirical evidence. The evidence from a very large number of field observations is to the contrary. There are not sufficient mature fish to provide the spawn previously known to have existed. As a result, food for numerous species at risk is no longer available in sufficient quantities to support populations as formerly occurred.

The Species at Risk Act SARA Southern Resident Killer Whales and Chinook Salmon

Southern Resident Killer Whales are designated by COSEWIC under the Species at Risk Act as Endangered.
In discussing the relationship of the herring fisheries to Southern Resident Killer Whales the Draft IFMP Herring 2023-24 discusses key threats. The first topic is Reduced Prey Availability 5.7.1.1).

“… Southern Resident Killer Whales feed primarily on salmon. The seasonal distribution and movement patterns of Resident Killer Whales are strongly associated with the availability of their preferred prey, Chinook salmon (Oncorhynchus tshawytscha), and secondarily, Chum salmon (O. keta) during summer and fall …. DFO and other researchers continue to advance new scientific information and analyses regarding the ecology of Resident Killer Whales. Much of this new information focuses on their feeding habits and preference for Chinook salmon, particularly in the Salish Sea with southern BC Chinook stocks experiencing poor returns in recent years.”

That is all that the IFMP has to say.

What it ought to say is that COSEWIC has also assessed the status, under the Species at Risk Act, of Chinook Salmon in the Strait of Georgia. Three separate populations of Chinook Salmon occur in the Strait of Georgia. Each population is treated individually by COSEWIC and given a “unit” number according to the river systems in which the fish breed. River systems draining into the Strait of Georgia from the east side of Vancouver Island from Goldstream (Saanich Inlet) in the south to Campbell River in the north are units 20 and 21. Each unit is “designatable under the Species at Risk Act. Unit 20 is assessed as Endangered and Unit 21 is assessed as Special Concern. Unit 18 with river systems draining the mainland side of the Strait of Georgia, could not be assessed as it is data deficient.

What the IFMP also ought to say is that one of the main reasons for the dire situation of Chinook Salmon in the Strait of Georgia is the lack of its prey – forage fish. Herring is was the principal component of the forage fish diet of Chinook Salmon.

We next discuss the collapse of herring populations in Haida Gwaii and the ecological consequences of this collapse.

The Situation in Haida Gwaii and its Significance to the Strait of Georgia

We ask why have Pacific Herring largely disappeared from the southern Strait of Georgia (SOG)? And why is there no recovery plan for the southern Strait of Georgia?

To find answers we examine the situation elsewhere on the BC coast. In Haida Gwaii Pacific Herring have largely disappeared. The Executive Summary of the recovery plan for Haida Gwaii states,

Spawn Index

“many of the herring populations around Haida Gwaii have significantly declined over the past three decades and remain at low levels today. This decline is having cascading effects on the ecological, cultural, social, and economic systems that depend on linang (herring) triggering the need for a plan to rebuild these populations.”

Council of Haida Nation, DFO and Parks Canada all agree that the cause of the decline is overfishing.
The first overfishing was the reduction fisheries, herring was ground up for fertilizer. The second overfishing was the Sac Roe Fishery.

All this has resulted in the Allee Effect which occurs when a fish stock is so low that the stock cannot rebuild. This results in inefficiencies due to external fertilization and continued natural predation hindering a potential rebuild.

The history of herring fishery in BC is one of a series of stock collapses. In the 150-year BC history since European settlement, the sardine fishery was the first to collapse in the 1940s putting more pressure on the herring fishery which collapsed in 1967. After the 1973 re-opening the food and bait component rapidly increased resulting in a series of changes to management. Now the roe fishery dominates herring fisheries in the Strait of Georgia. As shown earlier in this submission the roe fishery is rapidly reducing herring populations in area 14 to dangerously low numbers. In the last year only the Strait of Georgia Herring Fishery was open. We have no confidence in the current DFO approach to herring management in BC. The current biomass assessment models and the allowable fishing models are clearly failing to fulfill the DFO objective of conserving herring populations.

It is apparent that we are living through another collapse of the herring populations. Urgent action is needed if the Strait of Georgia fisheries are not to follow the experience of Haida Gwaii.

The Collapsed Herring Populations in the Southern Strait of Georgia and the Collapsing Fishery North of Nanaimo

As DFO is aware, once herring biomass drops below a certain level, recovery becomes very difficult and takes a very long time, if it is still possible. The now closed Haida Gwaii herring fishery is exhibiting no signs of recovery and may not recover. The lack of significant herring spawn south of Nanaimo in the last decade indicates that the southern Strait of Georgia is at a similar state and is about to suffer a similar fate if overfishing north of Nanaimo continues.

Stock Assessment

The “spawn index” right used by DFO shows a similar decline.

The graph left shows the spawn distance observed by the flight program for the last 10 years in the Strait of Georgia management area. The downward trend is alarming and potentially disastrous. A collapse seems to be imminent.

Here is our summary of the dire Pacific Herring situation in the southern Strait of Georgia (defined as the areas south of Dodds Narrows, boxed on the map on the next page). The spawn index map for the last decade, below, shows almost no spawn events in the southern Strait of Georgia. The graphs by decade of spawn events in the same area, shown beside the spawn map, show that the frequent spawns of seventy years ago no longer occur at all. The herring fisheries are rightfully closed.

Herring Spawn Index

Continued overfishing in management areas 14 and 17 is intercepting migratory herring that may have been destined to spawn in areas south of Dodds Narrows including area 18 and area 19 that includes Saanich Inlet (shown in the small rectangle on the map).

We conclude that the lack of herring and of herring spawn in the southern section of the Strait of Georgia is because they are totally intercepted by the DFO permitted herring fisheries in the sections north of Nanaimo.

DFO needs to aggressively manage the herring fishery north of Nanaimo for there to be any possibility of recovery in the southern Strait of Georgia. Chasing and removing the last remnants of these once enormous herring populations is risking the extirpation of this prolific source of natural wealth.

Discussion and Recommendations

  1. Herring populations in Saanich Inlet and many other areas of the southern Strait of Georgia have been virtually extirpated.
  2. Using the DFO mathematical model the Strait of Georgia Herring total allowable catch for 2022-23 should have been set at 4% of available biomass. The quota was set instead at 10%.
  3. The Precautionary Approach adopted by DFO has not been applied to the calculation of total allowable catch and quotas recommended. If the Precautionary Approach was included, the allowable quotas would most likely be, and should be, further reduced.
  4. The Spawn Index as measured by DFO for the Strait of Georgia has been steadily declining for the last decade, as has the actual catch.
  5. Ecosystem Management is supposed to be used in setting total allowable catch and quotas, but no work has been done by DFO to understand ecosystems in relation to the herring fisheries. It has not been incorporated into the quota calculations.
  6. Conclusive evidence exists that, once forage fish biomass drops below one third of maximum long-term biomass, seabird productivity drops precipitously. Pacific Herring biomass in the Strait of Georgia is now much less than one third of long-term biomass. Potential and existing threats to birds listed at risk under the Species at Risk Act have not been considered in assessing total allowable catch and quotas by DFO.
  7. The presence of two IBAs within the proposed herring fishery areas is not acknowledged by DFO and no measures are proposed to maintain herring populations and spawn in those two areas to conserve bird populations.
  8. Southern Resident Killer Whales are endangered as is their main, preferred prey, Chinook Salmon, Unit 20 in the Strait of Georgia. The draft IFMP Herring 2023-24 fails to mention that endangered Chinook Salmon prey on herring and that Southern Resident Killer Whales are endangered because of the lack of herring.
  9. The risk to herring populations of overfishing has been revised by DFO from moderate to high, but this is not included in the calculation of total allowable catch.
  10. The current status of herring in the Strait of Georgia is very similar to the pre-collapse situation in Haida Gwaii. Results from the herring population recovery plan adopted by DFO and partners in Haida Gwaii are so far not encouraging.
  11. All available evidence suggests that despite an increase in assessed herring biomass year over year, the downward spawning and biomass trends are long-term. These potentially catastrophic trends can only be reversed by pausing fisheries.

Recommendations

Saanich Inlet Protection Society concludes and recommends:

  1. To avoid the fast approaching collapse of herring populations in the Strait of Georgia, and the ecological consequences of such a collapse, including the effects on species at risk, DFO needs to act on its mandated “precautionary approach”. We therefore urgently request an immediate “pause” for all herring fisheries in the Strait of Georgia to allow for recovery before recovery becomes impossible. To be clear, for 2 23 – 2 24 there should be NO food and bait fishery and NO roe fishery. The Maximum Total Allowable Catch should be % zero.
  2. The “pause” we recommend is essential for protection of species at risk and to protect large congregations of birds at critical stages in their life cycle. To comply with SARA, the IFMP for Herring should identify areas in which the listed species at risk, and other globally or continentally significant concentrations of birds have historically been dependent on herring spawn, especially immediately prior to migration, or at any stage in their life cycle. In these areas the herring fishery should be paused indefinitely.
  3. Pacific Herring Recovery Plans are urgently required for:
    i. The southern Strait of Georgia, south of Dodds Narrows, where herring fisheries are currently closed, including areas 18 and 19 and those sections of area 17 south of Dodds Narrows, and

    ii. The northern sections of the Strait of Georgia where herring fisheries are currently still permitted, including area 14 and those sections of area 17 north of Dodds Narrows.

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