SIPS Vice President Michael Simmons has written our society's response to the Draft Commercial Fishing Plan for Herring for the coming year.
We have come to the conclusion that by not treating migratory herring separately from resident, non migratory, local herring in the Salish Sea, DFO has allowed the Food and Bait winter fishery to extirpate local populations of herring. Those that remain are mere unsustainable remnants. A recovery plan is urgently required.
We believe any recovery plan has to be based on allowing the population of migratory herring to increase in number and geographic extent. That action would allow migratory herring to mix with local populations. In time such an expansion may cause spawning to resume in areas adjacent to the current limited core spawning areas.
We therefore ask for DFO to coordinate a recovery plan for Salish Sea herring involving all the interested parties.
Please read the letter below.
Minister for Fisheries and Oceans Canada
Honourable Diane Lebouthillier, MP
Draft IFMP Herring 2024-25 Strait of Georgia BC
Dear Minister LeBouthillier,
We write concerning the proposed Herring Integrated Fishery Management Plan (IFMP) for Herring in the Strait of Georgia, otherwise known as the Salish Sea.
The draft plan proposes increases in the total allowable catch (TAC) for the coming year for both herring roe and for food and bait.
As we write most of the herring that will be caught for extraction of roe in March are still in the Pacific Ocean, waiting to begin a migration that will take them to spawning areas in the Salish Sea. Other herring, year-round residents in the Salish Sea, are fished between now and February. Roe fishing season opened last year on March 6 and closed March 12 for seine net fishing, and from March 13 to March 15 for those using gillnets, for a total of 177.5 hours. You would not think that such a short season could not do much harm, but in that time 5,710 tons of herring were caught at a rate of over 32 tons per hour. The winter-time food and bait fishery took another 1,288 tons of resident, non migratory herring.
Why are we worried? Only 8 years ago more than 25,000 tons of herring were taken from the Salish Sea alone, more than three times the amount taken last year. And 60 years ago, almost ten times as much herring was taken from all the coastal waters of BC. Now the Salish Sea herring fishery is the only remaining commercial herring fishery.
Local First Nations are worried too. All herring fisheries in the southern Salish Sea were closed by DFO after First Nations stated that they could no longer obtain sufficient herring spawn and fish for food, social and ceremonial purposes.
Our society, known as SIPS, focusses on the Saanich Inlet, an arm of the Salish Sea on southern Vancouver Island. It used to have plentiful herring spawn every Spring but there has not been a significant spawn for fifteen years. At first, we thought this was due to habitat loss, but we soon realised that there was no point improving the habitat if there are no fish. The last time local First Nations harvested roe in the Inlet was over 50 years ago in 1972.
Every year your department produces a data summary for herring in the Strait of Georgia which is submitted to an advisory committee. This year, on behalf of SIPS, I participated in the discussion. I was eager to learn how information SIPS provided to DFO last year had been incorporated into the draft plan for the coming year. To my dismay the answer was NOT AT ALL. Attached is the SIPS submission from last year.
We were told DFO has a new model to assess the TAC. It is called SISCAH. The first two letters of the acronym stand for “Spatially Integrated” except that it is not yet spatial. The Salish Sea herring are now only found in a very limited spatial area in which spawning occurs and fishing is permitted. A brilliant animation in the data summary shows herring spawning areas diminishing in number year by year since 1950, with a now almost complete lack of spawning in the southern Salish Sea.
The SISCAH model treats all herring in the Salish Sea as a single population which is convenient for the model but does not differentiate the reality of large migratory herring population and very many local resident herring that do not migrate. As the Salish Sea has been managed by DFO as a single stock since the 1950s, the winter herring fishery has been permitted to systematically over-fish the resident local populations until today only a few small remnants remain.
The new SISCAH model also uses a “density dependent” function as a surrogate for mortality by natural causes. DFO finally adopts a measure of increased predation when herring are in large schools. While this is intended as a means of estimating natural mortality, by which DFO “measures” ecological relationships, it is in our opinion totally inadequate for assessing ecological relationships between herring and their predators. The fundamental place of herring in the ecology of the Salish Sea is correctly described in the draft plan but is not used in calculating the TAC as there is “insufficient data” to do so.
The Precautionary Approach requires DFO to use caution when knowledge is uncertain. For Ecosystem Assessment knowledge is clearly uncertain. The draft IFMP vaguely suggests an intention to improve coordination with ecosystem researchers. SIPS regards DFOs approach to “Precaution” and “Ecosystems” as totally insufficient.
We previously pointed out that two Important Bird and Diversity Areas (IBAs) recognised internationally, K’omoks and Little Qualicum Estuary to Nanoose Bay, are omitted from a map in the IFMP that shows Federal Marine Conservation Initiatives. This same map, without correction, is reproduced in the current draft IFMP. We also reported that a number of bird Species at Risk listed under the SAR Act are present in the core herring fishing areas and depend on herring and herring spawn for critical stages in their life cycle. In the current draft plan no mention is made of bird species listed under SARA, only fish and other marine species are mentioned. There is a statutory obligation under SARA for all species at risk, that DFO must respect.
SIPS did receive a response to our submission last year from Neil Davis, Regional Director, Pacific Region for DFO in which he explained the process for establishing the herring TAC each year which we do understand but he did NOT respond to any of the content of the SIPS submission.
We therefore cannot support the proposed Herring TAC for both the Food and Bait Fishery nor for the Roe Fishery.
Further we reiterate our request for a Herring Recovery Plan for southern portions of the Salish Sea and for a pause in the herring fishery in Area 14 and those parts of Area 17 that are still open for herring fishing. This pause is necessary to allow both migratory and local populations to expand their range to adjacent areas which would include Saanich Inlet.
Thank you for your attention.
Sincerely,
Michael D. Simmons
Vice President
Saanich inlet Protection Society
Neil Davis, Bryan Rusch, Marisa Keefe, Jaclyn Cleary, Hong Tjhie - DFO
John Driscoll, Misty McDuffee - Marine Conservation Caucus
Sydney Dixon - Pacific Wild
Jim Shortreed - Herring Conservation and Restoration Society
John Rich, Bob Turner - Bowen Island Conservancy
Dorrie Woodward - Association of Stewards of Denman Island
Cath Grey - Conservancy Hornby Island
Briony Penn - Salt Spring Island Conservancy
Louise Blight Ph.D - School of Environmental Studies, University of Victoria
Elizabeth May - MP Saanich, Gulf Islands
Rob Bottrell - MLA Saanich North and the Islands
