PO Box 75, Brentwood Bay, BC V8M 1R3
Phone: 250-652-9758
Email: sips@saanichinletprotection.org
Registered Charity #88743 2268 RR0001
Response to DFO Request for Public Comments on the Draft IFMP Herring October 2025
Another Consultation Charade
Yet again we are subjected to the charade of a draft IFMP Herring supposedly produced for public consultation. It’s the sections dealing with the Strait of Georgia (SoG) that are of primary concern to us, but we believe what we say about the SoG applies to all other coastal regions of BC.
No Vision for Recovery of Former Abundance
This draft repeats the same recipe as in previous IFMPs for continuation of low levels of abundance for herring. The marine ecosystem of which herring is a vital part includes all the other marine life dependent on herring; whales, orcas, sea lions, seals, salmon and other fish, pelagic birds, shorebirds, and others. What we need and expect from DFO is a plan that begins the restoration of the abundant herring known from before the earliest industrial fishery, and which industrial fishing reduced to the remnant populations of today.
As we read the draft plan its as if the former abundant life of the SoG that depended so heavily on herring does not matter to DFO. Simply collecting more, and more, data on spawns, weight and length at age, and the economic value of the fish is not ever going to restore the abundance of sea life, of mammals, whales, salmon, sea birds and the herring on which they all depend. That abundance existed before DFO. Rather than producing plans that year after year maintain the status quo at historically low levels, we need a vision of a restored abundant ecosystem. How do we get there? Is DFO up to the challenge?
Supposed Public Consultation is a Charade
Why do we characterise this consultation as a charade? For the last two years SIPS has submitted responses to the annual draft plan produced to provide herring fishery quotas. Each year we expect there will be responses to the issues we raise. The final plans issued after the consultation periods have never responded to any concern we have raised. None of the issues we raise have even been mentioned in the revised plans. In fact, the sections for which we raise the most concerns contain exactly the same words and serious omissions year after year. That is why we now know these consultations are a charade.
Each IFMP follows the same formulaic approach, repeating similar devastatingly dismal survey results and projections, only the quotas calculated are different. We know that the total projected herring biomass in the SoG is now less than the total amount fished in the past. Does DFO have any vision of how we might ever recover our herring populations to those historic numbers? What SIPS would like to see is for DFO to produce a recovery plan that enables the SoG ecosystem to regain its former abundance.
The Truth is Buried in Appendix 13 - Ecosystem risks
We read (buried in Appendix 13 starting on page 246) that ecosystem risks are “moderate”. What does that mean? The Draft IFMP explains, “the fishery is managed using a conservative approach and therefore was identified as having a low impact on ecosystem processes”. We disagree with DFO’s assessment of “conservative” and therefore we disagree with the DFO conclusion. It seems that “conservative” implies maintenance of the status quo. Could DFO possibly embrace a “visionary” approach?
Next, in Appendix 13, we read, “Further analysis of additional resource management issues not incorporated into the preliminary risk calculation indicates there is a moderate to high potential to over-harvest in this fishery”. There is no further explanation in the draft plan. These exact words have been repeated in the last three draft plans.
What are these additional resource management issues? No one except DFO knows.
What is the remedy for such high potential risk? Enhanced monitoring of course. DFO explains that advanced monitoring is already in place (and we might add has been for the last three years) - so the conclusion is obvious, there is no need to change anything.
Food and Bait Fishery and Local Populations
Buried deep in Appendix 13 we read the Food and Bait fishery has “uncertain impact on smaller spatial stocks”. Those involved in the fishery know there are local populations of herring. These are the “smaller spatial stocks”. The impact of the Food and Bait Fishery on local populations is not uncertain, it is known to everyone involved in the fishery. The local populations have been decimated throughout the SoG and continuing the Food and Bait Fishery as proposed in the draft plan will further reduce “smaller spatial stocks”. No remedy is mentioned.
Public Perception of Roe Fisheries
For the roe (seine) fishery we read in Appendix 13 that there are negative public perceptions. That observation is correct. The perceptions are negative because roe fishing reduces the numbers of reproductive fish as they are preparing to reproduce. Thus, the roe fishery eliminates any possibility of a sustained recovery to pre-industrial herring population levels.
Appendix 13 correctly concludes the overall potential risk assessment is high. What is the remedy? None is mentioned.
Appendix 13 references in the Draft IFMP
Throughout the draft plan there has been no reference to the concerns articulated in Appendix 13. We wonder, why are these concerns only revealed in the final appendix? There are 245 pages in the draft plan before Appendix 13 none of which mention any of the concerns, nor any of the risk assessments, revealed in the appendix. Clearly DFO has no response to these concerns, as they might preclude continuation of the status quo.
Ecosystem Concerns and the SISCAH Model
DFO’s IFMP Herring pays lip service to ecosystem concerns. The reason is clear - the mathematical models at the core of this IFMP cannot possibly adequately model the ecosystem. Despite the assertion that the new SISCAH model is spatial DFO has not included any spatial parameters in the model. And the ecosystem is only mentioned in relation to prey.
Restoring Abundance
We'll say it again.
It's as if the former abundant life of the SoG that depended so heavily on herring does not matter to DFO. Simply collecting more, and more, data on spawns, weight and length at age, and the economic value of the fish is not ever going to restore the abundance of sea life, of mammals, whales, salmon, sea birds and the herring on which they all depend. That abundance was known before DFO existed. Rather than producing plans that year after year maintain the status quo at historically low levels, we need a vision of a restored abundant ecosystem. How do we get there? Is DFO up to the challenge?
