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Mackerel and Herring submission to FOPO, April 22nd and 24th, 2026

Barry appeared as a witness before the House of Commons Standing Committee on Fisheries on April 22nd 2026 and followed up with a written brief on April 24th 2026. Both follow:

Opening Statement for FOPO Committee

Good evening and thank you for this opportunity. I’m Barry Darby, a former harvester and retired college educator formally from the fishing community of Burin, Newfoundland. For years my main focus has been doing research and advocacy on fishery management policy with my partner Helen Forsey.

Our policy initiative “Changing Course” recommends a shift to Input-Based Management for our fisheries which is directly relevant to the subject of your current study. I want to address primarily the science and analysis of our mackerel and herring stocks, and current management and rebuilding efforts.

In our view, three major factors severely limit the science, management and rebuilding plans for these stocks:

First – There are huge inherent uncertainties in attempts to measure stock biomass, to regulate removals and to predict their effects. Those interlocking uncertainties render largely invalid the calculations and resulting operational decisions based on them, such as Spawning Stock Biomass, Total Allowable Catches, Limit Reference Points, rebuilding plans, etc.

The Second factor is confusing fishing with catching. Catches and biomass are quantities that can be measured or estimated in kilotonnes; fishing, on the other hand, is an activity involving many different variations and units of measurement. Trying to measure fishing or “overfishing” in kilotonnes is unscientific and gravely misleading, and diverts our focus from managing the fishing itself.

The third factor is the false assumption that humans can rebuild fish stocks. Restoring ecosystem balance is done by nature, not by humans.    We can only help with the rebuilding and stop hindering it. To do so we must understand the complexities of the ecosystem and our role as apex predators in it.

So how can we help rebuild and maintain Atlantic mackerel and herring stocks and harvest them optimally?

As we said in our Changing Course brief to this committee in 2022, DFO should stop focussing on how much fish we harvest (that is, TACs and quotas) and start focussing on how we go about harvesting it.

Instead of relying on output controls – trying to predict the unpredictable using highly uncertain data and error-prone computer modelling – DFO should shift to a system of input controls. Input-Based Management – IBM – regulates the inputs involved in the actual fishing activity – that is, what fishing gear is allowed, how much of it can be used, by whom, and when, and where.

To put into practice this “slow fishing”  IBM approach, DFO would mandate selective harvesting of mackerel and herring, using low-impact gear like hook and line or gillnets. Specifications (limits) would cover numbers, size and depth of gear, and its use only by qualified commercial harvesters, in designated areas, and during specified times. This seemingly “less efficient” way of fishing would catch mainly mid-size and mid-aged fish, leaving the younger recruits to grow and the largest spawners to continue replenishing the stock. It would also result in higher quality product, and would, in many cases, permit continuous fishing across a range of species year-round,  benefitting harvesters, processors and communities.

Under IBM, built-in feedback loops make the system largely self-adjusting, thus preventing overfishing. For example, it mackerel were scarce, the regulations for gear and other inputs would make “overcatching” impossible; if the fish were plentiful, harvests would be correspondingly large.  Proper monitoring and assessment would of course indicate successes and problems in real time, informing the specific changes to be made for the following year.

And the proof is in the pudding. Newfoundland and Labrador’s quota-less lobster fishery has been using Input-Based Management with great success for almost a century now, and many successful invertebrate fisheries in the United States also use it.

In closing, I’d like to suggest that we also urge our American neighbours to apply Input-Based Management to “their” mackerel and herring stocks as well.

Thank you again for this opportunity, and I look forward to your comments and questions.

Brief to FOPO – Mackerel and Herring Fisheries

Barry Darby

April 24, 2026

    This brief is being sumbitted to complement and reinforce my Opening Statement presented at FOPO Meeting 33 on April 22, 2026. That meeting as originally planned would have allowed for questions, clarifications and answers — a dynamic give-and-take that cannot be fully replaced by written words. However, we are taking this opportunity to point to several more aspects of our Changing Course message as it applies to the mackerel and herring fisheries, as well as more broadly.  

    We want first to express our appreciation of the excellent evidence given by the other witnesses at Meeting 33 and previous meetings, including their expert and first-hand accounts of the serious and persistent problems, and of the negative economic, social and ecological impacts that have resulted. Our research and analysis confirms the validity of these submissions, and reinforces the need for these witnesses to be not just heard, but heeded. 

    Our submission differs from the others in that we not only identify the problems with the current science and management of these fisheries and others, but put forward a comprehensive proposal for resolving them. Incorporated below is our 2022 brief to this committee on the mackerel closure, in which we urged a shift to a better way of addressing both the scientific process and the harvest management system.

Brief to the Commons Fisheries Committee on the Mackerel Fishery Closure

Barry Darby and Helen Forsey,

Changing Course, St. John’s, NL

November 17, 2022

The current problem with Atlantic mackerel presents a challenge to DFO’s overall management approach. The Committee has already heard a great deal of testimony showing that simply changing mackerel quotas is not the best way to respond to what is really going on with these important fish.

The current situation is a case of management failure, and mackerel are only one example. The experience of recent decades has shown that Canada’s current fishery management system is simply not capable of properly identifying the problems, and thus of coming up with adequate solutions. Because TACs, quotas and harvest decision rules are based on models using past data with high levels of uncertainty, this approach provides no way of knowing what the reality is right now in the ocean itself, and responding accordingly.

Harvesters tell us the mackerel are out there, but DFO has not been able to find them. So is the stock really in steep decline, or are we not looking in the right places? And if mackerel actually are scarce, is it because we’ve been catching too much, or is it that other factors are affecting the distribution and behaviour of the fish? The answers to these questions would tell us the nature of the problem and what we should do in response. But DFO doesn’t have the answers.

Total mortality is much more than just fishing mortality. Reducing harvest quotas to zero is not guaranteed to have the beneficial effect that is intended. But it certainly does make a significant difference – a very negative one – to the people who fish for mackerel or use them for bait. Harvesters and coastal communities should not have to pay the price for the failure of DFO’s management system to properly diagnose the problem.

Now is the time to try a better way. Instead of trying to manage a complex ecosystem by slashing how much mackerel we’re allowed to catch, let’s manage how we harvest them. This means controlling the inputs – what gear and how much can be used by whom, when and where. The use of low-impact gear in designated areas for specified times would ensure that little or no damage is done to the stock or its habitat.

The Committee has heard a good deal about this kind of approach in your recent meetings on the mackerel closure, with witness after witness pointing to the harm done by purse seines. They have gone on to describe their success in harvesting mackerel more sustainably using hook and line or gillnets instead of seines.

Input-based management policy would foster this approach by regulating inputs rather than outputs – fishing effort rather than quotas. This would ensure that harmful gear like purse seines are replaced by sustainable methods. This approach would be largely self-adjusting – harvesters would catch more mackerel if the fish were plentiful, but would be unable to catch many if they were scarce.

Moreover, a properly implemented input-based system of harvest management would also gather essential real-time information from the harvesting itself. Catch rates, age and size ratios and other data would indicate the relative scarcity or abundance of the stock, as well as observations on its condition. But at present, with a fishery closure and no harvesting happening, these types of vital information are simply unavailable.

The current mackerel crisis actually presents an opportunity to seriously consider a better way to manage our fisheries. Let’s try managing mackerel through effort regulations instead of quotas, respecting the precautionary principle and moving towards sustainability for the fish stocks, the ocean ecosystem, and the fishery itself.

The points we made and the reasons we gave at that time are even more compelling now. Developments over the past three years, not only in mackerel but in our other quota-managed fisheries, have provided further evidence that the current approach is fundamentally flawed, and that it is high time to change course. 

Respectfully submitted,

Barry Darby

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