Author: bdarbyfish

Dissappearing RedFish and DFO Math

bdarbyfish

Barry Darby

DFO’s announcement in late January with respect to redfish puts a glaring spotlight on the numbers problem in the Department’s science and management.

Its new research purports to show that the biomass of redfish in Area 1, despite there having been essentially no fishery, has declined since 2019 from 4.3 million tonnes to 2.8 million tonnes after growing exponentially for a decade.

This follows news in December, 2023, that the estimated number of seals in our Atlantic waters is now 4.8 million rather that the nearly 8 million a few years ago. As with so much in DFO, it is uncertain whether this reflects an actual change in the number of animals or statistical errors in DFOs computing system; most likely it is a real decline, complicated by errors. In any case, it’s a serious problem.

Another astounding revelation by DFO last October was that they were changing the Limit Reference Point for Northern cod in 2J3KL to 315 kt rather than 800 kt calculated a little over a decade ago. Under DFO’s current management framework, the LRP calculations determine the Total Allowable Catch, so this error prevented the harvest of millions of tonnes of cod during the time the old LRP was in place. This foregone harvest not only condemned large numbers of fish to death by starvation as their population outstripped food supply, it deprived the Newfoundland and Canadian economy of potentially more than a billion dollars.

A fourth example of this kind of major error is evident in DFO’s 2020 stock assessment for 3Ps cod, which raised the LRP enough to move the stock’s status from the cautious to the critical zone. (Three years earlier, the 2017 assessment had expressed various “concerns,” noting that the model used had “overestimated spawning stock biomass in recent years.”)

Surely it’s clear that so-called fixed reference points that are so subject to massive change do not constitute a good foundation on which to base harvest management policy.

Returning to the redfish puzzle, it would be a mistake to attribute the one and a half million tonne drop (from 4.3 million tonnes to 2.8 million tonnes) to “natural mortality.” In current fisheries discourse, “natural mortality” is a catchall phrase used to refer to all undetermined reasons why fish disappear – mainly predation, unrecorded harvest, disease, and starvation. But the cause of the recent dramatic decline in Gulf redfish is actually quite clear.

We can eliminate predation as a main cause because there has not been a massive increase in any predator species. Foreign over-fishing could be a factor if the fish were on the nose or tail of the Grand Banks or on the Flemish Cap, but not in the well protected Canadian waters of the Gulf. And there have been no reports of disease. Meanwhile, the area’s shrimp stock has been declining over this same time period, and shrimp constitute an important part of the diet of adult redfish. So although other unknown factors such as warming waters may also be involved, we are left to conclude that the disappearance of all those fish is largely due to starvation.

Since we’re talking numbers, it would also be incorrect to conclude that the loss of biomass between 2019 and 2023 was 1.5 million tonnes (4.3 minus 2.8) when it was actually more. Gulf redfish at their current size are still growing, though more slowly than in the cohort’s first decade. Positing a growth rate of 1 cm/yr in length, we calculate the growth in the weight of an individual redfish at about 10-12% per year, as compared with 25-40% for cod.

In a simplistic model with an assumption of zero mortality and omitting other variables, this would mean the stock biomass would have grown by over 50% from 2019 to the present – to 6.5 (4.3 plus 50%) million tonnes. Obviously that is unrealistic, but the conclusion remains that starvation has taken a huge toll on redfish in the past four years – perhaps as much as 3.5 million tonnes. With proper management and planning, much of that biomass could have been harvested. At a conservative price of 50 cents per pound, that much fish would theoretically be worth over 3 billion dollars. This kind of loss to the Canadian economy was one of the scenarios we predicted three years ago in our Navigator article, “Redfish: Bonanza or Boondoggle?“

So what now? At the 25-kilotonne annual rate of exploitation currently proposed, it would take just over one hundred years to catch all the redfish in today’s Gulf of St Lawrence stock, even if we assumed no fish growth (impossible) and no new recruitment (unlikely.) Of course, redfish are a long-lived species, but they won’t live that long. Still, the scenario demonstrates the absurdity of basing harvest plans on those kinds of calculations.

Perhaps we need to ask: Who’s doing the math in DFO?

Barry Darby is a retired fisherman and educator from Burin, NL, who has done extensive research on the economics and sustainability of the fish harvesting sector.Articles

Fishery Policy: A Better Way

bdarbyfish

Brief to the Senate Fisheries & Oceans Committee. We presented this brief in person to the Ssenate Standing Committee on Fisheris & Oceans on May 2nd, 2024

In Changing Course, we research fishery policy and advocate for change. We focus on the federal level because it is federal government policies that underlie and regulate most of the activities involved in fish harvesting. Your Committee can help to get those policies right, looking at fishery management through a new window, studying the roots of the ongoing problems with the current system and considering an alternative basis for policy.

We propose an alternative framework for Canada’s fishery policies, one that will be more truly sustainable and benefit all involved. This represents a paradigm shift in policy direction that will dramatically change the system currently in place. And change is urgently needed, because Canada’s existing fishery management policies have not led to sustainable fisheries.

Our brief is organized as follows:

Rationale for the Change

Proposing a “Way to the Better”

Essential Principles

Tools for Fishery Management: Input and Output Controls

How Input-Based Management (IBM) would Work

Possibilities and Impossibilities

Benefits of Shifting to Input-Based Management

Recommendations

Conclusion

Rationale for the Change

A main goal of all fishery policy should be sustainability. That word has three essential aspects – environmental sustainability, social sustainability, and economic sustainability. And like a three-legged stool, sustainability needs all three legs and a good foundation in order to stand. If any leg is missing or weak, too short or too long, the whole thing will overbalance and collapse. And if the foundation is weak, it can’t support the stool.

Likewise, good fishery policy must rest on all three legs and a solid foundation. It must be firmly based in current scientific reality, and must optimize the ecological, social and economic benefits, present and future, for all involved – humans and “all our relations” in the natural ecosystem.

As we shall explain, our proposed alternative policy framework meets this high bar.

More than a century ago, the poet Thomas Hardy wrote: “If way to the Better there be, it exacts a full look at the Worst.” Hardy may not have realized that his maxim would apply so perfectly to fishery management. But it does. Canada needs a “way to the Better” for managing our fisheries – so first we have to look at the Worst.

The current fishery management system has not fostered sustainability. On the contrary. Evidence shows clearly that for the past many decades we’ve been getting fishery management wrong. Look at that evidence: the northern cod Moratorium – 30 years now and counting. The decline of salmon on all our coasts. The shrinking of herring, capelin, shrimp, and mackerel stocks. The continuing struggle of harvesters just to make a living on the water. The ongoing decimation of coastal communities. And overall, as Daniel Pauly has been telling us for decades, we’re fishing further and further down the food web, eroding the structure of the ocean’s ecosystems.

Why does the current system not foster sustainability? The federal Department of Fisheries and Oceans bases their management system on the quotas and allocations of a calculated “Total Allowable Catch” (TAC). In other words, their focus is on defining the tonnage of fish biomass they project can be safely caught. This quota-based system is DFO’s “Precautionary Approach Framework,” or “PA Framework.”

And it’s not working. Again, the evidence shows that DFO’s supposedly “precautionary” policy framework is not protecting the ecosystem, and it is not maximizing benefits for harvesters or coastal communities either. Based on our research, we think we know why, and we believe we can offer a better way.

Proposing a “Way to the Better”

What we present here is a new way of looking at the challenge – a paradigm shift in thinking, policy and practice. The task of fishery management is to prevent overfishing and foster ecosystem health, and we propose an alternative management framework – one based on regulating inputs rather than outputs. Instead of attempting to estimate and allocate in advancethe number of kilotonnes of fish to be caught, we should regulate the activities of the fishing itself so as to foster sustainability.

This is done by implementing Input-Based Management (IBM). The inputs – the fishing effort, the “who, how, what, where and when” of harvesting – are regulated on the basis of scientific evidence, traditional knowledge and continuous real-time feedback. By properly regulating the fishing effort, we can reduce the pressure on the stocks and on the ecosystem in ways that will actually build sustainability for both fish and fisheries.

This Input-Based Management (IBM) may seem a radical idea, but it works. The traditional Atlantic cod fishery had no quotas, and the stocks survived more than four centuries of harvesting until modern industrial methods and the indiscriminate use of high-power technology led to devastation in a few short decades in the last half of the 1900s.

A current example of Input-Based Management in operation is Newfoundland’s lobster fishery. It is one of our most successful and sustainable fisheries, and it has been managed by input controls – without quotas – for the past 97 years. Instead of setting quotas or limiting the landed biomass, lobster fishery rules specify the season, the type of gear and the number and design of traps, and prevent the harvest of egg-bearing females. This selective harvesting explicitly targets the middle segment of the harvestable biomass, leaving both the very young and the mature reproducers in the water to replenish the stock. It thus mimics the natural system of predation in the wild, something Chris Darimont of the University of Victoria recommends if we want to harvest sustainably. Moreover, it enables larger harvests when the animals are plentiful, and smaller, non-damaging harvests when they are scarce – a key characteristic of a sustainable management approach.

Input-Based Management also meshes with Indigenous understandings and traditional practices, grounded in the recognition that humans are part of the natural world, not separate from it. As Climate Change and Covid have shown us, we humans are simply not in charge. That realization is appropriately humbling, and opens the door to changing failed approaches.

A corollary is that fishery management does not and cannot manage the fish or the ocean. It manages the fishery – that is, our human activity as predators in the marine ecosystem. In trying to optimize that management system, we would do well to incorporate the Indigenous concept of the “Honourable Harvest” with its unwritten rules based, as Potawatomi scientist-poet Robin Wall Kimmerer explains, on respect and reciprocity with “all our relations.” Take only that which is given. Harvest in ways that minimize harm. Never take more than half. Never waste. Our society is slowly starting to pay attention to those profound understandings, but we’re still just taking baby steps.

Essential Principles

The following principles underlie our “Changing Course” proposal for a better way:

  • The ocean’s ecosystems are of inherent value and must be kept healthy, so harvesting must be done selectively in sustainable ways;
  • The ocean is a commons, and, as recommended by the FAO, harvesters have “use rights” to harvest that commons sustainably;
  • The fishery management system must provide optimum net economic returns to harvesters and coastal communities;
  • The system must be equitable, inclusive and participatory, with implementation and management kept as simple and effective as possible.
  • The system must be based on verifiable real-time information and feedback, avoiding reliance on inherently uncertain theoretical predictions, and implementing practical measures for sustainable fishing.

Our overall policy direction should incentivize small scale fisheries where these principles can be reliably implemented, rather than encouraging and subsidizing large, corporate, industrialized fishing, where that is not the case.

Tools for Fishery Management – Input and Output Controls

We think of DFO’s fishery managers as having a toolbox with a set of tools. Fishery management involves choosing which tools to use and how to best combine them for the purposes of sustainability. The six main tools in the toolbox can be listed as six questions – the “Who,” the “What,” the “How,” the “When” the “Where,” and the “How Much” of harvesting.

The FAO’s Fishery Manager’s Guidebook describes the two main management approaches used in the fisheries of different countries: output controls and input controls. In both approaches, most of the same tools are used to some extent, but they are prioritized and employed very differently. This is because of the difference between the goals of the two systems – the main task that the tools are being used for in each case.

Output control systems focus on restricting the amount of fish biomass to be caught so that it will not exceed a calculated limit. They primarily regulate output, calculating in advance “How much” should get harvested, and relying heavily on advance estimates and calculations of Total Allowable Catches and resulting quota allocations. The “Who, What, How, When and Where” are partially addressed through licenses, seasons and zones, but the overriding and determining factor is the output – the “How much.” Output control is DFO’s current management system, their “PA Framework”, which we refer to as “Quota-Based Management.”

Input control systems focus on ensuring that the fishing activities themselves foster sustainability and do no harm. These systems regulate fishing effort, using the first five tools in combination – detailing the “Who, What, How, When, and Where” of harvesting. The sixth tool, the “How much,” is monitored and measured, but it is not estimated or set in advance, and it does not dominate the harvesting plan or determine the eventual catch. The input control system, in which harvesting is managed by regulating fishing effort, is the alternative framework we propose in Changing Course.

Let’s take a closer look at the six tools as questions for management in regard to commercial fish harvesting. Before outlining our proposed input-based approach, we want first to describe how DFO currently uses those tools to accomplish the task set by their quota-based management system.

The Task for DFO’s output-based system: to restrict the catch so that the amount of biomass removed will not exceed a pre-set limit.

1. “Who can fish?” Currently, harvesters may be owners/skippers or crew, based locally or elsewhere, trained and experienced or simply hired at the wharf. Other professionals such as registered nurses or people in the skilled trades need to meet specific qualification requirements in order to practise, but under the present system this is not so for harvesting crews. Nor do young people currently have any clear avenue to follow in order to become harvesters. Some work has already been done at provincial levels on certification and training, but it is still incomplete.

2. “What is being fished?” DFO’s quota-based system attempts to deal with each species in a separate theoretical silo. Since the ocean is not divided into silos, that fragmented approach is out of touch with the complex scientific reality of predators, prey, competition and other factors. The single-species approach also leads to serious problems of bycatch, where large quantities of non-target species are dumped unrecorded and unutilized. Although DFO is planning to move towards an ecosystem-based approach eventually, they are still managing mainly species-by-species, stock by stock, with all the attendant problems around bycatch, habitat and ecosystem balance.

3. “How is fishing being done?” This refers to harvesting methods and gear, which are of crucial importance to ecological and economic sustainability. But this factor is largely invisible in DFO’s current system, (beyond a misplaced and risky emphasis on the length of vessels.) Under the Department’s quota-based management, huge quantities of biomass are harvested by otter trawls, which fish indiscriminately, hauling in massive quantities of whatever life forms they can scoop from the sea floor and destroying the habitat in the process. Gillnets also harvest non-selectively, though they do less damage, and regulating mesh sizes and soak times can help. Hook and line fishing does little harm (except to the individual fish caught!) Despite these crucial distinctions, DFO’s management system fails to focus on the “how” of fishing, with the result that the bulk of the TAC (Total Allowable Catch) biomass of most stocks is harvested by large-scale non-selective industrial methods, mainly in the offshore.

4. “When can we fish?” Seasons are set – too often at the last minute – for each species in each area, based mainly on science and on observed patterns of fish reproduction, migration and behaviour. DFO sometimes also makes rules specifying times of day, frequency of hauling, etc, and there may be daily or weekly trip limits. In general, though, once a season opens, harvesters fish until they have caught their quota, which may or may not correspond to market factors, weather conditions, processing capacity, etc.

5. “Where can we fish?” Geographical fishing zones or areas for each target species are set by DFO within the larger zones defined by NAFO and other international agreements. DFO uses zones, together with seasons, primarily for administrative purposes.

Note: Beware of potential confusion between these actual geographical zones of the ocean (eg. 2J3KL), and DFO’s disconcerting use of the same word, “zone”, to refer to the presumed state or status of a stock (eg. “capelin is in the critical zone.”) Those non-geographical “zones” – “healthy,” “cautious” or “critical” – are defined by theoretical “reference points” calculated by mathematical models based on statistical estimates.

6. “How much canwe catch?” The main harvest management tool in DFO’s current quota-based system is the sixth one – “How Much.” It attempts to determine how many kilograms of biomass we should harvest from a given stock in a given year. Here’s how it’s done: DFO scientists use survey data – seldom up to date – to estimate the biomass of a given stock. These data, which have high margins of error and uncertainty, are then fed into computers, along with reference points calculated from historical data, all of which also involve a large range of variables, uncertainties and unknowns. The computers then model future scenarios as best they can, plotting projected biomass numbers and fishery removals on a graph. This eventually leads to the calculation of the TAC, the Total Allowable Catch, which is then allocated and distributed as marketable quotas of biomass.

This single output tool – “How much” – forms the fundamental basis for DFO’s harvest management planning. It largely drives what kind of science the Department undertakes and how that science is interpreted and applied. Some input tools are used as well, involving regulations for licensing, gear, seasons and zones, but input considerations are overridden by the top priority – setting TACs and quotas. “How much” is thus the final arbiter in determining harvest policies in DFO’s output-based system.

Note that the first five questions, which deal with inputs, all have answers that can be easily and accurately identified, measured, complied with and enforced in real time. They are “known knowns” – a necessity for effective management. In contrast, the current quota-based system deals with the projected output, relying heavily on the sixth question, and is thus full of unknowns and uncertainties, unmeasurable, and problematic to enforce. The answers to “How much” can only be roughly estimated at in advance, and any necessary corrections can only be made after the season is over, if at all.

How Input-Based Management (IBM) would Work

The Task for our proposed Input-Based Management system: to ensure that the fishing activities themselves foster sustainability and do no harm. There is not enough room here to cover all the details of implementation of our proposed IBM system, but a brief outline and a few examples will help explain the practicalities of our approach.

“Who” – This involves professional qualifications, training and safety, together with considerations of equity, inclusivity and participation. Under IBM, training and certification programs would be accessible to all, along with grandfathering for experienced harvesters. Commercial fishing would be the exclusive domain of certified professional harvesters – both owners and crew – who have registered their home port.

“What” – In fisheries circles internationally, there is now considerable agreement that fishery management should look at the whole marine ecosystem and work with it. With IBM, harvest policies and planning would take into account the multi-species nature of the ecosystem, predator-prey relationships, food supply and habitat. This would help minimize bycatch, and in any case all bycatch would be landed and recorded, with a system in place for utilizing it where possible.

“How” – This is a central element of Input-Based Management, a crucial one for preventing overfishing, maintaining ecosystem balance and healthy stocks. With IBM, fishery managers could regulate the choice, size and amount of gear, and set conditions for its use. For example:

  • Each harvester could use up to 1200 baited hooks or a specified number of traps;
  • Specific mesh sizes or escapement mechanisms for nets and traps could be set for each species to allow undersized juveniles to escape;
  • Other size limits could be used to restrict how much fish a particular gear could catch: eg. length of a longline, length and depth of a net;
  • Regulations could set maximum soak times for nets and longlines, number of tows per day for a trawl, etc.

Input-based systems foster selective fishing, specifying the types and amounts of gear being used in order to optimize the intended harvest, minimize bycatch and prevent damage to the habitat and ecosystem. Gear can be ranked according to a sustainability index, so that the most sustainable types (eg. handlines, pots and traps, and longlines) can be chosen wherever possible, and the most damaging (otter trawls, bottom gillnets and most seines) avoided. Using sustainable gear and harvesting selectively can actually increase the size of the harvest while simultaneously improving the state of the stock – a win-win proposition.

“When” and “Where” – Under IBM, seasons would be set well in advance for specific zones and areas, giving harvesters and processors time for advance planning and preparation. The “when” and “where” aspects of harvesting plans would take into account scientific and local knowledge of species distribution and migration, reproductive cycles, aggregation, feeding and other behaviour patterns. Decisions on seasons and zones would be guided by a massive increase in the use of Marine Spatial Planning, with many more zones and sub-zones than currently exist.

“How much” – Scientific monitoring, stock assessments, and measurement of catch rates, landed biomass, landed bycatch, and other outputs would of course continue under Input-Based Management, and would be improved and expanded with updated data collection and analytics technology, together with increased participation and feedback by harvesters and other citizen scientists. These data would be used for the regular stock assessments and in a wide range of scientific work to enhance understanding and improve management. However, in the quota-free system, the data would not be used for attempts to predict acceptable biomass removal or to set quotas. There might be some use of trip limits in certain circumstances, or a cap set on the total catch in a particularly vulnerable situation, as part of the ongoing process of adapting and fine-tuning the system in a rapidly changing world.

Possibilities and Impossibilities

With this overview of our proposed alternative sketched out, we now need to highlight some key points that differentiate the two systems. These points help explain why the output-based approach does not work, whereas IBM, the input-based alternative, will.

Fishing vs Catching: “Fishing” is not the same thing as “catching”, and using the two terms interchangeably is misleading. Fishing is what people do to try to harvest fish; catching is about the result they get (or hope for.) Sometimes we may fish all day, or all season, without catching very much; other times we catch a lot of fish in an hour, or get our whole quota in the first day or two of the season (which can also cause problems.) Moreover, some fishing methods are ecosystem-friendly whereas others are extremely harmful, regardless of the amount caught. Catching can be measured in kilograms of biomass; fishing cannot. Yet the quota-based system fails to take these crucial distinctions into account, making them invisible and thus unavailable for use in management.

Look at the term “overfishing.” Obviously, it is bad to remove more fish than biological reproduction can replace. But we see overfishing as fishing unsustainably, not just catching too much. For example, 20 industrial trawlers with otter trawls dragging the same area of seafloor for months constitutes overfishing, whether they catch a lot or a little.

This point is actually key to understanding one of the foundational flaws in DFO’s quota-based management system. Operationally, harvest managers under any system must set limits that will prevent overfishing. Our view is that we should place the limits mainly on the fishing itself, the effort, and continually monitor the results. This input-based approach, unlike a quota system, enables us to accurately establish, quantify, adhere to, monitor and enforce all the elements involved in harvesting our oceans. In this way, IBM proactively prevents both overfishing and overcatching.

TACs: An Impossible Task: Another fundamental problem with quota-based management is that it is impossible to calculate, with any degree of accuracy, a Total Allowable Catch, on which the whole quota system depends. To illustrate, take DFO’s stock assessments for 2J3KL cod over the past decade, which show estimated spawning stock biomass around 400 kilotonnes, with a margin of error of plus or minus 25%, i.e. 100 kt either way. (Estimates of other stocks are even more uncertain.)  In regard to the sustainable yield, historically as well as today, humans have consistently harvested 10% to 30% of this and similar cod stocks without depleting them.

Putting this information together as two scenarios at either end of the probability spectrum, we get:

Estimated Spawning Stock Biomass (SSB)                    300 kt   to   500 kt

Potential annual stock growth (sustainable yield)             10%      to   30%

            Multiply the above figures

Biomass that could be safely harvested (TAC)               30 kt     to  150 kt

As the example shows, trying to calculate a Total Allowable Catch based on those widely ranging estimated numbers results in a huge range of answers. If the initial biomass was actually at the lower end of the range, and the stock growth only 10%, the maximum sustainable harvest figure would be just 30 kt. However, if both higher figures were correct, the theoretically allowable catch might be as much as 150 kt. A TAC by definition has to be a specific number, and once chosen it is enforced by law. Yet any number chosen is simply an estimate – almost certainly wrong, quite likely seriously wrong. Sustainability requires getting things right. TACs are necessarily based on estimates, and that just doesn’t cut it.

Underfishing and Foregone Harvests: Since TACs are based on highly uncertain assumptions and calculations, the quota-based system often limits us to much smaller harvests than what could be caught sustainably, or even to full fishery closures, as with Pacific herring and Atlantic mackerel in recent years. This type of unnecessary loss, referred to as “foregone harvests,” represent major economic losses for harvesters, processors, communities and the Canadian economy as a whole. Catching too little can also be bad for the fish stock itself when it leaves too many fish in the water. If there are more hungry fish than the available food supply can support, those fish will be in poor condition and there will be starvation. In such cases, the arbitrary and highly uncertain output-based regulations limiting the harvest are actually counter-productive ecologically as well as economically and socially.

This may well be the situation now with redfish and shrimp in the Gulf and with cod and capelin in 2J3KL. Whereas the response by DFO and some other observers is too often a call to “Keep removals to a minimum,” that may only make matters worse. The real solution may be to manage the fishing effort by fishing selectively so as to catch a larger proportion of the hungry predator fish and leave more prey for the remaining ones to eat. Those remaining predator fish will then be in better condition and can grow, reproduce and more effectively replenish the stock. The simplistic mantra of “keeping removals to a minimum” can be appropriate in some circumstances, but in others it is exactly the wrong way to go.

Input-based management (IBM) prevents both over-fishing and under-fishing. It has built-in feedback loops, like poor condition of the fish or declining catch rates, which enable harvesting to be largely self-adjusting: if there are a lot of hungry fish around, more will be caught, whereas if there aren’t, harvesters will do less fishing. In both cases, the result is to reduce the pressure on fish stocks and the ecosystem – the most effective way to enable them to rebuild. That can even mean fishing less and catching more.

Positive Inefficiencies: With modern discoveries and technologies, humans now have the ability to fish out most species in a few years. We no longer need to “improve” gear efficiency; in fact, “slow fishing” is better for the ecosystem, for product quality, and often for the harvester’s net income as well. But with the current system, the focus on catching a quota creates conditions where harvesters use the gear and methods that appear to be the most efficient, in order to make a living. And quota-based management does little or nothing to regulate gear.

In contrast, IBM encourages a degree of in–efficiency in our gear, which helps to increase sustainability by ensuring that enough fish are left in the water to maintain the stock and the ecosystem balance for the coming years. Some gear has a natural degree of positive inefficiency. For example, baited hooks only remain effective for a few hours; traps catch mainly smaller fish; small seines can not encircle an entire school of fish. Other types of gear need to be adapted to a lesser degree of efficiency, usually by specifying mesh size or limiting overall length and depth so as to allow certain sizes and species of fish to avoid capture. All those aspects of gear can be accurately specified, measured and managed, and such “positive inefficiencies” constitute an important and practical element of an input-based system.

Biomass and BOFFFs – Big, Old, Fat, Fecund Females: Quota-based management relies heavily on biomass figures – estimates of the total weight of fish in a given stock. But a stock is not homogeneous, and when crucial policy decisions are based on an undifferentiated total, some key factors of scientific relevance to sustainability are missed.

For example, there’s the phenomenon of “reproductive hyperallometry.” That refers to the fact that in many fish species, the Big, Old, Fat, Fecund Females – “BOFFFs” – produce many more eggs and more surviving larvae than the equivalent weight of smaller individuals – perhaps as much as an order of magnitude more. But TACs are defined in terms of biomass – a kilo of fish is simply a kilo of fish, regardless of age, fecundity, or the condition of the fish making up the total. So the quota-based system is unable to properly take into account the multi-dimensional complexity of the scientific reality. Our proposed input-based management system is able to address this and other significant factors that are lacking in the current approach.

Benefits of shifting to Input-Based Management

Taking another look at both of the management approaches we’ve described here, we can summarize the benefits of shifting from the current quota-based system to one of input-based management (IBM.)

With the clear decline of major marine species over the past seven decades, respected fisheries scientists and advocates like Daniel Pauly have rightly called for a precautionary approach. DFO’s quota-based management system is an attempt to implement precaution, but it has failed and continues to fail. Our analysis shows that the flaws are in the approach itself, and trying harder or making piecemeal adjustments will not solve those inherent problems.

Basing fisheries management on quotas, as is currently done, actually works against sustainability. The quota-based system tacitly allows all fishing methods and gears. As long as you catch your quota, you can mostly use whatever gear you want, the main limit being the number of tonnes of fish you can catch. This means most harvesters will use gear that catches as much as possible as quickly as possible – which is also the gear that is least sustainable. Moreover, in our capitalist, market-driven economy, those with capital go big – larger boats, bigger trawls, etc.  Those large-scale gear types are often incompatible with the slower, more economical and less destructive gear. So small-scale fishers using hooks, pots or traps are effectively barred from the ocean or have only limited access. In practice, then, DFO’s quota-based policies and regulations favour large-scale, inefficient and destructive industrial fisheries, and this needs to be changed.

Among the other negatives associated with DFO’s quota-based PA framework are: High carbon emissions. Biodiversity loss. Habitat destruction. Plastic pollution. Low-quality products. Waste of protein. Exploitation of labour. Privatizing the ocean commons. Outmigration and flight of wealth from coastal communities … The list goes on. These problems can be resolved or significantly reduced by shifting to the input-based management policy framework that we are proposing.

Now let’s sum up the benefits of that solution.Input-based management works with Nature instead of making futile attempts to control it. IBM is designed to identify and respond to ever-changing ocean realities like natural predation, food supply, water temperature, disease and migration, all of which influence the sustainability of our fisheries. Its built-in feedback loops flag situations for our attention, and input controls enable us to respond in real time with selective harvesting methods. This inherent responsiveness allows us to catch more fish when fish are plentiful, and appropriately fewer when fish are scarce, helping to keep balance in the ecosystem. The use of more sustainable harvesting gear and methods means much less damage to the marine habitat and food chain, enhancing marine biodiversity. IBM also reduces bycatch, carbon emissions, and plastic pollution.

As input-based management becomes established, these ecological benefits will translate into economic and social benefits to coastal communities, and to the economy and society as a whole. Thanks to more sustainable fishing practices, fish will become more plentiful and enable larger harvests, benefitting both harvesting and processing sectors. Higher quality products and better prices, combined with lower expenses, will increase harvest efficiency, and result in increased net economic returns. The reduction in bycatch will reduce the associated waste and economic losses. With sustainable harvesting supported and the quota-related problem of “foregone harvests” resolved, economic activity will increase at both the local level and more broadly.

As people realize the benefits accruing from input-based management, harvesters will increasingly opt for the greater efficiency of smaller boats and “slow fishing” practices. This will lower the fishery’s carbon footprint, reduce the overcapitalization of the fleet, and make it easier for younger people to get into harvesting. The increased economic activity will strengthen local economies and help coastal communities survive and thrive.

Recommendation:

Our recommendation is a very inclusive one:

The Department of Fisheries and Oceans should expedite a fundamental policy shift for managing Canada’s fisheries, replacing the current output-based (quota) system with a comprehensive Input-Based Management (IBM) policy framework as described in this brief. That framework needs to include:

1) implementing Input-Based Management, controlling fishing effort instead of setting quotas;

2) making it a formal policy goal to optimize net economic benefits; 

3) certification and fishing rights for all qualified commercial harvesters;

4) requiring all dead bycatch to be landed and recorded;

5) improving and expanding the collection, analysis and use of data from a full range of sources;

6) harvester-processor independence, with regulated competition at the wharf’s edge;

7) increased involvement of harvesters, communities and citizens in decision-making at all levels;

8) reorienting DFO’s scientific work to support IBM and include other knowledge systems.

Conclusion:

In this brief, we have outlined our analysis of the ongoing failure of DFO’s current output-based fisheries management framework, and presented in broad terms our proposal for a paradigm shift in approach. The Input-Based Management system we are putting forward for the Committee’s consideration constitutes a very different and very promising alternative way of managing Canada’s commercial fisheries. We recognize that it will raise many questions and present many challenges, and we see this as a welcome opportunity to initiate, here in our Parliament’s Upper House, the necessary in-depth public discussion of this alternative.

We want to highlight a few key points about what we propose. First, Input-Based Management cannot be combined with DFO’s current quota-based approach, precisely because the two systems are built on different foundations. It’s fine to cherry-pick good ideas about sustainable gear or Marine Spatial Planning and insert them into the current system, but that would simply be putting bandaids on a broken leg. There are already some good ideas in DFO, but they are overridden by the finality – and impossibility – of TACs and quotas. That is why we call this a paradigm shift – what needs to change is the very basis of management policies and decisions.

Quota-based management has been in place for so long and is used so widely that a proposal to replace it will not be easily accepted. Because the fishery is now structured around this decades-old system, quotas are treated as a core element of the current regulatory, financial, institutional and physical structures governing our fisheries. Altering these established management practices will inevitably be challenging, and implementing the shift will require recognizing and mitigating temporary problems that may arise.

No system is perfect, of course, but some approaches to fishery management are better than others. This is the UN’s “Ocean Decade,” and the next few years will be a crucial time for our fisheries. We have the chance to replace the current year-to-year crisis management mode with a long-term approach that will benefit harvesters, coastal communities, and the nation in terms of both economics and sustainability.

Respectfully submitted,

Barry Darby and Helen Forsey

Redfish Re-opening – Getting it Wrong

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This article was published in the St. John’s Telegram on February 18th, 2024 following a DFO re-opening decision that was several years late.

The recent announcement of the re-opening of the redfish fishery in the Gulf of St. Lawrence is of crucial importance on multiple levels – economic, ecological, and political. In order to take advantage of this opportunity that Nature is offering, we need to get it right.

Unfortunately, the Department of Fisheries and Oceans and many informed commentators are getting it wrong.

Since the early evidence of a redfish population explosion five years ago, harvesters have been looking forward to the chance to build a renewed fishery on the basis of this long-lived and periodically abundant fish. In 2019 the stock was estimated at 4,300 kilotonnes, but recent estimates put the current size of the stock at about 2,500 kt – a whopping 42% decline, despite there having been no fishery. The loss of those 1.8 million tonnes of fish could be attributed to “natural mortality” – a misleading catch-all term used when nobody knows the explanation, covering everything from inadequate food supply to predation and from climate change to illegal fishing. The redfish stock that remains, however, is still huge – about six times the estimated current relatively stable biomass of cod in 2J3KL.

Now, despite all the unknowns, the Minister and her Redfish Advisory Committee are tasked with determining a Total Allowable Catch – itself a highly dubious basis for decision-making amid the complex realities of fishery management. And too often, the problem is being presented to the public as a contest between provinces for shares of whatever that Total Allowable Catch turns out to be.

Naturally, harvesters and processors from all five provinces involved are clamouring for a “fair share” of this natural bounty. But now confusion reigns. The day after the January 26th reopening announcement, DFO’s media department sent out a table depicting “Redfish fishery quota allocation (2024 estimated; 1993 historic; and 2024-1993) by province.” They note that the table’s projections are estimated and subject to change, but they nonetheless then proceed to compare apples and oranges – their estimated percentages for 2024 with the actual historical percentages from 1993 – and get even that wrong!

The DFO table puts a minus sign for Nova Scotia’s percentage-point difference from the 1993 share, when the actual difference needs a plus sign, same as the other provinces. According to the figures in the table:

Nova Scotia got 27.2% in 1993, and is expected to get 33% in 2024. That is 5.8 percentage points more.

Similarly, Newfoundland and Labrador got 17% in 1993, and expects 19% in 2024. That is 2 percentage points more.

Yet the DFO table shows a difference of “-5.8” (minus 5.8) for Nova Scotia and “+2.0” (plus 2.0) for NL!

This simple but highly significant arithmetical error leads to the mistaken conclusion that whereas all the other provinces gain share, Nova Scotia is losing. This is nonsense. The reverse would be nonsense as well. Yet the mistaken table has already been widely cited as authoritative, and is adding to the misplaced inter-provincial hostility.

Blaming Nova Scotia for getting the lion’s share of allocations, or blaming Newfoundland and Labrador for wanting more is just falling into the trap of “divide and conquer.” Harvesters and coastal people everywhere should be able to make a living and have a life without constant struggle. The dispute over the respective percentages of Total Allowable Catch allocated to different provinces is a red herring.

The fishery’s true inequities are between the people who try to make a living from the sea and the rapacious industrial entities that seek to maximize their profits; between the survival and well-being of marine ecosystems and coastal communities and the short-sighted selfish interests of corporations and governments. So the current DFO plan to continue allocating more than half the redfish harvest to the offshore sector with its big industrial factory-freezer trawlers – that plan is inequitable, unfair and unsustainable.

Meanwhile, back on shore in NL, neither the government nor the media appear to understand the unique biology of redfish – a long-lived and slow-growing species, living 50 to 75 years but only reaching a maximum length of 50 cm. Normal cycles for redfish stocks appear to be years of low recruitment, interrupted occasionally by one or more particularly large year classes, which in turn may grow to become a huge biomass. To speak of the redfish “collapse” in 1995, and refer to the subsequent rebuilding as a result of a moratorium, may well be inaccurate. Instead it could be largely a matter of understanding the natural cycles of this species, and then managing the fishing accordingly.

With proper management, good monitoring and sustainable gear, the current redfish stock could be harvested over many years. But we are off to a very late start, due to the lack of foresight and common sense by both federal and provincial governments.

DFO failed to reopen the redfish fishery soon after the stock reached its peak four years ago. Since then over one and a half million tonnes of redfish have apparently died, perhaps because of a shortage of food. A major part of the diet of full-grown redfish is shrimp, and this same four-year time period saw the recent decline in shrimp biomass in the Gulf. If we had had ecosystem-based management and had fished with appropriate gear, we might have harvested many of those redfish and at the same time helped to maintain the shrimp stock.

Provincial government policies have prevented NL’s processing sector from gearing up to process a massively increased redfish harvest for the benefit of our coastal communities. Markets could have been developed for whole fish of a smaller size, for which there is potential demand in many cultures. But the provincial decision-makers clung to the notion that only large fillets of redfish are marketable. The few redfish caught since 2018 in the experimental fishery – which was supposed to help develop markets – was mostly sold cheaply for lobster bait. Another opportunity wasted.

The real problem with the redfish fishery – and with most of our other fisheries as well – is the way the whole thing is envisaged and framed. The current quota-based system favours large-scale, capital-intensive industrial fishing, worsening the inequities, threatening sustainability, and increasing the damage to marine ecosystems, coastal communities and the planet itself. In order to enhance sustainability, we need to focus on how fishing is done and managed, not on how many tonnes of biomass we end up catching.

It’s high time for that paradigm shift.

            Changing Course is the fishery research and advocacy initiative of Barry Darby and Helen Forsey. Barry is a retired fisherman and educator from Burin, NL, who has done extensive research on the economics and sustainability of the fish harvesting sector. Helen is a writer with a background in agriculture, environment and public policy. Their website is www.barrydarby.com.  

Fish and Potatoes

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This saucy but serious comparison of the pricing system for two NL staple foods was published in the St. John’s Telegram on March 26th. 2024

So the harvesters and  processers  have not been able to reach an agreement.

This is not a surprise to anyone who has been following this story and has some idea of the fundamental underlying issues.

The manner our processing industry has been run for over two or more decades is governed by two Acts. Of the province.

The Fisheries Collective Bargaining Act  And the Processers Act The actions of both harvester and processers are governed by the rules and policies laid down in those acts. A sober recognition of this FACT is a necessary first step in stopping (fixing) this farce (charade) that is called the “fishing industry” in Newfoundland.

In Newfoundland when we eat fish it is often accompanied by potatoes; Fish and chips, Fish n Brewis, fish chowder, to name but a few. Those two foods have accompanied each other for millennia. So why don’t we a Potato collective Bargainining Act and a Potato Processing Act.

We don’t because there is no need to have such silly rules and policies.

The price of potatoes, as well as all other foods we eat, result from the regulated market forces that govern our economy and society and it would also work for all fish products as well.

Harvesters know and well understand the vagaries of the market place and will accept and adapt to its movements. What they should not accept are laws and policies that manipulate the market for the advantage of the “middleman” and to the disadvantage of both the primary producer and the consumer.

The underlying concept of the current process implies that we can “set the price” of fish,despite the evidence of the past two years that shows that  the market set the price and efforts to subvert that market will continually fail. Harvesters have now fully realized that, hence the current protest at the Confederation Building. 

The issue of allowing outside buyers into the province is a bit of a red herring. All fish transactions in the province should include, in addition to direct sales, deals made by provincially licensed fish brokers, who could send some product out of the province unprocessed. This would entail extra costs to the buyer and would only occur when there would be raw material in excess of local needs. This exporting of unfinished product would also be temporary until extra capacity could be ramped up locally.

The ball is clearly in Premier Furey’s court. His government can either side with the working people of this province or continue the current monopolistic practices that current legislation perpetuates. 

Let’s have a recipe that combines fish and potatoes.

Will the PERT Report Highlight Our Fishery?

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By Barry Darby and Helen Forsey

Photo by Peregrine981 on Wikimedia Commons.

*(Published in The Independent, April 30, 2021)*

The following is a slightly condensed version of a December 3, 2020 submission on the fishery to the Premier’s Economic Recovery Task Force.

While it is unclear when a report (interim or otherwise) from Dame Moya Greene’s Economic Recovery Team (PERT) will be released, our question is: Will it highlight the fishery as the key element it is for the Province’s recovery from the current perfect storm?

We have little way of knowing what most of the input has been to the PERT so far. The lack of transparency has been noted repeatedly, with only bits and pieces emerging as people or groups report on their meetings with Dame Moya or parts of her Team. Equally fuzzy is the path for citizens to follow in order to provide such input, as no contact information is given for the Team. The Terms of Reference merely suggest that anyone interested should offer their views through the online EngageNL portal; however, submissions there “will not be accepted … until after the caretaker period concludes following the 2021 provincial election.”  

Fortunately, we had a special opportunity to submit our suggestions several months ago, after Helen’s critical Sept. 9th letter to the media gained Dame Moya’s attention and led to a phone call. We were hoping for some sort of follow-up, but since that has yet to happen, we think it’s now time to make what we said public. The following is a slightly condensed version of our December 3, 2020 submission to PERT.

***

The Fishery – Key Element of NL’s Economic Recovery

This submission to the Premier’s Economic Recovery Team focuses on the fishery as a critical element of our economy and society, where recovery measures can be taken at zero cost to the Province. This paper sets out the framework for some specific recommendations, which are discussed and then listed at the end. The changes proposed here will not cost the Province a penny; in fact, many of them should result in modest reductions in expenditures and/or increases in tax revenues.

The fishery and provincial responsibility

The fishery, in all its aspects, is central to the life, economy and culture of Newfoundland and Labrador, and it must also be central to the work of the PERT. As our centuries of harvesting have proven, the rich marine life in our waters constitutes an economic resource that can sustain thousands of people and their communities. Moreover, unlike oil and gas or minerals, the life of the ocean is renewable – and the fisheries it supports can and must be as well.

Although fishery management comes under federal jurisdiction, provincial silence on this front is not an option. Our fishery sector needs the full attention of the Newfoundland and Labrador government if it is to thrive and optimize its contribution to our economy in the near future and beyond. The Province must treat the fishery as one of its top priorities, not just leave it with the federal government, where it too often takes a back seat – neglected, mismanaged or traded off in favour of other federal agendas. For our provincial government to abdicate its proper role in this crucial area is the height of folly.

[To quote from] a recent article:

…’The Province’s governing parties have apparently given up on the fishery, choosing instead to focus on hydro and offshore oil – two bets that they are now losing. The government’s downgrading of the fishery’s importance to the province has been reflected over the past several years in the changes to the name of the corresponding ministry: from “Fisheries and Aquaculture” to “Fisheries and Land Resources” to the present “Fisheries, Agriculture and Forestry.” This puts what once was (and still should be) the mainstay of Newfoundland and Labrador’s society way down the priority list, tucked in with a struggling forest industry and a small but valiant farming sector. Meanwhile, our fishing communities continue to struggle for survival.’

When asked recently about the controversy over the caplin harvest, Premier Furey reportedly brushed off the question, saying, “Sounds like a federal issue.” But that’s not good enough. Dr. Furey is now the premier of this province, and there is nothing more important to the economic and cultural survival of Newfoundland and Labrador than the fishery. The provincial government must take a much greater role in regard to this crucial sector, actively representing our interests and asserting our collective point of view as Newfoundlanders and Labradorians.

It’s true that the federal Department of Fisheries and Oceans is constitutionally in charge of the entire wild fishery – research, planning, management, harvesting, costs and revenues, harbours, environment, safety and more – as well as sharing jurisdiction over aquaculture. This appears to leave processing, marketing and harvester certification to the Province, but overlap and complexities limit provincial powers even in those domains. When things like trade agreement requirements, environmental regulation, foreign ownership, corporate concentration, or food safety are involved – as they often are – provincial jurisdiction is less than complete even where it theoretically holds sway.

These factors represent a major challenge, but they are not insurmountable, and giving up is not the answer. The fishery is what Newfoundlanders and Labradorians have been doing for hundreds of years, and we should demand that our experience and recommendations carry the corresponding weight in decisions at the national level.

What must the Province do?

Given all the factors noted above, [we] offer the PERT some suggestions for recommendations to the provincial government regarding the fishery. These fall into two categories:

  • A. Measures the Province can implement directly, within its own exclusive jurisdiction, and
  • B. Actions the Province can take towards achieving needed changes in matters of federal and shared jurisdiction that are vital to Newfoundland and Labrador.

A. Actions on fishery matters within exclusive provincial jurisdiction

1. Stop micro-managing

Our provincial government must seriously take on its political and moral responsibilities towards this rich renewable resource of ours. Instead, it seems to be trying to compensate for its relative powerlessness on the water by imposing the wrong kind of control on land. For years it has been micro-managing the processing, marketing and farming of fish in ways that favour big corporations at the expense of local small busineses, harvesters, and the rest of us. That has to stop. The government must step back from elaborate efforts at control, which stifle local initiative and community enterprise. In particular, it must remove existing bureaucratic and regulatory barriers to the local construction or expansion of processing facilities, so that entrepreneurs or existing companies can make their own business decisions, raise their own capital and take their own risks. The government should also stop obstructing harvesters’ direct fish sales to consumers, and encourage small-scale artisanal processing by harvesters. If unnecessary barriers are removed, diversification and innovation can thrive and contribute to the Province’s treasury.

2. Stop spending public money on private enterprises

In regard to government expenditures, the Province must end public subsidies, loan guarantees and investments that hand over taxpayer dollars to fish processing and aquaculture companies. It must also end tax breaks that do the same by reducing provincial revenues. We need profitable businesses to employ workers and provide much-needed taxable income, but well-managed businesses make their own profits and should take their own risks. It is not government’s job to pick winners and losers or to prop up private enterprise with public money.

3. Inhibit transshipment for processing elsewhere

In addition, the provincial government must use every means at its disposal to discourage transshipment of whole fish for processing elsewhere. NL’s Minimum Processing Requirements (MPRs) are supposed to restrict this, but they are inadequate and subject to many exemptions, and CETA may make the problem worse. Under current practice, our port facilities and cold storage plants can continue to be used to enable companies to ship our ocean harvests out of province. This may serve corporate interests, but it robs Newfoundland and Labrador’s workers and entrepreneurs of important economic opportunities, and cheats government coffers of what should be provincial income.

4. Maintain support for small coastal communities

The coastal communities and indigenous people of Newfoundland and Labrador are the carriers of the traditions and knowledge that have sustained them for generations. Our governments, both provincial and federal, need to recognize the economic and social potential of that fishery-related knowledge, located in small, resilient communities scattered along our coastlines in geographic proximity to the resource. With appropriate government policies and continued support for infrastructure and services, people in such localities could capitalize on those inherent advantages to establish community-scale enterprises that would be innovative, efficient and profitable. The Province should help by actively encouraging fishery co-operatives, local entrepreneurs and community-based initiatives.

5. Encourage consumption of local fish and seafood

With the ocean at our doorstep, fish and other marine life should constitute a major element of food security in Newfoundland and Labrador. However, various inappropriate policy and regulatory barriers prevent most people from drawing on these vitally important food sources. Our province has a high level of food insecurity, yet our per capita fish consumption is low in comparison with other ocean nations. The government should facilitate direct sale of fish by harvesters to consumers, which is still hampered by unnecessary restrictions. It should also explore further ways to encourage and enable greater utilization of our own marine food sources to build food security across the province.

B. Actions on fishery issues in federal and shared jurisdictions

6. Take an assertive, united stand vis-à-vis Ottawa 

Our provincial leaders must kick their bad habit of leaving the fishery to the feds. We have a unique point of view on fishery matters, and our legislators and government must keep it strong and visible. We must be proactive with the Department of Fisheries and Oceans, advising them on an ongoing basis as to how we think they should do what they are constitutionally charged with doing – i.e. managing the fishery. In the past, on other fronts such as oil and gas, Newfoundland and Labrador has taken a much more assertive stand with the government in Ottawa – with some success. As we begin our process of economic renewal, the Premier, cabinet and all provincial parties should agree to confront the federal government with a united voice, and to work with our neighbouring fishing provinces to demand long-overdue action on the Atlantic fishery by the federal Minister.

7. Press DFO for effort-based fishery management

What should that federal action look like? A paradigm shift is urgently needed in how we approach fishery management, particularly in regard to harvesting. Barry Darby’s innovative proposal to start replacing the current quota system with one based on fishing effort, which may initially have seemed unrealistic, now appears to be gaining some traction among informed people fed up with the endless litany of mismanagement, buck-passing and denial that we see so much of in DFO. Harvesters, coastal communities and the fish stocks themselves would benefit in multiple ways from a transition to effort-based management, instead of the current slavish adherence to a quota-based approach that clearly doesn’t work. That transition is a key policy shift that the Province should be pushing the federal government to consider for implementation.

8. Improve professionalization and labour market policies

The Province should work with the federal government to update and improve the policies and procedures regarding the fishery workforce, in order to maximize the efficiency and sustainability of the sector. It is essential to ensure that all professional harvesters have the right to fish commercially, that only professional harvesters have that right, and that new entrants are trained and certified. Likewise, labour market policies must foster employment and self-employment in the fishery, and creatively address the challenges of labour shortages, seasonality, and an aging workforce. Specific measures towards these ends are proposed in Barry Darby’s “Changing Course – A New Direction for Canadian Fisheries“, cited above, and in“A Future for the Fishery – Crisis and Renewal in Canada’s Neglected Fishing Industry“, by Dr. Rick Williams (Nimbus Publishing, Halifax, 2019).

9. Aim to maximize net economic returns

The goal of our economic policy in regard to the fishery should be to maximize the net economic returns to the people of fishing communities, while ensuring sustainability both for the resource and for the sector itself. Assessing both provincial and federal policies and proposals through this lens will enable a multitude of direct economic and social benefits and spin-offs to accrue, as good ideas are developed and implemented and mistakes prevented.

10. Ensure full involvement of community people

The men and women of Newfoundland and Labrador – especially harvesters and their communities – must be directly involved in developing and implementing the necessary measures at all levels to restore the incredibly rich renewable resource that Canada took over from us decades ago, ensuring that its benefits flow to those who work and live from it. Their wisdom and experience are a resource whose value cannot be measured in dollar terms, but without it, economic recovery could not work.

Summary of recommendations for the Province:

  • Make the fishery a top priority for the province’s economic recovery. Strengthen the capacity and profile of this key sector by restoring it to full status under a Minister of Fisheries and Aquaculture. Reassert the provincial government’s role in maximizing the fishery’s economic and social benefits to our people.
  • Stop micro-managing the processing, marketing and farming of fish and other seafood. Facilitate construction and expansion of processing enterprises by removing unnecessary licensing barriers and allowing them to make their own business decisions. Stop obstructing direct fish sales by harvesters to consumers.
  • End public subsidies, investments and tax breaks for processing and aquaculture companies. Implement and enforce major restrictions on the transshipment of whole fish for processing elsewhere.
  • Maintain infrastructure and services for small coastal and indigenous communities to enable them to build prosperous futures with their own marine and human resources.
  • Provide technical and advisory support to encourage fishery co-operatives and community-based initiatives that enhance the value and viability of the sector. Develop policies to increase local utilization of our own seafood resources, enhancing NL’s food security.
  • Work across party lines to develop a united voice wherever possible for dialogue with the federal government on key fishery issues. Press the federal government to actively consider transitioning to effort-based fishery management (see www.barrydarby.com/the-proposal/)  
  • Work with the federal government to develop and implement optimum professionalization measures and labour market policies for the fishery. Prioritize the goal of maximizing net economic returns to the people of fishing communities and to the provincial economy, and apply this lens to both provincial and federal policies.
  • Ensure that the men and women of fishing communities are fully represented and listened to in fishery-related policy development at all levels, to maximize fairness, practicability and effectiveness.

Thank you for the opportunity to contribute to the important work of your Team.

Gaps and Assumptions in Fisheries Management

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By Helen Forsey

Photo by Erik Mclean on Unsplash.

The following letter by Changing Course‘s Helen Forsey was published in the February 2022, issue of The Navigator.

Dear Editor,

The Navigator managing editor’s overview of the Oceana Fishery Audit in the January issue was welcome and invites comment.

I agree with the Audit’s assessment that the Department of Fisheries and Oceans’ (DFO) management of our fisheries leaves much to be desired, and I support Oceana’s goal of improving it. However, I would challenge certain basic elements of its approach that reflect the same mistaken assumptions that DFO’s management itself is shaped by.

First, “rebuilding” fish stocks is a problematic concept. Computer models, targets and timelines do not make rebuilding happen, and putting them into a “plan” is just playing to our delusion that we are in control. We humans cannot rebuild nature, let alone plan it. What we can do is allow nature to rebuild itself, and support that process.

Part of that support will certainly involve applying both good fisheries science and Indigenous knowledge, and it will definitely require a genuine ecosystem approach. The ocean is not a farm and fish do not live in separate species-defined silos. Some o four problems come from treating them as if they do.

As part of our marine ecosystems, human harvesters play a role as apex predators, but large-scale industrial fishing has distorted that role into something that is too often destructive. If we focus our fishery policies on managing effort – the who, how, when and where of catching fish – then we can limit or eliminate those destructive practices and enable sustainable harvests.

Another problem with the current output-control approach (quota-based management) is the assumption that we can count or measure the amount of fish in the sea. But we can’t. All efforts to do so have massive margins of error in their results. The vulnerability of all marine life to climate change only magnifies these uncertainties, making computer models and targets based on past estimates even less applicable.

What we can and should measure is what gets caught, including bycatch, most of which occurs in the large-scale fisheries. Instead of trying to micro-manage the so-called “recreational” food fishery with its miniscule proportion of the harvest, we need to focus on countering the waste and damage done to our fisheries and our marine environment by big industrial players.

The gaps in Canada’s marine fisheries management might be reframed as the gap between a new approach based on ecosystem realities, Indigenous wisdom and effort controls, and the current computer-modelled, quota-based approach that has shown itself time and again to be destined to fail.

Helen Forsey

St. John’s, NL 

Gaps and Assumptions in Fisheries ManagementDownload

Echoes – Newfoundland Outport Fisheries and Indigenous Traditions

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By Barry Darby and Helen Forsey

Photo by Erik Mclean on Unsplash.

The abstract and conclusion below are excerpted from an article in an e-book on small-scale fisheries in Canada, published in 2022. You can read the article here.

Abstract: This article argues the need for a fundamental shift in fish harvesting policy and practice in order to build future sustainability for the marine environment and fisheries. The new paradigm must prioritize small-scale fishing, and be re-envisioned in accordance with the traditional understandings and approach of Indigenous peoples. It must incorporate and apply the local knowledge and methods proven in Indigenous communities and in Newfoundland and Labrador’s outport past.

The authors describe features and characteristics of both Indigenous and outport harvesting traditions, highlighting how both contrast with the present-day large-scale industrial approach to fishing. They note how, despite fundamental differences, outport and Indigenous traditions sometimes echo each other, and suggest that those echoes represent valuable insights.

Based on those insights, they urge a shift to a predominantly small-scale fishery that effectively recognizes human harvesters as part of the ecosystem. It should operate in a framework of respect and reciprocity with “all our relations” as Indigenous traditions teach, draw on the practical knowledge and harvesting methods that enabled a sustainable outport fishery in Newfoundland and Labrador’s past, and implement the lessons shared by both sets of traditions.

Conclusion: Large-scale industrial fishing is not only environmentally unsustainable, it is also inefficient in economic terms and counter-productive socially. Seeing a dragger arrive in Burin with 500,000 lbs of cod, Barry’s Uncle Frank commented: “Dere’s enough fish in ‘er to keep two or three families going for a year, but all the crew’s getting is two weeks’ wages.” Caught between a rock and a hard place, and “managed” by DFO, Newfoundland and Labrador’s inshore harvesters were steered into destructive compliance on the margins of the industrial model.

Like industrial agriculture, industrial fisheries are part of the toxic legacy of patriarchal Western renaissance ideas about controlling Nature. The very term “fisheries management” embodies this approach, which has been thoughtfully challenged at a fundamental level elsewhere. The ongoing depletion of marine life worldwide is the result, echoed by parallel disasters in forests and farmlands.

If we want a viable future for ourselves and all our relations, we must step off our current destructive path and choose a better way. There are signs that can be done. In Ardoch, Algonquins and their allies still harvest their rice from canoes and “dance” it to edible form. In Fogo and Petty Harbour, harvesters catch top-quality fish by handlining in gillnet-free zones. But it will take more than that.

Indigenous prophesies describe our era as that of the Seventh Fire, a time when humanity must choose what path we will take into the future. Setting the course for fisheries will be part of that choice, and for that, the wisdom and knowledge of traditional harvesters will be essential.

That knowledge is of two very different kinds. The local knowledge and traditional fishing methods of the non-Indigenous people of the outports, proven through several centuries of sustainable harvesting, can be relearned and adapted for continuing use. But it is the other vast knowledge system – the Indigenous understanding of the natural world and humans’ place within it – that must form the indispensable framework for applying the specific local and practical knowledge of both Indigenous and outport harvesters.

Hope lies in using the marks of our Indigenous and outport past to set a course based in respect and reciprocity, to navigate safely and to harvest honourably the stormy waters of the future, listening through the fog for the echoes that can tell us how.

Newfoundland Outport Fisheries and Indigenous TraditionsDownload

Photo by Erik Mclean on Unsplash.

Driving to Central – A Fisherie’s Analogy

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By Barry Darby

Photo by Erik Mclean on Unsplash.

Is it an impossible job that DFO is tasked with in setting harvesting quotas? That’s something I’ve claimed in arguing for a different system for managing ocean harvesting, but it’s time to examine that assertion further. What exactly is it that’s impossible?

The numbers in DFO’s stock assessments for 2J3KL cod over recent years show a large variance. Spawning stock biomass (SSB) values in 2018 were listed between 304 and 418 kilotonnes (kts), and in 2019 between 306 and 518 kts. Other key factors such as natural predation, food supply and the stock’s age composition lead to further variability in estimating what yield would be sustainable. Moreover, there is a broad range of opinion as to what percentage of SSB is the correct one for calculating a sustainable harvest.

Let’s take a look at a simple example of the practical mathematics of variance in a non-fishery context. Suppose you have to travel from the Burin area to Central Newfoundland next week, a distance of 400-500 kilometres. You’ll be travelling at 80 – 120 km/hour. How long will it take you to get there?

A little bit of math will show you that you might possibly make it in as little as 3 hours and 20 minutes, but it could take you as long as 6 hours and 15 minutes.

This analysis leads to three conclusions:

  1. There is no exact answer to the problem.
  2. There is a range of possible answers that can inform your planning.
  3. There are many answers outside that range that you know are wrong: e.g., You can’t do it in two hours, but it won’t take you ten.

Now let’s apply the same process to harvesting 2J3KL cod. Comparable cod fisheries in Iceland, Norway, and pre-moratorium Newfoundland and Labrador show that sustainable harvesting rates vary widely. A conservative estimate based on the known information would suggest that harvest rates of between 10 and 30% of SSB can be, and have been, sustainable.

We know we have an SSB of between 300 and 500 kts of Northern Cod in 2J3KL. A bit of math shows that an appropriate harvest from this stock could be as low as 30 kts (10% of the lower estimate) or as high as 150 kts (30% of the higher estimate.)

Again we can draw three conclusions:

  1. There is no exact answer to the problem of how much to harvest.
  2. There is a range of possible answers that can inform our planning.
  3. There are many answers outside that range that we know are wrong: e.g., We shouldn’t catch 200 kts, but 12 kts is way too low.

Quota-based management (QBM) fails and will continue to fail because it requires exact answers to the question of how much fish to harvest. No matter how complex the modeling, it is simply not possible to determine a correct Total Allowable Catch from which to allocate the resulting quotas. From the efforts to calculate the Bmsy (Maximum Sustainable Yield) in the 1970s, and the use of F0.1 in the ’80s, to DFO’s new “harvest decision rule” of 2020, no system will enable us to do the impossible.

Quota-based management will continue to disappoint, and worse. We will either overfish as we did in the 1960s, or underfish as we are doing now. With the current system, we are harvesting less than we sustainably could – and in fact should, to help keep stocks in balance with the carrying capacity of their habitats. DFO needs to stop trying to achieve the impossible and start implementing a better way.

Driving to Central – A Fisheries AnalogyDownload

DFO’s Magic Machine – Science into Practice

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By Helen Forsey (May 2021)

Photo by Erik Mclean on Unsplash.

“Everything we do is science-based.” That’s the standard response of the Department of Fisheries and Oceans to doubts or criticisms about how they manage our fisheries.

Well, my B.Sc. degree doesn’t make me a scientist, but I do have enough scientific background to know when science is being applied and when it is not. And a lot of what DFO does in fishery management falls into that latter category.

The Department’s website, news releases and interviews constantly reiterate their claim that all their policies, plans and regulations are determined by “the science.” Of course, calling it “the science” tends to give the impression that fisheries science is one big homogeneous entity with no uncertainties, no disconnects and no disagreements – which if course is nonsense. But even apart from that, their claim is suspect.

Yes, DFO employs highly qualified fishery scientists who do a lot of valid and important work in a complex and challenging field. Their competence and dedication is not in question. The problem is something else entirely – the linkage between the science and the practice. Understanding that linkage – what it is and what it should be – goes a long way toward explaining why crises persist with our fish stocks.

This problem is two-fold. First is the question of how the scientific work gets converted into the management policies that govern fish harvesting. The second is how those policies in turn determine what scientific work the Department will undertake or pay attention to.

On the first question, the process by which DFO translates its science into policy and practice is never explained or even really questioned. How do their scientific studies, stock assessments and computer models metamorphose into management policies, allowable catches, quotas and harvest plans?

Apparently we’re supposed to believe that “the science” translates flawlessly into sustainable practice simply because they say it does. Is there some mysterious mechanism that reliably produces coherent and practicable harvest plans out of the scientific raw material fed into it? I can picture DFO functionaries pouring “the science” into a big funnel, through which it passes into some kind of magical machine, and – Presto! – out the other end come the required fishery policies, regulations and harvest plans.

Now that obviously can’t be how it happens. There is no magic machine that translates “science” into management plans by some invisible process. Instead, it is the people in the management system – the DFO fishery managers – who do that translating. They receive the scientific information, and then analyze and interpret it using the lenses the system provides them with.

Like the imaginary machine, the actual process is also invisible, making it a challenge for critics to zero in on what is wrong. But a closer look shows that DFO’s translation of science into practice is based on and bounded by the assumptions inherent in the Department’s management system, which revolves around quotas.

As fishery policy analyst Barry Darby explains in his paper, Changing Course, quota-based management is a form of output control, setting total allowable catches and quotas for each stock. What’s wrong with that? It’s unworkable because it imposes a supposed “solution” – TACs and quotas – without first properly identifying and analyzing the problems it’s meant to solve. In other words, it puts the cart before the horse.

When you start from the assumption that only a quota system can prevent overfishing, all the science fed into the process is analyzed through that lens and translated on that basis. The only questions asked are how much fish is there, and how much we can harvest. This can lead to massive errors in policy.

For example, if “the science” reveals a scarcity of cod, DFO applies a policy of “keeping removals as low as possible” by reducing TACs and quotas. But if the scarcity is caused by starvation due to an insufficient food supply, keeping removals low is exactly the wrong thing to do. In fact, reducing the catch will leave more fish competing for the limited food available, leading to an increase in natural mortality and perhaps in total mortality. The result – as we have been seeing in 2J3KL – is continuing stagnation of stock biomass and poor condition of the fish.

What would help in that case is the opposite policy: to relieve the pressure on the stock by increasing the catch, using selective harvest methods to target the middle-sized fish so as to allow the older, larger, fecund fish to thrive, reproduce prolifically and actually grow the stock.

The second issue is closely related. Not only does science influence policy, but the policies chosen also effectively determine what science will be done. When DFO’s overarching policy is focused on controlling the amount of fish caught, the Department will naturally develop and support the types of scientific study and analysis that help them do that. Unfortunately, that policy marginalizes other types of research which are deemed irrelevant to the quota-oriented framework.

The linkage between science and policy is not a one-way flow; it must incorporate the feedback loops that good management and good science provide. Stock assessments and data collection are only part of a whole range of reality-based scientific work. Science for sustainability needs to go well beyond the kind of quantitative material that shapes computer models and reference points; it must prioritize exploratory studies and innovative research and analysis that can inform more workable and sustainable policies.

Freed from the constraints of a policy framework that sees allowable catches and quotas as the only way to achieve sustainability, fisheries scientists could explore a full range of potential causes of a problem like decreasing stock biomass or poor condition of individual fish. The resulting scientific findings could then be used to adjust policies, regulations and harvest plans, which when implemented by harvesters would in turn provide feedback and information for corrections and improvements, and provide the basis for follow-up and related science.

That is the kind of fishery governance we need – a system based on the recognition that ends and means cannot be separated. If our fundamental goal is a sustainable marine environment and a sustainable fishery, then regulating the “whos, hows, whens and wheres” of fishing effort is far more relevant than calculating computer-modeled reference points in order to predetermine allowable harvest numbers.

In the fishery, the means largely determine what the ends will be. Our current system of quota-based management imposes a narrow definition of fishery science – one that limits our ability to see and understand what is really going on in the ocean and what we can do about it. That same quota-based system also demands a narrowing down of goals to fit numerical structures and targets – arbitrary measures of success which have in fact led to decades of failure.

But we can change this. Instead of pretending that “the science” is all-inclusive and that it automatically leads to sustainable fishery management, let’s recognize that there is no magic machine. Let’s push for a policy framework that supports and uses the whole range of relevant science. Then we will be able to develop and refine practical policies and harvest plans that respect the dynamic nature of the marine ecosystem, and honour our role as human predators in keeping it truly sustainable.

DFO’s Magic MachineDownload

PERT Fails the Fishing Sector

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By Barry Darby and Helen Forsey (June 2021)

Photo by Jeff Smith on Unsplash.

Changing Course

The small Fishery section of “The Big Reset” is profoundly disappointing. It presents a biased and superficial picture of the sector, implicitly belittling the importance of the fishery to our province’s economy and society. Of the 300-plus page PERT report, the wild fishery occupies a scant seven pages, with just two recommendations out of the total of 78 (five out of 179 if you count sub-recommendations.)

The report demonstrates a vast ignorance of and indifference to the fishery. Despite the wealth of information and ideas easily available in the public domain, the Team did not do its homework. The report’s 82-page Bibliography contains references from various organizations involved in oil and gas, hydro, and mining, but cites almost no fishery-related sources: there is nothing from the Marine Institute, the Association of Seafood Producers, the Fish Food and Allied Workers (FFAW), the Canadian Council of Professional Fish Harvesters (CCPFH), or even the federal Department of Fisheries and Oceans (DFO), which governs our entire fishery. Not surprisingly, then, the authors show almost no understanding of the realities of our fishery or its context – for example, the considerable difference between the economics of a processing plant and the economics (bioeconomics) of ocean harvesting.

The pro-corporate, pro-industrial, “bigger is better” bias that permeates the whole report is clearly predominant in the fishery segment. As a framework, it presents two contrasting “visions” for the future of the fishery – “a highly capitalized industrial approach with higher incomes for fewer participants,” versus “a more traditional lower capitalized industry with more plants and more seasonal work supported by EI.” This is a false dichotomy – one of those simplistic set-ups that misrepresent complex issues as either/or choices, thereby excluding from the discussion the rich diversity of possible alternatives. The authors are then able to disparage one view (in this case, the “traditional” one), leaving the other as supposedly the only option – one that fits beautifully with the PERT’s overall approach.

The report disparages the way the Employment Insurance system operates and its effect on harvesting. The relevance of this criticism at the provincial level is questionable, since EI is a federal system and harvesting policy is a federal responsibility. But in any case, fish harvesting, like tourism and agriculture, is subject to seasonal limitations, not only in NL but across the country. So of course workers will turn to EI; that’s what it’s there for.


Moreover, where EI impacts NL’s fish processing sector (provincial jurisdiction), the short employment periods result directly from DFO’s establishment of particular harvesting seasons for each species and the province’s refusal to permit multispecies processing by all fish plants. But the report does not reflect the distinctions among jurisdictions or the structural problems that arise from them.

It is unreasonable, to say the least, to imply that we should change our fishery so that EI would not be part of it. It’s not as if there aren’t sensible and informed proposals out there about what could be done to meet these challenges. Rick Williams’s book, “A Future for the Fishery – Crisis and Renewal in Canada’s Neglected Fishing Industry” (Nimbus, 2019), addresses the EI question specifically and in detail, together with an in-depth analysis of the labour market issues in the Atlantic Canadian fishery. But Williams’ book, like other pertinent sources, is not listed in PERT’s Bibliography.

Two of the five recommendations in the report’s fishery segment – rebuilding NL’s fisheries for future generations and taking the lead in research and management – fall into the motherhood category, and mainly in federal jurisdiction. Two other recommendations are mutually contradictory: one calls for increased fish processing, while the other recommends that no new processing licenses be issued.

The remaining recommendation, for equal custodianship of our marine resources with the federal government, was a rallying cry in the 1990s, but has since been largely abandoned as constitutionally unrealistic. Nonetheless, the point is well taken – the Province must indeed strengthen its voice on fisheries issues, push the federal government to listen, and demand that our experience and advice carry their due weight in DFO’s decisions.

Beyond those five, however, the report’s recommendations on the fishery are most noticeable by their absence. The authors make no recommendations at all on what appear to be some of their key points. For example, they criticize the current harvester-processor collective bargaining model, calling it “anti-competitive by nature” and claiming it ignores quality and other market considerations and can be disadvantageous to plant workers. They applaud transferable quotas and market-driven supply chains, and refer to fish auctions, yet they do not recommend anything. It would have been helpful if they had proposed more balanced and workable collective bargaining mechanisms (such as the single-desk selling used successfully in some agricultural sectors) instead of, in effect, condemning collective bargaining itself and leaving it to government to replace it with something unknown.

The report refers to better fishery management in Iceland and Norway, but again makes no recommendations. This despite the fact that Gus Etchegary of the Fishery Community Alliance met with Dame Moya and attempted to convey to her and her team the clear and feasible recommendations the group has been making publicly for months if not years. Notably, last October, they wrote to Premier Furey urging that a delegation of Newfoundlanders and Labradorians with in-depth fishery expertise visit Norway and Iceland to explore the problems with the North Atlantic fishery, discuss how they do things there, and come back to advise our governments. Surely PERT could have recommended that?

The recommendation to reinstate the threshold requirements for processing licenses is particularly baffling. “The Big Reset” is very big on privatization of government assets and activities. Fish processing is already a private sector domain, yet the report is urging the government to reassert its involvement in this business, right down to defining who can process what species, where a plant can be built, and a host of other requirements laid out in the provincial Fish Processing Licensing Act.

There are also some clear distortions of the facts. In regard to northern cod, the report states that “spawning stock biomass has dramatically declined and current values do not [reach] the minimum needed to support a commercial fishery.” However, figures for the past several years show a relatively stable estimated 400,000-tonne biomass, while annual removals barely exceed 2%. In the past we sustainably harvested 20-40% annually, and that is still the case in similar stocks in Iceland and Norway. It is obviously ridiculous to suggest that our current 2% represents overfishing.

Elsewhere, the authors confuse correlation with causality, stating that higher landed prices for snow crab were the result of “collaborative behaviour” between harvesters and processors, when it was simply that the world price went up. In regard to the labour supply, they suggest that efforts to increase employment opportunities by favouring the labour-intensive inshore fleet represents a contradiction with the use of temporary foreign workers in fish plants. But harvesting and processing are two very different labour markets, and there is no contradiction involved.

The report’s authors are critical of DFO’s recent prohibition of controlling agreements between harvesters and processors. They claim this inhibits vertical integration, and “removes any mechanism for processors to maintain security of supply,” without which, they say, the processors have trouble accessing capital. This may be another case of conflating correlation with causality, but if that’s a problem in this time of very low interest rates and excess capital, surely it’s not up to the government to solve it. And harvesters should not have to submit to outside control in order to access operating capital.

In conclusion, the fishery segment of the report starts from a series of faulty assumptions, proceeds without reviewing a diverse range of sources or checking its facts, imposes its pro-private sector leanings and ignores alternative analyses. Shallow and biased, this report leaves the government, the fishery and the public worse off than before.

PERT Fails the Fishing SectorDownload