Thank you, Mr. Chair.
My name is Dr. Charlotte Whitney, and as you said, I'm here as the fisheries management and science program director for the Central Coast Indigenous Resource Alliance, or CCIRA. Previous to this role, I did work with the Pacific Salmon Foundation.
I am calling in today from the unceded and traditional territory of the Nuxalk Nation in Bella Coola, British Columbia. I am joined today by Dr. Alejandro Frid, CCIRA's science coordinator.
Our testimony today pertains to some of our experiences with DFO, an organization that uses and develops science to inform decision-making for managing fisheries and aquatic ecosystems.
DFO can do excellent science. Further, the Canadian science advisory secretariat, or CSAS, process can allow DFO to inform management with the best available science and to be precautionary to future uncertainties related to climate change.
However, there are often disconnects between science advice and management decisions, and between stated policies and what occurs in practice. Where these disconnects occur, they have led to management decisions that maintain a status quo rather than applying the best available science. We've seen these disconnects manifest in several cases, including the northern shelf bioregion MPA network and fisheries for salmon, herring, rockfish and Dungeness crab, undermining precautionary fisheries management.
In the interest of time, I will give just one recent example focusing on assessment and allowable catch for Bocaccio, a Pacific rockfish, and we will conclude with our observations of DFO's consideration of indigenous knowledge.
The Bocaccio case study speaks directly to two themes that we understand this committee is interested in. One is inclusiveness in the CSAS process, and two is the handling of uncertainties and the precautionary principle in management decisions.
Bocaccio was recommended for endangered listing in 2013 by COSEWIC, an independent advisory panel specific to the federal government. As of 2019, Bocaccio had declined by 97% relative to their historical abundance, well into DFO's critical zone. Accordingly, the total allowable catch for this bycatch species was set fairly low at 75 tonnes. However, an unusually large single recruitment event occurred in 2016, 44 times greater than the long-term average.
Given this and the fact that Bocaccio is a choke species, i.e., not targeted but limiting to fisheries with bycatch restrictions, further surveys were prioritized and an updated assessment was produced in 2022, this year. Largely reflecting that large recruitment event, the abundance of Bocaccio was projected to increase well into the healthy zone for the start of this fishing season. In response, DFO managers increased the total allowable catch 24 times over just two years from that 75 tonnes to over 1,800 tonnes.
For a species estimated to have dropped to 3% of its original abundance only two years prior, this is analogous to shifting an entire investment portfolio based on a few good days of the stock market when there are clear signs of a broader economic depression. This increase of the total allowable catch is inconsistent with the precautionary principle. We do not know whether large recruitment events can lead to long-term stock productivity, particularly under rapidly changing ocean conditions due to climate change, which is the biological equivalent of that broader economic depression.
This 24-fold increase in catch was based on a CSAS document categorized as a “science response”, which allows for a non-inclusive group of participants and peer reviewers, in this case just DFO staff and two commercial fishing representatives. The science response process exempts the requirement for participation from independent scientists and first nations, including those working on a species at risk.
Given Bocaccio's recent history of collapse and the implication for target fisheries, this was not illegal but certainly not in line with the principles of transparency or openness.
Finally, given that many targeted and bycatch stocks have outdated assessments or no assessment at all, this case study also raises questions as to how DFO prioritizes stock assessment.
Next I will comment on our experience of how DFO treats indigenous knowledge. Despite numerous DFO policies claiming to consider and incorporate indigenous knowledge and decision-making, for Pacific Canada we are unaware of cases in which DFO deemed indigenous knowledge worthy of triggering an early issue identification to be addressed by CSAS. This is despite first nations and specifically the central coast nations we work for having reported numerous declines in species that are critical to culture, food security and health.
For example, central coast first nations first expressed concerns to DFO about declining Dungeness crab catch rates in 2007, with great impact on food security and cultural practice. It took 10 years of engagement and nation-led western science before DFO managers showed an appropriate response to that concern.
Currently, central coast first nations have been experiencing a similar lack of response to their concerns about the precipitous decline in Pacific salmon, despite investing in nation-led western science. DFO has still failed to consider their consistent direction to limit commercial and recreational fisheries in the face of that decline.
To conclude, I offer the following recommendations for DFO to improve its application of science advice and to consistently apply its own policies and principles.
One, do not compromise inclusiveness in the CSAS process in order to rush either stock assessments or management decisions.
Two, thoroughly engage DFO’s excellent scientists in addressing climate uncertainties in stock assessments, as well as broader questions about ecosystem-based management, in order to advance beyond the current institutional inertia.
Three, abandon tokenisms about the application of indigenous knowledge. Indigenous knowledge often has longer baselines and superior understanding of local ecosystems than western science does and, therefore, should be treated as the valid knowledge system that it is. To do so, DFO should work with first nations to develop a culturally appropriate way to use indigenous knowledge in management, such as to trigger early warning signs about the health of marine species and ecosystems.
Finally, honour and respect existing fisheries and oceans management co-governance agreements and implement those processes wholeheartedly that are inclusive of indigenous knowledge, ecosystem needs and precautionary thresholds.
Thank you, Mr. Chair.