Thank you, Mr. Chair.
The BC Seafood Alliance is an umbrella organization whose 30 members represent fisheries accounting for about 90% of the value of wild seafood from Canada's Pacific coast.
This study is one of the most important the committee has undertaken, and I want to give you my perspective on what works and what does not.
First, the CSAS process can and should be improved, but it provides a critical peer-review process for science advice to fisheries management. It incorporates new knowledge, data and updated stock assessment analyses consistent with the precautionary approach and accepted principles and standards of fisheries sustainability.
Second, DFO science in support of fish harvest management has long been starved of resources.
Third, when ministers ignore the science in favour of their own views, we are on dangerous ground.
The current process for peer-reviewed science advice is fundamental. It starts with a request for science advice, usually from fish management. CSAS identifies the lead scientists who will develop a response and pull together available data and research. A working group then assists the lead scientists in their review of the data, the validity of assumptions, and the development of assessment models. A draft research paper or assessment is produced for peer review by DFO scientists, academics, professional fisheries analysts and other interested parties. Independent peer review is provided by three expert reviewers, two external to DFO. Revisions may be recommended and provided for further review. The advice is then provided as a science advisory report to fisheries management, where it will be considered, along with social, cultural, economic and operational information, in the development of sustainable harvest advice.
The CSAS process provides a sound foundation, but would benefit from improvements to standardized procedures and the provision of formal reviewers. Other international jurisdictions compensate external reviewers so they can reliably obtain the services of subject matter experts, who are key to the integrity of the system. You get what you pay for. In our experience, qualified industry experts have an essential role to play. Not for someone like me, but our members and professional analysts bring an understanding of fisheries and survey data, assessment methodologies, evaluation, and the management context that scientists may not have. My members believe that good science is critical for fisheries sustainability and, therefore, invest in fisheries science and monitoring to the tune of almost $10 million annually. That's for groundfish and shellfish alone. Independent peer review of fisheries science, in support of management via CSAS, needs shoring up and strengthening, not tearing down.
Generally, resources for fisheries science have not grown with the demand for harvest advice. The Species at Risk Act, the sustainable fisheries framework, the fish stock provisions, and external demands for recognition of sustainability and good management—such as marine stewardship certification—put a huge burden on a very small number of highly qualified personnel on this coast. For example, our groundfish fishery has fully integrated over more than 60 different stocks, some of which have never had a stock assessment. Others have not had one for more than 30 years.
DFO has the resources to do only about two domestic west coast groundfish assessments a year, even when supported by professional analysts. In the absence of timely stock assessments, TACs may be more precautionary than necessary, meaning benefits to Canadians are constrained.
Lastly, I must mention the minister's December 2021 decision on Pacific herring, including cutting the TAC for Strait of Georgia herring in half. Pacific herring stocks have excellent long-term datasets and a thoroughly reviewed assessment and management approach. Herring stocks are surveyed and assessed annually, and there are no other valid estimates of their status. In particular, the Strait of Georgia herring population is estimated to be in the healthy zone, and has been above the limit reference point for decades. A harvest control rule is in place, which will reduce catches and cease commercial activity before the stock declines to a critical level. An arbitrary 50% cut by the minister ignores this information and discredits the work of DFO science and the CSAS process.
I hope the committee's recommendations will include providing resources to reinforce stock assessment, ensuring scientific peer review by an improved CSAS, improving effective monitoring and enforcement, and reducing political interference. These changes are important to fisheries on the west coast.