Gaps between Policy and Practice in DFO’s Scientific Approach

Bocaccio rockfish image courtesy of the Monterey Bay Aquarium.

In April 2022, CCIRA representatives were invited to present feedback to the Parliamentary Standing Committee on Fisheries and Oceans on the use and application of science in the Department of Fisheries and Oceans (DFO).

Fisheries Program Director Charlotte Whitney, Science Coordinator Alejandro Frid and Applied Quantitative Biologist Kyle Wilson worked together to prepare a written statement (see below), reflecting on our experiences with specific examples on the effectiveness of the scientific process within DFO.

The experience proved to be a telling report card on DFO’s science integrity. The overarching take home message, across all witness statements, was that DFO can do good science, and has the policies, capacity and expertise to implement sound scientific advice which could inform management actions. However, the resounding message across all witnesses to this session of the Standing Committee – including representatives from the Pacific Salmon Foundation, Watershed Watch Salmon Society, BC Wildlife Federation and the Fraser Salmon Management Council – was the disconnect between policy and practice, and the implementation gap between science and management which has had dire consequences for fish, ecosystems, and people.

See below for a series of excerpts from this testimony to the Fisheries and Oceans Standing Committee on April 26 and 28, 2022.

The following is CCIRA’s written statement to the Standing Committee. To watch the full meeting, click here.

Written Statement: Standing Committee on Fisheries and Oceans
My name is Dr. Charlotte Whitney. I am here as the Fisheries Management and Science Program Director for the Central Coast Indigenous Resource Alliance, or CCIRA. Previous to this role, I worked with the Pacific Salmon Foundation. I am calling in today from the unceded and traditional territory of the Nuxalk Nation, or Bella Coola, British Columbia. I am joined by Dr. Alejandro Frid, CCIRA’s Science Coordinator.

Our testimony 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 (CSAS) process can allow DFO to inform management with the best-available science and be precautionary to future uncertainties related to climate change. However, there often are disconnects between science advice and management decisions, and between stated policies and what occurs in practice.

When 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 process, and fisheries for salmon, rockfishes, and Dungeness crab, undermining precautionary fisheries management.

In the interest of time, we 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.

Bocaccio
The Bocaccio case speaks directly to 2 themes we understand this committee is examining: (1) inclusiveness in the CSAS process and (2) 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 to the federal government. As of 2019, bocaccio had declined by 97% relative to their historical abundance, well into DFO’s critical zone¹. Accordingly, the total allowable catch for this bycatch species was set fairly low, at 75 tons. However, an unusually large single recruitment event occurred in 2016—44 times greater than the long-term average.

Given this recruitment event and the fact that bocaccio is a “choke species” (not targeted but limiting to fisheries with bycatch restrictions), further surveys were prioritized and an updated assessment was produced in 2022². Largely reflecting that 2016 recruitment event, the abundance of bocaccio was projected to increase into the “healthy zone” for the start of the 2022 fishing season.

In response, DFO groundfish managers increased the total allowable catch 24-fold over just two years, from 75 tons to 1800 tons³. For a species estimated to have dropped to 3% of its original abundance only 2 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 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 total allowable 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 requirements for participation from First Nations and non-DFO scientists, including those working on Species at Risk with Environment Canada. Given bocaccio’s history of recent collapse and the implications for target fisheries, this was not illegal, but clearly not in line with principles of transparency and openness.

Finally, given that many targeted and bycatch stocks have outdated assessments or no assessment at all, the bocaccio case study also raises questions as to how DFO prioritizes stock assessment.

Indigenous knowledge
Next, I will comment on our experience of how DFO treats Indigenous knowledge. Despite numerous DFO policies claiming to consider and incorporate Indigenous knowledge in 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 First Nations we work for, having reported numerous declines in species that are critical to culture, food security, and health (Frid et al. 2016; Ban et al. 2017, 2018; Eckert et al. 2017; McGreer & Frid 2017; Steel et al. 2021, Atlas et al. 2021).

For example, Central Coast First Nations first expressed concerns to DFO about declining Dungeness crab catch rates in 2007, with great impact to food security and cultural practices. It took 10 years of engagement and Nation-led Western science before DFO managers showed an appropriate response to that concern. Central Coast First Nations have experienced a similar lack of response to their concerns about the precipitous decline in Pacific salmon, despite investing in Nation-led Western science, and DFO has still failed to consider their consistent direction to limit commercial and recreational fisheries in the face of that decline.

Concluding remark
I will conclude by offering the following recommendations for DFO to improve its application of science advice and consistently apply its own policies and principles:

• Do not compromise inclusiveness in the CSAS process in order to rush stock assessments or management decisions.
• Thoroughly engage DFO’s excellent scientists in addressing climate uncertainties in stock assessments and broader questions about ecosystem-based management, in order to advance beyond the current institutional inertia.
• Abandon tokenisms about the application of Indigenous knowledge. Indigenous knowledge often has longer baselines and superior understanding of local ecosystems than Western science, and therefore should be treated as the valid knowledge system that it is (Ban et al. 2018; Berkes 2018; Reid et al. 2021). 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, honor and respect existing fisheries and oceans management co-governance agreements and implement those processes wholeheartedly, being inclusive of Indigenous knowledge, ecosystem needs, and precautionary thresholds.

¹ DFO. (2020). Bocaccio (Sebastes paucispinis) stock assessment for British Columbia in 2019, including guidance for rebuilding plans. Can. Sci. Advis. Sec. Sci. Advis. Rep, 2020/025.
² DFO. 2022. Update of the 2019 Bocaccio (Sebastes paucispinis) stock assessment for British Columbia in 2021. DFO Can. Sci. Advis. Sec. Sci. Resp. 2022/001.
³ Pacific Region Integrated Fisheries Management Plan Groundfish, Effective February 21, 2022, Version 1.0.

References
Ban, N.C., Eckert, L., McGreer, M. & Frid, A. (2017). Indigenous knowledge as data for modern fishery management: a case study of Dungeness crab in Pacific Canada. Ecosyst. Heal. Sustain., 3, 1379887.
Ban, N.C., Frid, A., Reid, M., Edgar, B., Shaw, D. & Siwallace, P. (2018). Incorporate Indigenous perspectives for impactful research and effective management. Nat. Ecol. Evol., 2, 1680–1683.
Eckert, L.E., Ban, N.C., Frid, A. & Mcgreer, M. (2017). Diving back in time: Extending historical baselines for yelloweye rockfish with Indigenous knowledge. Aquat. Conserv. Mar. Freshw. Ecosyst.
Frid, A., McGreer, M. & Stevenson, A. (2016). Rapid recovery of Dungeness crab within spatial fishery closures declared under indigenous law in British Columbia. Glob. Ecol. Conserv., 6, 48–57.
McGreer, M. & Frid, A. (2017). Declining size and age of rockfishes (Sebastes spp.) inherent to Indigenous cultures of Pacific Canada. Ocean Coast. Manag., 145, 14–20.
Steel, J.R., Atlas, W.I., Ban, N.C., Wilson, K., Wilson, J., Housty, W.G., 2021. Understanding barriers, access, and management of marine mixed-stock fisheries in an era of reconciliation: Indigenous-led salmon monitoring in British Columbia. FACETS 6, 592–613. https://doi.org/10.1139/facets-2020-0080
Atlas, W.I., Ban, N.C., Moore, J.W., Tuohy, A.M., Greening, S., Reid, A.J., Morven, N., White, E., Housty, W.G., Housty, J.A., Service, C.N., Greba, L., Harrison, S., Sharpe, C., Butts, K.I.R., Shepert, W.M., Sweeney-Bergen, E., Macintyre, D., Sloat, M.R., Connors, K., 2021. Indigenous Systems of Management for Culturally and Ecologically Resilient Pacific Salmon (Oncorhynchus spp.) Fisheries. Bioscience 71, 186–204. https://doi.org/10.1093/biosci/biaa144