9, 2006 - I appeared as a witness before the Canadian House
of Commons Standing Committee on Fisheries and Oceans. Below
is the text of my verbal presentation and written brief submitted
to the committee. After receiving this information, the Members
of Parliament did not ask me one question regarding the two
objections I had raised to the seal hunt: (1) significant food
web damage has already been sustained as a result of ocean predator
removal and seals should therefore be protected because of their
valuable role as natural predators, and (2) processing seals
using only "fish inspection" protocols risks passing
mammalian bacterial diseases from seals to human consumers.)
Seal Hunt and Ecosystem-based Fisheries Management
submitted to the Standing Committee on Fisheries and Oceans
Debbie MacKenzie, chair
Grey Seal Conservation Society (GCSC)
Nova Scotia, Canada
years ago, l explained to this committee that starvation is
the major factor preventing the recovery of the cod stocks and
that this has resulted from a decline in plankton. Unless fisheries
managers begin to consider the health of the ocean overall,
we stand to see a total collapse of everything. Three years
ago, my comments to this effect were not included in your report
on Atlantic fisheries issues.
is one reason why ecosystem-based fisheries management is not
now used in Canada. It is not because we lack scientific understanding
of what must be done; it is rather because fisheries managers,
including the seal hunt managers, simply refuse to acknowledge
that this information exists and that it pertains to their work.
Objective-based fisheries management, as described, is not ecosystem-based
fisheries management unless the objectives are ecosystem conservation
objectives. There's a difference. That single-species approach,
when you count the seals and try to keep them above 70% of the
maximum, is not ecosystem-based.
now realize that fishing has undermined the fundamental workings
of sea life, altering the entire web from top to bottom. The
problems we now see in Atlantic Canada--the starvation of cod,
the decline of numerous other species, including everything
from shark to herring to barnacles and seaweed, along with a
general degradation of ocean water quality--are manifestations
of the ecological end result of centuries of human fishing.
grim as that sounds, this conclusion is well supported by the
scientific literature. The removal of virtually all large predatory
animals from the sea is now acknowledged as a major cause of
the current collapse of the ecosystem. That is why Canada should
place a moratorium on commercial seal hunting, because seals
are the last surviving large ocean predators in Atlantic Canada.
As such, their presence is needed. Large natural predators are
needed, because the ocean is dying and because the fish are
play an important role in cycling nutrients and in maintaining
the health of fish. The tonnage and types of fish eaten by seals
is beside the point. That question is like asking, how much
blood is cycled through a person's lungs? Fish removed by humans
is like blood drawn from a vein, while fish eaten by natural
predators is like blood following its normal course, a crucial
process that must continue for the survival of the larger entity,
in this case the ocean.
ecologists have used the word “catastrophic” to describe ecological
changes that have been caused by large predator removal on the
Scotian Shelf. Consider, too, that the ecological impact of
marine mammals was recently analyzed by other DFO scientists,
including Mike Hammill. The conclusion of the study was that
the beneficial predation effect is even greater than the predation
itself, leading to an overall positive impact of the predator
on the system. Why are these facts not considered by seal hunt
the ocean exhibit signs and symptoms beyond catastrophic before
fisheries managers take notice that all is not well, and before
they take the necessary steps to protect ocean health? New ecological
insights are ignored by fisheries managers, who control what
scientists are allowed to tell them during their science advisory
process. It seems that fisheries managers must not be told certain
things that the fishing industry does not want to hear. Why
do taxpayers fund ecological studies that are then ignored by
our public resource managers?
are excluded from fisheries management consultations, and if
anyone else tries to enter their findings into the record—as
l did at DFO's Seal Forum last November—then the information
is still ignored. When l tried to include DFO's own ecosystem
science in the 2005 Seal Forum, my written submission was lost
and it was omitted from the record. Despite being asked repeatedly,
DFO management refused to correct their error.
have tried for years to warn the government about the ecological
damage caused by fishing. l have suggested, since 1999, that
a decline in plankton production has been caused by fishing,
and l have asked that plankton ecology become a focus of DFO
science research. Two years ago, l warned of an impending crash
of the herring stocks, and today that seems to be happening
in the Maritimes. Crustacean stocks are showing signs of starvation
too, and these fisheries will also be doomed if the ecological
recommendations are as follows...
committee should undertake a study of the issues affecting ocean
health, because oceans are your mandate too, with particular
attention to the ecological impact of fishing. In this regard,
I'll leave you with a selection of relevant documents that I
ask you to review.
the seal hunt managers to include a full and open discussion
with ocean ecologists before approving any seal hunt plan. As
it stands now, DFO does not even have a seal management plan,
although one was supposed to have been produced by last spring.
DFO Science to provide a comprehensive report on the full scope
of what scientists have learned about the ecological impact
of fishing. Make it clear that this information is to be considered
by fisheries managers.
a new body, like a minister’s advisory council on oceans. A
previous entity by that name provided only broad policy advice,
but a new advisory council on oceans should have the mandate
to advise the government on the practical implementation of
ocean conservation. This must not be controlled by fishing interests.
the seal hunt under the Oceans Act, for ecological reasons already
given. This will be preferable to stopping the seal hunt after
Canadian seal marketing causes an international food safety
incident. In this regard, I recommend that you consult with
veterinarians on the wisdom of processing seals for human consumption
using only fish inspection protocols, as is the current practice.
Marketing seals as if they were fish instead of meat is dishonest,
it potentially threatens the health of consumers, and it may
thereby ultimately damage the good reputation of Canada's legitimate
fish and meat exporting industries.