Pacific Wild’s Recommendations for the Pacific Herring IFMP

Pacific Wild is submitting the following as per the request for input pertaining to the 2021/2022 Integrated Fishery Management Plan for Pacific herring.

Cover Photo by Kali Wexler

Pacific Wild recommends the following amendments to the 2021/2022 Pacific herring IFMP and in consideration for future management plans:

  1. Move towards Ecosystem-Based Management (EBM)
    The new Sustainable Fisheries Framework is outlined in the IFMP and includes policies for adopting EBM approaches. This is a step in the right direction. As a community with a shared objective (to ensure biodiversity and healthy oceans for future generations) we must not dig a deeper hole by allowing commercial fishing to proceed as usual while surrounding stocks remain depleted. While we speculate, we still do not fully understand Pacific herring’s value as a foundational species in the marine ecosystem and its correlation to the endangered status of Chinook salmon and Southern Resident Killer Whales. EBM allows for a holistic analysis of the herring fishery in relation to the ecosystem, rather than simply at a species level.

  2. Identify migratory and resident herring populations in the IFMP
    The spatial distribution of herring stocks is still not recognized in the Pacific herring management plan. The IFMP assigns stocks to the area in which they are fished – however, there is sufficient evidence to suggest that many regions are home to both local and migratory populations of herring. As such, they cannot be managed as the same unit. The commercial fishery has been known to open prior to the arrival of migratory stocks, depleting the local and extremely vulnerable populations. This crucial information has remained under-researched and unmentioned in management plans. DFO should be aware that management mitigations must be prepared for both migratory and non-migratory populations of herring. We encourage DFO to review the work of the Juanes lab at the University of Victoria, in particular the work investigating the ecosystem impacts of migratory herring on Chinook salmon by Jessica Qualley and Wesley Greentree.

  3. Conduct catch-per-unit-effort analysis that is publicly available
    In fisheries biology, the catch-per-unit-effort (CPUE) is an indirect measure of the abundance of a target species. Changes in the CPUE are used to signify changes to the target species’ true abundance. If effort in the Pacific herring fishery remains stagnant while the catch is decreasing, this would demonstrate a collapse in the stock and should be publicly shared.

    There has been very little change in the number of licenses distributed, number of vessels, and fishing effort in the commercial herring fishery while the stocks move closer to collapse. Additionally, the number of licenses issued has not decreased while the quota has continued to decrease. Last year, the commercial landings of Pacific herring totaled nearly 16,000 tons, not even fulfilling the 18,001 ton quota that was set in the 2020/2021 IFMP. This suggests that despite the fishing effort, there were insufficient amounts of fish to fulfill the quota.

  4. Outline a more consistent plan to integrate TEK into management
    The 2021/2022 herring IFMP mentions the need to integrate Traditional Ecological Knowledge (TEK) and Indigneous Knowledge (IK) into DFO management plans. Consulting with First Nations is a necessary step in Fisheries Reconciliation and ensuring access to fishing rights. Having this mentioned in the IFMP is promising, however, direct action and steps in accomplishing this integration should be outlined and incorporated into the IFMP.

  5. Prioritize SOK fisheries over other harvesting methods
    A point of concern in the continued opening of commercial fisheries in the Strait of Georgia is that while seiners and gillnetters are still allowed to operate, Spawn-on-Kelp (SOK) operations are not. SOK fisheries are a sustainable method of harvesting and should not be suffering while gillnetters and seiners continue to profit. Additionally, SOK fisheries are not yielding sufficient herring eggs in the population collapse. The fact that this sustainable fishery cannot yield enough catch should be evidence enough that the remaining gear methods should not be in operation.