(November 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.)


Canadian Seal Hunt and Ecosystem-based Fisheries Management

Brief submitted to the Standing Committee on Fisheries and Oceans

November 9, 2006

By Debbie MacKenzie, chair
Grey Seal Conservation Society (GCSC)
Nova Scotia, Canada
email: debbie@greyseal.net or codmother2@aol.com

 Three 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.

    There 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.

    Scientists 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.

    As 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 starving.

    Predators 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.

    DFO 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 managers?

    Must 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?

    Ecologists 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.

    l 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 breakdown continues.

Our recommendations are as follows...

    This 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.

    Direct 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.

    Direct 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.

    Create 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.

    Stop 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.


See also:

Standing Committiee on Fisheries and Oceans - Evidence, November 09, 2006

Sealers complain to committee

HANSARD - Grey Seal Conservation Society(GSCS) and the committee on Natural Resources...