David W. Ellis
3872 Point Grey Road
Vancouver, B.C.
V6R 1B4 604-222-8394 davidellis@lightspeed.ca

April 30, 2009
The Honourable Stephen Harper
Prime Minister of Canada
Office of the Prime Minister
80 Wellington Street
Ottawa, K1A 0A2
President Barack Obama
President of the United States of America
The White House
1600 Pennsylvania Avenue
Washington, DC, 20500
Dear Mr. Prime Minister and Mr. President:
The selective removal of the older female herring over the years, and the “serial overfishing” of the poorly understood stocks, has brought the herring fishery, the First Nations and Tribes, and the entire marine ecosystem, to a crisis point. The situation is the same in British Columbia, California and Alaska. If the fishery continues, recovery is impossible, as the older and more fecund fishes, will yet again be removed.
This fishery is simply not a sustainable activity. The 20% harvest concept has proved irrelevant, not only because the local effects of overfishing on local First Nation and Tribal harvesting clearly show that the “metastock” concept is biologically unsupportable, but also because roe herring fishing selectively removes the older female fish at a higher rate. It contradicts rational and sensible fisheries management practice, and the high value gained from selling the roe in Japan can not legitimize what is a biologically and socially unsustainable practice. In past public policy analyses, fisheries managers on both sides of the border (with the exception of Washington State, which has now banned roe herring fishing and has a “forage fish” policy in place) have focused only on the gross revenue from the fishery. However, future public policy analysis needs to include the health costs to First Nations, of the loss of both herring and herring eggs. Also, analysis needs to include the loss of access to forage fish by endangered or depressed salmon stocks, as well as the loss to the tourism related industries. A new, multi-species and multi-disciplinary analysis inclusive of social science data will, in all probability, reveal that the roe herring fishery is actually costing both Canada and the United States many millions more than the revenues now received from the roe fishery. Other values cannot be measured by economic models, such as the cultural loss to the First Nations and Tribes, and the loss of quality of life by residents who enjoy the presence of high abundances of local fish, wildlife, and bird populations.
For the First Nations and Tribes all along the Pacific coast, this fishery has been nothing less than an instrument of cultural marginalization, for herring are just as important as salmon to these cultures. Roe herring fishing near the First Nation communities has everywhere left them without access to herring eggs on branches and roe on kelp, nutritious delicacies that are a hallmark of their unique and distinctive culture and a must at feasts and ceremonies of note. For example, of the approximately 32,000 First Nations people who live around the Georgia and Johnstone Straits, I would estimate that less than 3,000 are able to get even a taste of herring or herring eggs today. Local, long term depletions are the usual reason, following roe herring fisheries. First Nation harvesters also note the removal of the older fish in the roe herring fishery on the larger “migratory” stocks renders egg deposition much thinner than needed for traditional roe-on-branch operations. With all of the major stocks now driven to low levels in British Columbia, a financially desperate industry is now actively seeking access to the few remaining local stocks where First Nations still enjoy traditional levels of abundance. Allowing this to happen can only breed years of conflict, litigation, and the ill feelings that accompany cultural dispossession.
The situation is in some ways the same as that faced on the east coast of Canada, when the cod collapsed. The roe herring fishery is now dead from a moral, biological, and economic standpoint; to continue to “fish down the biomass”, is an irresponsible option, both for Canada and the U.S. Vast areas of quality herring spawning habitat are not used every year, as in the prime Hornby/Denman Island area of British Columbia and the Kah Shakes area in Alaska. Fortunately, herring is so resilient and adaptive that extirpation has not occurred, with remnant stocks still in place in past areas of overfishing or severe habitat damage. Thus unlike the case in most fisheries, the possibilities for herring recovery are generational, not multi-generational, as with ground fish, etc.
However, indecisive or delayed action is not an option for this key Pacific coast issue, as it will only exacerbate the social hurt, and prolong the biological rebuilding process.
The time has come for open and cooperative information sharing, decisive leadership, and firm and co-ordinated international action. Information especially needs to now be sharing by fisheries managers, regarding First Nation and Tribal access.
Roe herring fishing, or the targeting of the large female fish at the spawning time, has never been and will never be a sustainable fishery. It is time to outlaw it forever. The “reduction” or fish meal fishery, was outlawed in Canada in 1970, after it proved unsustainable. Learning together from our mistakes, is the only way to move responsible resource management and stewardship, forward.
In Canada, the immediate buy back and retirement of the entire roe herring fleet is necessary, both from a social and conservation perspective. This experimental fishery was created in Canada in 1972. It is important to let the fishers retire with dignity. Perhaps in twenty years, after all stocks rebuild and First Nation and Tribal cultures are restored, it may be possible to consider modest food fisheries. Rushing back to fish in a few years would immediately nullify any social and biological gains.
Intense research must be undertaken to fully understand the regional stock dynamics of herring. In Canada, full inventories of the status of all of the stocks have never been undertaken; the Local Traditional Knowledge and experience of long term local residents, and the older roe herring and bait fishers will be crucial in this research effort, to document all past fishing effort by time and area. Reconstruction work on former spawning areas and stock abundance is already in progress in Alaska with the Tribes, and this knowledge must now become the mainstay in a new era of fisheries management. In southern Canada, particularly, we are far behind on the integration of Local and First Nations knowledge in the actual management of fisheries; distrust born of years of conflict, and the present uni-disciplinary nature of fisheries management, are the main reasons. A multi-disciplinary approach to herring fisheries management, fully inclusive of social science, is long overdue; this is a major challenge for those who teach fisheries management at the University level. They will need much help and support if this transition is to finally occur; it will be a challenge to avoid conflict or competition and to finally bring the disciplines together. In fact, governmental intervention to mandate such a change is now needed, if real carry-through to the management level is to be achieved.
The possibility remains that all herring fishing may have to remain closed, for the ecosystem or “forage fish” needs, for herring, are acute. The Killer Whale Recovery Plan is tied to the recovery of regional ecosystem health, and a ban on all further roe herring fishing would offer immediate and strong support to this recovery (the Killer Whale/Chinook/herring interaction issue). A ban would also offer real support for coho, rock fish and ling cod rebuilding, as well as the restoration of many bird populations that will benefit from again being able to utilize an enlarged herring biomass for daily feeding and increased reproductive success.
The closure of herring fishing in Canada will hugely benefit the United States, as it will enable faster recovery of the many endangered U.S. salmon stocks that forage in Canadian waters for much of their lives. Similarly, as many depressed or declining Canadian stocks forage in Alaskan waters, finally allowing herring stocks to rebuild there will greatly benefit Canada. It is important to note that the short term loss of employment in the roe herring and sac roe industries will eventually translate into increased employment and prosperity in the commercial and sport salmon, halibut, etc., fisheries.
Thank you for your attention to this urgent matter.
Yours Sincerely,
David W. Ellis, B.A., M. Sc.
Former Head, Marine Fish, Pacific, Committee on the Status of Endangered Wildlife in Canada
Executive Director, The Fish For Life Foundation
Governor Sarah Palin
State of Alaska
550 West 7th Avenue, Suite 1700
Anchorage, AK 99501
Governor Chris Gregoire
Office of the Governor
PO Box 40002
Olympia, WA 98504-0002
Governor Arnold Schwarzenegger
State Capitol Building
Sacramento, CA 95814
Dr. Jane Lubchenco
Under Secretary of Commerce for Oceans and Atmosphere and NOAA Administrator
National Oceanic and Atmospheric Administration
1401 Constitution Avenue, NW
Room 5128
Washington, DC 20230
Dr. Thomas Thornton
Dept Anthropology
Portland State University
Post Office Box 751
Portland Oregon 97207-0751
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