October 20, 2005

To:       The Honourable Geoff Regan, M.P
            Minister of Fisheries and Oceans, Canada
            1801 Hollis Street, Suite 1210
            Halifax, Nova Scotia,      B3J 3N4

From:   Debbie MacKenzie
           Grey Seal Conservation Society (GSCS)

The DFO Science Advisory Process used to generate advice for the new Atlantic Seal Management Plan included no consultation on ecosystem considerations: This is a serious omission that requires urgent correction.

Dear Mr. Regan, 

Please elicit advice from DFO Science on how ecosystem considerations should be incorporated into the next Atlantic Seal Management Plan. At this time, the Science Advisory Schedule does not indicate that any meeting has been held, or is planned, with the objective of producing advice on this matter. Omitting ecosystem considerations from marine resource harvest planning should no longer be acceptable practice in Canada.

DFO held a Science Advisory meeting on September 7 – 8, 2005 to discuss “Harp and Grey Seal: science advice for the next Atlantic Seal Management Plan.” I was not permitted to participate in this meeting. This meeting failed to meet DFO’s criteria for transparency and inclusiveness, and insufficient information was considered.

On October 17, 2005 the Terms of Reference for the above mentioned science advisory meeting were made public on DFO’s website. The Terms of Reference indicate that discussion was limited to modeling trends in seal populations under various harvest management scenarios, with a view to recommending quotas for future seal hunts. Also discussed was the updated size estimate for the Scotian Shelf grey seal population, and a “Potential Biological Removal” (PBR) was calculated on this basis.

I am greatly concerned to note that the list of working papers and background documents that were considered by the meeting participants lacked any publication describing ecosystem considerations in marine resource management. Participation in the meeting was limited to three DFO scientists who have worked on seal biology and seal population models, and two external participants with similar backgrounds, both of whom were previously appointed to the “Eminent Panel on Seal Management” in 2000-2001.

There is no sign that the creation of science advice for the new seal management plan was done with any consideration of the gains in ecosystem understanding that have been made by DFO Science in the years since the Eminent Panel completed its investigation. But this is clearly what should have been done under Canada’s Oceans Strategy (2002), which includes “ecosystem-based management” as a major tenet. The report of the Eminent Panel (2001), and seal hunts subsequently planned on its basis, did not include ecosystem considerations. It is important to realize that much has changed since 2001, and a reiteration of the conclusions of the Eminent Panel on Seal Management neither meets current “ecosystem-based” management criteria, nor does it compare to the best science now available from DFO.

Since 2001, DFO has made much progress towards its goal of broadening the scope of marine resource management from single-species models to holistic “ecosystem management.” It is now widely recognized by scientists that a single species approach to management risks causing broad-scale unintended consequences at the ecosystem level. A great deal of scientific thought in the last few years has been devoted to finding ways to understand, to avoid and to mitigate such ecosystem damage.

Since 2001, DFO scientists have published ground-breaking analytical ecosystem studies. Exhaustive reviews have been completed as DFO scientists have tried to integrate their knowledge of a great many ecosystem components and their complex patterns of interaction. Masses of oceanographic data have been analyzed in new ways, and new patterns have been discovered. DFO’s first “Ecosystem Status Reports” and “Habitat Status Reports” were produced in 2003. Comprehensive ecosystem studies have also been done under CDEENA, and new hypotheses have been advanced by DFO scientists to explain unexpected changes in marine food webs. Also, DFO’s open collaborative approach to planning for integrated management of multiple ocean uses seems now to be progressing nicely.

Mr. Regan, it is unacceptable to think that you may not be given the benefit of this body of new knowledge in science advice on seal management provided to you this fall. Missing may be important insights into ecosystem science that were recently gained by DFO, concepts that must now be considered when setting objectives for the management of the seal herds. However, it seems that if you wish to receive this level of current, comprehensive science advice on this matter, you must ask for it explicitly.

Please act without delay to trigger a DFO science advisory meeting tasked with providing your office with objective science advice on how ecosystem considerations should be applied to seal management. Please also ensure that this additional science advice on seal management is delivered to your office prior to your approval of the next Atlantic Seal Management Plan. I would appreciate an opportunity to provide input in drafting the Terms of Reference for this proposed meeting, and I would also appreciate being invited to attend the meeting as an external participant. Thank you.


Debbie MacKenzie

P.S. Below is a list of some recent publications written by DFO scientists, that contain information relevant to the task of including ecosystem considerations in planning seal herd management. I recommend inviting several of these authors to the proposed advisory meeting (at least Rice, Frank and Bundy), along with the DFO seal biologists who took part in the science advisory meeting that was held on September 7 – 8, 2005.

DFO, 2003. State of the Eastern Scotian Shelf Ecosystem. DFO Ecosystem Status Report 2003/004

Bundy, A. 2004. Mass balance models of the eastern Scotian Shelf before and after the cod collapse and other ecosystem changes. Can. Tech. Rep. Fish. Aquat. Sci. 2520: xii + 193 p.

DFO, 2004. Operationalizing an Ecosystem Conservation Framework for the Eastern Scotian Shelf. Can. Sci. Advis. Sec. Research Document 2004/076

Choi, Jae S., Kenneth T. Frank, William C. Leggett, and Ken Drinkwater. 2004. Transition to an alternate state in a continental shelf ecosystem. Can. J. Fish. Aquat. Sci. 61: 505 – 510

DFO, 2004. Habitat Status Report on Ecosystem Objectives. Can. Sci. Advis. Sec. Habitat Status Report 2004/001

Frank, Kenneth T., Brian Petrie, Jae S. Choi, William C. Leggett. 2005. Trophic Cascades in a Formerly Cod-Dominated Ecosystem. Science 308: 1621 – 1623

DFO, 2005. Eastern Scotian Shelf Integrated Ocean Management Plan (2006 – 2011) Draft for Discussion. Oceans and Coastal Management Report 2005-02.

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See also: Seal Forum 2005

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