Letter re Fisheries Management Plan

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200 - 1627 Fort St., Victoria, BC  V8R 1H8 
Telephone  (250) 405-5151    Fax  (250) 405-5155 
Toll Free via Enquiry BC in Vancouver 604.660.2421.  Elsewhere in BC 1.800.663.7867 
Email  information@islandstrust.bc.ca 
Web  www.islandstrust.bc.ca 
 
 
Bowen  Denman  Hornby  Gabriola Galiano  Gambier  Lasqueti  Mayne  North Pender  Salt Spring  Saturna  South Pender  Thetis 
February 8, 2018 
Via email victoria.postlethwaite@dfo-mpo.gc.ca  
 
Victoria Postlethwaite 
Resource Manager - Herring 
Fisheries and Oceans Canada 
1420-401 Burrard Street 
Vancouver, BC V6C 3S4 
 
Dear Victoria Postlethwaite: 
 
Re: Draft 2017/2018 Pacific Herring Integrated Fisheries Management Plan 
 
Thank you for providing an opportunity to comment on the draft 2017/2018 Pacific Herring Integrated Fisheries Management 
Plan. We do not have any staff expertise in fishery management so are providing general comments.  
 
We are interested in herring management issues because Pacific Herring are foundational to the food web of the Salish Sea 
and play a critical role in the functioning of our ecosystems. We understand that Pacific Herring are the dominant forage fish 
in the Salish Sea and a vital food source for species for seabirds and for many species of fish, including Chinook salmon, which 
it turn, is the main food source of the resident orcas.  
 
We are concerned that the annual removal of 20% of the herring population may not support the needs of predator species, 
especially as populations recover.  
 
We note that the Minister LeBlanc’s mandate letter includes the direction to "Use scientific evidence and the precautionary 
principle, and take into account climate change, when making decisions affecting fish stocks and ecosystem management”. 
We question whether there is sufficient scientific evidence available on the population, habitat, and ecosystem and fishery 
dynamics of the BC Pacific Herring to support management decisions. We are not aware of information being available about 
appropriate conservation limits for Pacific Herring based on ecosystem considerations. 
 
It is concerning to us that the IFMP states that “the current maximum harvest rate of 20% under the herring management 
framework is believed to be conservative” after acknowledging that “there is no information available on the appropriate 
conservation limits for Pacific Herring based on ecosystem considerations”. It does not seem precautionary to remove one 
fifth of a key forage fish from an ecosystem when the ecosystem-based needs of other species have not been fully 
considered.  
 
The IFMP states that “research is ongoing to better understand these ecosystem processes and the role Pacific Herring play in 
maintaining the integrity and functioning of the ecosystem”. This might sound reassuring– except that I understand that 
Pacific Herring IMFP’s have contained a similar message for fourteen years. We encourage you to base future herring 
management decisions on sound, ecosystem-based 

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