The Honorable Geoff Regan, M.P.                                          
Minister of Fisheries and Oceans, Canada
200 Kent Street
Ottawa, ON K1A 0E6
Min@dfo-mpo.gc.ca

Dear Mr. Regan,

The Science branch of the Canadian Department of Fisheries and Oceans (DFO) has failed to recognize that broad patterns of decline in fish and other marine life offer strong evidence consistent with a fundamental decline in ocean fertility. This is an unexpected negative development, one that poses a grave threat to the future of fisheries, but that also carries far more significant and wide-reaching ecological consequences. My repeated efforts to discuss this with DFO Science in recent years have been stonewalled, seemingly since a serious flaw in the accepted science has been revealed: that the currently used indicators of ocean fertility are woefully unreliable, as is the assumption that ocean fertility could never be eroded by fishing. Declining ecosystem fertility offers a highly plausible explanation for the suite of changes we are witnessing in marine life today, and while this is strongly supported by DFO’s scientific data, it is missing from their published analyses of the situation.

DFO has committed a grave error in putting the ocean in the back seat, while single-mindedly pursing the goals of fisheries.

Mr. Regan, I am dissatisfied with your reply to my earlier correspondence.

In November, 2003, I sent to your office my concerns regarding serious shortcomings of DFO Science. However, presumably on the advice of the science branch, you deflected my input with “I would suggest that you have your work submitted to a relevant scientific journal.” Perhaps I was too abstract in my cover letter to you, but I doubt it. I had sent to you eleven written articles and a videotape, with the request that DFO Science review the concerns raised within. While some of my work I might reasonably choose to send the route of standard scientific publication, I have raised some very specific points that require answers now from the DFO Science branch. The focus of my concern is specifically “oceans” health rather than “fisheries” health. DFO’s mandate includes both, in an arrangement that now appears to have been surprisingly inappropriate

I am now formally requesting you to direct the appropriate members of your scientific staff to respond to the following concerns:

1. Plankton.

Direct evidence of a long-term decline in plankton production is visible along the Nova Scotia shoreline in the form of disappearing barnacles. This has been overlooked by marine science but the implications for ocean health and productivity are serious. My observations and evidence of this decline are detailed in an article titled “The Barnacle Zone,” a copy of which has already been sent to your office. It is also available online at http://www.fisherycrisis.com/barnacles.html . My formal request is that the government oceanographers responsible for assessing trends in marine plankton production comment on the significance of this pattern of decline and redistribution of barnacles. This change is mirrored in declining trends in many other shoreline organisms (even including seaweeds) and offers a parallel to changes that have been observed in commercial fish stocks. This is an important clue, and it relates directly to falling ocean fertility. I would like to draw the evidence of the remarkable decline of coastal barnacles to the attention of your scientists in the hope that a deeper understanding may be acquired of changes occurring in the ocean at the ecosystem level. Our discussion of this cannot reasonably be made contingent upon my publication of this material in a scientific journal. That is not the normal route by which the public expects to communicate with public servants.

Plankton science, and especially integrating observed changing trends in plankton into ecosystem assessments (i.e. relating these to patterns in fish or seals), is an area of serious weakness in DFO Science, judging by recent publications. Without sound plankton science (including, for instance, an identified line of questioning into the reasons for the recent unexpected finding of sustained divergent trends between phytoplankton and zooplankton in coastal waters), ocean health cannot be sensibly evaluated.

2. Where are the stomach contents (diet) data on groundfish in the Maritimes Region?

If the groundfish die-off has been driven, in part or in whole, by a decline in their food base (a predictable consequence of lowered fertility), 40+ years of DFO data on fish stomach contents might reasonably be expected to help to verify, or to refute, this hypothesis. However, analysis of this accumulated data has not yet been included in published assessments of the 4VsW (Eastern Scotian Shelf) cod stock, for instance, despite DFO scientists reporting that the growth failure of these fish remains “perplexing to say the least” (DFO 2003). To me, DFO’s failure to consider and report on all of the data in their possession, and to respond to my specific and repeated requests to see the cod diet data, is also “perplexing to say the least.” I am now formally requesting to see this data.

3. Smith Sound cod kill

In April, 2003, a large unexpected die-off affected the last remaining significant aggregation of Newfoundland’s Northern cod stock. Hundreds of tons of dead cod surfaced at Smith Sound, and a detailed scientific study of the incident was conducted by DFO Science and by scientists based at the Memorial University of Newfoundland. Last spring DFO cod scientists indicated that a final report of their findings regarding this incident would be published after analysis. Has this been completed? If so, where can I read it? If not, why not? The anniversary of this unfortunate incident fast approaches. Has DFO attempted to gauge the risk of a reoccurrence?

4. Dissolved organic matter (DOM)

The largest reservoir of organic matter in seawater (90%) exists in dissolved form, and this resource is critical to the support of marine animal life at all levels. Crucial organisms living at lower positions in the food web (bacteria and invertebrates) use DOM directly as a food source. This is therefore an integral factor in ocean health. I am unaware of any routine program for monitoring DOM that has been conducted in Atlantic Canada or elsewhere, but am concerned that an important, and potentially changing, variable might have been overlooked.

I have occasionally found publications describing detailed one-time inventories of seawater DOM from other parts of the world (e.g. Russia). However, nowhere have I seen a time-series approach to this, such as would be needed to assess whether or not this important organic resource might be becoming depleted in the ocean. Realizing that routine DOM measurements have not been reported in DFO’s literature, I hoped nevertheless that a one-time seawater DOM inventory might have been conducted by Canadian scientists at some time in the past. Incredibly, the barrier of non-communication that has been erected between myself and DFO Science has prevented my eliciting an answer to even this simple yes/no question. It seems I must now formally request your assistance, as the Minister responsible for the department. Has DFO Science, or has it not, at any time conducted an inventory of the DOM resource in Canadian waters? Yes or no?

5. Seal research

I have a serious concerns regarding the scientific contribution to the imminent decision regarding the culling of Nova Scotia grey seals in a bid to preserve dwindling stocks of groundfish, and by extension, to decisions regarding all seal killing in Canada.

My major concern is that worrisome negative changes in ocean plankton (seen most clearly in the decline of zooplankton) are fundamentally related to the cause of the fish decline. I have tried to draw to the attention of DFO, the FRCC, the parliamentary and senate standing committees on fisheries and oceans, and two previous Ministers of Fisheries and Oceans, the importance of the fact that there exist plankton-positive aspects to the natural ecology of seals. I am disappointed to see no evidence yet that this concept is being investigated, or that it will be included in DFO’s program of “seal research.”

Given the recent earmarking of $6 million in additional funding for “seal research,” it is not unreasonable to expect that studies might progress beyond those designed to discover how much fish seals are eating. Framing the question only as “the role of seal predation” denies the reality of the other side of the story. What requires urgent consideration is better described as “the ecological role of seals.” A few specific questions:

Who is overseeing seal research for DFO? What are the goals and the mandate of the program?

How is the money for seal research being spent? If research money is being diverted to the development and marketing of seal products before conducting a comprehensive study of the complexities of seal ecology, we may be squandering precious resources, and destroying animals that could prove to be worth more to “ocean health” alive than dead.

To what extent is DFO now paying fishermen to kill seals? Has the recent “Fisheries Science Collaborative Project on Seals” in Cape Breton been funded with the new seal research money? If so, how much has this cost? The project sounds as if it will produce one of the “seal exclusion zones” that fishermen have been demanding in recent years. Is “seal exclusion” one of the goals of this project? If an experiment in “seal exclusion” is being conducted by DFO, is it being balanced by the establishment of appropriate scientific controls, by the designation of comparable “seal protection zones?”

Will DFO be funding the new seal cull that has been proposed in Nova Scotia by the “Grey Seal Society?” Will the Grey Seal Society be required to give an account of the numbers of seals killed 

Nova Scotia grey seals – I have a serious concern about this seal population specifically, and the recent mounting pressure for a cull. Has DFO taken the precaution of conducting a new, recent assessment of the Sable Island population component of the Nova Scotia grey seals? Were they monitored, or were pups counted, during the just-completed winter 2004 pupping season? The most recent previously reported grey seal count was done in 1997. I am concerned that the Nova Scotia grey seal, the offshore component in particular, may be affected already, or in the very near future, by a spontaneous decline of significant proportions. As has been recently seen with fish stocks, DFO may have sorely overestimated the capacity of these animals to continue to expand and to “bounce back” from the proposed cull. The Grey Seal Society seems to think that inshore grey seals can be indiscriminately shot on sight – until there are no more in sight – because the offshore population can always be depended upon to preserve the species. I would not bet on this.

I have described in detail the reasons for my concern about the health of the Nova Scotia grey seal population, plus plankton-positive aspects of seal ecology that deserve the serious consideration of modern seal researchers. In a further formal request, I ask you to direct DFO Science to review and respond to the following article: “Nova Scotia Grey Seal Hunt, 2004.”

Also, please convince me that Canada is not playing a word game like that of Japan, which now pursues whale killing under the thin disguise of “whale research.” The rest of the world watches this Japanese activity with scorn, recognizing a brutal commercial hunt when they see one. Japan is also greatly concerned, it seems, about the deleterious effects that whales are having on fish stocks in their waters, on “the role of whale predation.”

Neither Canada nor Japan yet suspects what I do: that whales and seals marginally overcompensate for the fish they consume by means of the exquisitely fine-tuned “other side of the story,” in which they stimulate the production of plankton, and thereby of more food for fish. Natural predators optimize the health of their prey in multiple ways, and an important unrecognized strategy has always been by the active stimulation and maintenance of their food base. This was an important secret to their millions of years of successful coexistence as predator and prey.

6. Eastern Scotian Shelf Ecosystem Status Report (DFO 2003)

I have several concerns about the information presented in this report (what is there and what is lacking), the accuracy of certain numerical assessments, and the general conclusions that have been drawn about the overall “health” of the ecosystem. I have made several attempts to communicate my specific concerns to DFO Science, in a column that was published in the Halifax Herald on November 16, 2003, titled “DFO Ignores Ocean Fertility,” and in a longer web article titled “2003: ‘Extraordinary’ increase in herring, mackerel, and capelin numbers on the Eastern Scotian Shelf?” Copies of both of these have already been sent to your office, and both are available online, at     http://www.fisherycrisis.com/DFO/herald.htm and http://www.fisherycrisis.com/DFO/baitfish.htm .

When the calculated small pelagic fish biomass was so far out of line with indices of zooplankton and groundfish, why was their abundance not verified by a directed survey that included gathering acoustic data?

No estimate of fertility, or primary productivity, was included in the Ecosystem Status Report. Since seawater chlorophyll concentrations (which were included in the assembled data) do not provide reliable evidence of the rate of organic production, and since so many other indices have been falling (zooplankton density, size, condition and numbers of groundfish), the lack of attention to this crucial parameter of “ocean health” appears as an important omission. Lacking algorithms by which the rate of primary organic production (plant growth) might be quantified from measurements of chlorophyll and zooplankton (which have both shifted substantially, but, unexpectedly, in opposite directions), it might reasonably be expected that Atlantic Canadian oceanographers would seek other direct evidence of the vigor of marine plant growth. The assessment of growth rates in certain long-lived perennial seaweeds is more readily done than it is for phytoplankton, since, once these larger marine plants are established, virtually nothing eats them directly.

Long-term changes (over decades) that I have personally observed in rockweeds and Irish moss growing on pristine sections of the Nova Scotia coastline agree exactly with changes that would predictably occur should ocean fertility decline. The science of seaweed physiology backs up my conclusions. This strengthens the impression of declining fertility given by the decline in barnacles and multiple other forms of marine animal life. It has long been argued by some academic scientists that the best index of fertility/primary production (which also equates to energy input) is in the combined biomass of all animal life supported in the system. On that basis, we have ample evidence today to suspect that ocean fertility in Atlantic Canada might be declining.

Fertility, or primary productivity, is the single, most fundamental parameter that must be included in a meaningful assessment of “ocean health,” carrying ecological ramifications that extend far beyond fisheries.

DFO has reported in late 2003 that fisheries in the Maritimes Region are “healthy” and, gauged on an economic scale, perhaps that is still true. However, the recent dramatic shift of the focus of fisheries harvest from fish to crustaceans has been essential to the maintenance of this particular “health” indicator. This change reflects a downshifting of the fishing target to a lower trophic level, a phenomenon that has been well described in the literature. This is the only accomodation that fisheries could possibly have made to maintain its own “health” as ocean “health” faltered.

The “health” of fisheries and oceans might easily become blurred in the public mind. The failure of DFO Science, however, to clearly distinguish between the two represents a major deficiency in the fulfillment of their “oceans” mandate.

Fisheries ignores Oceans at its own peril…

Indications of declining growth and health of targeted crustaceans are now becoming increasingly apparent in the Maritimes Region. Although the numbers caught remain high, a mysterious weakening and die-off is beginning to affect a significant fraction of lobsters. The pattern is too reminiscent of what happened to groundfish a decade ago. Should the lobster population collapse, we can expect a dramatic loss of the “health” of fisheries. A further downgrading of the human target along the trophic scale will essentially mean that people will next try to eat what lobsters now eat. But unfortunately, this is mud…market value: zero. Mr. Regan, without exaggeration I warn you that this scenario might play out during your watch as Minister of Fisheries and Oceans.

7. Minister’s Advisory Council on Oceans (MACO)

MACO, intended to complement the FRCC in providing expert advice to the government on “oceans,” as a part of “Canada’s Oceans Strategy,” was initiated in 2000 by Herb Dhaliwal. However, when reading MACO’s website today, one wonders whether or not this body might already have been disbanded. There are no published reports of the advice that has been offered to the Minister, such as are produced regularly by the FRCC. Nothing has been entered into their “media room” since 2002, and no council meetings later than January 2003 are indicated under “events and dates.” Council members’ “bios” reveal the presence of fishing industry representatives, plus some marine scientists, but it does not appear that anyone sitting on MACO has a special interest or academic background in plankton science. MACO might therefore fail to identify declining ocean fertility as a crucial challenge and a threat, and might fail to offer clear advice to the Minister on how important knowledge gaps might be closed.

As a public service, my independent non-commercial website, www.fisherycrisis.com , was launched at approximately the same time as MACO, in early 2000. It now contains hundreds of pages of clear, specific information and carefully thought out advice to DFO and to previous Ministers of Fisheries and Oceans. However, all of this seems to have fallen on deaf ears (of those in charge of “managing” the ocean for Canadians…in contrast, I have received a great deal of positive feedback from ordinary concerned citizens and from other scientists around the world).

Consider these excerpts from “Canada’s Oceans Strategy”:

One of three “core commitments” is to “engage Canadians in oceans-related decisions in which they have a stake.” (…Has DFO decided that as a private Canadian citizen, I have no “stake” in a healthy ocean?)

“There are also non-government organizations, interest groups and academics with a wealth of expertise who can provide informed advice on matters such as economic, environmental and social issues, science and technology…Canada’s Oceans Strategy is designed to actively encourage the participation of these groups and individuals in its evolution and implementation.” (Canada’s Oceans Strategy, page 9) (…yet DFO actively discourages my participation…do you see a problem yet?)

Mr. Regan, an urgent impartial inquiry into “ocean health” is needed.

The truth will out, and the truth is that an unanticipated catastrophic decline has already occurred in our coastal region, that has affected everything from fish to barnacles, mussels, snails, starfish, urchins, anemones, etc…and that even the traditionally dominant seaweeds are disappearing. It is also true that remaining fish, seals and seabirds are starving. An unavoidable conclusion is that ocean fertility is in decline, and further unavoidable conclusions are that this problem has not resulted from "pollution" or from "climate change." And DFO, as the publicly funded seat of ocean science in this country, owes the people of Canada an explanation for this ominous unexpected development.

DFO’s refusal to respond to me, and their recent refusal to grant CBC television an interview on this issue, begins to look very bad. Nothing here has been stated lightly. I have been formally educated only as a “health professional,” but I am highly science-literate and have spent the last six years working full-time doing an independent review of marine science and of the alarming ongoing decline with marine life. DFO’s disjointed, narrow approach to the study of elements of ocean life prevents any deepening of their appreciation of how all of the parts work together. And it leaves us open to the risk of “inadvertently” damaging the “health of the ocean” to a far greater extent that has ever been imagined.

I have spoken with your office staff in Halifax and been informed that there are a great many fishing industry stakeholders in line ahead of me, who are seeking to draw your attention to their concerns. However, I urge you and DFO Science to try a new approach, to let the “ocean” step to the front of the line. Please contact me for a meeting. Thank you.

Sincerely,

Debbie MacKenzie

Nova Scotia, Canada

April 19, 2004 - Geoff Regan's reply to this letter was received.
May 10, 2004 - My letter to Mr. Regan following our meeting on April 30,2004.