Herring Scrap 41: A Deadline-day Comment on Canada's Draft Plan for Pacific Herring

Today, November 17th, is the deadline for comments to Fisheries and Oceans Canada regarding their DRAFT Pacific Region Integrated Management Plan 2025-2026 for Pacific Herring. I've submitted the comment below and would like to share it with you in case you'd like to comment yourself. I recommend also checking out Pacific Wild's page for their Protect Pacific Herring campaign page, and using their handy letter-submitting tool and/or template to make the whole thing extra easy. I invite you to use any of the following text as you see fit.


To whom it may concern,

I have reviewed the draft Pacific Region Integrated Management Plan 2025-2026 for Pacific Herring.

I am writing to express my dismay that Canada continues to pursue a herring management strategy that involves the industrial extraction of a keystone species of forage fish at the most critical and vulnerable moment of their life cycle.

This strategy doubles down on an approach to herring management that has failed widely and persistently up and down the coast in recent decades at great cost to the resilience of the maritime systems on which all coastal life depends.

To commit these harms for the paltry short-term economic gains (a fraction of that of salmon or halibut, which each depend on herring) offered by this fishery - which can scarcely even be characterized as a food fishery - is preposterous at this stage.

Though the science has been slow to catch up to Traditional Ecological Knowledge, it's caught up enough that we should know better than to carry on with this fishery. Western science now has the language and evidence to understand that herring tend to return to their natal spawning grounds (Petrou 2019; Moll 2025); to understand that a resilient herring population - such as once thrived in all BC waters - features a genetic diversity that results in a longer spawning season than that which we now witness (Petrou et al 2022); to understand that the harms of exposure to PAHs in urban and shipping waterways or near the sites of spills take place at lower exposures than instruments are typically designed to measure (Incardona 2021); to understand that there are consequences to longevity overfishing (Beamish 2006), and that herring behavior changes in ways that may lead to unsuccessful spawning behavior when the cultural memory of older fish is removed from the population (Slotte 2025); to understand that conventional herring modeling does not account for the importance of older fish, nor does it account for the likelihood that the abandonment of spawning grounds would be a likely feature of decline (McCall et al, 2018); to understand that herring are sensitive creatures who are vulnerable to new infrastructure, new shipping, new sources of marine noise, and that as a consequence of development, pollution, overfishing, and other forms of habitat destruction, forage fish populations (including herring) are a fraction of what they once were along these shores (Morin et al 2023; Thornton & Moss 2021; McKechnie 2014).

We know all sorts of things. We know that fisheries modeling can lead to estrangement from reality (Pauly 1995) and that retrospective assessments of fish populations tend to come in lower than contemporaneous assessments, which means that "“1.85× more assessed stocks have collapsed (B/Bmax < 0.1) than currently recognized” (Edgar 2024). We know that the unpredictability of climate change will stress and strain the survivability of life on earth for all living beings, including by introducing so-called metabolic inefficiencies in herring (Murray 2022). We know that a new marine heat wave - a new blob - is upon us.

This management plan targets those herring populations which are presently thriving. Based on the track record of herring fisheries in the North Pacific, this is a path to ensuring that no herring populations thrive. That's no good. I urge DFO to implement an immediate moratorium on commercial herring fisheries.

We have every reason to know by now that this seining and gillnetting of spawning herring must cease. I ask you to set aside your model-based rationalizations, and rely instead on the short section (p44-46) in your long management plan which features the perspectives of the First Nations which were submitted by your Island Marine Aquatic Working Group. I close this comment with a long excerpt from that section:

"Traditional harvest, knowledge and handling methods, passed down through the generations, varied from families and language groups. These methods were performed in a way that ensured there was the least amount of disturbance to the spawning herring, and their habitat, to make sure they returned every year. Today, Indigenous communities, on and around Vancouver Island, practice a multitude of adaptive harvest methods:

• Nuu-chah-nulth (West Coast of Vancouver Island): elders indicate that when the herring arrived to spawn, the entire community was engaged, from harvesting to processing. Tree boughs for the harvest of roe, (Qwikmiss), were placed in the water very quietly and carefully, so as not to disturb the schooling herring. The roe was collected from boughs and dried. Historical observations indicate the spawn used to be ten layers thick. Today, it varies from one to three layers in thickness. Harvesting methods utilized today involve using cedar trees and canoes whereas the tree is left in the water for about a week until the herring spawn. The roe is removed and salted or frozen to preserve it. Local observations on the West Coast indicate that herring are spawning in deeper water and in different locations compared to where they spawned historically.

• Kwakwaka’wakw (North Coast of Vancouver Island): elders indicate that individual groups from the community would harvest herring using nets made out of spruce roots and kelp. The harvested herring would be brought back to the community to share and primarily eaten fresh or preserved using salt. The spawn used to be over six inches thick. Today, northern Vancouver Island communities must rely on Central Coast or Haida to provide herring roe because of the limited spawn in the area and the lack of resources to access the herring.

• Coast Salish (South Coast of Vancouver Island): elders indicate that herring was traditionally harvested by individual families, rather than by the entire community. A herring rake (a long pole with spikes), was used as the primary harvest tool. This method was successful because the herring were so abundant in this area. Captured herring would be smoked or eaten fresh. Herring roe was traditionally, and currently, harvested by using trees or boughs placed in the water allowing the herring eggs to collect on the boughs. Today, some of the Hul’qumi’num can’t harvest herring at all because a very small number of herring spawn in this area, and where they do spawn, it is in very low densities. Community members must travel north to Comox or Deep Bay to harvest herring and roe, and often it is harvested from kelp, which is not the method/source preferred by elders.

What more do you need to know?

Sincerely,

Peter