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Open letter to Minister of Fisheries and Oceans and Minister of Science: Place science over industry and political whim

Real change for our new government to place science over industry and political whim in ocean management decisions: An open letter to the Honorable Hunter Tootoo (Minister of Fisheries and Oceans) and the Honorable Kirsty Duncan (Minister of Science)
Live clams and shells in a net.


After awareness was raised by scientific and community groups, including E4D, the Honourable Hunter Tootoo announced on December 18, 2015 that the Atlantic Surf Clam fishery quota would not be increased or changed until formal science reviews are conducted. This Minister stated that this decision highlights Canada’s commitment to evidence-based decision making, the precautionary principle, and the need to ensure the long-term sustainability of fisheries for both economic and environmental prosperity.

While the authors of the letter appreciate this dedication, we hope the Minister will take this opportunity is taken to create real change within the Department of Fisheries and Oceans (DFO) regarding ecosystem-based management and accounting, which was not explicitly mentioned with this decision. DFO currently has no policy to formally document or guide these sorts of changes within fisheries, and would benefit from the implementation of a formal process including documentation, consultation, and scientific review.

November 24, 2015

Dear Hon. Hunter Tootoo and Hon. Kirsty Duncan,

We would like to congratulate you on your well-deserved appointments to cabinet. We are pleased that our new government has vowed to make ocean conservation a priority. The ocean is critical to regulating the climate and providing livelihoods and food security for coastal communities, as well as producing 50% of the oxygen we breathe: just a few of the important services that the ocean provides. Our ocean will continue to face increasing impacts from human uses and climate change. It is important that we make management decisions based on both the ecosystem and precautionary approaches, as we have committed to do under the United Nations Fish Stocks Agreement.

In advance of the election, the Liberal Party committed to return to evidence–based decision-making in the public service. We are pleased to see initial efforts to fulfill that commitment have been made (like the return of the long-form census and the loosening of communications restrictions placed on public sector scientists). However there remain unsolved bureaucratic problems, which threaten our commitments under the UN Fish Stocks Agreement. Today, we would like to bring to your attention the issue of ministerial discretion in the setting of fishing quotas.

As you are aware, the setting of fishing quotas has always been at the discretion of the Minister, which has often placed political whim and pressure from industry above scientific evidence. This has gone on for decades, and is at least partially responsible for the collapse of the Atlantic cod, which has yet to recover to commercially meaningful levels.(1-3) The 2014 Atlantic mackerel quota was set by the Minister at 10,000 tonnes despite science advice for a quota not more than 800 tonnes.(4)

Just this past summer, a decision was made by the former Minister of Fisheries and Oceans to permit quota expansion for the Arctic Surf Clam (Mactromeris polynyma) fishery on Banquereau Bank, Scotian Shelf. This was done without science advice. A 35% increase in quota occurred without a formal science review or consideration of wider ecosystem-level impacts.

We are respectfully requesting that our newly elected government re-evaluate this particular decision, and challenge the status quo of fisheries decision-making in general moving forward. While the decision to increase the Surf Clam quota may have been made in order to offer other industry players entrance into the fishery (which is currently dominated by one company), increasing the quota allocation is not a responsible, science-based approach. If the goal is equity of access, the existing quota could be shared among additional players. To review our outline of the existing science and systemic problem with the decision by the former Minister, please click here. The Ecology Action Center, a non-profit, conservation based NGO in Halifax Nova Scotia, also outlines the dangers of the increased quota for groundfish, which are depleted, and find important habitat on Banquero Bank.(5)

The available evidence suggests that the Surf Clam fishery may have negative impacts on the Banquereau Bank ecosystem; therefore, we advise that a formal science review is necessary to justify the expansion of this and any fishery. We suggest that evidence be provided aside from the sustainability of catch of the target species. Given Canada’s commitment to ecosystem-based management we request that formal science review for the purpose of identifying the ecosystem-level impacts of any planned activities be undertaken. Further, no fishery or ocean-based activity should be opened or expanded if it is shown that its activities would be detrimental to the larger ecosystem, which includes other commercially important species.

We hope you will consider our advice and accordingly re-evaluate the current process of decision-making in fisheries management. We hope you will make it mandatory that all decisions involving activities in our oceans are made following rigorous scientific review, consistent with our ecosystem-based policies and UN commitments, not solely on the basis of political whim.

We look forward to a new Canada that makes decisions based on science, and begins to protect our ocean and prioritize sustainable management of fisheries resources from an ecosystem perspective.


Christine Stortini, PhD Student, Queen’s University

Stephanie Boudreau, PhD, Postdoctoral Fellow, Consultant

Alana Westwood, PhD Candidate, Dalhousie University and Research Coordinator, Evidence for Democracy



1. Hutchings, J. A. (2005). Can. J. Fish. Aquat. Sci., 62(4), 824-832.

2. Shelton, P. A., et al. (2006). Can. J. Fish. Aquat. Sci., 63(2), 235-238.

3. Brander, K. M. (2006). ICES Journal of Marine Science, 64.




Cover image public domain, courtesty of NOAA –

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