Category Archives: longer posts – like a Chinook

Cohen Commisson: Science Advisory Panel disbanded; member speaks out

Yesterday evening just before dinner, on the CBC Radio program All Points West here in BC, host Joanne Roberts spoke to Dr. Carl Walters regarding the recently “disbanded” Cohen Commission Scientific Advisory Panel. I was  a bit surprised by the use of the word disbanded, as that was most-certainly not the phrase used in the Commission news release the other day.

The news release is worded slickly. Reading it may leave one with the impression that many of the “pre-eminent” scientists involved on the Panel may be taking on the twelve “research” projects related to the Commission’s work; or maybe another function. The word “disbanded” … not used.

Surprisingly as well… was the reason given by Dr. Walters for the disbanding — e.g. the controversy surrounding many of the members potential for conflict of interest (see a few earlier posts on this site).

Dr. Walters didn’t mention the potential for conflict of interest (which includes himself); however he did bring up the controversy surrounding some of the appointments. Maybe that includes the resignation of Dr. Brian Riddell?– a 30+ yr DFO scientist prior to leaving DFO, and taking over at the Pacific Salmon Foundation.

This reasoning is a bit of a slippery slope, and I’m sure there’s potentially more to the story — however, is there not a danger now, that the Cohen Commission could be perceived as flawed and susceptible to public pressure?

Might one not suggest, that as the Cohen Commission works feverishly to produce some 10,000+ pages of paper (with writing on them) by May 2011 that various public interest groups can just start squawking and screeching and thus influence the workings of the Commission?

Furthermore, if the reasons for disbanding the Scientific Panel are because folks were right — in raising the potential for conflict of interest — is the early work of the Commission now tainted? How big are the finger prints of the individuals on the Commission who were potentially in a conflict of interest?

First a resignation, then a full disbanding…?

And now what happens if the public doesn’t like the researchers chosen for the 12 research priorities?


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And then to add more pie in the face, Dr. Walters decided to take some parting shots. He sounded a bit like a kid who was selected last for the school yard game of red rover. He figured that his idea for research priorities should have been chosen — the idea that commercial fisheries have “lost out” on some $100 million of economic opportunities because of DFO mis-management.

He explained that he feels that DFO management of sockeye salmon is a giant experiment (of which I most certainly agree); however, he suggests the current method of allocating commercial catch is messed because commercial fisherfolks should be getting much higher allocations.

His suggestion is that in the 1990s, DFO started to reduce the total percentage of Fraser sockeye caught from the highs of 70-80% of the run  down closer to 50% of the run. He figures that this is the reason for the lower productivity that we are now experiencing because in essence ‘too many salmon are spawning’ and this means that baby salmon have too much competition in their nursery lakes and thus fewer baby salmon heading out to sea, and in turn fewer adults returning.

Apparently, Dr. Walters a long-time fisheries scientist and often outspoken individual, has bought into the idea of Maximum Sustainable Yield, which in my humble observations obviously ain’t too sustainable now is it?

Now, I’m not a “pre-eminent” fisheries scientist — nor is Ms. Roberts who hosts the CBC Radio program — however her tone was indicative of mine… although, I think I might have dropped a few more f-bombs with question marks (not too appropriate for public radio). Ms. Roberts questions and puzzlement were much more politely phrased.

I would most certainly like to see Dr. Walters’ data on this issue — as I’ve pointed out in many other posts, the history of “fisheries science” is not such a good one. Actually… maybe it’s one of the most questionable of “scientific” practices (I can hear the tomatoes hitting my computer now…). There’s a reason why the United Nations Food and Agriculture Organization (FAO) has suggested that well over 70% of the world’s fished fisheries populations are either over-exploited, fully exploited, or trying to recover. The history of fisheries science and management over the last century or so, is abysmal.

Of course, many might suggest the problem is more the “management” not the “science”…

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Dr. Walters’ logic suggests that because DFO has allowed “too many” fish into the river — the commercial fishing industry has “missed out” on over $100 million of “economic opportunities”.

Wow… strong statement. Enough to incite rioting in the fishing crews of the coast.

Sadly, and this is my main point on this issue, Dr. Walters has maybe not traveled to enough BC First Nation communities that depend on Fraser sockeye (however, maybe he has and has some better logic on this issue). Under the Constitution of Canada within Section 35 rights (as I understand it, and I stand to be corrected) — the federal government has a fiduciary responsibility to provide First Nations with access to fish to meet food, social and ceremonial (FSC) needs.

In the upper Fraser River — this requirement has not been met in most First Nation communities for decades… if not the last century. It’s written clear as day in the Wild Salmon Policy and it’s clear in legislation, and it’s been clear in the courts.When it comes to salmon:

  • Conservation first;
  • then First Nation food, social, and ceremonial needs;
  • then commercial and sport allocations (depending on species for which interest group first)

I know many folks out there love to quibble about this and some like to make right-leaning comments and lack of equality and race-based fisheries and so on and so on… yet the law is pretty clear on this one; as is the Constitution.

Like it or not that’s what we have to go by.

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So, maybe before Dr. Walters starts carrying on about all the “lost economic opportunities” at the mouth of the river, inciting rage in the commercial fishing boat owners, and suggesting the Cohen Commission should be looking into this issue… we could add a research project to the twelve listed by the Cohen Commission that looks into just what are the food, social and ceremonial needs of First Nations for the 150 or so different Nations, Bands and communities that depend on the annual return of salmon. As that has higher priority than commercial fisheries — by law.

How much has the catch for communities dwindled over the last 50-60 years when DFO management kicked in?

The needs are most certainly, more than the arbitrary 1 million that’s thrown their way now in Fraser allocations.

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Or maybe, just maybe, we could investigate what are true needs of the ecosystem — in regards to salmon returns. What do the bears need?

In the 1930s a study conducted in the Columbia River watershed found (through sampling grizzly bear fur) found that grizzly bears over 1000 km from the ocean depended on up to 90% of their diet from salmon. How has that changed? How has it changed in the Fraser?

It’s great that the Commission is looking at marine predation… but how about marine animal needs, the needs of animals upstream, and so on?

Just some thoughts…

Cohen Commission: making it up as we go along…

Yesterday the Cohen Commission issued a news release:  Cohen Commission Aug 17 news release.

As suggested:

At the beginning of the commission’s scientific research program a Scientific Advisory Panel composed of six pre-eminent fisheries scientists was created to assist with the development of the commission’s scientific research program. The commission has determined it is appropriate to transition from the model of the Scientific Advisory Panel to a new model that will focus on the peer review of the researchers’ reports.

Might we surmise that there is no connection between this and the many potential conflict of interest implications of several of the scientific advisors and the resignation of former DFO scientist Dr. Brian Riddell?

Would appear that Ms. Shore (the PR specialist hired to do communications) did a marvelous job of wording this press release. A good public relations consultant can be worth the significant invoices. There’s certainly a reference in the news release to the folks out there that have suggested: maybe having folks that have done significant amounts of work on the Department of Fisheries and Oceans dime may not be the most “independent” advisors for looking into the broken piggy bank that is DFO…

“The Panel members, all pre-eminent scientists with a high degree of expertise in the areas to be investigated by the commission, have performed their advisory role in a completely independent, professional manner in the best interests of the commission,” said Wallace [senior commission counsel].

I’d be curious to know what the “best interests of the commission” means…? Does that mean the “public”? Or does that mean in the best interests of the folks that created and funded the Commission… (e.g. Mr. Steve-O Harper)? Or does that mean in the best interests of the advisors, as they are part of “the commission”?

Curious statement…

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In essence, what the news release might really be suggesting is that the batter for Cohen cookies is being made from scratch — not from the recipe book…(unfortunately, I just hope that the first ingredient isn’t a whole lot of cups of chaff and not a lot of flour…and lacking significantly in chocolate chips):

The commission is also considering other processes for exploring the various technical and scientific issues, such as panel discussions and forums in which experts retained by the commission and those nominated by participants could exchange views and challenge each other’s findings and conclusions in an open but non-adversarial setting.

Here we are approaching nine months left in the Commission’s ridiculous time line (deadline of May 2011 for final report) and the “model” for the scientific panel has changed and we are “considering other processes for exploring”…. Yikes…

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Accompanying the finely crafted new release basically stating: ‘we are really making this up as we go’ — is a BackgrounderCohen Commission Aug 17 backgrounder outlining all the “technical and scientific research projects” that the Commission is undertaking (twelve of them). Here they are with some commentary and thoughts:

Project 1 of Cohen Commission

Excellent… however, in the 10,000 full time equivalents (FTEs) currently hired by the federal Department of Fisheries and Oceans (DFO) — which by the way has the legislated mandate to “CONSERVE WILD SALMON” — has not been able in the last fifty years to hire or contract out a “veterinary scientist” to take a broad view…?

Project 2

Did you read my commentary on Project 1?

Ummm, wouldn’t “contaminants” in relation to “distribution of sockeye Conservation Units” (CUs) be a pretty key component of a Wild Salmon Policy that apparently contains somewhere between 35-45 Sockeye CUs in the Fraser River (it’s constantly changing)…?

Oh no… well… hold on a second… we do have a Wild Salmon Policy in Canada… we have for five years as legislation and well over ten as draft legislation…

Project 3

Now there’s a thought… great plan. I’ll be looking forward to reading the report on this project… but wait a second… wouldn’t this also be a pretty damn important part of a DFO staffer job description? Wouldn’t this be a crucial part of implementing an effective Wild Salmon Policy?

Project 4

Last time I checked it was called the: Department of Fisheries and OCEANS… 10,000 FTEs and there isn’t a specific research arm looking at this…?

Project five

Well… HELLO Province of British Columbia… wasn’t this your mandate? Oh yeah, the courts just determined that the federal government screwed up ‘royally’ when they handed the management of salmon farms to the Province… And how does that new proposed salmon farm legislation look?

(ever heard the expression “dilution is the solution to pollution”?  Yeah, it’s also the solution to drafting legislation…)

Projects Seven and Eight

uh huh… please refer to previous comments. Last time I checked it was called the Department of FISHERIES and OCEANS

Project nine

Looking forward to reading this one as well… however, there is also this brilliant concept out there… it’s been around awhile… PRECAUTIONARY PRINCIPLE… (I use it from time to time when I drive through a traffic light intersection…).

By the way have you seen Environment Canada’s Frequently Asked Questions (FAQs) on Climate Change… it’s only about 52 pages… nice light read. What do you think this report will get to? (triple that… quad… quint…)

Project 10

Could be an interesting read… However, please refer to job description of DFO researchers tasked with this… oh wait… there isn’t one.

“Over-escapement”? Please read Joseph Campbell’s many fascinating books on myths and storytelling.

This is a concept crafted about the same time as Kraft Dinner. How can there be such a thing when the same Fraser River once supported sockeye populations of over 160 million fish on peak years?

Project eleven

Another good read, I’m sure. I’m very curious about the economic analysis (see numbers from last year on #1 most popular post on this site $2 for one wild salmon) and DFO’s abilities…  Just wondering if this will be like reading Tolstoy’s War and Peace… rather longgggg…

Project twelve

Great idea… DFO where you been on this one. Isn’t there a “no net loss” to habitat policy? And really… how does one replace over 100 streams lost in the lower Fraser Valley over the last few decades due to urbanization?

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Now I recognize my posts can sometimes can get a little long and windy… but how many pages do you think these twelve research reports will entail…. 2500 pages…? 5000 pages…? 10,000 pages?

I seem to remember a press release from the Cohen Commission not that long ago explaining delays in the hearing process due to the hundreds of thousands of DFO documents flowing into their offices like the landslide near Pemberton.

So now, there are close to 100 days of hearings scheduled from October through the New Year (five days a week for 20 weeks) for individuals and organizations granted “standing”… there are days and days of hearings for public presentations throughout the Province… and now the Commission is “considering other processes for exploring the various technical and scientific issues”…

PLUS, these twelve projects:

In most cases, the researchers will provide the commission with a progress report by November 15, 2010 and a final report by January 31, 2011. These reports will be peer-reviewed with researchers and external reviewers providing critical analysis. The researchers will summarize their findings and conclusions during the commission’s public evidentiary hearings in the winter, at which counsel for participants will have an opportunity to question the researchers and test their theories.

AND THEN… Justice Cohen is going to analyze all of that and come up with a FINAL REPORT by May 2011 (nine months from now).

Give me a break folks.

One, if Justice Cohen and his crew does achieve this by May 2011 – award them the Nobel Prize or something equivalent.

Two, if the Commission achieves that deadline… how good will their analysis and recommendations be?

Three, if the analysis and recommendations are watered down due to tight timelines.. has the whole exercise really been worth it?

Four, where the ^@#! has DFO been the last five decades on all of the “Projects” announced above?

Lastly… how is someone from the general public, a First Nation, a youth, or otherwise (with much knowledge that may not be “pre-eminent” scientific) be able to review these twelve projects and every other piece of paper pumped out by the Commission and then provide feedback and input?

This “Commission” is simply turning into the realm of lawyers, scientists, and “pre-eminent experts” with very little opportunity for truly informing the public, truly informing youth that will inherit this issue, or providing a true opportunity for public participation. Oh wait, if you’d like to make a public presentation you have to keep it to 10 minutes… thanks for that…

Public input = presentations capped at 10 minutes (sadly, this may be labeled as: tokenism)

Folks and organizations granted “standing” = well over 100 days of hearings

pre-eminent scientists = At least 12 projects, peer review, potential panel discussions, and review by folks granted “standing”, and thousands upon thousands of pre-eminent academic pages that should gather a good solid dose of pre-eminent dust in coming decades…

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What about the possibility that leaving the “management” of sockeye to pre-eminent scientists and politicians and experts (e.g. Ministers with incredible discretionary decision-making power) could very well be the main issue at hand?

I do remain hopeful that Justice Cohen and his staff can come up with something that can truly make a difference… however, sadly, as the process is being made up along the way and the paper production starts to resemble ten year’s production from a Prince George pulp mill… I get a bit sad.

Is this simply a $15-$20 million paper production exercise…? will it come up with anything better than the last five public inquiries into the issue in the last 20 years?

Good luck…truly.

I hope that this is the pre-eminent public inquiry that truly creates the change in how we look after Fraser sockeye — once the pre-eminent sockeye run of the world.

Fraser sockeye: Certainty about uncertainty…

If there is one thing we can all be absolutely certain about… it’s all the uncertainty surrounding: “what the heck is going on out there?”

Last year being the classic case — in the neighborhood of 10 – 11 million Fraser sockeye forecast to return and only 1.3 million showing up (and in relation to yesterday’s post… that’s showing up to the river – not successfully spawning).

The panic button was pressed — despite the fact that this trend has been in plain view for quite some time (see productivity graph in yesterday’s post and previous posts) and the fact there hadn’t been any Fraser sockeye focussed commercial fisheries in a couple of years. The calls for a public (or judicial as some folks call it) inquiry went out. The Prime Minister acquiesced and Justice Cohen was hired for the job and a $15 million (or so) budget was earmarked.

(Note: last year’s landed value of all salmon in B.C. was only about $20 million — see #1 most popular post on this site — which was based on about 10 million salmon caught… $2 per salmon… makes sense to me…)

And, thus, over the winter and into the spring fishy folks fussed and fumed and freaked and foamed at the mouth and flew (as in hopped on planes and ran around to meetings and summits and think tanks and forums and forever more).

The most popular message of all this was: “WE JUST DON’T KNOW“.

The Simon Fraser University convened Salmon Think Tank was even titled: Adapting to Change: Managing Fraser sockeye in the face of declining productivity and increasing uncertainty.

But wait… there is a qualifier… lots of fishy folks are clear to suggest: “This trend is not due to fishing.” But everything else? – we just don’t know…

_ _ _ _ _

Then began the marketing campaign to ensure that everyone understands that pre-season salmon forecasting is highly inaccurate… (no, wait)… speculative. There are comparisons of pre-season forecasting to weather forecasting — see earlier post and that weather forecasting is far better, far more tools, far more funding and so on and so on.

washed up squid near Tofino 2009 -- Vancouver Sun

And then there’s the squids… yup, big Humboldt squid off the coast of BC.

Last summer, I saw hundreds of them washed on the beaches of Haida Gwaii. Our kids were fascinated… except the smell…

The rumour is that these pack-hunting squid may be preying upon baby salmon as they set out on their migration. Pecking them with their beaks and preying upon them with vicious pack mentality…

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And thus the fishy folks ask:

Is it changing ocean currents? conditions? competition in the North Pacific from hatchery and salmon ranching efforts around the Pacific Rim? ocean acidification?

It’s not overfishing.

Is it pollution? logging? mining? sewage? urbanization?

It’s definitely not overfishing.

Is it agricultural run-off? water draw down for irrigation? expanding Vancouver suburbs…?

It’s certainly not overfishing.

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And… well… it appears that DFO has also bit onto this bottom-bouncing bait… hook, line, and sinker… (pardon the ridiculous puns).

Or, simply believe — like so many others — that killing about 80% (and more) of a species year in and year out since the 1950s (and probably longer) is simply not a problem…

Salmon Think Tank -- December 2009

(I suppose maybe some of the folks suggesting overfishing is not the problem — haven’t read the popular bestseller “The Tipping Point” by Malcolm Gladwell.)

The point I am getting at here (in my long-winded way) is that in the first year in four that the Fraser River is finally seeing some decent returns of sockeye — DFO starts opening commercial and sport fisheries like U.S. Banks handing out sub-prime mortgages.

Or maybe a better comparison would be — after the collapse; how George W. started handing out TARP relief to failing U.S. Banks or General Motors.

It seems this year, that Fraser sockeye fisheries are being opened like there was never really a problem.

Lower productivity… what lower productivity?

Endangered stocks with the lowest productivity on record? Whatchyoo talkin ’bout?

Cohen Commission what? ahhh… don’t worry about them; we buried them in more documents then Conrad Black’s legal travails…

Constitutional and legal obligations to meet First Nation food, social and ceremonial needs? ahhh, we did that, like, twenty years ago…

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I still find it fascinating that the Fisheries Minister (obviously informed by her senior staff) found it necessary to suspend the fisheries portion of all Treaty negotiations in BC (there are about 150 First Nations — of 200 or so in BC — with some dependence on Fraser sockeye) while the Cohen Commission is underway.

DFO staff were also directed not to attend the Simon Fraser University Fraser Sockeye Summit in late March 2010: “because of Cohen Commission commitments”.

I attended an international salmon summit in Portland, Oregon earlier this year and some DFO staff were unable to attend to make scheduled presentations because of Cohen Commission commitments (at least that was the word at the conference).

I’ve been at various meetings with DFO through the pre-season and there were various rumblings of commitments to the Commission and thus dropping other commitments.

And yet… and… yet… DFO staff has found more than enough time to open commercial and sport fisheries on Fraser sockeye (and apparently analyze all the risks associated… see below).

This despite all the uncertainties. This despite significantly elevated water temperatures in the Fraser River (approaching 20 C, which can be lethal to many Fraser sockeye stocks). This despite the fact that the Cohen Commission has over 100 days of hearings scheduled (five days a week) starting in October through to 2011. This despite productivity levels that are hanging around in the basement.

What, really, would be the “danger” of just leaving Fraser sockeye fisheries closed and allowing as many fish as possible get upstream?

Granted, I do understand that there is an impact on commercial fisherfolks — especially the small family operations — however, with DFO paying out $80 – $90 million per year to First Nation fisheries initiatives, multiple millions to license buy-back schemes, and the feds granting an approximately $15 million budget, or so, to the Cohen Commission — I’m sure some funding could be found to assist hurting fisherfolks.

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Here is DFO’s stated approach to “Conservation” as stated in this years Integrated Fisheries Management Plan (IFMP):

2010 South Coast IFMP

“…Management actions will be precautionary and risks will be specifically evaluated…” Important point, don’t you think?

I still haven’t seen the specific evaluation of risk that suggests the inherent mixed stock fisheries that have been opened on Fraser sockeye this past week are the best for the “social and economic values that are derived from them” or reduce the risks of long-term impacts.

Nice words on paper; uselessly implemented.

Certainty about uncertainty… you bet. Uncertainty about certainty…uh huh.

Fraser sockeye commercial fishery opening; first time in over 3 years… but, how do you spell precautionary approach?

The other day I listened in to the Pacific Salmon Commission and Fraser Panel (component of Commission) conference call updates on the status of Fraser River sockeye. On the decent news front… it appears that one of the “groups” of sockeye is returning higher than pre-season forecasts.

The “Early Summer” sockeye run comprised of various upper river stocks had pre-season forecasts of just over 780,000 and now in-season estimates are suggesting about 950,000 sockeye. Some conservation measures were proposed on the “Early Summers” to protect some of the more endangered stocks within that group, for example the sockeye that return to the Bowron River east of Prince George, BC.

You know, the same Bowron River that sports what was once referred to as one of the biggest contiguous clearcuts on the planet… In my younger days, I spent the better part of several treeplanting seasons in the Bowron Valley Area trying to kick start the reforestation process so that another of the great human monuments that can be seen from space might begin to regenerate.

The Upper Bowron Spruce Beetle Outbreak: A Case History

Check out the The Upper Bowron Spruce Beetle Outbreak: A Case History. At the peak of the madness in the early 80s it is estimated that 700 loaded logging trucks a day were leaving the Bowron.

Coordinated harvesting operations removed 15 million m3 [a m3 — cubic metre — of wood is approximately one telephone pole] green attacked timber between 1981 and 1987. This amount of raw material could produce enough lumber to build 900,000 average 1,200 square foot homes! Logging trucks, with radiator caps touching the red flag of the truck in front, carrying 15 million m 3 of logs would stretch for 5,300 miles.

But, alas, there’s probably no connection between the dwindling Bowron sockeye and the intense deforestation in that area in the 70s and 80s… (however, I digress…)

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On the conference call, I am quite sure that I heard the Chief Biologist from the Pacific Salmon Commission suggest he had no recommendations on opening a fishery just yet because the “Summer” group of Fraser sockeye appeared to be running late. The “Summers” had a pre-season forecast of just over 2.6 million. This ‘group’ is comprised of the famous runs to the Quesnel River (e.g. Horsefly and Quesnel Lakes, east of Williams Lake) and the Chilko run, west of Williams Lake, plus two up-river stocks in the Nechako River, northwest of Prince George.

If the “Summers” return at pre-season forecasts then there will most likely be some commercial fishing opportunities — the first in over three years. However, with the “Summers” running late.

At least that’s the hope…right. You know how it is when you get stood up for a date. For the first little while you think… “oh, she’ll be here soon, she’s just running late…” And then you move to: “oh gee, I hope she’s OK and nothing happened…”. Then reality begins to set in: “shit, she’s not coming…” Then disappointment and anger… rejection.. and so on.

Ok, I’m not speaking from experience, just hypothesizing that that’s what it feels like…

The point being, that I seem to remember last year this thought of: “gee… they must just be running late…” Soon to be followed by some slight concern… then panic… then denial… then a judicial inquiry… then burying the judicial inquiry in hundreds upon hundreds of thousands of documents…

You probably get my point.

So, what I heard suggested was, maybe we shouldn’t go fishing on the “Early Summers” yet because that would mean we might start hitting “Summers” and we don’t have enough information for an in-season estimate on the “Summers” yet. So we better hold off for now.

I’m positive that something to that effect was said by the fisheries scientists in the group. (and please correct me if I’m wrong, however, I’ve also had that confirmed by one individual within Fisheries and Oceans)

See, and something like that must have been said because when you look at the Pacific Salmon Commission news release for Tues, Aug. 3 it states:

Pacific Salmon Commission news release

So no in -season “Summer” forecasts for a few weeks yet. And as a result:

Pacific Salmon Commission


Ok, that seems pretty definitive. “Remain closed to fishing”

But then on Wens, Aug. 4th I receive a press release from the Department of Fisheries and Oceans (DFO) dated Aug. 3rd:

Fishery Notice – Fisheries and Oceans Canada

Subject: FN0587-Salmon: Fraser River Sockeye Update – August 3 – Areas 11 to 29

Based on the observed migration of Summer-run sockeye through the marine  approach routes to-date, assessments of abundance are less than expected if  their arrival timing is similar to pre-season expectations. Based on later run  timing for Early Stuart and Early Summer runs, Summer-run stocks may be  migrating later than expected but it is too early to confirm run size.

Proportions of Summer run stocks are approximately 30-40% of marine test  fisheries catches. The estimated escapement of Summer-run sockeye past Mission  through August 2 is 218,000 fish.

The following fisheries are planned:

Licence Area B seine will open daily from 6 AM to 9PM on Thursday, August 5,  and Friday, August 6, in portions of Management Area 12 and 13.

Licence Area D gill net will open 6 AM to 3PM in portions of Management Areas  11, 12 and 13.

And so… the “theory” is that these openings are targeting “Early Summers” not “Summers”.

This is the justification passed along to me anyways… yet if one looks at the test fishing scale sample information it appears that there could be as high as 30%-40%  “Summers” in the areas (e.g. Area 12 and 13 — near Campbell River on Vancouver Is.) — as pointed out in DFO’s own press release.

So, even though DFO’s own press release suggests there is no in-season estimate of “Summers” (and that they are just “late”) and the Pacific Salmon Commission says they don’t have enough information to predict “Summer” sockeye run size, and that the PSC suggests that Canadian waters “remain closed to fishing”.

…There are commercial nets in the water right now as I type, catching Fraser sockeye.

Makes sense to me… does it make sense to you?

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Maybe everyone is just so eager to prove how “sustainable” the Fraser sockeye fishery is after the Marine Stewardship Council (MSC) “eco-certified” it officially the other day.

Curiously, the MSC defines the precautionary approach as (and it’s a mouthful):

Precautionary approach – A set of measures and actions, including future courses of action, which ensures prudent foresight, reduces or avoids risk to the resources, the environment, and the people, to the extent possible, taking explicitly into account existing uncertainties and the potential consequences of being wrong.

Oh yea…

how do you define precautionary approach?

Does it include opening purse seine fishing opportunities on limited information and unavailable in-season population estimates?

Does it include opening fishing opportunities while there is a judicial inquiry (Cohen Commission) into declines on Fraser Sockeye?

I do find it remarkable that the Department of Fisheries and Oceans suspended all fisheries aspects of First Nation Treaty negotiations in B.C. with the justification that we must wait until Justice Cohen releases his findings…

Yet, DFO still thinks that their ability to “manage” Fraser sockeye is acceptable… hmmmm.

Who’s in charge here?

wild salmon dissonance and patchwork quilts for fisheries managers

Dissonance, the Free Online Dictionary suggests means:

Wild Salmon Policy?

1. A harsh, disagreeable combination of sounds; discord.

2. Lack of agreement, consistency, or harmony; conflict.

Under the first definition I was privy to some serious dissonance this past week while sitting in salmon-related  meetings listening to a senior Department of Fisheries and Oceans manager run circles around questions. At one point, he was even asked for a “yes” or “no” answer; yet a long-winded response would start winding up…

“No, no… I said YES or NO, please” said the questioner again.

“Well… yeah… but… you need to understand…” said the bureaucrat.

One of the most offensive ways to answer a question or begin any explanation is: “you have to understand…”

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Part of the meeting involved discussions around Fraser sockeye and predicted returns. Of course, this type of discussion involves the computer simulation model Fraser River Spawning Sockeye Initiative (FRSSI) which apparently pumps out fishing plans, or “TAM rules” (total allowable mortality). This model is great for theoretical understandings of biological organisms — like Fraser sockeye — but an absolute joke for “managing” biological organisms in the wild — like Fraser sockeye.

Worse yet (and you can read more on previous posts on this site) the Fraser River is suggested to have approximately 200 distinct sockeye populations or stocks; and approximately 150 different spawning areas, and countless nursery lakes. The FRSSI is based on information on 19 stocks or populations, much of that information spotty at best, and only about 50 years of data which means approximately 12-15 life cycles of sockeye. Those 19 stocks are further simplified into four groups based on the timing of their upstream migration and spawning.

The model has various productivity scenarios fed in (again spotty estimates); with the added benefit that DFO only studies two sockeye rearing lakes (yeah that’s 2).

Worse yet, the FRSSI model does not incorporate any data prior to about 1948 when DFO started keeping records.

Worse yet, the model has no ecological values factored in — things like seals, bears, eagles, and so on. It simply sets fishing rates and guesstimates how many sockeye need to reach spawning grounds.

It’s supposed to be “Pilot Study” and is listed as such in DFO promotional material… yet, it’s being used to “manage” sockeye on the Fraser, even though there hasn’t been a commercial fishery in three years (that will probably change this year…).

However, I suppose one positive out of this is that the maximum fishing rates (maximum sustained yield – MSY) is now 60% of total run size, not 80% as it has been in the past….

Salmon think tank... salmon fisheries in the tank...

_ _ _ _

The second definition of dissonance occurred in the same meetings last week when DFO reps started presenting information on Fraser River Chinook: pre-season forecasts, proposed exploitation (a.k.a. fishing) rates, and various forecasted population scenarios with proposed fishing rates:

The 5 represents the age of these fish and the small subscript 2 represents how many winters they spent in fresh water as babies (i.e. fry) and the Spring and Summer referring to timing of their migration.

Estimates for this year suggest a run of these Chinook somewhere between 58,000 and 62,000; however, not a lot is known about these fish and they represent a huge geographic area in the various Fraser tributaries that they spawn in – from the far upper Fraser to tributaries downstream through Williams Lake (Chilcotin) and Thompson River and tributaries.

I asked what seemed like the obvious question to me: “what is the rate for maximum sustained yield (MSY)?… is it 80% of the run — like in the past; 60% like it is with sockeye now; 50% like many Alaskan salmon runs are managed to?”

“Well, you have to understand…” began the DFO rep…

Eghad, here we go again.

“…these Chinook are managed differently… it’s based on habitat capacity and output…so it’s not a set rate”

“Gee… that sounds accurate”, was the response that slipped out of my mouth.

I was given a name of a DFO scientist working in Nanaimo that is apparently the expert on this: “Parken”.

_ _ _ _

I looked up his work (apologies, I’m assuming it’s a he… i think I heard the pronoun “he”). I came across a report on the Canadian Science Advisory Secretariat: Habitat-based methods to estimate escapement goals for data limited Chinook salmon stocks in British Columbia, 2004

Seems like some pretty interesting work… although I was struck immediately by a key phrase in the title: “data limited“.

There’s another way to phrase that, that might be more accurate: “limited data“.

In other words… we don’t really know because we have limited data.

And this is laid out quite clearly in the report, even in the abstract:

Our habitat-based model can generate biologically-based escapement goals, rooted in fish-production relationships, for data limited stocks over a broad range of environments. This simple approach requires easily acquirable data and makes few assumptions. However, spawner escapements of known accuracy and reliability are required, which may impede implementation for some systems. The approach is well suited for most data limited stocks in BC and can be tested and refined as new stock-recruitment data become available. Since the habitat-based method was more accurate than the interim method for BC Key Streams, we recommend applying it for data limited stocks in BC to establish escapement goals until more stock-specific data are available. [my emphasis]

Again… as mentioned previously in other posts. My comments are not meant to be a jerk; just pointing out some gaping voids and massive assumptions. Sometimes these assumptions are pointed out in papers and reports; yet, many/most fisheries science folks still talk in circles around them. It’s as if the massive assumptions and “data limited” experiments are a personal affront against them and their “science”.

Our goal was to develop a habitat-based approach to generate escapement goals for data limited Chinook stocks in British Columbia (BC). We focused on developing a model with general applicability that could be applied inexpensively and quickly, while making sufficiently accurate predictions to suit fisheries management purposes.

That’s the problem in most cases… “fisheries management” is more speculative then investing in penny stocks sold out of some guys basement. And thus the “purpose” of fisheries management is to carve out as many fish as possible for human consumption, economic opportunities, and social considerations — then think about the environmental/ecological implications…thus “sufficiently accurate” for fisheries management?! Yikes…

We focused on developing simple models that lacked biological detail, yet described general biological patterns across a range of environmental conditions and Chinook salmon biology. Inasmuch as high precision and accuracy are desirable properties of models, we aimed to develop a method with reasonable accuracy and precision for most domestic and international fisheries management purposes.

But isn’t “biological detail” the whole purpose of looking after fish populations and all the critters that depend on them?

Yes, precision and accuracy are desirable properties… especially if you work for the same federal department responsible for decimating North Atlantic Cod.

There’s a big important word missing after the “properties or models” and the “,” (comma); it’s “BUT”…

As in “… , but we aimed to develop a model with reasonable accuracy”

“Reasonable” accuracy…?! what the ^*!#?

reasonable to whom…?

Is this like the legal test: “a reasonable person…” or is this like “reasonable” to fisheries management folks… or “reasonable” to a Fisheries minister with a long distinguished career with Revenue Canada.

Sorry folks, but the history of “reasonable accuracy and precision for domestic and international fisheries management purposes” is brutal. There’s a reason why the oceans have lost 90% of large predator fish and 75% of the world’s fish populations subject to fisheries pressure are in trouble.

Time for a new paradigm.

Is this a wet blanket?

And maybe time for DFO to stop managing salmon via a patchwork quilt of methods…

Or at least fully admit limitations — especially “data limited” limitations — and get a whole lot more precautionary. Oh wait, isn’t the precautionary approach part of the Wild Salmon Policy…?

All models simplify reality in order to improve understanding…(hmmm)

“All models — in physics, biology, or economics — simplify reality in order to improve our understanding of it.” So suggests my Economics textbook.

"ANGEL " doll face, toy wings, tape, bathroom scale approx 6 x 12" by Simon Davies

Is it me… or is “simplify reality” sort of like an oxymoron. It rings in the same frequency of Department of Fisheries and Oceans new favorite phrase: “low abundance”.

Yeah… “low abundance” is the new phrase used often in meetings by DFO to describe crashing Fraser River sockeye runs and other dwindling BC wild salmon populations. Yup, “abundance” the word that means: “a profusion; a great plenty; an overflowing quantity.”

So what is a “low” overflowing abundance?

I’m not sure if the phrase is used purposefully, or just one of those bureaucratic bumpf phrases spawned from the hallowed halls of government expediency. (I’m getting into the spirit of it…).

It’s sad, really. It’s the same innocuous phraseology that suggests that innocent people killed in western airforce bombings in the Middle East are “collateral damage” or that “terrorists are hiding behind human shields…”

It’s the same cardboard phraseology that suggests that ‘biological models’ or ‘economic models’ —- “simplify reality”. Not forgetting that the word reality means “the quality or state of being actual or true.” So how is it that we “simplify” things that are in a state of being actual or true?

If we simplify these things… does this not mean that we then subtract from the “actual-ness” or “true-ness” of these things?

_ _ _ _

“High school biology teachers teach basic anatomy with plastic replicas of the human body. These models have all the major organs — the heart, the liver, the kidneys, and so on. The models allow teachers to show their students in a simple way how the important parts of the body fit together.” — (more from my Economics textbook).

Is this “simplifying reality”?

Well, no… because as much as certain components of the human body can be displayed in plastic, with pretty painted colors, it does not answer many of the great mysteries of life, or mysteries of the human body.

“Of course, these plastic models are not actual human bodies, and no one would mistake the model for a real person. These models are stylized, and they omit many details. Yet despite this lack of realism — indeed, because of this lack of realism — studying these models is useful for learning how the human body works.”

Sort of.

It teaches how bits and pieces work — like food goes in, poop comes out. Blood moves through veins and arteries and the heart beats to pump it through, and so on, and so on… However, these “models” don’t give us enlightenment into the human brain and the mysteries therein.

Economists use models to learn about the world, but instead of being made of plastic, they are most often composed of diagrams and equations. Like a biology teacher’s plastic model, economic models omit many details to allow us to see what is truly important.

There’s the fundamental issue. I’m curious, who is making the value call on: “what is truly important”?

This is like suggesting that the “models” of a Paris runway fashion show: “allow us to see what is truly important”. (personally, seeing someone’s hip socket and all their ribs is not really my idea of reality — especially in a society that currently includes over 60% of the population obese or overweight).

Or that the “reality show” Survivor models reality of a group of people surviving on a deserted island — when we know that this reality, in true actuality, can mean cannibalism and desperate choices (watch the movie or read the book “Alive: the story of the Andes survivors” by Piers Paul Read)

This is the same set of assumptions that suggests that looking under the hood of a car allows people to see “in a simple way how the important parts of the car fit together” and that we therefore understand how the car runs. Well… no… we might understand the mechanics, but this does not mean we understand combustion and how that combustion is harnessed and how the oil needed to be extracted from the earth to make that car run, and how that oil is comprised of long dead critters, and how the oil was transformed into gasoline, and how the engine parts are comprised of various minerals that needed to be mined somewhere, and so on, and so on.

This is exactly the issue.

If economists assume that they understand human economies through diagrams and equations — i.e. “simplifying reality”; and that doctors understand human bodies through plastic replicas; and that biologists understand ecosystems through mathematical equations and computer programming… well… then we have some serious problems on our hands. (and we do).

(not to forget that I listened to a Dr. in economics explain at a recent conference in Portland — in no uncertain terms — that no system exists for modeling social and cultural impacts of economic decisions. This is an important point in relation to yesterday’s post re: Taseko Mines proposing to turn Fish Lake into a waste rock – tailings facility — Or, in relation to crashing BC salmon populations and the social and cultural impacts on First Nation and settler societies)

_ _ _ _

So how do we deal with some of these issues?

"Dancing Block Head" by Simon Davies

Well… we create empty, innocuous language that skirts around the margins of the issues — rather than get right into the heart of the issues. (Or, we create another model… that “simplifies reality”…). We convene about 5 – 20 meetings, teleconferences, and conferences per month and talk around the issue, collect our healthy day rates and per diems and full benefit packages, eat our greasy hotel breakfast, and await the minutes from the last, and agenda for the next…

We call crashing salmon populations — “low abundance”. We call people maimed and killed by incredibly destructive and non-selective weapons — “collateral damage”. We have government institutions say things like “conservation is our number one priority” but then prove time and time again that “conservation” doesn’t actually mean don’t do something at all (e.g. fishing an endangered population of fish) — it actually means government agencies will “balance perspectives and stakeholders”.

(Meaning: thou with the most lobbying power will be succesful)

For example, “conservation” of Early Stuart Sockeye in the Fraser River right now (a once great population, now a mere shadow of its former self in less than 100 years) means catching an estimated 10% of the population every year in “test fisheries”. So we are forcing this population further down the road of extinction, for the simple purpose that we can count it.

Why do we need to count it?

Because we need to put those numbers into more models and equations to predict the overall run size (i.e. “simplify reality”).

Why do we need to predict the overall run size?

So that we can go fishing.

This is brilliant.

_ _ _ _ _

“Simplify reality”… that’s what we need models for.

Models like the Fraser River Spawning Sockeye Initiative (FRSSI), or other various fisheries models and equations utilized by fisheries management institutions — are meant to “improve our understanding”.

So I’m wondering how that “improved understanding” through the “modeling” — i.e. simplifying reality — of salmon runs, through “conservation first”  — i.e. conservation = some of us are going fishing — is assisting us these days?

Wait… I have the answer: last year on the Fraser River 10 million sockeye forecast; 1 million actually returned.

Yup, models… they simplify reality.

I don’t know if it gets much simpler than: we’re F^*^%d unless we start meaning what we say, and saying what we mean.

Difficult decisions: if not now; when?

Doesn’t the great hallowed phrase “sustainable development” mean something to the effect that we have to ensure we leave something for future generations?

High time for more real business and less fishy business in DFO?

This is not one of those red-neck leaning commentaries on First Nation organizations — this is directed at the many shoes that must drop at the Department of Fisheries and Oceans (DFO). This is also a commentary based on some pro bono work I do for a First Nation community in an ‘isolated’ area of British Columbia. And some commentary on the challenges of politics, deal-brokering, and negotiations that involve healthy day rates, many jet flights, and endless per diems — that will continue to stifle actual progress, actual implementation, and real “action” (not plans for action – as in “Action Plans”).

National Geographic

At the same time, it’s not to take away from places where good work is being done, where some results can actually be demonstrated, and relationships are changing for the better.(I’d be happy to hear about these…)

The aboriginal organization I attempt to assist straddles a fascinating part of the Province; they have part of their territory in the Fraser watershed, part of their territory in the Skeena watershed, and part of their territory in the Arctic (Peace/Mackenzie River drainage). The once huge sockeye runs that spawned in the upper Fraser watershed, are going the way of North-Atlantic Cod; and thus this community is left to catch their food fish (for a community several hours from the nearest paved road and grocery store) in the headwaters of the Skeena watershed (a long journey from the main community).

(Sturgeon in the Fraser, and specifically in this area, are already parallel with North-Atlantic cod…)

In the Arctic drainage portion of their territory, fish such as grayling and rainbow trout have been heavily impacted by that fine engineering feat: WAC Bennett Dam and 350+km long Williston Reservoir downstream — the same body of water that has a fish advisory suggesting only one fish a year is suitable to eat (due to significant levels of mercury – natural leaching and from the trees that were never logged prior to flooding).

Throw in the apparent benefit of over a hundred years of placer mining for gold (when a stream bed is turned upside down and hosed out to find gold nuggets), multiple decades of logging, and now the scourge of online mineral staking and mineral exploration.

Twenty minutes from the main community is a 1940s mining relic — a mercury mine that has never been properly cleaned up and still leaches mercury into the surrounding environment. The same road that accesses the old mine is now used by another mineral exploration company with a large, active drilling program zeroing in on a potentially large copper-gold deposit.

In the community itself, cancer rates and other illnesses — e.g. diabetes, strains of which are now being linked directly to Persistent Organic Pollutants (POPs) like PCBs and other chemicals that exist for a long time and build up in food chains — exist at scarily-high rates.

_ _ _ _ _

A visit to Fisheries and Oceans Canada website: Fisheries and Oceans Canada  Departmental Plan for Transfer Payment Programs 2010-13 shows all of the planned annual transfer payments to various programs over the next few years. Within the Fisheries and Aquaculture Management program there are a variety of programs with upcoming annual transfer payments. For example the Aboriginal Fisheries Strategy (a program in existence since 1992 following the Sparrow decision in the Supreme Court of Canada) will have transfer payments of approximately $32.3 million each year.

The Aboriginal Aquatic Resources and Ocean Management (AAROM) program — which funds aboriginal coalition or collaborative organizations — will have transfer payments of almost $14 million per year. Part of this program includes license buy-backs in the commercial sector.

The Pacific Integrated Commercial Fisheries Initiative (PICFI) will have transfer payments of approximately $35.5 million. Parts of this are also commercial license buy-backs.

Other programs of note: the Pacific Salmon Foundation will receive close to $1 million; the Fraser Basin Initiative $1.1 million; and the Maa-Nulth treaty settlement (west coast of Vancouver Island) $3.4 million.

Rough total for transfer payments related to Pacific salmon management: just under $90 million per year.

This does not include DFO staff costs – of which if you’ve seen earlier posts – on the Draft 2010 Integrated Fisheries Management Plans (IFMPs) close to 100 staff are listed as contacts in relation to these plans. And thus could we say on the very, very low end each of those staff cost about $100,000 each when one adds in wages, benefits, employer costs, and travel. Is my math right to suggest that’s about $10 million? (on the very, very low end. Travel adds up in a hurry. For example, for me to attend two days of meetings in Kamloops, BC traveling from Prince George, BC is easily over $1000 a pop in travel and meal costs alone. I was at meetings recently where DFO showed up with 13 staff members to a meeting where 2 would have sufficed).

What’s my point here?

Have you seen my post (it appears to be rather popular) — $2 for one wild salmon… do you see a problem?

Last year the landed value of wild salmon was only $20 million.

Are there some imbalances at work here….?

_ _ _ _ _

And how much does this aboriginal organization I do research for receive in Fisheries funding?


This organization is part of a tribal council that receives approximately $300,000 in funding from fisheries — however this is largely project-based funding, with a focus on counting fish (enumeration). Plus this tribal council represents approximately 6 different communities in its fisheries work, so that the $300,000 does not go far. Probably pays for about two staff members and some sporadic project funding — this across a substantial geographic area and is only focussed on the Fraser River watershed.

So where is the $90 million or so of funding going?

And what happens when there’s no more salmon to count? Will DFO then actually begin doing habitat restoration work?

_ _ _ _ _

One is left asking — are there any evaluations of these programs?

In a 2007 evaluation of the AFS program:

The evaluation concludes that the AFS assists DFO to manage fisheries in a manner consistent with the decision of the Supreme Court of Canada in Sparrow and subsequent decisions. The AFS also relates directly to DFO’s strategic outcome of Sustainable Fisheries and Aquaculture.

The relevance of AFS to the public interest is amply demonstrated in that the AFS works to build stronger relationships and improve the quality of life of Aboriginal peoples in Canada, and facilitates the participation of Aboriginal peoples in modern fishing and aquatic resource management.

These statements are made early in the paper, and yet when one reads to find any substance to these claims, for example, for an isolated community that received absolutely zero funding even though they straddle three major watersheds. Apparently there is a process of DFO evaluation called: Results-based Management and Accountability Framework (RMAF).

A RMAF was developed for the AFS in 2003, providing a strategy for measuring the performance of the AFS through the identification of expected outcomes. The RMAF also identified the data requirements that were to be used to assess the achievement of the expected results of the Program. The formative evaluation team encountered a number of challenges that affected its ability to assess achievement of the AFS program’s expected outcomes.

…The data required to support the outcomes and performance indicators was not collected in a systematic manner that would allow for the RMAF to be used as an effective management tool. The evaluation also found that some outcomes and indicators identified in the RMAF may no longer be relevant and need to be validated. In addition, accountability for data collection had not been effectively assigned

…A second challenge was that a planned national database had not been implemented at the time of the evaluation….

…A third challenge was that the quality of reporting from some Aboriginal groups, especially those with smaller agreements, was either weak or absent in many instances

In other words, in 15 years of the program by the time of this evaluation — and 4 years of a renewed program certain basic evaluation tools were never put in place. That makes sense at over $30 million per year:

“The relevance of AFS to the public interest is amply demonstrated”

… is that so?

_ _ _ _ _

The Aboriginal Aquatic Resources and Ocean Management (AAROM) program isn’t any better.

In a 2009 an internal evaluation of the program was released by DFO.

AAROM was a 5-year contribution program from 2004-05 to 2008-09. Participation in this program was voluntary and the funding totalled $51.0M over five years.

The internal evaluation found that this program ran pretty ad hoc and loose:

A Performance Measurement Strategy, that identified expected results as well as the indicators and data collection methodology to assess them, had been prepared for AAROM.  The strategy, however, was not fully implemented.  Individuals involved in the program explained the successes of the program, however, much of this is based on anecdotal information and not on concrete reliable performance information.

Success of this $51 million program is based on anecdotal information?


It gets even better – and remember this is an internal evaluation…fishy folks investigating fishy folks:

At the time that AAROM was implemented in 2004, a Results-based Management and Accountability Framework (RMAF) was prepared for the program.  The RMAF included a performance measurement strategy (PMS) for the program.  This strategy was never implemented.

While the RMAF set out criteria for assessing the program, the information needed was unavailable as this had either not been collected or where collected, it had not been consolidated in a manner to allow for program assessment.

The Aboriginal Policy and Governance Directorate (APG) had planned to implement a database that would capture key information that would measure the performance of the program.  This database has not been put in place and remained under development at the time of the evaluation.

[still in development 5 years into the program? are you kidding me?]

The non-implementation of the the PMS and the absence of the database to accumulate performance information limited the evaluation team’s ability to fully assess the program.

So how the heck does anyone know these multi-million dollar programs are doing anything effectively…?

_ _ _ _ _

Is it time for third-party management of DFO?

Maybe more folks with business backgrounds and a little less fishy experience?

Cohen Commission — more sticky territory

The fuss over the Cohen Commission — Public inquiry into Fraser River sockeye declines — continues. Apologies, I’m a day late on this article from Mark Hume at the Globe and Mail:

cohen commission:  Salmon inquiry’s credibility under fire

John Cummins, MP from Delta-Richmond east (Vancouver area) continues his relentless attack on the Commission in two press releases the past couple of days:

The Cohen Inquiry Has Turned Into a Farce

Unfortunately neither Cohen nor his scientific panel see a conflict of interest when these same scientists who made a career out of providing DFO with advice are now placed in the position of evaluating their own work and recommendations,” concluded Cummins.

This is Not a Science Seminar

If the Cohen Inquiry is to regain even a modicum of credibility, the first order of the day must be the replacement of the existing scientific advisory panel with outsiders untainted by any association with DFO and the return of the Inquiry to its original purpose: that of evaluating the policies and practices at DFO that have lead Fraser River stocks to the brink of collapse.

_ _ _ _ _

I define a conflict of interest as “a situation in which a person, such as a public official, an employee, or a professional, has a private or personal interest sufficient to appear to influence the objective exercise of his or her official duties.”

-Michael McDonald at UBC’s W. Maurice Young Centre for Applied Ethics: Ethics and Conflict of Interest

There are three key elements in this definition. First, there is a private or personal interest. Often this is a financial interest…

The problem comes when this private interest comes into conflict with the second feature of the definition, an “official duty” — quite literally the duty you have because you have an office or act in an official capacity. As a professional you take on certain official responsibilities, by which you acquire obligations to clients, employers, or others…

Third, conflicts of interest interfere with professional responsibilities in a specific way, namely, by interfering with objective professional judgment. A major reasons clients and employers value professionals is that they expect professionals to be objective and independent. Factors, like private and personal interests, that either interfere or appear likely to interfere with objectivity are then a matter of legitimate concern to those who rely on professionals — be they clients, employers, professional colleagues, or the general public. So it is also important to avoid apparent and potential as well as actual conflicts of interests.

An apparent conflict of interest is one which a reasonable person would think that the professional’s judgment is likely to be compromised. A potential conflict of interest involves a situation that may develop into an actual conflict of interest.

And this where I think some folks have very legitimate concerns surrounding the appointment of some specific individuals as scientific advisers to the Cohen Commission. It is by no means a suggestion that these well-qualified individuals can not provide top notch, objective information — nor that they lack any caring for salmon — nor that they are not consummate professionals.

The issue is simply with the appearance of factors that might interfere with objectivity, and as McDonald points out its important to avoid “apparent and potential” conflicts of interest as well as actual.

Now I recognize, I might be forced to the gallows for dare questioning the “objectivity” of these important fisheries scientists… however, again, that is not the issue at hand here. The issue at hand, at this point in time, is simply appearance of factors that could impact some individuals objectivity.

McDonald offers some “tests”:

How do you determine if you are in a conflict of interest, whether actual, apparent, or potential? The key is to determine whether the situation you are in is likely to interfere or appear to interfere with the independent judgment you are supposed to show as a professional in performing your official duties…

And, so here we are again with the simple “appearance” of conflict of interest. And here’s a crucial point:

Trust, in my opinion, is at the ethical heart or core of this issue. Conflicts of interest involve the abuse, actual or potential, of the trust people have in professionals. This is why conflicts of interest not only injure particular clients and employers, but they also damage the whole profession by reducing the trust people generally have in professionals.

I think I can safely suggest that maybe the entire profession of “fisheries science” is coming under the microscope at ever finer focus. We are not really awash in examples of “fisheries science” going well; granted it’s not always the ‘science’ that’s the issue but more the lack of brave action by politicians or difficult decisions by industry… and maybe quite a lot of the old tragedy of the commons.

But sometimes it isn’t enough to know that there is a particular private interest influencing a professional’s judgment; the client, employer, etc. expects that the professional will stay out of such situations. So the second way to avoid conflicts of interests is to absent yourself from decision making or advice giving if you have a private interest.

This is a sticky point… are any of the scientific advisers to the Cohen Commission, or the organizations they represent, going to be receiving,  funding from Fisheries and Oceans in the future? (many have certainly benefited from employment, contracts, or research in the past). If so, does this not have the “appearance” of conflict?

McDonald offers some advice:

It may take some skill and good judgment to recognizing that you are in a conflict of interest situation. This is because private and personal interests can cloud a person’s objectivity. So it may be a lot easier to recognize when others are in a conflict, than when you are. This suggests that it may be useful to talk to a trusted colleague or friend when you are in doubt.

But once you recognize that you are in or are headed into a conflict of interest situation, the ethical responses are straightforward: get out of the situation, or, if you can’t, make known to all affected parties your private interest. These responses will preserve the trust essential to professional objectivity.

Conflict of interest can be a gray, shape-shifting, issue — and I think often misunderstood, as, simple “appearance” of this beast, or simple perception,  can often be worse than an actual conflict.

Boreal Forest Agreement… absurdity grows + Greenpeace, read your own material, are you not “polishing a turd”?

Maybe it’s a general feeling in the air… maybe it’s a universal force that has decided to crack down on the waste of hot CO2 emissions — the biggest culprit?

Us. Humans.

It’s called how to say a whole lot, without saying anything at all. Seth Godin has a great short little post on this very issue today — I’ve taken the liberty to replace his example, with empty, meaningless language from the Canadian Boreal Forest Agreement. His post:

But you’re not saying anything

And this is the problem with just about every lame speech, every overlooked memo, every worthless bit of boilerplate foisted on the world: you write and write and talk and talk and bullet and bullet but no, you’re not really saying anything.

It took me two minutes to find a million examples. Here’s one, [“The shared challenge is to address sometimes conflicting social, economic, and, and environmental imperatives in a manner that captures the economic opportunities that are emerging for forest products of the highest environmental quality.”]

Write nothing instead. It’s shorter.

Most people work hard to find artful ways to say very little. Instead of polishing that turd, why not work harder to think of something remarkable or important to say in the first place?

Funnily enough, if you visit the Greenpeace USA website there is an entire campaign dedicated to “Stop Greenwashing“.

Every day, Americans are bombarded with advertising about environmentally friendly goods and services. But how many really are green, and how many are just pretending?

Yeah, Greenpeace, I couldn’t agree more. And how does Greenpeace define this issue?:

These days, green is the new black. Corporations are falling all over themselves to demonstrate that they are environmentally conscious. The average citizen is finding it more and more difficult to tell the difference between those companies genuinely dedicated to making a difference and those that are using a green curtain to conceal dark motives.

Uh, huh. And better yet Greenpeace has four criteria for their “Stop Greenwash” campaign: Dirty Business, Ad Bluster, Political Spin, It’s the Law Stupid.

Dirty Business:

Touting an environmental program or product, while the corporation’s product or core business is inherently polluting or unsustainable. For example, if a company brags about its boutique green R&D projects but the majority of spending and investment reinforces old, unsustainable, polluting practices.

Hmmm, could this maybe be like many of the signatories to this “historic” “world-leading” Agreement. This has been raised by other critics to this Agreement. For example, go visit Environment Canada’s website: National Pollutant Release Inventory for the Pulp and Paper industry. I went to, for example, ID number 1 on the list, which is one Alberta Pacific’s (signatory to Agreement) mills in Alberta.

What is it releasing? Well…in 2008:

  • 171 kg of Arsenic
  • 282 tonnes of Volatile Organic Compounds.(things like formaldehyde, acetone, chlorofluorocarbons — great things for living critters to process).
  • 763 tonnes of sulphur dioxide.

Logging in the Boreal Forest, and particularly this agreement are about: “maintaining essential fibre supply for uninterrupted mill operations” (CBF Agreement website). That fibre supply is meant to keep pulp and paper mills going. Producing pulp and paper at its very nature — is a polluting business.

Thus, Greenpeace, is this Agreement not “allowing companies to brag about [green logging practices but keep the] majority of spending and investment reinforcing old, unsustainable, polluting practices” ?

Sure a couple of caribou might be happier out there in the hinterland — but what about the people that are left breathing, absorbing, and circulating the long time pollutants released from the pulp and paper mills from your partner signatories?

_ _ _ _

Ad Buster:

Using targeted advertising and public relations campaigns to exaggerate an environmental achievement in order to divert attention away from environmental problems or if it spends more money advertising an environmental achievement than actually doing it. For example, if a company were to do a million dollar ad campaign about a clean up that cost less.

Hmmm… so Pew & Ivey Foundations; how much has negotiating, brokering, and funding this “Agreement” cost to this point in time, and over the next three years?

And Greenpeace, what about the Greenhouse Gas Emissions of all the jet flights involved?

worth it?

_ _ _ _ _

Political Spin

Advertising or speaking about corporate “green” commitments while lobbying against pending or current environmental laws and regulations. For example, if advertising or public statements are used to emphasize corporate environmental responsibility in the midst of legislative pressure or legal action.

Ummm, Greenpeace, I’m guessing you’re familiar with aboriginal and treaty rights in Canada… only a “few” outstanding legal actions there. And how many of the logging company signatories have outstanding legal actions surrounding their logging practices and/or pulp and paper production?

Are these companies going to share their current lobbying efforts in all of the Provincial capitals and in Ottawa — surrounding logging practices, effluent and toxins releases, and other matters? What about caps on carbon emissions, or sulphur dioxide, or formaldehyde… like the elevated levels in the Prince George, BC area?

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It’s the Law Stupid

Advertising or branding a product with environmental achievements that are already required or mandated by existing laws. For example, if an industry or company has been forced to change a product, clean up its pollution or protect an endangered species, then uses PR campaigns to make such action look proactive or voluntary.

So when I did a quick search online I found that several (if not all) Provincial governments are already enacting “ecosystem-based management” as a core principle in forestry and other resource industries, for example:

Your B.C. Government is applying ecosystem-based management to protect key elements of old growth forests, such as representative ecosystems, freshwater ecosystems and critical grizzly bear habitat. (Province of BC website: entire site dedicated to ecosystem-based management)

To maintain ecosystem health the Conservation Strategy recommends “that the Government of Alberta and forest land users adopt and implement ecosystem-based forest management as quickly as practicable.

To provide direction for developing long-term forest management plans that are consistent with Saskatchewan’s commitment to both ecosystem-based and sustainable forest management.

A pilot project on the east side of Lake Winnipeg was conducted as a first step to implementing Manitoba’s Forest Plan Towards Ecosystems Based Management. The forest plan is a long-term framework to create ecosystems-based forest management.

The Ministry of Natural Resources manages wildlife to ensure it is healthy today and available for future generations to enjoy. Ontario’s wildlife managers know that individual species are part of complex ecosystems. While management decisions are often directed at certain species, these decisions are made in the context of the entire ecosystem. This is an ecosystem-based approach to wildlife management.

Identification of ecosystem management zones (EMZ) for multiple resource use, accounting for approximately 70% of the available productive forest. In the EMZs, ecosystem-based management with the goal of increasing the supply of goods and services derived from various forest resources (e.g. timber, wildlife, leisure and tourism, etc.) with a view to achieving integrated management. (Government of Quebec document Forests: building a future for Quebec)

(make sure you read all of these with the voice of a cheesy radio announcer… it’s more fun that way).

So, who really is advertising a product or brand (e.g. Canadian Boreal Forest Agreement) when several of the ‘celebrated’ principles of this agreement are already required or mandated by Provincial forestry laws?

Maybe the nine enviro signatories to this agreement should return to that thing… that place… that cliche that everyone likes to use…ummm….uhhh…. oh right: the drawing board.

Ecosystem-based management? Read yesterday’s post and other posts on “Bumpf” on this website. The term “ecosystem-based management” now has about as much meaning as the old Ford slogan “Quality is Job 1″…

Good luck on this dirty business, ad bluster, political spin, already in law, stupid — campaign.

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The most ridiculous aspect of this whole exercise — as communicated by one of the executive leaders of one of the “enviro” signatories:

…it is important to put the CBFA in proper context. It is an aspirational agreement, based on voluntary commitments between participants and a number of goals which will require a great deal of goodwill and hard work to achieve. It is not legally binding on anyone, even those participating in the agreement. It doesn’t compel anyone to do anything against their own interests… [my emphasis]

Oh yeah, I know that whenever I, or someone apparently representing me, spends two years negotiating an agreement — it makes sense that the agreement be “aspirational” and “voluntary” and “not legally binding”. What a great use of resources…

Back to the words of Godin:

Instead of polishing that turd, why not work harder to think of something remarkable or important to say in the first place?

Canadian Boreal Forest Agreement: giving appearances of “solidity to pure wind” or fog banks

“The difference between the right word and the almost-right word is the difference between lightning and lightning bug”   – Mark Twain

Political language — and with variations this is true of all political parties, from Conservatives to Anarchists — is designed to make lies sound truthful and murder respectable, and to give an appearance of solidity to pure wind. — George Orwell, Politics and English Language, 1946

Over the last few days to a week, I’ve been sifting through a leaked version of the Canadian Boreal Forest Agreement — the actual signed copy is still not posted on the website. Other reviewers and criticisms of the agreement suggest certain Orwellian characteristics. I quite appreciate this comparison, as Orwell was a fan of simple language and wrote novels like 1984 about the dangers of political-speak (newspeak).

Now I may not go so far as to suggest that this particular agreement is making lies sound truthful (although maybe yesterday’s post suggested so) and murder respectable; however, there is certainly no shortage of that type of language in our political elite, which has certainly become well adopted by the media and in the delivery of TV nightly news (news-speak). For example, when “collateral damage” is used to make murder sound respectable.


(I have alluded to this in several earlier posts on this site: Words Matter; Why Business People Speak Like Idiots; how the term  “conservation” is like scotch broom; bullshit bumpf to blame for salmon disappearing,  and so on…)


The Canadian Boreal Forest Agreement is full of these empty, meaningless, wind-full words that obscure any meaning like a Pacific coast fog bank obscures landmarks. When the fog of empty-bumpf language rolls in — active adaptive management, precautionary approach, sustainability, ecosystem-based management, ecological integrity — meaning disappears faster than the horizon, or the island of real meaning that was just moments before serving as a beacon for our direction.

If you’ve ever spent time on the coast, you know that Pacific fog banks slide in so thick sometimes that vertigo sets in. One can not tell the sea from the sky, up from down, north from south… in a kayak, or a seaplane, it can be especially dangerous, more so without a compass to trust.

Several years back, I fell into a fisheries contract as the person initially hired was killed in a float plane crash. She had been working in an isolated logging camp on Haida Gwaii (formerly known as the Queen Charlotte Is.). Her and her crew were picked up by float plane on the west coast and were flying back to town. The Pacific fog bank rolled in, and the pilot was left trying to navigate by flying very low and following a logging road on the ground and relying on local knowledge.

The only problem is he followed a different logging road then he thought… the one he followed ends abruptly in a mountain cliff.

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And that’s the point here. When we all get lost in fog-full empty-language which has lost meaning and obscures reality — how do we navigate safely to make sure that we are saying what we mean, and meaning what we say?

What compass (moral, integrity or otherwise) do we use when business, environmental groups, government, or otherwise start using fog-full language that obscures any actual meaning?

And — especially — know what we are signing. And — most especially — know what we are communicating to greater audiences (e.g. marketing tool for big business to appeal to consumers).

if thought corrupts language, language can also corrupt thought. A bad usage can spread by tradition and imitation even among people who should and do know better.  — George Orwell

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Following my first few posts re: the Canadian Boreal Forest Agreement — I emailed all of the ‘communications’ people listed on the Agreement website including the Forest Products Association and the nine enviro groups to let them know about this site and my thoughts on the agreement.

I did it partially as a test to see how well everyone was standing by language in the Agreement — specifically that any signatories were supposed to let other signatories know about “third parties” that “may take a position or make public statements that are contrary to the principles and intent of the CBFA”  — pg. 38 under Goal 6: Marketplace Recognition. (which makes me think maybe the signatories don’t understand social media…?)

I think some of my comments might be considered “contrary”…? (and by the way if you’d still like to send a letter to the CEO of Abitibi-Bowater — one of the signatories — protesting their operations in Canada’s Boreal Forest… you still can: from Greenpeace’s (one of the signatories) website.

I only got a response from two individuals — both enviro signatories. To be fair, I won’t state who and what organization; however, this is part of one of the responses:

We at the […] are confident in the science that underpins the agreement and are hopeful that other key stakeholders in this unprecedented process will ensure that at the end of the day the Boreal is indeed protected.


The “science”? hmmm.

The “Goal” of this Agreement, as clearly stated in its own section:

"Goal" of Canadian Boreal Forest Agreement; pg 5 of leaked version


(Is this not one of the worst run-on sentences you have ever read… worse than a “short” salmonguy blog post… I have visions of my grade 8 English teacher butchering that sentence with her red pen bayonet)


Here’s a decent definition of science from Wikipedia to use as a barometer:

Science (from the Latin scientia, meaning “knowledge”) is a systematic enterprise of gathering knowledge about the world and organizing and condensing that knowledge into testable laws and theories. As knowledge has increased, some methods have proved more reliable than others, and today the scientific method is the standard for science. It includes the use of careful observation, experiment, measurement, mathematics, and replication — to be considered a science, a body of knowledge must stand up to repeated testing by independent observers.


So what is the science “underpinning” this Agreement?

  • The science of “boreal forest conservation” and “forest sector competitiveness“…?
  • The science of “conservation and protection of boreal biodiversity“…?
  • The science of “forest products… recognized as a climate-friendly choice in the marketplace“…?
  • Or, the science of a “global source of supply of sustainable forest products“…?

Oh, no wait… it’s the science ‘underpinning’ the Agreement… So that would be the: “Core elements of the agreement” , which include: ecosystem-based management, active adaptive management, protected areas, precautionary approach,  “recovery of species at risk” , greenhouse gas emission (GHGs) reductions, and so on…

Somebody please explain to me the “science” of ecosystem-based management…

Where in the world has the science of “ecosystem-based management” been implemented over a long enough time period; over a large enough geographic area to prove that it assisted in “recovering” species at risk…(for example caribou which have declined by over 60% from historical estimates)?

Where has it significantly reduced greenhouse gas emissions…? Where has it been used along with “active adaptive management” and the “precautionary approach” in a mass industrial development setting?

Where have all of these been “scientific principles” been utilized in such a manner as to be recognized as “testable laws and theories” and have resulted in a “body of knowledge” that has stood up “to repeated testing by independent observers.” ?

They haven’t.

— it’s voodoo science at best. It’s mushy, fog-full language, simply reproduced through the mating of corporate enviro groups, corporate industry, and government spin-doctors resulting in offspring that resemble this Agreement and many other document like it (e.g. The Wild Salmon Policy)

Harsh… maybe… however someone explain to me exactly how a “sustainable” forest industry operates…. what is “sustainable”? What does it mean? What does it mean for the communities in those forests? What does it mean for the revered ‘bou (caribou)?

Somebody show me were a “network of protected areas” has made a difference for large migratory animals like caribou (or salmon, or grizzly bears – yeah Jasper and Banff are doing wonders for the grizzly)…

how big does this “network” have to be? How big was it before industrial forestry? (Oh wait, it was all of it…)

Show me exactly how “science” is going to allow severely depressed caribou herds to co-habitate with expanding industrial forestry, tar sands operations, and mineral exploration and mining —  which is only going to expand as world populations grow (ever heard of Potash?).

It’s not possible. This is a big experiment… with a whole lot more flash; then dash. A whole lot more: ‘maybe this, maybe that’. A whole lot of fog bank language rather then saying what we mean, and meaning what we say.

It’s high time that folks stop hiding behind bullshit bumpf words like ecosystem-based management, precautionary approach, sustainability, adaptive management, and whatever other concocted bafflegab gets cooked up over the burners of windowless boardrooms, transcontinental jet flights offset by carbon credits, and float & bloat schmooze fests in the ‘wildernesses’ of North America.

What the hell are we actually trying to do here…?

“If you think learning your vocabulary words doesn’t make a difference, try going into a store and asking for toilet paper when you only know the word for sandpaper”

— Alan Webber: Rules of Thumb: 52 truths for winning at business without losing yourself