Standing Committee On Fisheries and Oceans

SCIENCE AT THE DEPARTMENT OF
FISHERIES AND OCEANS

Report of the Standing Committee on Fisheries
and Oceans
Ken McDonald, Chair
MARCH 2023
44th PARLIAMENT, 1st SESSION
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SCIENCE AT THE DEPARTMENT OF
Report of the Standing Committee on

Fisheries and Oceans
Ken McDonald
Chair
MARCH 2023
44th PARLIAMENT, 1st SESSION

NOTICE TO READER
Reports from committees presented to the House of Commons
Presenting a report to the House is the way a committee makes public its findings and recommendations
on a particular topic. Substantive reports on a subject-matter study usually contain a synopsis of the
testimony heard, the recommendations made by the committee, as well as the reasons for those
recommendations.
STANDING COMMITTEE ON FISHERIES
AND OCEANS
CHAIR
Ken McDonald
VICE-CHAIRS
Mel Arnold
Caroline Desbiens
MEMBERS
Lisa Marie Barron
Richard Bragdon
Serge Cormier
Brendan Hanley
Ken Hardie
Mike Kelloway
Robert J. Morrissey
Rick Perkins
Clifford Small
OTHER MEMBERS OF PARLIAMENT WHO PARTICIPATED

Sylvie Bérubé
Maxime Blanchette-Joncas
Luc Desilets
Stephen Ellis
Dave Epp
Andy Fillmore
Iqwinder Gaheer
Michael Kram
Viviane Lapointe
Ron Liepert
Elizabeth May
iii
Marc G. Serré
Denis Trudel
Rechie Valdez
Bob Zimmer
CLERKS OF THE COMMITTEE

Tina Miller
Christine Sing
LIBRARY OF PARLIAMENT
Parliamentary Information, Education and Research Services
Michael Chalupovitsch, Analyst
Natacha Kramski, Analyst
Joanne Markle LaMontagne, Analyst
Edouard McIntyre, Analyst
Thai Nguyen, Analyst
iv
THE STANDING COMMITTEE ON
has the honour to present its
EIGHTH REPORT
Pursuant to its mandate under Standing Order 108(2), the committee has studied science at the
Department of Fisheries and Oceans and has agreed to report the following:
v
TABLE OF CONTENTS
GLOSSARY OF TERMS ......................................................................................................................... IX
LIST OF RECOMMENDATIONS .......................................................................................................... 1
SCIENCE AT THE DEPARTMENT OF FISHERIES AND OCEANS ........................................ 13

Introduction .................................................................................................................................... 13
Policies and Guidelines for the Development of Science Advice Used in
Decision-Making at Fisheries and Oceans Canada ................................................... 14
Communication of Scientific Information and Advice ..................................... 17
Ministerial Decision-Making for Fisheries Management ................................ 17
The Collection of Scientific Data and the Production of Scientific Products by
Fisheries and Oceans Canada................................................................................................... 19
Stock Assessments ................................................................................................................ 22
Modelling ........................................................................................................................... 27
The Development of Science Advice through the Canadian Science Advisory
Secretariat ....................................................................................................................................... 29
Composition of Groups Involved in Canadian Science Advisory
Secretariat Processes ........................................................................................................... 29
Use of Consensus during the Canadian Science Advisory Secretariat
Process....................................................................................................................................... 31
Transparency and Communication of Scientific Information .............................. 32
Indigenous Involvement ............................................................................................................ 34
Industry Involvement ................................................................................................................. 36
Role of Science in Decision-Making at Fisheries and Oceans Canada ...................... 39
Communication of Science Advice to the Minister ................................................... 40
Integration of Fisheries Science and Other Considerations into
Fisheries Management Decisions............................................................................. 41
Need for and Use of Science in Relation to Particular Species .................................... 45
Example: The Impact of Pinnipeds on Various Fish Stocks .................................. 46
vii
Example: Aquaculture and Wild Pacific Salmon........................................................ 48
Conflict of Interest for Participants in Canadian Science Advisory
Secretariat Processes related to Pacific Salmon................................................. 50
Use of Consensus in Canadian Science Advisory Secretariat Processes
related to Pacific Salmon ............................................................................................. 51
Transparency and Communication of Scientific Information related to
Pacific Salmon .................................................................................................................. 51
Communication of Science Advice related to Pacific Salmon to
the Minister ...................................................................................................................... 54
Conclusion ....................................................................................................................................... 55
APPENDIX A LIST OF WITNESSES ................................................................................................ 57
APPENDIX B LIST OF BRIEFS .......................................................................................................... 61
REQUEST FOR GOVERNMENT RESPONSE ................................................................................ 63
SUPPLEMENTARY OPINION OF THE CONSERVATIVE PARTY OF CANADA ................ 65
viii
GLOSSARY OF TERMS
Cautious Zone
A part of the precautionary approach in fisheries management. In the cautious zone,

“decisions and strategies promote stock rebuilding to the healthy zone.” 1
Critical Zone
A part of the precautionary approach in fisheries management. In the critical zone,

“stock growth is promoted and removals are kept to the lowest possible level.” 2
Chief Science Advisor of Canada
The Chief Science Advisors’s key functions are as follows:
• “Provide advice on the development and implementation of guidelines to

ensure that government science is fully available to the public and that
federal scientists are able to speak freely about their work;
• Provide advice on creating and implementing processes to ensure that

scientific analyses are considered when the Government makes
decisions;
• Assess and recommend ways to improve the existing science advisory

function within the federal government;
• Assess and recommend ways for the Government to better support

quality scientific research within the federal system.” 3
External Advisory Committee on Aquaculture Science
Created in 2019, this committee is meant to ensure that, among other objectives,
Fisheries and Oceans Canada has access to external perspectives when designing
aquaculture research programs and policies. The creation of this committee stemmed
1 Government of Canada, A Fishery Decision-Making Framework Incorporating the Precautionary Approach.

2 Ibid.
3 Government of Canada, Office of the Chief Science Advisor.
ix
from recommendations made in the 2018 Report of the Independent Expert Panel on
Aquaculture Science. 4
Healthy Zone
A part of the precautionary approach in fisheries management. In the healthy zone, “the
fish stock status is good, and fisheries management decisions and harvest strategies are
designed to maintain fish stocks within this zone.” 5
Independent Expert Panel on Aquaculture Science
A panel led by the Chief Science Advisor with the mandate of “providing the Department
of Fisheries and Oceans (DFO) with advice and recommendations on the appropriate use
of scientific evidence in risk-based aquaculture decision-making, the priority-setting
process for aquaculture science at DFO, and the communication of aquaculture science
and resulting decisions to Canadians.” 6 The panel’s mandate was fulfilled in December
2018 when the Report of the Independent Expert Panel on Aquaculture Science was
presented to the Minister of Fisheries, Oceans and the Canadian Coast Guard and the
Minister of Science and Sport.
Precautionary approach
In fisheries management, the precautionary approach is about “being cautious when

scientific knowledge is uncertain, and not using the absence of adequate scientific
information as a reason to postpone action or failure to take action to avoid serious
harm to fish stocks or their ecosystem. This approach is widely accepted as an essential
part of sustainable fisheries management.” 7
Recovery Potential Assessment
After the Committee on the Status of Endangered Wildlife in Canada (COSEWIC)

“assesses an aquatic species as Threatened, Endangered, or Extirpated, Fisheries and
Oceans Canada (DFO), as the responsible jurisdiction for aquatic species under the
Species at Risk Act (SARA), undertakes several actions to support implementation of
4 Fisheries and Oceans Canada, External Advisory Committee on Aquaculture Science; and Fisheries and
Oceans Canada, Government of Canada moves to strengthen science on aquaculture ensuring protection of
wild fish stocks, press release, 28 May 2019.
6 Government of Canada, Report of the Independent Expert Panel on Aquaculture Science.
x
SARA. Many of these actions require scientific information on the current status of the
species, threats to its survival and recovery, and the species’ potential for recovery.
Formulation of this scientific advice has typically been developed through a Recovery
Potential Assessment (RPA) following the COSEWIC assessment. This timing allows for
the consideration of peer-reviewed scientific analyses within SARA processes, including
the decision whether or not to list a species on Schedule 1, and during recovery planning
if the species is listed.” 8
8 Fisheries and Oceans Canada, Recovery Potential Assessment for Lower Fraser River White Sturgeon 2020.
DFO Can. Sci. Advis. Sec. Sci. Advis. Rep. 2021/011, 2021.
xi
LIST OF RECOMMENDATIONS
As a result of their deliberations committees may make recommendations which they

include in their reports for the consideration of the House of Commons or the Government.
Recommendations related to this study are listed below.
Recommendation 1
That the Ocean science activities of the Department of Fisheries and Oceans
(DFO) prioritize a comprehensive research strategy to determine the current
and estimated future impacts of climate change on marine life and provide
regular public updates on findings. ........................................................................... 20
Recommendation 2
That the Government of Canada request that the Chief Science Advisor
examine how and to what degree DFO has deployed an ecosystem-based
approach for stock management and recovery, and, if necessary, make
recommendations on how DFO may better implement ecosystem-based
fisheries management. ............................................................................................. 20
Recommendation 3
That DFO speed up the implementation of an ecosystem-based approach to
fisheries management in Canada given the impact of climate change. ...................... 20
Recommendation 4
That Canada increase collaboration with our international allies and neighbors
for stock assessments and scientific research for all transboundary species. ............. 21
Recommendation 5
That the Minister of Fisheries, Oceans and the Canadian Coast Guard direct
departmental officials to immediately initiate a review of DFO allocations for
science to ensure departmental resources are available for the scientific work
in both fisheries and ocean science that is required to inform decisions of DFO
and Minister and likewise ensure that DFO scientists are not dependant on
external funding streams to complete their work. .................................................... 22
Recommendation 6
That DFO conduct an internal audit on the performance of new research
vessels to ensure the suitability of new vessels to maintain and improve the
DFO’s ability to conduct stock assessments, and that the results of this audit be
communicated to the House of Commons Standing Committee on Fisheries
and Oceans. ............................................................................................................. 24
Recommendation 7
That DFO allocate sufficient resources, including sufficient at-sea capabilities,
to conduct timely and comprehensive stock assessments and acoustic surveys
for all commercial fish species. ................................................................................. 25
Recommendation 8
Considering that DFO’s scientific models used for stock assessments rely on
data from surveys, the Committee recommends that greater emphasis be
placed on completing surveys and robust data acquisition, even when vessels
break down or are unavailable. That DFO do this by fostering relationships with
the fishing industry to utilize commercial fishing license holders and vessels to
supplement DFO scientific data collection. ............................................................... 26
Recommendation 9
That, in order to ensure stock assessment surveys are completed, DFO identify
and use opportunities that exist for harvester data to be included in stock
assessment activities, thereby contributing to collaborative and citizen science. ....... 26
Recommendation 10
That DFO immediately implement, in partnership with academic and industry
scientists, a review of the criteria for the selection of survey areas to consider
variability in stock distributions as well as harvester observations in order to
have a more realistic view of the status of fish stocks and fishing pressure.
These stock surveys should take place twice a year................................................... 26
2
Recommendation 11
Given the importance of a sustainable fishery on the economic and social
health of small, coastal communities and our obligations toward Indigenous
reconciliation, that DFO prioritize completing regular and thorough stock
assessments on all three coasts and commit to timely and fulsome community
and stakeholder engagement on proposed fishing restrictions to protect fish
stocks and marine species threatened or at risk. ....................................................... 26
Recommendation 12
That DFO commit to more timely decision-making to provide certainty to fish
harvesters and industries impacted by fisheries decisions. This would ensure
that those impacted, whether positively or negatively by these decisions have
enough time to prepare and react to the changes and will ensure that
government can provide support for those industries negatively impacted by
fishery closures. ....................................................................................................... 26
Recommendation 13
That DFO review the allocation of its resources, financial and otherwise,
between ocean science and fisheries science to
• ensure sufficient funding for the stock assessments required for sound
management, eco certifications and rebuilding plans required to restore
depleted stocks; and
• reflect the commercial, social, and cultural importance of fisheries in

coastal communities. .................................................................................... 26
Recommendation 14
That DFO introduce an annual Report to Parliament on the status of fish stocks,
staffing levels and expenditures by program area, and fisheries management
performance in a publicly available report to enable transparency of evidence
used for ministerial decision-making, including any pertinent decision notes. ........... 27
3
Recommendation 15
That the Minister of Fisheries, Oceans and the Canadian Coast Guard
immediately direct departmental officials to provide the Committee on an
annual and ongoing basis with documentation containing tables reflecting how
many fishery stocks DFO manages, how many stocks have and have not been
assessed in the current year, and what actions the Minister will commit to
ensure resources and direction are provided to increase stock assessments
starting in 2023 as an annual exercise. ...................................................................... 27
Recommendation 16
That the current DFO modelling used for stock assessments be changed to
allow for fisher data input and that the DFO modelling should be reviewed in
the European stock assessment modelling concept. .................................................. 28
Recommendation 17
That DFO conduct robust peer reviewed, non-biased science with academic
organizations and include both harvesters’ knowledge and Indigenous
traditional knowledge. ............................................................................................. 31
Recommendation 18
That the Government of Canada initiate an independent audit of how and to
what degree DFO has implemented their science integrity policy and that the
resulting audit report be tabled in the House of Commons in 2023. .......................... 31
Recommendation 19
That DFO improve the transparency of data and research by developing a
portal to publish the detailed studies, including the scientific and socio-
economic impact documentation, that are the inputs into the CSAS and
COSEWIC processes. This portal should be easy to navigate and include both
raw data and summaries free of scientific or bureaucratic jargon so that all
Canadians, and fishers in particular, can understand the findings.............................. 33
Recommendation 20
Make all scientific data produced by DFO publicly available for peer review
from researchers outside of the Department. ........................................................... 33
4
Recommendation 21
That the government expand the CSAS process beyond scientists and
individuals with a scientific background to be more inclusive of traditional
Indigenous knowledge and harvesters’ knowledge. .................................................. 35
Recommendation 22
That DFO work to incorporate traditional Indigenous knowledge and fisher
knowledge into its scientific activities and to give it greater consideration. ............... 35
Recommendation 23
That DFO increase the collaborations with Indigenous peoples and fishers in
the development of field and lab work, as well as in the development of
scientific conclusions. ............................................................................................... 35
Recommendation 24
DFO should work with First Nations to develop a culturally appropriate way to
use traditional Indigenous knowledge and fisher knowledge in management,
such as to trigger early warning signs about the health of marine species
and ecosystems. ....................................................................................................... 35
Recommendation 25
Honour and respect existing fisheries and oceans management cogovernance
agreements and implement those processes that are inclusive of Indigenous
knowledge, ecosystem and precautionary thresholds. .............................................. 36
Recommendation 26
That the government build scientific and technical capacity with First Nations
and their organizations in recognition of their inherent Indigenous title
and rights. ................................................................................................................ 36
Recommendation 27
That DFO should work with fish harvesters to communicate, in a more open
and transparent manner their work and scientific conclusions, especially in
cases where the evidence seems at odds with the observations of
fish harvesters.......................................................................................................... 37
5
Recommendation 28
That DFO make greater efforts to improve the flow of information from fish
harvesters to the DFO Science branch about what they are seeing out on
the water. ................................................................................................................ 37
Recommendation 29
That DFO include knowledge and data collected by commercial fishers,
including independent inshore fishers, in the peer review process, including
their knowledge and observations regarding changes in distribution and
abundance. That DFO formalize a system for fishers to participate and provide
input in all aspects of fisheries management, including stock assessment
protocols and management plans. ............................................................................ 37
Recommendation 30
That DFO apply the same management measures to all fishers of a given
species in a given fishing zone based primarily on science and stock
conservation for a sustainable fishery....................................................................... 37
Recommendation 31
That DFO revitalize relationships with the recreational and commercial fishing
industries and demonstrate fair process in decision-making. .................................... 38
Recommendation 32
That DFO consult those who could be most socio-economically impacted by its
decisions and ensure that the socio-economic impacts on communities and the
fishing industry are factored in its decision-making processes. The assessment
of economic and social impacts resulting from decisions should be provided
when requested by Canadians. ................................................................................. 43
Recommendation 33
• undertake an examination of how DFO fisheries management officials

influence the work and findings of DFO scientists; and
• produce a report to government including
6
• an assessment of such influence,
• whether this influence is appropriate and ethical; and
• recommendations, if necessary, of how to reform fisheries

management influence on science in DFO in order to increase
independence of DFO science and ensure there is an established
conduit for science to be directly channeled from scientists to
decision-makers for them to consider when making decisions.................. 43
Recommendation 34
• assess the viability of restructuring existing DFO systems and processes

in a manner that would ensure that science advice is independently
collated, assessed and delivered to managers and decision-makers by
DFO scientists; and
• produce a report with recommendations from this assessment and that

that report be tabled by the government in the House of Commons
by 2024. ........................................................................................................ 43
Recommendation 35
• examine to what degree science advice from scientists is implemented

in DFO management and decision-making processes; and
• produce a report with advice and recommendations for establishing

protocols to measure to what degree science advice from scientists is
implemented in DFO management and decision-making processes and
that this report be tabled in the House of Commons by 2024. ........................ 44
7
Recommendation 36
That the Government of Canada develop and table legislation that establishes
a science-based fisheries management framework and a requirement for the
government, through DFO, to ensure that DFO decisions align with the science-
based management framework and demonstrate alignment of decisions with
the framework by publicly releasing scientific reasons and other factors
for decisions. ............................................................................................................ 44
Recommendation 37
That the Government of Canada initiate an independent audit of how and to
what degree DFO has implemented the Sustainable Fisheries Framework and
that the resulting audit report be tabled in the House of Commons by
December 15, 2023................................................................................................... 44
Recommendation 38
• assess the viability of establishing an independent science advice body

to directly advise DFO decision-makers, assess health and performances
of fisheries, make recommendations on scientific research priorities,
and oversee the implementation of science-based activities; and
• provide this assessment in a report with recommendations to the

government to be tabled by 2024. ................................................................. 44
Recommendation 39
That scientists conduct pinniped diet analysis for all species of pinnipeds over
longer periods of the year in more diverse regions than in the past and make
their data publicly available by posting it on the DFO website................................... 48
Recommendation 40
That, in order to accurately assess the effects of pinniped predation when
estimating mortality levels in fish stock biomass, scientists compare data from
countries with similar species of pinnipeds. .............................................................. 48
8
Recommendation 41
Given the conflict of interest between DFO’s mandate relating to aquaculture
versus the application of the precautionary principle and the ongoing crisis for
the health of wild Pacific salmon stocks, that the government implement, on
the West Coast only, Recommendation #3 in the Cohen Commission report on
the state of wild salmon:
“The Government of Canada should remove from the Department of

Fisheries and Oceans’ mandate the promotion of salmon farming as an
industry and farmed salmon as a product.” ......................................................... 49
Recommendation 42
That the Government of Canada initiate an independent audit of what
recommendations of the December 2018 report titled “Report of the
Independent Expert Panel on Aquaculture Science” have been implemented
by DFO, how many have been fully implemented and timelines for full
implementation for recommendations that are not yet fully implemented
and that the resulting audit report be tabled in the House of Commons by
June 9, 2023. ............................................................................................................ 49
Recommendation 43
That, in light of the established aquaculture management division within the
department and that DFO favours the interest of the salmon-farming industry
over the health of wild fish stocks, DFO establish a wild salmon position
independent from this division as recommended in Recommendation 4 of the
Cohen Commission report to maintain impartiality. .................................................. 50
Recommendation 44
That DFO place appropriate and adequate value to perspectives provided by
the External Advisory Committee on Aquaculture Science, and reflect such
perspectives in policy recommendations and advice to the Minister of
Fisheries, Oceans and the Canadian Coast Guard, and that the work of the
External Advisory Committee on Aquaculture Science be reported to
Parliament on an annual basis. ................................................................................. 50
9
Recommendation 45
Given the perceived issues with the DFO’s risk assessment of the impact of
aquaculture operations in the Discovery Islands on wild fish stocks including:
• the failure to assess the cumulative impacts of the viruses and bacteria
detected; and
• the suppression of additional research that could have had a material

impact on the overall risk assessment,
that DFO submit to an independent review of the risk assessment, including

but not limited to decisions on the assessment’s terms of reference and factors
that resulted in the suppression of research findings on the impact of sea lice
and possibly other issues with a material impact on the health of wild fish
stocks. That there be an independent audit and analysis to determine the
accuracy and decision-informing value of the Science Advisory Report
presented to the Minister of Fisheries, Oceans and the Canadian Coast Guard
on DFO’s risk assessment of aquaculture operations in the Discovery Islands. ........... 52
Recommendation 46
That the Minister of Fisheries, Oceans and the Canadian Coast Guard provide in
writing to the Committee a statement as to whether or not DFO omitted,
canceled or in any other way did not complete or make unavailable a 10th
CSAS risk assessment examining potential risks to Fraser sockeye............................. 52
Recommendation 47
That in light of new scientific revelations of potential impacts of Tenacibaculum
maritimum and Piscine orthoreovirus (PRV) on wild Pacific salmon, the
Government of Canada request that the Chief Science Advisor assess and make
recommendations to the Minister of Fisheries, Oceans and the Canadian Coast
Guard on the potential necessity for a CSAS assessment of risks posed by
Tenacibaculum maritimum and PRV on all species of wild Pacific salmon,
including Fraser sockeye. .......................................................................................... 53
10
Recommendation 48
That, within 60 days after of this report being presented to the House of
Commons, DFO make publicly available on their website all documents,
including working papers, the Science Advisory Report and the Recovery
Potential Assessment, associated with the CSAS assessment of interior Fraser
steelhead in British Columbia. .................................................................................. 55
11
SCIENCE AT THE DEPARTMENT
OF FISHERIES AND OCEANS
INTRODUCTION
On 1 February 2022, the House of Commons Standing Committee on Fisheries and
Oceans (the Committee) agreed to undertake a study to “examine how the Department of
Fisheries and Oceans prioritizes, resources and develops scientific studies and advice for
the department, how the results of scientific study are communicated to the Minister and
Canadians, and how the minister applies data and advice provided by the department and
other government departments to ministerial decisions.” 1 The Committee heard from
57 witnesses over nine meetings held between 26 April 2022 and 7 October 2022.
During the study, the Committee heard from current and former Fisheries and Oceans
Canada (DFO) employees, scientists, and representatives of Indigenous organizations,
fishers and fisheries organizations, non-governmental organizations, and other
stakeholders. These witnesses discussed the different elements involved in the
formulation of science advice for decision-making including the collection and
prioritization of scientific data within DFO, the Canadian Science Advisory Secretariat
(CSAS) process used to generate peer-reviewed science advice, and the way science
advice is provided to the Minister. The testimony heard by the Committee was
somewhat polarized. Departmental officials told the Committee that DFO produces
science advice for decision-making that is based on processes and policies that include
collaboration and transparency and prevent conflicts of interest. However, other
witnesses and stakeholders did not feel this was the case.
Witnesses agreed that DFO scientists do quality work. Dominique Robert, professor and
Canada Research Chair in Fisheries Ecology at the Institut des sciences de la mer,
Université du Québec à Rimouski, commended the quality of the work of DFO
researchers and added that he believes they “are highly qualified to carry out the
scientific work in their mandate.” 2 The Committee heard that DFO has many good
policies that outline the process to be followed during the development of science
advice but that these policies were not being followed. Andrew Bateman, Manager,
1 House of Commons, Standing Committee on Fisheries and Oceans, Minutes of Proceedings,

1 February 2022.
2 Dominique Robert, Professor and Canada Research Chair in Fisheries Ecology, Institut des sciences de la
mer, Université du Québec à Rimouski, As an individual, Evidence, 5 May 2022.
13
Salmon Health at the Pacific Salmon Foundation, believed that “DFO’s current science
advice aims are laudable on paper, but principles and guidelines are only as good as
their implementation.” 3 Andrew Trites, Professor, Marine Mammal Research Unit,
Institute for the Oceans and Fisheries at the University of British Columbia, stated that:
Canada is recognized as a world leader in fisheries and oceans research, which reflects
well on the productivity and quality of research done by DFO, universities and other
groups. However, I think we fall short as a country in terms of doing science that
matters to fishermen, coastal communities, tourist operators and fisheries managers,
among others. I think a new approach is warranted to ensure that the fisheries and
oceans research undertaken in the coming years addresses the concerns expressed by
the different sectors that have a significant stake in the health of Canada's fisheries and
marine ecosystems. 4
Policies and Guidelines for the Development of Science Advice Used

in Decision-Making at Fisheries and Oceans Canada
At DFO, approximately 2,000 staff working at over 17 research institutes, laboratories
and experimental centres are responsible for the production of scientific data, analysis,
and advice. 5 The core role of science at DFO is to provide the evidence and data that will
inform fisheries and oceans management decisions. For example, an important part of
science at DFO is to support the fishing industry by providing stock assessment data
which can feed into the eco-certification process completed by third parties that assess
whether a fishery is well-managed and sustainable. Science staff at DFO also collaborate
with international partners in research activities to support domestic and global
policy-making.
DFO’s CSAS coordinates the production of peer-reviewed assessments and science

advice for departmental decision-makers. Figure 1 illustrates the process used by CSAS
to generate science advice, which includes a peer review step.
3 Andrew Bateman, Manager, Salmon Health, Pacific Salmon Foundation, Evidence, 28 April 2022.
4 Andrew Trites, Professor, Marine Mammal Research Unit, Institute for the Oceans and Fisheries, University
of British Columbia, As an individual, Evidence, 14 June 2022.
5 Fisheries and Oceans Canada (DFO), “Science at DFO,” Machinery of Government, 2021.
14
SCIENCE AT THE DEPARTMENT OF FISHERIES AND OCEANS
Figure 1 : Canadian Science Advisory Secretariat Process at Fisheries and

Oceans Canada
Source: Fisheries and Oceans Canada, “Science Advice,” Machinery of Government, 2021.
Pursuant to DFO policies, the participation of external experts in a CSAS process occurs
by departmental invitation only. External experts are selected by a steering committee
“based on their experience and expertise relevant to the subject matter of the review.
Participants may include representatives of DFO, other government departments, First
Nations, stakeholders, academia, environmental non-government organizations, as well
15
as international experts.” 6 External experts have been invited to participate in the CSAS
process since 1997.
The Policy on Science Integrity, which took effect in 2019, encourages “discussion based
on differing interpretations of research and scientific evidence as a legitimate and
necessary part of the research and scientific processes and, where appropriate,
ensure[s] that these differences are made explicit and accurately represented.” 7 The
Policy on Science Integrity also aims to ensure that DFO “research and science and any
research or scientific products, as well as any associated communications, are free from
political, commercial, client and stakeholder interference.” 8
Mona Nemer, Chief Science Advisor at the Office of the Chief Science Advisor, explained
that the Policy on Science Integrity is “meant to put in place the proper frameworks for
the responsible conduct of research, including the ability of the scientists to publish their
work without undue influence.” 9 Arran McPherson, Assistant Deputy Minister of
Ecosystems and Oceans Science at DFO, specified that although the Deputy Minister is
responsible for the overall application of the Policy on Science Integrity, the
Ombudsperson is responsible for managing any allegations of policy breaches. 10
Different policies and guidelines based on the Policy on Science Integrity, such as the
Policy on Conflict of Interest in Science Peer Review Processes and the Policy on
Participation in Science Peer Review Meetings, are followed during the CSAS process.
However, the Committee heard many witnesses describe elements of CSAS processes as
problematic. They described the long delays encountered before getting a report on the
detection of Piscine orthoreovirus (PRV) in farmed Chinook salmon published because of
a disagreement between industry veterinarians and DFO staff on the interpretation of
the data, the inclusion of particular interest groups in the CSAS process, and the use of
consensus during the CSAS process as a suppression tactic. These examples are
discussed in further detail later in this report.
6 DFO, Understanding the Canadian Science Advisory Secretariat.

7 DFO, Policy on science integrity.
8 Ibid.
9 Mona Nemer, Chief Science Advisor, Office of the Chief Science Advisor, Evidence, 26 April 2022.
10 Arran McPherson, Assistant Deputy Minister, Ecosystems and Oceans Science, DFO, Evidence,
7 October 2022.
16
Communication of Scientific Information and Advice
Upon completion and approval, all CSAS process documents are to be made public on
the CSAS website in accordance with DFO’s Policy on Distribution of Publications. CSAS
publications include:
• Research documents, which contain the supporting scientific information

and analyses needed to generate advice;
• Science advisory reports, which contain scientific advice and outline the
uncertainties and limitations of the advice;
• Proceedings, which document the discussions held during the peer

review process and include a list of internal and external participants; and
• Science responses, which document the peer-reviewed scientific advice

and proceedings for urgent and unforeseen requests for information or
advice following the Science Special Response Process. 11
While DFO recognizes the role of researchers and scientists in communicating

information to the public, the Policy on Science Integrity states that there may be
“legitimate and compelling reasons that may limit the disclosure or availability of
research or scientific information to employees, stakeholders or the public.” 12 Examples
of legitimate and compelling reasons given by the policy include “the need for caution
and prudence in the public communication of classified or sensitive scientific or research
information, as well as existing legal constraints on information disclosure”. 13 However,
the policy also mentions that DFO researchers and scientists “have the right, and are
encouraged, to speak about or otherwise express themselves on science and their
research without approval or pre-approval [from their managers or supervisors] and
without being designated as an official spokesperson.” 14
Ministerial Decision-Making for Fisheries Management
Although ministerial decisions may be informed by science advice, pursuant to

section 2.5 of the Fisheries Act, the Minister may also consider factors such as
11 DFO, Policy on Publication of Non-CSAS Documents on the CSAS Website.

12 DFO, Policy on science integrity.
13 Ibid.
14 Ibid.
17
community knowledge, Indigenous knowledge, and social, economic, and cultural
issues. 15 Ministerial decisions must, however, respect conservation principles, legally-
binding agreements, and Aboriginal rights and treaty rights. 16 Regarding fisheries
management, the Minister of Fisheries, Oceans and the Canadian Coast Guard, pursuant
to the Fisheries Act, has the authority to determine, among other responsibilities:
• the annual total allowable catch (TAC) of a species or stock;
• fisheries licence conditions;
• the times and seasons for fishing; and
• restrictions to be imposed (e.g., gear type, dockside or at-sea monitoring,

reporting requirements).
Bernard Vigneault, Director General of the Ecosystem Science Directorate at DFO,

summarized the production of science advice at DFO as follows:
As a science-based department, science integrity is essential to the work of the

department and its employees. Science integrity is critical to the decision-making
process, from the planning and conduct of research to the production and the
application of advice. Departmental scientists are bound by our code of ethics and
values, and our science integrity policy, which reinforces principles such as
transparency, scientific excellence and ensuring high standards of research ethics.
DFO generates science advice in a transparent way, using the Canadian Science Advisory
Secretariat, which is based on the principle of evidence-based peer review. Participants
in the peer review process participate as objective experts to complete the peer review
of the science under consideration. To guide participation, DFO has published a conflict
of interest policy and a policy on participation for the CSAS meetings. 17
During the study, witnesses described various stages during the development of advice
for decision-makers where scientific information could be blocked or modified, such as
during the CSAS process or as the information was being prepared to be communicated
to the Minister. For example, Alexandra Morton, Independent Scientist (as an individual),
described a situation where DFO management briefed representatives of the
aquaculture industry but did not brief the Minister about the risk posed to young Fraser
sockeye by Tenacibaculum maritimum after having been alerted to the risk by DFO
15 Fisheries Act, R.S.C., 1985, F-14.

16 DFO, Fisheries management decision-making.
17 Bernard Vigneault, Director General, Ecosystem Science Directorate, DFO, Evidence, 26 April 2022.
18
scientists. 18 Robert Chamberlin, chairman of the First Nations Wild Salmon Alliance,
believed that the aquaculture industry had been much too involved in the CSAS process
related to open-net cage fish farms for it to be objective. 19 Witnesses also described
issues with DFO’s data collection, which is the foundation for all the department’s
science advice.
THE COLLECTION OF SCIENTIFIC DATA AND THE PRODUCTION OF

SCIENTIFIC PRODUCTS BY FISHERIES AND OCEANS CANADA
Bernard Vigneault described the collection of scientific data and the production of
scientific products at DFO as follows:
Each year, DFO science mobilizes teams of research scientists, biologists and technicians
to conduct field and laboratory studies for hundreds of distinct projects in marine and
freshwater systems. This results in a wealth of knowledge about our ecosystems and
fish populations to support the departmental decision-making. The science sector has
expertise in a wide range of fields, including marine environment and aquatic ecosystems,
hydrography, oceanography, fisheries, aquaculture and biotechnology. DFO science is
made up of science professionals located in research institutes, laboratories, experimental
centres and offices across the country. Science staff collect data and conduct research and
monitoring activities, the results of which contribute to the science advice that can be
used to answer specific questions or to inform decisions. 20
DFO uses an ecosystem science approach. Greig Oldford, PhD Candidate and Scientist at
the University of British Columbia (as an individual), defines this approach “as a broad
approach to studying relationships and interactions in the ecosystem, and it integrates
science outputs. We prioritize and try to understand the key relationships in nature and
their links to human needs and management actions.” 21 Dominique Robert recommended
accelerating the implementation of an ecosystem approach to fisheries management in
Canada, noting that a 2019 CSAS report concluded that less than half of the 178 stock
assessments reviewed considered ecosystem aspects. 22 He believed that if “we want to
offer better scientific advice with an ecosystem approach to management, but there is a
18  Alexandra Morton, Independent Scientist, As an individual, Evidence, 12 May 2022.

19 Robert Chamberlin, Chairman, First Nation Wild Salmon Alliance, Evidence, 12 May 2022.
21 Greig Oldford, PhD Candidate and Scientist, University of British Columbia, As an individual, Evidence,
5 May 2022.
See: Pepin, P., et al., Incorporating climate, oceanographic and ecological change considerations into
population assessments: A review of Fisheries and Oceans Canada’s science advisory process, 2019.
19
lack of certain crucial components of the ecosystem, such as forage species, it will be
difficult to achieve this.” 23 Keith Sullivan, President of Fish, Food and Allied Workers -
Unifor, agreed that the use of an ecosystem approach was appropriate but emphasized
the need to consider all elements of the ecosystem, including predators such as seals. 24
Mona Nemer explained that climate change is changing different conditions in the ocean,
including the temperature, salinity and acidity of the water. 25 Dominique Robert believed
the “rapid ecosystem changes we are currently experiencing because of global warming
also require the consideration of ecosystem variables in stock assessments to ensure
sustainable management of our resources.” 26
Recommendation 1
That the Ocean science activities of the Department of Fisheries and Oceans (DFO)
prioritize a comprehensive research strategy to determine the current and estimated
future impacts of climate change on marine life and provide regular public updates
on findings.
Recommendation 2
That the Government of Canada request that the Chief Science Advisor examine how and
to what degree DFO has deployed an ecosystem-based approach for stock management
and recovery, and, if necessary, make recommendations on how DFO may better
implement ecosystem-based fisheries management.
Recommendation 3
That DFO speed up the implementation of an ecosystem-based approach to fisheries

management in Canada given the impact of climate change.
Witnesses mentioned the importance of cooperation within the federal government as

well as with different stakeholder groups and associations, including industry, Indigenous
groups, universities and citizen anglers, to maximize the data available. Jean Côté,
Scientific Director at the Regroupement des pêcheurs professionnels du sud de la
Gaspésie, described the Lobster Group (or Lobster Node) as “a group of fishers’
24 Keith Sullivan, President, Fish, Food and Allied Workers - Unifor, Evidence, 2 June 2022.
20
associations from the five Atlantic provinces. Government researchers from DFO, a
provincial ministry, as well as university researchers” that “conducts studies and fills the
gaps in our knowledge about the productivity, structure and connectivity of lobster
stocks in their distribution area” through collaborative study. 27 Andrew Trites believed a
“collaborative research program overseen by fishermen, academics and government
scientists,” such as the Canadian Fisheries Research Network which existed between
2010 and 2015, would be a good way to address many of the concerns raised about
science at DFO.28 Brian E. Riddell, Science Advisor at the Pacific Salmon Foundation,
reminded the Committee that citizen science can be a powerful data collection tool.29
Witnesses also mentioned the importance of collaborating with the United States when
working on transboundary species such as wild Pacific salmon or Atlantic mackerel. 30
Recommendation 4
That Canada increase collaboration with our international allies and neighbors for stock
assessments and scientific research for all transboundary species.
Kathryn Moran, President and Chief Executive Officer at Ocean Networks Canada,
described the Sea Grant program in the United States where regional funding is directed
towards the interests of fishers and the “science they need to help them advance their
economic benefit.” 31 She suggested this could be a model to consider in Canada.
Dr. Kristi Miller-Saunders explained that funding within DFO is “largely based on
competitive proposals.” 32 She told the Committee that she anticipated funding under
the Pacific Salmon Strategy Initiative but had yet to receive any. Her research program
on pathogens, environmental stress and climate change is funded “principally through
money [from] outside of the department” because of better success in generating funds
to do the research with outside granting agencies than from within DFO. 33
27 Jean Côté, Scientific Director, Regroupement des pêcheurs professionnels du sud de la Gaspésie, Evidence,
2 June 2022.
29 Brian E. Riddell, Science Advisor, Pacific Salmon Foundation, Evidence, 28 April 2022.
30 Rebecca Reid, Regional Director General, Pacific Region, DFO, Evidence, 7 October 2022; and
Christopher Jones, Senior Fisheries Manager, Department of Fisheries and Oceans (Retired), As an
individual, Evidence, 14 June 2022.
31 Kathryn Moran, President and Chief Executive Officer, Ocean Networks Canada, Evidence, 5 May 2022.
32 Dr. Kristi Miller-Saunders, Senior Research Scientist, DFO, Evidence, 26 April 2022.
33 Ibid.
21
Recommendation 5
That the Minister of Fisheries, Oceans and the Canadian Coast Guard direct departmental
officials to immediately initiate a review of DFO allocations for science to ensure
departmental resources are available for the scientific work in both fisheries and ocean
science that is required to inform decisions of DFO and Minister and likewise ensure that
DFO scientists are not dependant on external funding streams to complete their work.
Stock Assessments
In fisheries management, the precautionary approach means “being cautious when
scientific information is uncertain, unreliable or inadequate and not using the absence of
adequate scientific information as a reason to postpone or fail to take action to avoid
serious harm to the resource.” 34 Sufficient and timely data is therefore important
because the quality of recommendations made to decision-makers depends on the data
available. Robert Chamberlin believed the precautionary approach requires the removal
of fish farms from coastal British Columbia. 35
Witnesses expressed concern that a lack of capacity and resources within DFO, as well as
competing priorities between oceans and fisheries sciences, could mean that some stock
assessments or surveys cannot be completed in a timely manner. Adam Burns, Acting
Assistant Deputy Minister of Fisheries and Harbour Management at DFO, stated that
decisions for stock assessments “are informed by the best available science” even in
cases when the science might have been done prior to the year in question. 36 According
to Christina Burridge, Executive Director at the BC Seafood Alliance, if stock assessments
are not timely, “TACs may be more precautionary than necessary, meaning benefits to
Canadians are constrained.” 37 Kris Vascotto, Executive Director of the Atlantic Groundfish
Council and Carey Bonnell, Vice-President, Sustainability and Engagement at Ocean
Choice International L.P., expressed dismay at delayed stock assessments. 38
Given the “ongoing challenges in most DFO regions in getting the science programs
delivered,” Morley Knight, retired Assistant Deputy Minister of Fisheries Policy at DFO
34 DFO, A fishery decision-making framework incorporating the precautionary approach.

36 Adam Burns, Acting Assistant Deputy Minister, Fisheries and Harbour Management, DFO, Evidence,
7 October 2022.
37 Christina Burridge, Executive Director, BC Seafood Alliance, Evidence, 2 June 2022.
38 Kris Vascotto, Executive Director, Atlantic Groundfish Council, Evidence, 21 June 2022; and Carey Bonnell,
Vice-President, Sustainability and Engagement, Ocean Choice International L.P., Evidence, 21 June 2022.
22
(as an individual), believed that “[t]hose responsible should be held accountable to make
sure that the surveys are done and that DFO science gets top priority. When it doesn't
get delivered, those who were responsible should be held accountable.” 39
Charlotte K. Whitney, Program Director of Fisheries Management and Science at the

Central Coast Indigenous Resource Alliance, questioned how DFO prioritizes stock
assessments given that “many targeted and bycatch stocks have outdated assessments or
no assessment at all.” 40 Given that 80% of stocks have no fishing mortality estimates,
Robert Rangeley, Director of Science at Oceana Canada, hoped that DFO would address
inconsistencies in catch monitoring by fully implementing the fishery monitoring policy.41
Christopher Jones, retired Senior Fisheries Manager at DFO (as an individual), explained
that in the Maritimes region, scientific effort had been focused on certain high-profile
stocks such as crab, lobster and halibut because of limited resources. Fisheries that are
not high profile receive “very little to practically no science support” in the two-tier
system. 42 Dominique Robert explained that, more generally,
the quality of available data varies greatly between stocks. The assessment of some
historically and culturally important species, such as Atlantic cod in eastern Canada,
relies on high quality data from multiple sources. Other stocks, however, such as forage
species, are data poor. Basic measures, such as their spawning biomass, are sometimes
unknown. The quality of the recommendations that scientists can make is therefore
directly dependent on the data available. 43
Morley Knight believed that when there is greater uncertainty about the status of a
particular stock, “there has to be a redoubling of efforts to find out the real truth and be
more certain about what the real situation is.” 44 He suggested that could be the case
with the Atlantic mackerel.
39 Morley Knight, Former Assistant Deputy Minister, Fisheries Policy, Department of Fisheries and Oceans
(Retired), as an individual, Evidence, 7 October 2022.
40 Charlotte K. Whitney, Program Director, Fisheries Management and Science, Central Coast Indigenous
Resource Alliance, Evidence, 28 April 2022.
41 Robert Rangeley, Director of Science, Oceana Canada, Evidence, 14 June 2022.
42 Christopher Jones, Senior Fisheries Manager, Department of Fisheries and Oceans (Retired), As an
44 Morley Knight, Former Assistant Deputy Minister, Fisheries Policy, Department of Fisheries and Oceans
(Retired), As an individual, Evidence, 7 October 2022.
23
Melanie Giffin, Marine Biologist and Program Planner at the Prince Edward Island
Fishermen's Association, emphasized that the collection of field and at-sea data
necessary for stock assessments is crucial and that funding for these activities must be
ensured. She suggested that this data could be collected by DFO or by industry on behalf
of DFO. 45 Kathryn Moran suggested that DFO could make use of autonomous surface
vehicles to complete stock assessments. 46
Dominique Robert believed that a limitation for collecting new data is aging Canadian
Coast Guard (CCG) vessels, which are already in such high demand for existing surveys
that finding the time to repair them is difficult. 47 Kris Vascotto and Carey Bonnell agreed
and suggested that more resources be directed to this issue.48 Arran McPherson told the
Committee that three new dedicated CCG fisheries vessels have recently transitioned
into service. 49
Recommendation 6
That DFO conduct an internal audit on the performance of new research vessels to
ensure the suitability of new vessels to maintain and improve the DFO’s ability to
conduct stock assessments, and that the results of this audit be communicated to the
House of Commons Standing Committee on Fisheries and Oceans.
Witnesses also discussed the ability of departmental officials to complete all the
required data analysis. Kris Vascotto worried “[r]ecent staffing efforts focused on
populating new programs have resulted in a drain from existing ones. This means more
vacancies in key stock assessment positions and gaps in analytical capacity.” 50 Robert
Rangely suggested that DFO might have a difficult time meeting the timelines of
Canada’s new stock rebuilding regulations. 51 Christopher Jones wondered what impact
the attribution of physical and human resources to monitoring protected areas would
45 Melanie Giffin, Marine Biologist and Program Planner, Prince Edward Island Fishermen's Association,
Evidence, 2 June 2022.
46 Kathryn Moran, President and Chief Executive Officer, Ocean Networks Canada, Evidence, 5 May 2022.
48 Kris Vascotto, Executive Director, Atlantic Groundfish Council, Evidence, 21 June 2022; and Carey Bonnell,
Vice-President, Sustainability and Engagement, Ocean Choice International L.P., Evidence, 21 June 2022.
7 October 2022.
50 Kris Vascotto, Executive Director, Atlantic Groundfish Council, Evidence, 21 June 2022.
24
have on the department’s ability to undertake stock assessments. 52 Christina Burridge

worried that stock assessments necessary to meet the conditions necessary to obtain a
Marine Stewardship Council (MSC) certification could be delayed in favour of regulatory
or legislative requirements, such as those under the Species at Risk Act, due to a lack of
sufficient staff. 53 The Fisheries Council of Canada stated in its brief that delays in stock
assessments can lead to fisheries losing their MSC certifications. 54 Kris Vascotto
emphasized the importance of mentorship opportunities for newer staff within DFO as
well as staff retention policies to develop and keep stock assessment knowledge within
the department. 55
Carey Bonnell expressed concern that, “even though demands for government-required
rebuilding plans, as well as sustainability certification supports” have grown in the last
few years, recent investments in DFO science
have primarily been to support ocean science—such as funding to support marine

conservation targets, marine mammal research, etc.—as opposed to its capacity and
expertise for commercial stock assessments. While investment in ocean science is
critical to monitor the health of our oceans, it is high-quality stock assessment science
that ensures the sustainable and optimal utilization of Canada's fish stocks. 56
Martin Mallet, Executive Director of the Maritime Fishermen's Union, suggested that
DFO stock assessments be adapted and properly funded to reflect a “rapidly changing
ecosystem associated with climate change.” 57
Recommendation 7
That DFO allocate sufficient resources, including sufficient at-sea capabilities, to conduct
timely and comprehensive stock assessments and acoustic surveys for all commercial
fish species.
54 Fisheries Council of Canada, “Science at the Department of Fisheries and Oceans,” Written submission to
the House of Commons Standing Committee on Fisheries and Oceans, 31 August 2022.
55 Kris Vascotto, Executive Director, Atlantic Groundfish Council, Evidence, 21 June 2022.
56 Carey Bonnell, Vice-President, Sustainability and Engagement, Ocean Choice International L.P., Evidence,
21 June 2022.
57 Martin Mallet, Executive Director, Maritime Fishermen's Union, Evidence, 9 June 2022.
25
Recommendation 8
Considering that DFO’s scientific models used for stock assessments rely on data from
surveys, the Committee recommends that greater emphasis be placed on completing
surveys and robust data acquisition, even when vessels break down or are unavailable.
That DFO do this by fostering relationships with the fishing industry to utilize commercial
fishing license holders and vessels to supplement DFO scientific data collection.
Recommendation 9
That, in order to ensure stock assessment surveys are completed, DFO identify and use
opportunities that exist for harvester data to be included in stock assessment activities,
thereby contributing to collaborative and citizen science.
Recommendation 10
That DFO immediately implement, in partnership with academic and industry scientists,
a review of the criteria for the selection of survey areas to consider variability in stock
distributions as well as harvester observations in order to have a more realistic view of
the status of fish stocks and fishing pressure. These stock surveys should take place twice
a year.
Recommendation 11
Given the importance of a sustainable fishery on the economic and social health of small,
coastal communities and our obligations toward Indigenous reconciliation, that DFO
prioritize completing regular and thorough stock assessments on all three coasts and
commit to timely and fulsome community and stakeholder engagement on proposed
fishing restrictions to protect fish stocks and marine species threatened or at risk.
Recommendation 12
That DFO commit to more timely decision-making to provide certainty to fish harvesters
and industries impacted by fisheries decisions. This would ensure that those impacted,
whether positively or negatively by these decisions have enough time to prepare and
react to the changes and will ensure that government can provide support for those
industries negatively impacted by fishery closures.
Recommendation 13
That DFO review the allocation of its resources, financial and otherwise, between ocean
science and fisheries science to
26
• ensure sufficient funding for the stock assessments required for sound
management, eco certifications and rebuilding plans required to restore
depleted stocks; and
• reflect the commercial, social, and cultural importance of fisheries in

coastal communities.
Recommendation 14
That DFO introduce an annual Report to Parliament on the status of fish stocks, staffing
levels and expenditures by program area, and fisheries management performance in a
publicly available report to enable transparency of evidence used for ministerial
decision-making, including any pertinent decision notes.
Recommendation 15
That the Minister of Fisheries, Oceans and the Canadian Coast Guard immediately direct
departmental officials to provide the Committee on an annual and ongoing basis with
documentation containing tables reflecting how many fishery stocks DFO manages, how
many stocks have and have not been assessed in the current year, and what actions the
Minister will commit to ensure resources and direction are provided to increase stock
assessments starting in 2023 as an annual exercise.
Modelling
Greig Oldford told the Committee that “simulation modelling and computer modelling
[do] play an outsized role in marine ecology.” 58 He added that it isn’t easy to navigate
uncertainty in modelling, especially in marine ecology since variables can’t be isolated in
controlled experiments and long-term data series are not always available. 59 Andrew
Trites explained that an aspect of modelling that is often overlooked is the degree of
certainty of a model (i.e., how likely a particular outcome is). He added that a higher
certainty (such as 80%) is likely preferred for big decisions and that a lower certainty
(say 30% to 40%) could be enough for decisions where what is at stake is not considered
to be of high value. 60
58 Greig Oldford, PhD Candidate and Scientist, University of British Columbia, As an individual, Evidence,
5 May 2022.
59 Ibid.
27
Christopher Jones told the Committee that over the past several years, it seemed as
though “DFO has updated most of its stock assessment models, which for the most part
have resulted in decreasing assessments.” 61 He wondered why the models had been
updated at this time, if the models were updated to take an approach more focused on
conservation, which parameters had been updated and to what extent, and whether the
models had been modified to more closely resemble Scandinavian stock assessment
models. He described the impact of the new model on the halibut stock assessment, a
fishery that “has been solid on the Atlantic coast for years,” as follows:
The population has recovered under the existing models. This has created questions. If
the existing model was either inadequate or flawed, how could the halibut population
thrive using it? What was the rationale for changing the model if the model may not
have been flawed? The new model suggests reducing the quota by 13%. Is this an
indicator of increased accuracy within the new model, or has the model been adjusted
to reflect the enhanced conservation objectives? If not, is there an accuracy threshold
that the new assessment modelling is striving to achieve? 62
Jesse Zeman, Executive Director, B.C. Wildlife Federation, described how DFO
management, not DFO science, developed a model for the period where interior Fraser
steelhead move through the Fraser River. While this model “was rejected through the
peer review process,” Mr. Zeman stated that “DFO management is still using this
rejected model to brief the minister.” 63
Jean Côté told the Committee about to a novel artificial intelligence model that uses
“post-season data collected over the last 10 years to predict the evolution of stocks and
catches” that his organization had developed with a private company rather than in
collaboration with DFO because of a lack of availability from the relevant DFO official.64
Recommendation 16
That the current DFO modelling used for stock assessments be changed to allow for
fisher data input and that the DFO modelling should be reviewed in the European stock
assessment modelling concept.
62 Ibid.
63 Jesse Zeman, Executive Director, B.C. Wildlife Federation, Evidence, 28 April 2022.
2 June 2022.
28
THE DEVELOPMENT OF SCIENCE ADVICE THROUGH THE CANADIAN

SCIENCE ADVISORY SECRETARIAT
The Committee heard many witnesses describe what they believed were shortcomings
within the CSAS process, including potential conflicts of interest for participants to the
CSAS process and the use of consensus to stifle opposing views. Witnesses including
Jeffery Young, Senior Science and Policy Analyst at the David Suzuki Foundation, Greg
Taylor, Consultant and Fisheries Advisor at the Watershed Watch Salmon Society, and
Andrew Bateman told the Committee that DFO’s processes are good in theory but not
in practice. 65 Robert Chamberlin suggested that “CSAS is a shining example of the
environment within DFO that needs to be meticulously analyzed and restored back to its
original mandate—namely, the mandate of actually working to protect the environment
and wild fish for Canadians.” 66 Jeffery Young stated that “the process for DFO decision-
making is broken, and science is at the middle of this failure, or, more concerningly, is
being pushed to the side.” 67
While most witnesses agreed that there were issues with at least some elements of the
CSAS process, they suggested differing levels of necessary intervention. Alexandra
Morton suggested the formation of a “a non-government board of scientists to monitor
DFO's response to science.” 68 John Reynolds suggested that DFO could “adopt a prime
directive where management objectives are expressly prohibited from influencing
science, and there could be checks and balances along the way to ensure that is
occurring.” 69 Jesse Zeman proposed a “full restart” in order to “separate DFO
management from DFO science.” 70
Composition of Groups Involved in Canadian Science Advisory

Secretariat Processes
DFO’s Policy on Conflict of Interest in Science Peer Review Processes was implemented in
2021. The policy “directly addresses the importance of objective science, free from
65 Jeffery Young, Senior Science and Policy Analyst, David Suzuki Foundation, Evidence, 14 June 2022; Greg
Taylor, Consultant and Fisheries Advisor, Watershed Watch Salmon Society, Evidence, 28 April 2022; and
Andrew Bateman, Manager, Salmon Health, Pacific Salmon Foundation, Evidence, 28 April 2022.
67 Jeffery Young, Senior Science and Policy Analyst, David Suzuki Foundation, Evidence, 14 June 2022.
69  John Reynolds, Chair, Committee on the Status of Endangered Wildlife in Canada, Evidence, 5 May 2022.
29
political, commercial and client interference.” 71 According to Arran McPherson, who is
the DFO official responsible for the policy, the conflict of interest policy “codified what
was already a best practice in many of our CSAS processes across the country, and
codified that participants who come to our meetings are in fact there as impartial
experts bringing their expertise and not a consideration of the impacts of decisions.” 72
She further explained that the chair of individual CSAS processes is “responsible for
ensuring that the conflict of interest policies are respected throughout the process.” 73
Bernard Vigneault described peer review as a “vital component of the important
challenge function that the DFO science sector provides” with the objective of providing
“sound, objective and impartial science information and advice.” 74
Witnesses expressed apprehension about the composition of some the panels and
tables in CSAS processes, worrying that the presence of a particular interest group could
skew the conclusions reached. For example, Keith Sullivan, Martin Mallet, Jean
Lanteigne, Director General of the Fédération régionale acadienne des pêcheurs
professionnels, and Kris Vascotto spoke of the presence of environmental non-
governmental organizations at fisheries advisory tables. 75 Various witnesses also spoke
about the presence of the fish farming industry during CSAS processes related to
aquaculture and wild Pacific salmon. These examples are presented in an upcoming
section.
Jeffery Young proposed that “[s]takeholder tables and even technical working groups
formed by DFO have largely served to reposition DFO as an arbiter between interests
rather than a regulator and upholder of good science and evidence-based
information.” 76
However, not all the witnesses believed that undue influence was being exerted by
participants in CSAS processes. The experience of Josh Korman, Fisheries Scientist at
Ecometric Research Inc., with the CSAS process led him to believe that the review
71 Government of Canada, Canadian Science Advisory Secretariat, Policy on Conflict of Interest in Science Peer
Review Processes.
7 October 2022.
73 Ibid.
75 Keith Sullivan, President, Fish, Food and Allied Workers - Unifor, Evidence, 2 June 2022; Martin Mallet,
Executive Director, Maritime Fishermen's Union, Evidence, 9 June 2022; Jean Lanteigne, Director General,
Fédération régionale acadienne des pêcheurs professionnels, Evidence, 9 June 2022; and Kris Vascotto,
Executive Director, Atlantic Groundfish Council, Evidence, 21 June 2022.
30
process of working papers is actually “quite rigorous,” and he had “not observed that
unsupported bias from DFO fisheries management or outside parties have unduly
influenced CSAS working papers or their final versions.” 77
Recommendation 17
That DFO conduct robust peer reviewed, non-biased science with academic organizations
and include both harvesters’ knowledge and Indigenous traditional knowledge.
Recommendation 18
That the Government of Canada initiate an independent audit of how and to what
degree DFO has implemented their science integrity policy and that the resulting audit
report be tabled in the House of Commons in 2023.
Use of Consensus during the Canadian Science Advisory Secretariat

Process
Regarding the consensus needed to formulate science advice during the CSAS process,
DFO documentation notes that:
[i]n cases where there are two or more equally reasonable conclusions, the peer review
may apply a “weight of evidence” approach to clarify which is most strongly backed by
current available scientific evidence. Strongly opposing opinions or viewpoints may be
noted in the record of proceedings. 78
Witnesses who had participated in CSAS meetings questioned the atmosphere at these
meetings. Michael Dadswell, retired professor of biology at Acadia University (as an
individual) shared that, based on his experience at more than 20 CSAS meetings,
“differing opinions on data and conclusions that are contradictory to DFO policy and
unsanctioned by CSAS are most often totally unwelcome and usually ignored.” 79 Andrew
Bateman explained that “consensus is held up as a strength of CSAS, but meetings apply
strong social pressure on dissenting voices […]. There is no mechanism for errors to be
addressed once the consensus box has been ticked.” 80 He added that:
77 Josh Korman, Fisheries Scientist, Ecometric Research Inc., Evidence, 5 May 2022.
78 DFO, Understanding the Canadian Science Advisory Secretariat.
79 Michael Dadswell, Retired Professor of Biology, Acadia University, As an individual, Evidence, 12 May 2022.
31
In any case, consensus is not a requirement of the scientific process, and the practice of
minimizing real disagreement does a disservice to decision-makers and flies in the face
of the SAGE guidelines that state that decision-makers should consider the multiple
viewpoints received, not just the distilled version of uncertainty used in practice. 81
Brian Riddell, Science Advisor at the Pacific Salmon Foundation, argued that forcing
consensus was a disservice to the Minister since they have “the responsibility to
understand the uncertainties, as well. That’s where the management of policy comes
into play, not in the science.” 82
Arran McPherson clarified that DFO defines consensus as “‘absence of evidence-based

opposition'. It's not enough to disagree. There needs to be evidence that's brought
forward to support the point of view that's being made at the meeting itself.” She added
that the possibility to make note of “perspectives or issues that did not arrive at
consensus” does exist within the CSAS process and is left to the discretion of the chair.
She explained that it was an element that could be used more often. 83
Examples of the use of consensus during the CSAS process in the context of wild Pacific
salmon are discussed in an upcoming section.
Transparency and Communication of Scientific Information

Bernard Vigneault stated that the results of peer reviews and the supporting
analyses are
published on the department's website. These scientific analyses inform departmental

decision-making and provide Canadians with the scientific analyses and advice
generated by the departmental science staff. DFO also supports open science, has an
action plan and continues to publish data, including through the open government data
portals. All DFO science reports are open and accessible. 84
Jeffery Young described the importance of the transparent scientific communication

as follows:
Our challenge today is a lack of accountability built on a foundation of transparent,

evidence-based reporting. Science needs to be recentred in the decision-making
81 Ibid.
7 October 2022.
32
structure, while we ensure that it is adequately transparent and independent of political

interference. It is appropriate for the political decision-makers to weigh multiple
considerations, but it is critical that science advice and information be as objective as
possible and be made available to the public. 85
Witnesses were dissatisfied with the amount of publicly available information.

Robert Rangely told the Committee that less than 10% of science publications are
released on time despite the CSAS policy to “ensure transparency and timely
dissemination of publications.” He added that
the most relevant science advice was often not publicly available until after the decision
was made and communicated. As a result, and despite the government's intention to
promote public transparency and policy engagement, decision-making in DFO may be
based too frequently on a flawed or limited understanding of the underlying scientific
evidence. 86
Many witnesses shared examples of scientific information related to wild Pacific salmon
seemingly being suppressed or altered at different stages of the CSAS process before
being communicated to the Minister or made available to the public. Examples of
difficulty gaining access to information, apparent changes in research plans to avoid
troublesome results and inappropriate interpretation of CSAS documents are presented
in an upcoming section.
Recommendation 19
That DFO improve the transparency of data and research by developing a portal to
publish the detailed studies, including the scientific and socio-economic impact
documentation, that are the inputs into the CSAS and COSEWIC processes. This portal
should be easy to navigate and include both raw data and summaries free of scientific or
bureaucratic jargon so that all Canadians, and fishers in particular, can understand
the findings.
Recommendation 20
Make all scientific data produced by DFO publicly available for peer review from
researchers outside of the Department.
33
INDIGENOUS INVOLVEMENT
Aidan Fisher, Biologist at the Lower Fraser Fisheries Alliance, and Greg Taylor described a
desire for the increased involvement of Indigenous peoples in the development of
scientific conclusions as well as the field and lab work necessary to develop them.87
Michael Staley, Biologist at the Fraser Salmon Management Council, explained that
support to develop the scientific and technical capabilities of First Nations would enable
them to take up their role in the co-management of fish and fisheries resources
with DFO. 88
Carey Bonnell suggested that Indigenous knowledge and Indigenous stakeholders

“deserve a seat at the table, and direct representation and input into the decision-
making process.” 89
The role of Indigenous knowledge in the development of science advice was discussed.
Witnesses expressed hope that traditional knowledge would be better incorporated into
DFO’s scientific activities and conclusions. The Committee heard that it is currently only
applied as a small part of the peer review process and often not applied in the final
recommendations. Charlotte K. Whitney explained that “Indigenous knowledge often has
longer baselines and superior understanding of local ecosystems than western science
does and, therefore, should be treated as the valid knowledge system that it is.” 90
Alejandro Frid, Science Coordinator at the Central Coast Indigenous Resource Alliance,
gave the Committee an example of the longer baselines of Indigenous knowledge and
how they can benefit the development of science advice. He described an analysis of
data that showed “very rapid declines in the size and age structure of yelloweye
rockfish.” 91 The DFO survey data from 2003 to 2015 showed a “decline of about half a
centimetre per year in the average size of yelloweye rockfish and an average decline of
about 10 months per year in the average age of yelloweye rockfish.” 92 Since larger
females are more fecund than smaller females per unit of body size, Alejandro Frid
87 Aidan Fisher, Biologist, Lower Fraser Fisheries Alliance, Evidence, 2 June 2022; and Greg Taylor, Consultant
and Fisheries Advisor, Watershed Watch Salmon Society, Evidence, 28 April 2022.
88 Michael Staley, Biologist, Fraser Salmon Management Council, Evidence, 28 April 2022.
89 Carey Bonnell, Vice-President, Sustainability and Engagement, Ocean Choice International L.P., Evidence,
21 June 2022.
91 Alejandro Frid, Science Coordinator, Central Coast Indigenous Resource Alliance, Evidence, 28 April 2022.
92 Ibid.
34
explained that this has tremendous implications for fecundity. He further explained that
DFO’s data collection started in 2003, after the commercial fisheries had already cause
declines in yelloweye rockfish.
Looking at indigenous knowledge through structured interviews, we reconstructed the

body sizes of yelloweye going back to the 1950s or so and how, in the catches of
indigenous fishers, those sizes changed over time. Between 1980—which is before any
of these scientific surveys had begun—and 2000, we see a decline of nearly half the
average size. If we only look at the scientific data, we will have a shifting baseline of
what would have been considered normal. It would be starting in 2003, which is about
half the body size and disproportionally lower fecundity that was there before the
commercial fisheries got under way. 93
Robert Chamberlin emphasized that Indigenous rights are not site-specific, giving the
example of the impacts fish farms in the Discovery Islands have on Pacific wild salmon
that migrate past them and into the interior of British Columbia.94
Recommendation 21
That the government expand the CSAS process beyond scientists and individuals with a
scientific background to be more inclusive of traditional Indigenous knowledge and
harvesters’ knowledge.
Recommendation 22
That DFO work to incorporate traditional Indigenous knowledge and fisher knowledge
into its scientific activities and to give it greater consideration.
Recommendation 23
That DFO increase the collaborations with Indigenous peoples and fishers in the
development of field and lab work, as well as in the development of
scientific conclusions.
Recommendation 24
DFO should work with First Nations to develop a culturally appropriate way to use
traditional Indigenous knowledge and fisher knowledge in management, such as to
trigger early warning signs about the health of marine species and ecosystems.
93 Ibid.
35
Recommendation 25
Honour and respect existing fisheries and oceans management cogovernance

agreements and implement those processes that are inclusive of Indigenous knowledge,
ecosystem and precautionary thresholds.
Recommendation 26
That the government build scientific and technical capacity with First Nations and their
organizations in recognition of their inherent Indigenous title and rights.
INDUSTRY INVOLVEMENT
Bernard Vigneault described current interactions between DFO and industry as follows:
We have key collaborations and we consider the information provided by fishers in

different ways. It can start from the very beginning. In some cases, we do data collection
in partnership with industry, which provides us with samples and participates in
sampling. It can also go as far as interpretation and peer review of the data, where we
invite industry experts to provide and validate information about fishing activities,
observations and methods used. 95
Matthew Hardy, Regional Director of Science, Gulf Region, DFO, explained that DFO
carries out projects in cooperation with industry stakeholders and that “information we
derive from industry partnerships is an important factor in many of our assessments.” 96
Witnesses such as Keith Sullivan, Jean Lanteigne and Martin Mallet believed industry
could collaborate more closely with DFO to supplement the department’s ability to
collect data. 97 Martin Mallet listed the benefits stemming from a collaborative science
process:
[Collaborative science processes] allow fishermen leaders within our membership to

understand and buy into the science-backed management measures that are needed to
improve our fisheries—for example, lobster and snow crab. For DFO scientists, they
enable them to get to know and discuss with fishermen their daily, yearly and even
generational observations and insights with regard to ecosystem patterns experienced
while fishing. On many occasions, science projects are then developed to test some of
96 Matthew Hardy, Regional Director, Science, Gulf Region, DFO, Evidence, 26 April 2022.
97 Keith Sullivan, President, Fish, Food and Allied Workers - Unifor, Evidence, 2 June 2022; Jean Lanteigne,
Director General, Fédération régionale acadienne des pêcheurs professionnels, Evidence, 9 June 2022; and
Martin Mallet, Executive Director, Maritime Fishermen's Union, Evidence, 9 June 2022.
36
these patterns with success. On all occasions, it’s been an opportunity for all parties to
exchange, raise awareness on issues and develop trust in a common science process.
Where this formula has been used, we have seen success stories such as in the
management of the lobster and snow crab fisheries in the southern Gulf of Saint
Lawrence. However, with other resources such as herring and mackerel, we are
currently facing challenges where this collaboration has not been established or
is limited. 98
Recommendation 27
That DFO should work with fish harvesters to communicate, in a more open and
transparent manner their work and scientific conclusions, especially in cases where the
evidence seems at odds with the observations of fish harvesters.
Recommendation 28
That DFO make greater efforts to improve the flow of information from fish harvesters to
the DFO Science branch about what they are seeing out on the water.
Recommendation 29
That DFO include knowledge and data collected by commercial fishers, including
independent inshore fishers, in the peer review process, including their knowledge and
observations regarding changes in distribution and abundance. That DFO formalize a
system for fishers to participate and provide input in all aspects of fisheries
management, including stock assessment protocols and management plans.
Recommendation 30
That DFO apply the same management measures to all fishers of a given species in a
given fishing zone based primarily on science and stock conservation for a
sustainable fishery.
Industry witnesses expressed a desire for more opportunities for input in the CSAS
process. Keith Sullivan was disappointed that a section for harvester or stakeholder
observations was removed from the CSAS process. 99 Witnesses such as Jean Côté;
Melanie Giffin; Kris Vascotto; Eda Roussel, Fisheries Advisor at the Association des
crevettiers acadiens du Golfe; Herb Nash, President of the 4VN Management Board (as
an individual); and Leonard LeBlanc, Professional Advisor, Gulf Nova Scotia Fishermen's
37
Coalition, felt that industry knowledge is not given the weight it deserves since
harvesters are out on the water and are often the first to see changes. 100
Christina Burridge described the contribution of industry experts and analysts as

bringing “an understanding of fisheries and survey data, assessment methodologies,
evaluation, and the management context that scientists may not have.” 101 Jean Côté
believed it was one thing to “consult” industry but that “sometimes you have to take our
advice and what we say into account.” 102 Christopher Jones added that current DFO
consultations assume all fishers are part of an association. He felt that those who aren’t
“are discounted, not engaged, not involved and not contacted.” 103
Recommendation 31
That DFO revitalize relationships with the recreational and commercial fishing industries
and demonstrate fair process in decision-making.
Not all witnesses believed that the involvement of industry should be increased. Robert
Chamberlin spoke about the CSAS process for the Discovery Islands risk assessments and
stated that a science peer review process that allows a proponent, which is a fish farm
company, and industry stakeholders to participate “from the beginning to the end of this
process is utterly and completely lacking any measure of objectivity or credibility.” 104 He
explained that such situations had led to “CSAS as a peer review secretariat [having] zero
credibility with the first nation members of the First Nation Wild Salmon Alliance.” 105
2 June 2022; Melanie Giffin, Marine Biologist and Program Planner, Prince Edward Island Fishermen's
Association, Evidence, 2 June 2022; Kris Vascotto, Executive Director, Atlantic Groundfish Council, Evidence,
21 June 2022; Eda Roussel, Fisheries Advisor, Association des crevettiers acadiens du Golfe, Evidence,
9 June 2022; Herb Nash, President 4VN Management Board, As an individual, Evidence, 7 October 2022;
and Leonard LeBlanc, Professional Advisor, Gulf Nova Scotia Fishermen's Coalition, Evidence, 21 June 2022.
2 June 2022.
105 Ibid.
38
ROLE OF SCIENCE IN DECISION-MAKING AT FISHERIES AND

OCEANS CANADA
Mona Nemer explained that science “helps government decision-makers gather data,
analyze evidence and assess different policy options and their impacts” and added that
“[open] science and transparency are essential not only for creating good policy, but also
for maintaining and building trust in our public institutions.” 106
Greg Taylor believed that the “risk to our fisheries from decisions inconsistent with
good science are immeasurably greater” than 40 years ago due to “the climate crisis,
cumulative land and water use impacts and a decision-making process that continues to
put fisheries before fish.” 107 There was general agreement amongst witnesses that
species should be managed in a way that prioritizes the long-term health of a species
rather than yearly quotas.
Witnesses spoke about elements of good policy or approaches at DFO that were being
incorrectly implemented. Greg Taylor believed Canada has a policy structure in place
that would be “extremely effective in turning science advice into good management
decisions. It's just that managers have not implemented it.” 108 As an example, he
pointed to the Sustainable Fisheries Framework, which provides specific direction to
managers but unfortunately “these powerful science-based policies and the
management guidance laid out within them are ignored in management decisions.” 109
He added that independent monitoring or oversight could be added to the existing basic
structure to ensure it is implemented.
Gideon Mordecai, Research Associate at the Institute for the Oceans and Fisheries,
University of British Columbia (as an individual), argued it was important to focus on
“making sure the science information can get to the decision-makers” without
information being blocked at any of the various steps in the process.110
Greg Taylor mentioned that, contrary to the Constitution of the State of Alaska or the
Magnuson-Stevens Fishery Conservation and Management Act in the United States,
Canada does not have “an obligation to ensure decisions are consistent with a science-
107 Greg Taylor, Consultant and Fisheries Advisor, Watershed Watch Salmon Society, Evidence, 28 April 2022.
108 Ibid.
109 Ibid.
110 Gideon Mordecai, Research Associate, Institute for the Oceans and Fisheries, University of British Columbia,
As an individual, Evidence, 5 May 2022.
39
based management framework” and that acknowledging or considering policies is “a far
cry from either implementing them or being bound by them as managers are in other
jurisdictions such Alaska or the U.S.” 111
Communication of Science Advice to the Minister

Many witnesses expressed concerns about the scientific advice that was being
communicated to the Minister of Fisheries, Oceans and the Canadian Coast Guard;
believing that incomplete, modified or misrepresented scientific conclusions may be
being provided to the Minister. They believed the advice of competent DFO scientists
was being edited along the way to reflect policy preferences. Jesse Zeman stated that his
organization was “not concerned with DFO scientists' ability to conduct science. It is
concerned with decision-makers and senior managers' willingness to edit, suppress and
hide that science.” 112 Josh Korman believed a “sort of firewall […] to confirm that what
the science says is translated into the management advice” was needed, sharing that key
conclusions from the Recovery Potential Assessment report for interior Fraser steelhead,
for which he was the senior author, were not reflected in management advice. 113
Charlotte K. Whitney shared that when disconnects occur between science advice and
management decisions, “they have led to management decisions that maintain a status
quo rather than applying the best available science.” 114
Judith Leblanc, Science Advisor at DFO, stated that over her 26 years at DFO, she had
learned to accept her “area of influence” and that her duties as science advisor included
providing science advice to the department’s management but that once the advice is
submitted, the “decisions rest with management,” not with her in her role as science
advisor. 115 Dr. Kristi Miller-Saunders agreed and added that “[w]e have very little control
or a limited amount of input on what science moves forward to the minister, or even to
upper managers in Ottawa, and how they utilize that science.” 116
Sean Jones, Legal Counsel at Wild First, believed that
115 Judith Leblanc, Science Advisor, DFO, Evidence, 26 April 2022.
40
DFO managers need to allow scientists to communicate directly with those decision-
makers and allow the briefing notes and materials that they prepare to go
unadulterated to the minister. We've documented numerous examples where scientists
are trying to get critical information to the minister, but DFO managers simply interfere
and rewrite the materials, so that the science that is presented is done in a way that
confirms existing policy, rather than presenting the minister with the best available
information. 117
He added that DFO would likely see fewer decisions being overturned on judicial reviews
if “DFO managers were providing the minister with a more fulsome and objective
representation of the evidence before her.” 118
Examples of situations where peer-reviewed science advice about wild Pacific salmon
was seemingly not translated into management advice or not communicated to the
Minister is discussed in an upcoming section.
Integration of Fisheries Science and Other Considerations into Fisheries

Management Decisions
According to Sessional Paper 8555-431-445, tabled in the House of Commons on 20 July

2020, the CSAS process “explicitly does not consider socioeconomic impacts or the
management implications of the advice. The science advice is intended to serve as an
input into the decision-making process.” 119 However, some witnesses felt that desired
policy outcomes often taint the science advice before it reaches the Minister.
Andrew Bateman believed that science was not the only decision-making factor at the
table and that DFO was manipulating science advice. He added that decision-makers
have to weigh competing or complementary demands, the economy being one of them.
It's really that the science advice that's presented to the decision-makers, ultimately to
the minister, needs to be unfettered by departmental manipulation by mid- and upper-
level managers. 120
Martin Mallet, Keith Sullivan, Martin Paish, Director, Business Development at the Sport
Fishing Institute of British Columbia, and Jean Lanteigne agreed that, along with
scientific data, social and economic factors should be considered by the Minister as
117 Sean Jones, Legal Counsel, Wild First, Evidence, 14 June 2022.
118 Ibid.
119 Government of Canada, Sessional Paper 8555-431-445, July 2020.
41
critical components of fishery sustainability. 121 Witnesses underscored the need for
transparent and independent scientific advice to be provided to the Minister without it
having been tainted by other considerations. John Reynolds, Chair of the Committee on
the Status of Endangered Wildlife in Canada, described such a process:
You can model or advise on what the potential options are and what are mostly likely to
be effective. The minister then can take that information about the options and what the
science is that is supporting those options, and then bring in these other factors that they
have to consider, the trade-offs and the people who will be harmed by the management
actions, for example. As long as that’s done in a transparent and open way so that people
can see where the science enters and what other factors were being considered, then that
would certainly be a process that I think a lot of people could sign up to. 122
Outside of the CSAS process, DFO does conduct economic analyses to assist
departmental decision-makers evaluating the impacts of resource management, policy
and regulatory decisions.123 Witnesses questioned the level of detail within what the
department called a socio-economic analysis. Tasha Sutcliffe, Senior Policy Advisor at
Ecotrust Canada, suggested that what the department considers a socio-economic
analysis is actually a “very shallow economic analysis. It doesn’t go into enough detail
on the basic economics around distribution of benefit, coastal community impacts,
incomes, for example.” 124 Martin Mallet agreed that “socio-economic science expertise
is sorely lacking and is needed more than ever to help us better plan and adapt to [the
changes in the ecology, distribution and biomass of several species due to climate
change] that are affecting our fisheries and the coastal communities that depend
on them.” 125
Witnesses believed that ignoring early trends and waiting to act risked leading to larger,
more drastic actions being required later to protect species. Jean Lanteigne believed that
DFO “lets things drag on until its back is against the wall; then it starts asking what it can
do. Very often, it ends up closing the fishery because that’s all it can do when things get
to that point. That’s no solution.” 126 Dominique Robert gave the example of the Atlantic
121 Martin Mallet, Executive Director, Maritime Fishermen's Union, Evidence, 9 June 2022; Keith Sullivan,
President, Fish, Food and Allied Workers - Unifor, Evidence, 2 June 2022; Martin Paish, Director, Business
Development, Sport Fishing Institute of British Columbia, Evidence, 9 June 2022; and Jean Lanteigne,
Director General, Fédération régionale acadienne des pêcheurs professionnels, Evidence, 9 June 2022.
122  John Reynolds, Chair, Committee on the Status of Endangered Wildlife in Canada, Evidence, 5 May 2022.
123 DFO, Economic analysis.
124 Tasha Sutcliffe, Senior Policy Advisor, Ecotrust Canada, Evidence, 12 May 2022.
126 Jean Lanteigne, Director General, Fédération régionale acadienne des pêcheurs professionnels, Evidence,
9 June 2022.
42
mackerel commercial and bait fisheries in Quebec and Atlantic Canada being closed with
very little warning in 2022 after at least a decade of DFO stock assessments indicating
that fishing pressure on the stock was too high, stating that: “It was the right decision to
make given the state of the stock, but I think mackerel fishing should have been
suspended or severely restricted long before that.” 127
Recommendation 32
That DFO consult those who could be most socio-economically impacted by its decisions
and ensure that the socio-economic impacts on communities and the fishing industry are
factored in its decision-making processes. The assessment of economic and social
impacts resulting from decisions should be provided when requested by Canadians.
Recommendation 33
• undertake an examination of how DFO fisheries management officials

influence the work and findings of DFO scientists; and
• produce a report to government including
• an assessment of such influence,
• whether this influence is appropriate and ethical; and
• recommendations, if necessary, of how to reform fisheries management

influence on science in DFO in order to increase independence of DFO
science and ensure there is an established conduit for science to be directly
channeled from scientists to decision-makers for them to consider when
making decisions.
Recommendation 34
• assess the viability of restructuring existing DFO systems and processes

in a manner that would ensure that science advice is independently
43
collated, assessed and delivered to managers and decision-makers by
DFO scientists; and
• produce a report with recommendations from this assessment and that

that report be tabled by the government in the House of Commons
by 2024.
Recommendation 35
• examine to what degree science advice from scientists is implemented

in DFO management and decision-making processes; and
• produce a report with advice and recommendations for establishing

protocols to measure to what degree science advice from scientists is
implemented in DFO management and decision-making processes and
that this report be tabled in the House of Commons by 2024.
Recommendation 36
That the Government of Canada develop and table legislation that establishes a science-
based fisheries management framework and a requirement for the government, through
DFO, to ensure that DFO decisions align with the science-based management framework
and demonstrate alignment of decisions with the framework by publicly releasing
scientific reasons and other factors for decisions.
Recommendation 37
That the Government of Canada initiate an independent audit of how and to what
degree DFO has implemented the Sustainable Fisheries Framework and that the resulting
audit report be tabled in the House of Commons by December 15, 2023.
Recommendation 38
• assess the viability of establishing an independent science advice body

to directly advise DFO decision-makers, assess health and performances
of fisheries, make recommendations on scientific research priorities,
and oversee the implementation of science-based activities; and
44
• provide this assessment in a report with recommendations to the

government to be tabled by 2024.
NEED FOR AND USE OF SCIENCE IN RELATION TO PARTICULAR

SPECIES
Witnesses shared examples where they felt scientific conclusions had been suppressed
or modified before reaching the Minister or where the decisions taken seemed counter
to scientific advice or data. For example:
• Greg Taylor described the “arbitrary decision to cut in half the harvest of
herring on the west coast” in 2022, even though the fishery had been
managed in a way that was consistent with both science advice and
policy up until that point. 128
• Charlotte K. Whitney wondered why the TAC for Bocaccio, a Pacific

rockfish, was increased 24-fold from 75 tonnes to 1,800 tonnes based on
an unusually strong recruitment event in 2016. 129
• Jean Côté described a second commercial lobster fishing season opened

in 2020, ostensibly to collect data, in Lobster Fishing Area 21 that seemed
counter to recent DFO science advice that “in the context of
environmental change, inducing a new source of variability is
undesirable.” 130
• Phil Morlock, Director, Government Affairs at the Canadian Sportfishing

Industry Association, stated that “official DFO policy” seemed to have
become “[a]rbitrary public access closures by percentage targets with no
basis in science or evidence of benefit.” 131
2 June 2022.
131 Phil Morlock, Director, Government Affairs, Canadian Sportfishing Industry Association, Evidence,
9 June 2022.
45
Witnesses also told the Committee about situations where they believed more data was
needed or that data appeared to have been ignored. For example:
• Eda Roussel suggested more data was needed to understand the impact
of rockfish predation on shrimp.132
• Keith Sullivan expressed frustration at the recent closure of the Atlantic

mackerel fishery despite repeated proposals to study harvesters’
observations of small mackerel that were likely not born in the Gulf
of St. Lawrence: “It's really disappointing when a result ends up in a
moratorium and you believe there are people thrown out of work, when
there are questions that could have been answered.” 133 Melanie Giffin
suggested that standardized voluntary logbooks could be a way to record
the small mackerel currently being anecdotally reported in Prince Edward
Island and Newfoundland. The information could then be forwarded
to DFO. 134
• Martin Mallet described a roughshod protocol developed quickly with

DFO to collect data on the spring herring fishery, after the closure of the
fishery led to the loss of access to data previously collected
by harvesters. 135
Two specific examples are described in more detail below.
Example: The Impact of Pinnipeds on Various Fish Stocks

Witnesses discussed the impact of increasing pinniped populations on various fish
stocks, including West and East coast salmon, mackerel, herring, capelin, Atlantic cod
and Atlantic mackerel. Keith Sullivan questioned if fishing quotas could ever be reduced
enough to lead to a rebuilding of stocks if increasing pinniped populations consume
more than the quotas themselves. 136 Robert Hardy, Fisheries Consultant, stated that
DFO Science is reluctant to accept the impact of seals on any fish stocks, and instead
132 Eda Roussel, Fisheries Advisor, Association des crevettiers acadiens du Golfe, Evidence, 9 June 2022.
134 Melanie Giffin, Marine Biologist and Program Planner, Prince Edward Island Fishermen's Association,
Evidence, 2 June 2022.
46
remains dismissive and ignores the evidence provided by fishers, Indigenous peoples,
industry associations and seal science from other North Atlantic fishing nations. 137
Josh Korman described to the Committee how the main conclusions of the Science
Advisory Report (SAR) for interior Fraser steelhead were not consistent with the main
findings of the Recovery Potential Assessment report, which was developed in a peer-
reviewed CSAS process. A main conclusion of the Recovery Potential Assessment report
was that
reductions in the abundance of seals and sea lions was deemed to be the most effective
way of recovering steelhead populations. This fundamental conclusion was substantially
altered by DFO when they wrote the SAR. For example, they stated there was no
consensus that there was a causal relationship between the two—meaning a relation
between steelhead and seals and sea lions. 138
Josh Korman did not recall hearing any substantiated objections to the conclusions that
reducing pinniped abundance is the most effect way to recovering steelhead populations
but could not document the discrepancy because the proceedings of the CSAS process
are not publicly available. He believed this misrepresentation was problematic because it
“misrepresents the primary tool available to us to improve the status of interior Fraser
steelhead and likely for chinook and other salmon.” 139
Keith Sullivan, Robert Hardy, and Leonard LeBlanc expressed the desire to include the
fishing industry and local communities in plans to establish a market for seal products. 140
Mark Prevost, President of Bait Masters Inc., believed that a potential use for seal
byproducts could be as an ingredient in alternative bait sausages for the crustacean
fishery.141
Other witnesses expressed caution at the idea of managing pinniped populations as a

way of increasing the number of fish available for fishers. Jeffery Young mentioned that
the removal of predators such as pinnipeds could have unexpected and unpredictable
impacts on the ecosystem. 142 Alexandra Morton explained that seals and sea lions prey
137 Robert Hardy, Fisheries Consultant, As an individual, Evidence, 14 June 2022.

139 Ibid.
140 Keith Sullivan, President, Fish, Food and Allied Workers - Unifor, Evidence, 2 June 2022; Robert Hardy,
Fisheries Consultant, As an individual, Evidence, 14 June 2022; and Leonard LeBlanc, Professional Advisor,
Gulf Nova Scotia Fishermen's Coalition, Evidence, 21 June 2022.
141 Mark Prevost, President, Bait Masters Inc., Evidence, 21 June 2022.
47
on hake which consume juvenile salmon. A reduced pinniped population could mean a
larger hake population and stronger hake predation on juvenile salmon. 143
Recommendation 39
That scientists conduct pinniped diet analysis for all species of pinnipeds over longer
periods of the year in more diverse regions than in the past and make their data publicly
available by posting it on the DFO website.
Recommendation 40
That, in order to accurately assess the effects of pinniped predation when estimating
mortality levels in fish stock biomass, scientists compare data from countries with similar
species of pinnipeds.
Example: Aquaculture and Wild Pacific Salmon

Witnesses told the Committee about different situations related to wild Pacific salmon
that illustrate many of the different issues described with the CSAS process including
conflicts of interest for participants and the inappropriate use of consensus. They also
told the Committee about problems with transparency and the communication of
scientific information to the public and with the communication of science advice to the
Minister. Jesse Zeman summarized the situation as follows: “When there is good science
and it affects DFO management, that science is hidden or edited or suppressed from
Canadians.” 144
Additionally, witnesses frequently mentioned the apparent conflict of interest within

DFO between its mandate to protect aquatic species and its mandate to regulate and
promote aquaculture. Alexandra Morton did not understand why there was a “big,
aggressive, powerful aquaculture management division in DFO and nothing to
counterbalance it with the wild salmon […] Aquaculture is thriving. Wild salmon are
collapsing. It's pretty clear that they need advocates within DFO.” 145 She gave the
example of a situation where industry communicated to DFO that proposed aquaculture
conditions of license related to the limit of sea lice per farmed salmon
“could have significant impact on... the... financial performance of Mowi's operations”.
Specifically mentioning sea lice, they say that the pace of “regulatory change is

48
outpacing our company's capacity.” Two weeks later, the draft conditions of licence
contained the weakened requirement to produce a plan to reduce sea lice, with no
requirement that the plan was actually successful. 146
Sean Jones and Alexandra Morton believed that an independent scientific advisor should
be appointed to advise the Minister on scientific evidence related to the impacts of
aquaculture on wild Pacific salmon.147
Rebecca Reid, Regional Director General of DFO’s Pacific Region, explained that the
regional director in the Pacific region is responsible for the management of all fisheries
in the Pacific region as well as for aquaculture.148 She believed DFO understands its role
and responsibilities for the management of wild salmon and aquaculture and does so
appropriately. Sarah Murdoch, Senior Director of Pacific Salmon Strategy Transformation
at DFO, described a new group launched at DFO through the Pacific Salmon Strategy
Initiative that works with “colleagues and representatives from branches throughout the
department that do salmon work, whether that be salmon science, fish management,
enforcement or salmon enhancement.” 149
Recommendation 41
Given the conflict of interest between DFO’s mandate relating to aquaculture versus the
application of the precautionary principle and the ongoing crisis for the health of wild
Pacific salmon stocks, that the government implement, on the West Coast only,
Recommendation #3 in the Cohen Commission report on the state of wild salmon:
“The Government of Canada should remove from the Department of

Fisheries and Oceans’ mandate the promotion of salmon farming as an
industry and farmed salmon as a product.”
Recommendation 42
That the Government of Canada initiate an independent audit of what recommendations

of the December 2018 report titled “Report of the Independent Expert Panel on
Aquaculture Science” have been implemented by DFO, how many have been fully
implemented and timelines for full implementation for recommendations that are not
146  Ibid.
147 Sean Jones, Legal Counsel, Wild First, Evidence, 14 June 2022;  Alexandra Morton, Independent Scientist, As
an individual, Evidence, 12 May 2022; and
148 Rebecca Reid, Regional Director General, Pacific Region, DFO, Evidence, 7 October 2022.
149 Sarah Murdoch, Senior Director, Pacific Salmon Strategy Transformation, DFO, Evidence, 7 October 2022.
49
yet fully implemented and that the resulting audit report be tabled in the House of
Commons by June 9, 2023.
Recommendation 43
That, in light of the established aquaculture management division within the department
and that DFO favours the interest of the salmon-farming industry over the health of wild
fish stocks, DFO establish a wild salmon position independent from this division as
recommended in Recommendation 4 of the Cohen Commission report to maintain
impartiality.
Recommendation 44
That DFO place appropriate and adequate value to perspectives provided by the External
Advisory Committee on Aquaculture Science, and reflect such perspectives in policy
recommendations and advice to the Minister of Fisheries, Oceans and the Canadian
Coast Guard, and that the work of the External Advisory Committee on Aquaculture
Science be reported to Parliament on an annual basis.
Conflict of Interest for Participants in Canadian Science Advisory

Secretariat Processes related to Pacific Salmon
Gideon Mordecai spoke about the presence of the salmon farming industry during CSAS
assessments of the impacts of PRV on wild Pacific salmon, stating that “[n]ormally in
science, reviewers who have a conflict of interest are often excluded, especially if the
conflict is financial.” 150 Sean Jones agreed since “industry licensees were asked to vote
on how to diagnose a disease that, if diagnosed, would create significant regulatory
burdens on their operations.” 151
Andrew Bateman described the CSAS processes for the Discovery Island risk assessments
in which he participated as follows:
The processes were neither unbiased nor independent. The risk assessments were
implemented, closely managed and influenced by senior officials from DFO aquaculture,
and employees, contractors and others linked to the salmon farming industry served on
50
the steering committee and as senior reviewers, so that conflict of interest threatened
the integrity of the process. 152
Use of Consensus in Canadian Science Advisory Secretariat Processes

related to Pacific Salmon
In the context of the assessment of the risk to Fraser River sockeye salmon due to the
transfer of Tenacibaculum maritimum from Atlantic Salmon farms in the Discovery
Islands area, Andrew Bateman felt that “dissenting voices were all but bulldozed, such
that the resulting advice document doesn’t reflect the true reality of opinion.” 153 He
added that, for the Discovery Island risk assessments as a whole, the “findings of
minimal risk reflect neither the current state of knowledge nor true scientific consensus.
Key risks were omitted. Sea lice, cumulative effects and the conservation status of the
sockeye stocks were ignored.” 154
Transparency and Communication of Scientific Information related to

Pacific Salmon
Gideon Mordecai, Alexandra Morton, and others believed the impacts of PRV and
Tenacibaculum maritimum on Pacific wild salmon were being minimized by DFO in
favour of the aquaculture industry. 155 Sean Jones agreed, sharing that his experiences
had convinced him that:
[T]he aquaculture management directorate and the Canadian science advisory

secretariat consistently suppress, misrepresent and ignore the scientific evidence
demonstrating that open net-pen feedlots of Atlantic salmon threaten the survival of
wild Pacific salmon. DFO relies on this suppression and misrepresentation to excuse
itself from executing its legal obligations, both domestically and internationally. 156
Stan Proboszcz, Senior Scientist at the Watershed Watch Salmon Society, believed that
DFO may have decided to complete only nine risk assessments for aquaculture
operations in the Discovery Islands area and not a 10th risk assessment on the effects of
153 Ibid.
154 Ibid.
As an individual, Evidence, 5 May 2022; Alexandra Morton, Independent Scientist, As an individual,
Evidence, 12 May 2022; and Sean Jones, Legal Counsel, Wild First, Evidence, 14 June 2022.
51
sea lice on sockeye salmon to avoid publicizing inconvenient research. Initial lab studies
on the effects of sea lice on sockeye salmon
turned out to be quite significant in showing that sea lice dramatically affect the health
of sockeye salmon. DFO started to communicate about this evidence that they had of
minimal risk, but they don't talk about these studies at all in their communications at
the press conference or later on, when they talked to media people. 157
Recommendation 45
Given the perceived issues with the DFO’s risk assessment of the impact of aquaculture
operations in the Discovery Islands on wild fish stocks including:
• the failure to assess the cumulative impacts of the viruses and bacteria
detected; and
• the suppression of additional research that could have had a material

impact on the overall risk assessment,
that DFO submit to an independent review of the risk assessment, including but not
limited to decisions on the assessment’s terms of reference and factors that resulted in
the suppression of research findings on the impact of sea lice and possibly other issues
with a material impact on the health of wild fish stocks. That there be an independent
audit and analysis to determine the accuracy and decision-informing value of the Science
Advisory Report presented to the Minister of Fisheries, Oceans and the Canadian Coast
Guard on DFO’s risk assessment of aquaculture operations in the Discovery Islands.
Recommendation 46
That the Minister of Fisheries, Oceans and the Canadian Coast Guard provide in writing
to the Committee a statement as to whether or not DFO omitted, canceled or in any
other way did not complete or make unavailable a 10th CSAS risk assessment examining
potential risks to Fraser sockeye.
Dr. Kristi Miller-Saunders described the long delay between the drafting of a report on
PRV and its publication. The 2012 report showed that PRV, a virus that may cause heart
disease in salmon species, had been detected in farmed Chinook salmon that were
suffering from disease. This was the “first sign that PRV might pose a risk to Pacific
157 Stan Proboszcz, Senior Scientist, Watershed Watch Salmon Society, Evidence, 12 May 2022.
52
salmon.” 158 The publication delay “was due to a disagreement between [Dr. Miller-
Saunders] and the industry vets on the interpretation of the science. That delay has
continued for 10 years, because apparently there needs to be an agreement on the
interpretation of the science before the report can be put in, or before a manuscript can
be prepared.” 159 Gideon Mordecai wondered whether, if this work had not been “held
back from the scientific community, perhaps some of the impact on salmon in B.C. from
this virus may have been prevented.” 160
Recommendation 47
That in light of new scientific revelations of potential impacts of Tenacibaculum

maritimum and Piscine orthoreovirus (PRV) on wild Pacific salmon, the Government of
Canada request that the Chief Science Advisor assess and make recommendations to the
Minister of Fisheries, Oceans and the Canadian Coast Guard on the potential necessity
for a CSAS assessment of risks posed by Tenacibaculum maritimum and PRV on all
species of wild Pacific salmon, including Fraser sockeye.
Jesse Zeman described the long, frustrating process to attempt to gain access to
information related to Fraser steelhead which involved an Access to Information and
Privacy (ATIP) request. He relayed how, following a complaint by the B.C. Wildlife
Federation about the 10-month turnaround for the request given by DFO, the Office of
the Information Commissioner found that the exclusion was not reasonable given the
circumstances even if DFO had deemed refusal of access to the requested records. The
Office informed the B.C. Wildlife Federation that pursuing this issue further would mean
applying to the Federal Court for a review. Jesse Zeman though it was unreasonable to
expect his organization to pay legal fees to gain access to records paid for by Canadians.
In his opinion, the refusal to grant access means that “transparency within this
institution is non-existent. Within the context of science, it means that DFO is willing and
happy to not only hide and edit science. It is now happy to refuse to disclose records.” 161
Andrew Bateman was dismayed that, even ignoring problems with the CSAS process
itself, CSAS findings can be “misrepresented by some within DFO.” He gave the example
of the findings from the sockeye risk assessments being used to “argue that B.C. salmon
53
farming poses no more than a minimal risk to wild salmon. This is absolutely not what
the CSAS studies found, being highly specific to the risks from Discovery Islands farms to
Fraser River sockeye salmon alone.” 162
Josh Korman had observed “substantive meddling by DFO in the conversion of a

recovery potential assessment report for interior Fraser steelhead into the scientific
advice report.” 163 John Reynolds gave an example of this meddling by describing the
reduced emphasis of the role of bycatch as an ongoing threat to Steelhead, noting that
bycatch is the responsibility of DFO.164 He also stated that DFO has, until recently, denied
the harm caused to wild salmon by salmon farming which suggested to him that “policy
preferences [had] been affecting science advice rather than the other way around.” 165
Communication of Science Advice related to Pacific Salmon to

the Minister
Sean Jones and Andrew Bateman compared the current situation regarding DFO and its
action on aquaculture and wild Pacific salmon to the situation in the 1990s related to
the collapse of cod stocks. 166
Jesse Zeman described information he obtained about the development of the Science
Advisory Report for the Recovery Potential Assessment for interior Fraser steelhead as
part an ATIP request. The Recovery Potential Assessment was triggered by a
recommendation by the Committee on the Status of Endangered Wildlife in Canada to
list interior Fraser steelhead as endangered. He stated that, in this case, the CSAS
process was “completely undermined” by DFO. He noted that the thousands of pages
received in the ATIP of the CSAS process
revealed the assistant deputy minister's office gave a directive to modify some key
points related to allowable harm for interior Fraser steelhead. Additionally, the chair of
the process indicated they were cut out of the process and expressed serious concerns
about the scientific integrity of the process. Furthermore, in these documents the chair
164 John Reynolds, Chair, Committee on the Status of Endangered Wildlife in Canada, Evidence, 5 May 2022.
165 Ibid.
166 Sean Jones, Legal Counsel, Wild First, Evidence, 14 June 2022; and Andrew Bateman, Manager, Salmon
Health, Pacific Salmon Foundation, Evidence, 28 April 2022.
54
states that there were things that happened to the SAR, science advisory report, after
they signed it off. 167
Jesse Zeman shared that the Recovery Potential Assessment for interior Fraser steelhead
has not been published years after its completion. He was not aware of this happening
for “any other species that has gone through this process associated with the Species at
Risk Act.” 168
Recommendation 48
That, within 60 days after of this report being presented to the House of Commons, DFO
make publicly available on their website all documents, including working papers, the
Science Advisory Report and the Recovery Potential Assessment, associated with the
CSAS assessment of interior Fraser steelhead in British Columbia.
CONCLUSION
Throughout the study, the Committee heard about the high-quality science produced by
DFO scientists and witnesses agreed that DFO scientists do excellent work. The
Committee also heard examples of how integrating additional knowledge sources, such
as Indigenous knowledge and fisher knowledge, can help inform, frame, and interpret
scientific data. Some witnesses told the Committee that DFO has the policies and
guidelines necessary to produce the science advice necessary to inform fisheries
management decisions, but that better implementation of these policies and guidelines
is required to make what is good on paper good in practice.
Many witnesses also shared their concerns regarding steps within the CSAS process,
including the perceived conflicts of interests of some participants and the quality of the
science advice provided to the Minister and other decision-makers. Witnesses also
questioned what information was being communicated to the Minister and whether
information meant to inform ministerial decisions had been manipulated before
reaching the Minister or was being withheld. This lack of transparency can undermine
trust in DFO’s decision-making process.
In the context of a changing ocean, witnesses agreed that the best fisheries
management decisions are based in sound science. A decision-making process that is
based on sufficient and appropriate data and transparently considers the environmental
168 Ibid.
55
and socio-economic impacts of decisions is the best way to manage Canada’s aquatic
resources while also maintaining Canadians’ trust in the process.
56
APPENDIX A
LIST OF WITNESSES
The following table lists the witnesses who appeared before the committee at its
meetings related to this report. Transcripts of all public meetings related to this report
are available on the committee’s webpage for this study.
Organizations and Individuals Date Meeting
Department of Fisheries and Oceans 2022/04/26 18

Matthew Hardy, Regional Director,
Science, Gulf Region
Judith Leblanc, Science Advisor
Kristi Miller-Saunders, Senior Research Scientist
Andrew Thomson, Regional Director,
Science, Pacific Region
Bernard Vigneault, Director General,
Ecosystem Science Directorate
Kristana Worcester, Director,
Strategic Science Planning and Program Integrity
Office of the Chief Science Advisor 2022/04/26 18
Mona Nemer, Chief Science Advisor
B.C. Wildlife Federation 2022/04/28 19
Jesse Zeman, Executive Director
Central Coast Indigenous Resource Alliance 2022/04/28 19
Alejandro Frid, Science Coordinator
Charlotte K. Whitney, Program Director,
Fisheries Management and Science
Fraser Salmon Management Council 2022/04/28 19
Michael Staley, Biologist
Pacific Salmon Foundation 2022/04/28 19
Andrew Bateman, Manager,
Salmon Health
Brian E. Riddell, Science Advisor
57
Watershed Watch Salmon Society 2022/04/28 19

Greg Taylor, Consultant and Fisheries Advisor
As an individual 2022/05/05 21
Gideon Mordecai, Research Associate,

Institute for the Oceans and Fisheries, University of British
Columbia
Greig Oldford, PhD Candidate and Scientist,
University of British Columbia
Dominique Robert, Professor and Canada Research Chair in
Fisheries Ecology,
Institut des sciences de la mer, Université du Québec à
Rimouski
Committee on the Status of Endangered Wildlife 2022/05/05 21
in Canada
John Reynolds, Chair
Ecometric Research Inc. 2022/05/05 21
Josh Korman, Fisheries Scientist
Ocean Networks Canada 2022/05/05 21
Kathryn Moran, President and Chief Executive Officer
Michael Dadswell, Retired Professor of Biology,
Acadia University
Alexandra Morton, Independent Scientist
Ecotrust Canada 2022/05/12 23
Tasha Sutcliffe, Senior Policy Advisor
First Nation Wild Salmon Alliance 2022/05/12 23
Robert Chamberlin, Chairman
Watershed Watch Salmon Society 2022/05/12 23
Stan Proboszcz, Senior Scientist
BC Seafood Alliance 2022/06/02 25
Christina Burridge, Executive Director
Fish, Food and Allied Workers - Unifor 2022/06/02 25
Keith Sullivan, President
58
Lower Fraser Fisheries Alliance 2022/06/02 25

Aidan Fisher, Biologist
Prince Edward Island Fishermen's Association 2022/06/02 25
Melanie Giffin, Marine Biologist and Industry Program
Planner
Regroupement des pêcheurs professionnels du sud 2022/06/02 25
de la Gaspésie
Jean Côté, Scientific Director
Association des crevettiers acadiens du Golfe 2022/06/09 27
Eda Roussel, Fisheries Advisor
Canadian Sportfishing Industry Association 2022/06/09 27
Phil Morlock, Director,
Government Affairs
Fédération régionale acadienne des pêcheurs 2022/06/09 27
professionnels
Jean Lanteigne, Director General
Maritime Fishermen's Union 2022/06/09 27
Martin Mallet, Executive Director
Public Fishery Alliance 2022/06/09 27
Dave Brown
South Vancouver Island Anglers Coalition 2022/06/09 27
Christopher J. Bos, President
Sport Fishing Institute of British Columbia 2022/06/09 27
Owen Bird, Executive Director
Martin Paish, Director,
Business Development
Robert Hardy, Fisheries Consultant
Christopher Jones, Senior Fisheries Manager, Department
of Fisheries and Oceans (Retired)
Andrew Trites, Professor, Marine Mammal Research Unit,
Institute for the Oceans and Fisheries, University of British
Columbia
59
David Suzuki Foundation 2022/06/14 28

Jeffery Young, Senior Science and Policy Analyst
Oceana Canada 2022/06/14 28
Robert Rangeley, Director of Science
Wild First 2022/06/14 28
Sean Jones, Lawyer
Atlantic Groundfish Council 2022/06/21 30
Kris Vascotto, Executive Director
Bait Masters Inc. 2022/06/21 30
Wally MacPhee, Vice-President
Mark Prevost, President
Gulf Nova Scotia Fishermen's Coalition 2022/06/21 30
Leonard LeBlanc, Professional Advisor
Ocean Choice International L.P. 2022/06/21 30
Carey Bonnell, Vice-President
Sustainability and Engagement
Morley Knight
4VN Management Society 2022/10/07 34
Herb Nash, President
Department of Fisheries and Oceans 2022/10/07 34
Adam Burns, Acting Assistant Deputy Minister,
Fisheries and Harbour Management
Neil Davis, Regional Director,
Fisheries Management Branch, Pacific Region
Arran McPherson, Assistant Deputy Minister,
Ecosystems and Oceans Science
Sarah Murdoch, Senior Director,
Pacific Salmon Strategy Transformation
Rebecca Reid, Regional Director General,
Pacific Region
Doug Wentzell, Regional Director General,
Maritimes Region
60
APPENDIX B
LIST OF BRIEFS
The following is an alphabetical list of organizations and individuals who submitted briefs
to the committee related to this report. For more information, please consult the
committee’s webpage for this study.
Allard, Tony
Atlantic Groundfish Council
BC Seafood Alliance
Breau, Herb
Canadian Aquaculture Industry Alliance
Canadian Association of University Teachers
Central Coast Indigenous Resource Alliance
David Suzuki Foundation
First Nation Wild Salmon Alliance
Fish, Food and Allied Workers - Unifor
Fisheries Council of Canada
Marty, Gary D.
Mordecai, Gideon
Oceans North
Wild First
61
REQUEST FOR GOVERNMENT RESPONSE
Pursuant to Standing Order 109, the committee requests that the government table a
comprehensive response to this report.
A copy of the relevant Minutes of Proceedings (Meetings Nos. 18, 19, 21, 23, 25, 27, 28,
30, 34, 35, 47, 48, 49 and 53) is tabled.
Respectfully submitted,
Ken McDonald
Chair
63
Crisis of Trust in DFO Science
Conservative Party Supplementary Report
Introduction
On February 1, 2022, the Standing Committee on Fisheries and Oceans (FOPO) passed a motion
introduced by MP Mel Arnold for the committee to study how the Department of Fisheries and
Oceans (DFO) prioritizes, resources, and develops scientific studies and advice for the
department, how the results of scientific study are communicated to the Minister and
Canadians, and how the Minister applies data and advice provided by the department and
other government departments to ministerial decisions.
Science should be a fundamental factor informing decisions of the Minister of Fisheries and
Oceans (the Minister) and DFO. While provisions of the Fisheries Act allow for the Minister to
exercise discretion and consider multiple factors in making decisions, fisheries and oceans are
inherently biological and therefore require science-based assessments, decisions, and
strategies if they are to be effectively managed and conserved.
Despite significant investments in DFO science, tangible improvement in management of major
stocks is not evident, as some stocks continue to decline, and management decisions have been
made in the absence of adequate scientific assessment. The absence of adequate assessments
also undermines the ability of the Minister and DFO to identify and make available
opportunities that may exist in fisheries capable of supporting sustainable harvest.
Moreover, the weighted values of science and conservation in the decisions, actions and
inactions of the Minister and department are repeatedly unclear and unexplained.
After years of witnessing decisions of a series of fisheries ministers and the DFO being
announced without science reasons or explanations of factors weighed, Canadians, especially
those directly impacted by the decisions, are concerned. Conservatives share these concerns
and are motivated to press the government for the answers and change that Canadians
deserve.
Unfulfilled Commitments
In the 2015 federal election, the Trudeau Liberals presented Canadians with a platform that
stated “[g]overnment should base its policies on facts, not make up facts to suit a preferred
policy. Common sense, good policy, and evidence about what works should guide the decisions
that government makes.” 1 This appropriate commitment was seemingly reinforced in the
mandate letters of the first two of the five fisheries ministers that held the position since 2015.
While Minister Tootoo 2 and Minister LeBlanc 3’s mandate letters directed them to “ensure that
decisions are based on science, facts, and evidence, and serve the public interest,” these
1 “A New Plan for a Strong Middle Class,” Liberal Party of Canada 2015 platform, p. 36.
2 Mandate Letter to the Minister of Fisheries and Oceans, 12 November 2015.
3 Mandate Letter to the Minister of Fisheries and Oceans, 19 August 2016.
65
mandates were absent in the mandate letters of the three fisheries ministers who followed
them since 2018.
Today, the promises of the 2015 Liberal platform and first two fisheries ministers’ mandates
have all but disappeared. Rather than basing decisions on transparent science, facts, and
evidence, decisions of the Minister and DFO have increasingly been based on policy for political
reasons rather than the benefit of the public interest in sustainable fisheries supporting
harvesters and the coastal communities and supply chains they sustain.
Conservatives share the concerns of many Canadians that ideology-driven policy has eclipsed
factors of science, conservation, and socio-economic considerations in the decisions made by
the Minister as she seeks to fulfill her mandate from the Prime Minister- decisions that have
destabilized harvester livelihoods and coastal communities while failing to manage, restore,
and conserve fisheries.
Study Focus 1: How the Department of Fisheries and Oceans (DFO) prioritizes, resources and
develops scientific studies and advice for the department.
In assessing how DFO prioritizes science, it is important to again consider mandates from the
Prime Minister to his ministers responsible for managing fisheries and oceans. In every
mandate letter since 2015, all five fisheries ministers have been mandated to prioritize ocean or
marine science while fisheries science has not been mentioned once.
The Prime Minister’s focus on ocean science may serve his political or policy objectives, but it
has precipitated an imbalance of priorities and allocations of resources for science in DFO,
especially fisheries science. These imbalances have in turn exacerbated science and knowledge
gaps directly undermining the ability of the Minister and DFO to make informed management
decisions. The absence of fisheries science has led to an increasing reliance on the
precautionary principle and several reductions in fisheries access for harvesters and
communities that depend on them.
Harvesters raised serious concerns after the Minister reportedly told an annual meeting of the
Canadian Independent Fish Harvesters Federation her vision for the east coast fishery is based
on her goal of leaving as many fish in the water as possible and to grow as much vegetation in
the water as possible so that the Atlantic Ocean can better absorb carbon to combat climate
change. 4
These statements were followed by a news release from Fish, Food and Allied Workers – Unifor
(FFAW) that further stated the Minister, “also stated that fish harvesters will have to accept this
sacrifice as part of Canada’s commitment to fight climate change, noting that given techno‐
logical advancements, harvesters could change career paths and work remotely from their
communities.” 5
4
“Fish Harvester Unions Speak Out Against DFO Minister,” FFAW News Release,17 Feb 2022.
5 Ibid.
66
After the Minister’s statements were raised publicly by FFAW, the Minister’s office released a
statement saying that her words had been “publicly mischaracterized.” 6 However, the Minister
has not publicly clarified her statements and decisions she has made before and after her
statements about leaving “as many fish in the ocean as possible” seem to reinforce that stated
goal.
When asked about these comments when he appeared for the study, FFAW then-President
Keith Sullivan testified “I don't think it was mis‐construed. We'd heard similar things before and
were quite concerned. Our colleagues on the west coast, as Ms. Burridge mentioned, were
highly concerned about a decision we had seen on herring. Our members were very concerned
about some of the messages we were seeing, and we just wanted to raise our concerns.” 7
The Trudeau government’s decision to prioritize ocean science over fisheries science
contradicts mandates of the Minister and her department to support sustainable, stable,
prosperous fisheries that can “can continue to grow the economy and sustain coastal
communities.” 8
In his appearance for this study, Dr. Robert Rangeley of Oceana Canada testified that “DFO
must prioritize and resource the increase in capacity necessary to complete fisheries rebuilding
plans.” 9 Rangeley stated how Oceana’s annual fisheries audit found that “only seven of 33
critically depleted stocks—that's about 21%—have rebuilding plans and that most are of poor
quality. DFO achieves only 20% of their deliverables laid out in annual work plans, but had they
met their priorities, they would have doubled the number of completed rebuilding plans.”
“Because of a lack of science resources, the task may be larger than DFO is acknowledging,”
Rangeley continued. “A new analysis that includes data-poor stocks suggests that the total
number in the critical zone may be 58, or 25% of all our stocks, not counting salmon.” 10
In her testimony, Christina Burridge of the BC Seafood Alliance said that “as welcome as the
influx of science money has been over the last few years, most of it has gone to ocean science
and very little has gone to fisheries science.” 11
“As I'm sure my colleagues will agree, stock assessment, evaluation of the risk and the risk
mitigation that fisheries management undertakes are absolutely essential,” Burridge stated.
“We are seeing that the increased demand on science has grown exponentially.” 12
Burridge also warned that attrition of experienced DFO fisheries stock assessment and technical
personnel and absence of any strategy for mentoring the recently graduated next generation of
personnel further exacerbates DFO’s already-deficient capacities in fisheries science. 13
6 “N.L. fisheries' union head calls federal minister 'grossly misinformed' over reported climate change comments,” CBC Online
New Story, 22 February 2022.
8 Mandate Letter to the Minister of Fisheries and Oceans, 16 December 2021.
10 Ibid.
12 Ibid.
13 Ibid.
67
Burridge went on to explain how much of the increased demands for fisheries science has been
precipitated by regulations and legislation and these demands are displacing regular stock
assessments that are required for eco-certifications of Canadian fish and seafood. 14
Eco-certifications have a value-adding affect on fish and seafood and the loss of such
certification due to an absence of adequate DFO fisheries science devalues Canadian fish and
seafood supply chains from the harvester to consumer.
Moreover, inadequate fisheries science at DFO raises serious questions of how fisheries are
managed and conserved by the Minister and department. DFO cannot manage what it does not
measure, and the absence of priority and adequate resources for fisheries science at DFO
directly undermines the Minister’s capacity to lead the department in achieving its stated
mandate of “sustainably managing fisheries.” 15
DFO is also mandated to work “with fishers, coastal and Indigenous communities to enable
their continued prosperity from fish and seafood.” 16 The Trudeau government’s failure to
ensure DFO has sufficient stock assessments perpetuates continued failures of the Minister and
department to identify and grant opportunities that may exist to enable the prosperity of
fishers, coastal and Indigenous communities on all coasts.
Harvesters depend on fisheries resources being sustained and have made efforts to fill the
science and knowledge gaps in DFO’s fisheries science. Keith Sullivan of the FFAW also told the
committee that the union “has invested greatly in building a competent science team with full-
time scientists and other staff. We know that much of the science has filled gaps left by the
federal government. Each year, over 1,000 individuals volunteer their time and knowledge,
making meaningful contributions to science.” 17
Jean Côté of the Regroupement des pêcheurs professionnels du sud de la Gaspésie (RPPSG)
testified that to answer questions of eco-certification assessors, he conducts an annual analysis
of fishing bait and bycatch data using catch data provided by harvester members of his
organization. 18
Despite such efforts and investments of harvester organizations such as these, the committee
heard that DFO is not receptive of their work. Côté stated that despite spending over 10 years
conducting surveys and analyses of lobster stocks in the Gaspé, DFO has provided no
opportunity for his organization to “move towards further collaboration with DFO on data
analysis and scientific work done by the RPPSG.” 19

15 Government of Canada, Fisheries and Oceans Canada Mandate and Role.
16 Ibid.
2 June 2022.
19 Ibid.
68
Sullivan likewise testified that despite his union’s investments and contributions to fisheries
science, “harvesters still do not have a valued seat at the table, and DFO continues to disregard
harvesters and their contributions.” 20
Former DFO Regional Director of Fisheries Management, Morley Knight, echoed the reality that
in the absence of essential fisheries science capacities, the DFO does not utilize data from
harvesters. Despite being internationally recognized and well-funded, Knight stated that “DFO
science is often unable to produce science advice adequate for the management of the
fisheries.” 21
Knight pointed to troves of harvester data that remains unused by DFO. “Available information
is not always included in the output or in the models, including logbook data or observer data,”
Knight testified. “There is not enough emphasis on getting harvesters to collect data and
samples. Stock status reports are produced without due consideration of anecdotal information
from fish harvesters and indigenous groups about the health of the stock.” 22
In discussing DFO’s assessment and management decisions for transboundary Atlantic mackerel
stocks, retired DFO Senior Fisheries Manager Christopher Jones was asked about whether
science and stock management were coordinated between Canadian and US regulators and
Jones responded that he is not aware of such coordination.23
Jones was then asked whether ocean water temperatures during DFO’s spawning biomass
surveys assessing the biomass of the Atlantic mackerel stocks are a factor that should be
considered.
Jones responded “what it suggests is that it needs broader input into the science assessment.
Temperature and egg stock status reference is one. However, years ago and perhaps over a
decade ago, we had scientists come along the coasts of both Nova Scotia and Newfoundland,
working with the fishing industry, doing measurements and expanding the database for the
assessment of mackerel.” 24
Morley Knight also provided perspectives on DFO’s assessment of Atlantic mackerel and stated
“science programs and scientists are married to theoretical processes and models. These
processes fall apart when a survey doesn't get completed or when the models just aren't
producing results consistent with a glaring body of evidence that shows the models just aren't
producing a reality.” 25
21 Morley Knight, Former Assistant Deputy Minister, Fisheries Policy, Department of Fisheries and Oceans (Retired), as an
individual, Evidence, 7 October 2022.
22 Ibid.
23 Christopher Jones, Senior Fisheries Manager, Department of Fisheries and Oceans (Retired), As an individual, Evidence, 14
June 2022.
24 Ibid.
69
“Models use data such as abundance, size at age, maturity, natural mortality, etc., as well as
some judgments by scientists, but can never account for all variables such as, for example,
unknown changes in the size at maturity,” Knight stated. “The models are not always right.” 26
Knight also spoke to the need to ensure “that the ships that scientists need to do their work are
operating. They should be made a priority to get the science done, and people should be held
accountable for making sure that the program gets delivered.” 27
DFO Science Resourcing
The Minister has stated that she is responsible for her department and for fulfilling the
mandate provided to her by the Prime Minister, so it is no surprise that apparent priorities
reflected in funding decisions of the Minister and DFO dovetail with the mandates issued by the
Prime Minister.
Mandate letters from Prime Minister Trudeau to Ministers Tootoo (2015), LeBlanc (2016), and
Wilkinson (2018) mandated the ministers to act on Cohen Commission recommendations.
However, this mandate was absent in the Prime Minister’s mandates to Ministers Jordan (2019)
and Murray (2021).
The Cohen Commission was established in 2009 to investigate declines of Fraser River sockeye
salmon. In his report released in late 2012, Justice Cohen stated that in assessing impacts of
Pacific salmon farms on wild salmon stocks, he had not determined a “smoking gun,” 28 but did
accept that “likelihood of harm” exists. 29 In his recommendations, Cohen prescribed focused
scientific examination of such impacts and the federal government promptly responded by
establishing the Strategic Salmon Health Initiative (SSHI) in early 2013.
The committee received testimony from Dr. Kristi Miller-Saunders who previously led the SSHI
and was the only DFO scientist who appeared as a witness for the study. Despite increased
funding for DFO science, SSHI’s scientific examination of impacts of BC salmon farms on wild
salmon was not provided funding to complete the third phase of its four-phase mandate.30
For decades, British Columbians, DFO, federal and provincial governments, and salmon farm
operators have been confronted with major questions of what impacts BC salmon farms have
on wild Pacific salmon- questions that require funded and focused science over time to be
answered. This is what Cohen concluded and this why the SSHI was established in 2013, but the
Trudeau government has failed to move Cohen’s recommendations or the SSHI to completion.
In her testimony to the committee, Dr. Miller-Saunders stated “funding in the department is
largely based on competitive proposals. There is the new Pacific salmon strategy initiative. I
have not yet received any funding from that strategy, but I anticipate that hopefully I will.” 31
27 Ibid.
28 “The Uncertain Future of Fraser River Sockeye,” Cohen Commission Report- Vol.III, p.88.
29 “The Uncertain Future of Fraser River Sockeye,” Cohen Commission Report- Vol.III, p.21.
70
Miller-Saunders further testified, “I fund my program principally through money outside of the
department, because I have better success in generating funds to do my research with outside
granting agencies than I do inside the department.”
These statements raise serious questions about how DFO prioritizes resources for science
research. If the $647 million Pacific Salmon Strategy Initiative (PSSI) is meant to “stem the
devastating historic declines in key Pacific salmon stocks and rebuild these species to a
sustainable level,” then why do DFO scientists like Dr. Miller-Saunders need to seek funding
from outside of DFO?
The removal of previous ministerial mandates to act on Cohen recommendations and the non-
allocation of resources for completing all phases of the corresponding SSHI science work raises
serious questions of why the Prime Minister in his mandate letters has abandoned Cohen
Commission recommendations and essential science for fisheries management such as
investigations that the SSHI was mandated to complete.
Development of Science Advice
During its study, the committee received testimony describing how science provided to DFO
managers has resulted in science advice to decision makers that does not align with the initial
scientific findings of scientists.
The committee was told how DFO scientists “have very little control...or a limited amount of
input on what science moves forward to the minister, or even to upper managers in Ottawa,
and how they utilize that science.” 32 Jesse Zeman testified that the BC Wildlife Federation “is
not concerned with DFO scientists' ability to conduct science. It is concerned with decision-
makers and senior managers' willingness to edit, suppress and hide that science.” 33
Greg Taylor of Watershed Watch Salmon Society DFO previously developed the sustainable
fisheries framework (SFF) comprised of “bits and bites of science programmed into policy, and
they often provide specific direction to managers.” 34 “Unfortunately,” Taylor continued, “these
powerful science-based policies and the management guidance laid out within them are
ignored in management decisions.” 35
“Recent examples of this failure are not hard to find. In 2019, the Canadian fishing industry,
after a decade of DFO's promising to implement its national policies, was forced to drop out of
its hard-earned certification of sustainability from the Marine Stewardship Council, losing
important and key access to world markets,” Taylor stated.36
“This year, the minister made an arbitrary decision to cut in half the harvest of herring on the
west coast, even though the fishery was consistent with both science advice and policy,” Taylor
continued. “Last year, the minister announced the closure of 60% of commercial fisheries. The
decision was not founded on a scientific analysis of what fisheries should be closed. In fact,
35 Ibid.
36 Ibid.
71
development of a methodology to decide which fisheries should be closed is only happening
now, without direct input from science.” 37
Dr. Andrew Bateman of the Pacific Salmon Foundation testified that “science is not the only
decision-making factor at the table.” “The decision-makers, as others have mentioned, have to
weigh competing or complementary demands, the economy being one of them,” Bateman
stated. “It's really that the science advice that's presented to the decision-makers, ultimately to
the minister, needs to be unfettered by departmental manipulation by mid- and upper-level
managers.” 38
More recently, Atlantic Canadians who harvest shrimp in waters of Newfoundland and
Labrador’s Area 6 have raised their concerns regarding DFO’s Species Quota Report 39 that
harvesters expect will be followed by a decision reducing harvest opportunities. Again, we see a
DFO decisions progressing without adequate fisheries science or assessment.
Adequate science is not consistently available to inform decisions of the Minister and DFO.
Witnesses told the committee that even when science advice is provided to decision makers, it
does not always directly reflect scientific data submitted by scientists and the process of
providing science advice is not transparent.
How the results of scientific study are communicated to the Minister and Canadians.
In assessing how DFO communicates science to the Canadians, it is important to again note the
2015 Liberal platform that stated “[w]e will value science and treat scientists with respect. We
will appoint a Chief Science Officer who will ensure that government science is fully available to
the public, that scientists are able to speak freely about their work, and that scientific analyses
are considered when the government makes decisions.” 40
In 2017, Dr. Mona Nemer was appointed to the position of Chief Science Advisor (CSA) and in
2018 was tasked with leading the Independent Expert Panel on Aquaculture (the Panel) in
producing a report for the Minister of Fisheries and Oceans and DFO with recommendations on
“on the appropriate use of scientific evidence in risk-based aquaculture decision-making, the
priority-setting process for aquaculture science at DFO, and the communication of aquaculture
science and resulting decisions to Canadians.” 41
When Dr. Nemer appeared as a witness, it was apparent that she had not followed-up with the
Minister or DFO on how or if the 19 recommendations of the panel’s report have been
implemented. “I must say that I have not looked in detail, but I do believe a number of them
are still outstanding,” Dr. Nemer replied. 42 When asked if she was responsible for following up
on whether fundamental questions she was mandated with were answered, Nemer responded,
38
Andrew Bateman, Manager, Salmon Health, Pacific Salmon Foundation, Evidence, 28 April 2022.
39
Species Quota Report, DFO Web Page, Updated 26 February 2023 21:09.
40
“A New Plan for a Strong Middle Class,” Liberal Party of Canada 2015 platform, p. 36.
41
“Report of the Independent Expert Panel on Aquaculture,” December 2018.
42
Mona Nemer, Chief Science Advisor, Office of the Chief Science Advisor, Evidence, 26 April 2022.
72
“again it's not part of my role and mandate to follow up on what's been implemented in the
various departments.” 43
The lone Panel report recommendation that Dr. Nemer confirmed had been implemented was
the appointment of DFO’s Departmental Science Advisor, Dr. Paul Snelgrove. However, despite
being appointed to his position in 2020, it is unclear what Dr. Snelgrove’s mandate, role, and
responsibilities are within DFO let alone what Dr. Snelgrove has done at DFO since his
appointment.
There are no apparent links of collaboration or coordination between Dr. Snelgrove or Dr.
Nemer and DFO decisions, including day to day decisions of the department determining
science priorities, funding allocations, or communication or science and decisions to Canadians.
It is very troubling that the Chief Science Advisor position was created for purposes of ensuring
government science is fully available to the public, that scientists are able to speak freely about
their work, and that scientific analyses are considered when the government makes decisions,
yet there is scant, if any, evidence of these three objectives being progressed. All of these
objectives are necessary, yet the Chief Science Advisor’s appearance for our study on science at
DFO raised more questions than it answered around how Dr. Nemer is facilitating movement in
DFO toward achieving the objectives her role was meant to achieve.
How the minister applies data and advice provided by the department and other government
departments to ministerial decisions.
We share the concerns of Canadians related to how the Trudeau government and fisheries
Minister apply science data and advice to decisions. These concerns are a direct result of years
of decisions announced by the government, fisheries ministers and DFO without any scientific
analyses cited let alone such science being made available to the public.
Prime examples of such decisions include the 2019 Liberal campaign platform promise to
transition salmon farms in British Columbia by 2025 and the first (2020) and second (2023)
Discovery Islands decisions. The 2019 campaign promise and 2020 Discovery Islands decision
were presented to Canadians with no mention of science or scientific basis- and there should
have been. The DFO news release for the 2023 Discovery Islands decision made a single brief
reference to “recent science,” but still did not describe scientific reasons for the decision, let
alone provide the science that was cited.44
What is more, neither of the Discovery Islands decisions nor the 2019 campaign promise were
announced with any citation or consideration of socio-economic factors considered in the
decisions nor a plan to support transitions of Indigenous and non-Indigenous workers and
communities in British Columbia directly impacted by these three announcements.
43
Mona Nemer, Chief Science Advisor, Office of the Chief Science Advisor, Evidence, 26 April 2022.
44
“Government of Canada takes action to protect wild Pacific salmon migrating through the Discovery Islands,” DFO News
Release, 17 February 2023.
73
Conclusion
Despite almost eight years of the current government’s promises, ministerial mandates,
creations of new science advisor positions and the existence of established protocols like the
sustainable fisheries framework, successive Ministers of Fisheries and Oceans and the
Department of Fisheries and Oceans do not treat science with respect that ensures their
decisions are based on science, facts, and evidence, and serve the public interest.
While unfettered scientific analysis and advice is not consistently provided to the Minister and
DFO decision makers, major decisions continue to be made- many of them exacting harmful
effects on Canadians and communities that depend on fisheries resources.
After years of being marginalized and watching their contributions being ignored by the
Minister and DFO, harvesters have little, if any, trust in those whose decisions rule their lives. At
the same time, Canadians see some environmental non-government organizations being
granted increasing influence in fisheries and oceans policies and decisions.
Taken together, these conclusions make it impossible for Canadians to know what the balance
of influence and factors are in fisheries and oceans decisions of the government that was
supposed to ensure decisions were based on science, facts, and evidence to serve the public
interest. The government’s own Chief Science Advisor cannot account for whether she has
delivered on the supposed objectives of her role including ensuring decisions consider scientific
analysis and ensuring science is provided to Canadians.
The crisis of trust that exists between the regulated and the regulator in Canada’s sphere of
fisheries and oceans must be dealt with and this must be led by the Minister.
It would be appropriate and helpful for the Minister to provide Canadians with a clear
commitment of ensuring her decisions and those of her department will be based on science,
facts, and evidence, and serve the public interest. The Minister could also build public
confidence in decisions she and her department make by committing to making science related
to those decisions fully available to Canadians.
Managing fisheries, oceans and aquatic habitats is complicated, but better outcomes and
relationships can be achieved if the Minister takes a personal interest in providing greater
transparency and accountability by driving the improvement that DFO desperately needs in its
science capacities and processes, decisions, and relationships that it, as the regulator, ought to
foster and respect.
Those living and working under the authority of the Minister and DFO are not just the
regulated, they are Canadians who sustain families and communities; they deserve to be
informed and they deserve to be heard.
74

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Standing Committee On Fisheries and Oceans

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SCIENCE AT THE DEPARTMENT OF

FISHERIES AND OCEANS

Ken McDonald, Chair

Also available on the House of Commons website

Report of the Standing Committee on

44th PARLIAMENT, 1st SESSION

Reports from committees presented to the House of Commons

OTHER MEMBERS OF PARLIAMENT WHO PARTICIPATED

CLERKS OF THE COMMITTEE

GLOSSARY OF TERMS ......................................................................................................................... IX

LIST OF RECOMMENDATIONS .......................................................................................................... 1

SCIENCE AT THE DEPARTMENT OF FISHERIES AND OCEANS ........................................ 13

APPENDIX A LIST OF WITNESSES ................................................................................................ 57

APPENDIX B LIST OF BRIEFS .......................................................................................................... 61

REQUEST FOR GOVERNMENT RESPONSE ................................................................................ 63

SUPPLEMENTARY OPINION OF THE CONSERVATIVE PARTY OF CANADA ................ 65

A part of the precautionary approach in fisheries management. In the cautious zone,

A part of the precautionary approach in fisheries management. In the critical zone,

Chief Science Advisor of Canada

The Chief Science Advisors’s key functions are as follows:

• “Provide advice on the development and implementation of guidelines to

• Provide advice on creating and implementing processes to ensure that

• Assess and recommend ways to improve the existing science advisory

• Assess and recommend ways for the Government to better support

External Advisory Committee on Aquaculture Science

1 Government of Canada, A Fishery Decision-Making Framework Incorporating the Precautionary Approach.

Independent Expert Panel on Aquaculture Science

In fisheries management, the precautionary approach is about “being cautious when

Recovery Potential Assessment

After the Committee on the Status of Endangered Wildlife in Canada (COSEWIC)

As a result of their deliberations committees may make recommendations which they

• reflect the commercial, social, and cultural importance of fisheries in

• undertake an examination of how DFO fisheries management officials

• produce a report to government including

• whether this influence is appropriate and ethical; and

• recommendations, if necessary, of how to reform fisheries

• assess the viability of restructuring existing DFO systems and processes

• produce a report with recommendations from this assessment and that

• examine to what degree science advice from scientists is implemented

• produce a report with advice and recommendations for establishing

• assess the viability of establishing an independent science advice body

• provide this assessment in a report with recommendations to the

“The Government of Canada should remove from the Department of

• the suppression of additional research that could have had a material

that DFO submit to an independent review of the risk assessment, including

1 House of Commons, Standing Committee on Fisheries and Oceans, Minutes of Proceedings,

Policies and Guidelines for the Development of Science Advice Used

DFO’s CSAS coordinates the production of peer-reviewed assessments and science

Figure 1 : Canadian Science Advisory Secretariat Process at Fisheries and

6 DFO, Understanding the Canadian Science Advisory Secretariat.

Communication of Scientific Information and Advice

• Research documents, which contain the supporting scientific information

• Proceedings, which document the discussions held during the peer

• Science responses, which document the peer-reviewed scientific advice

While DFO recognizes the role of researchers and scientists in communicating

Ministerial Decision-Making for Fisheries Management

Although ministerial decisions may be informed by science advice, pursuant to

11 DFO, Policy on Publication of Non-CSAS Documents on the CSAS Website.

• the annual total allowable catch (TAC) of a species or stock;

18  Alexandra Morton, Independent Scientist, As an individual, Evidence, 12 May 2022.

143  Alexandra Morton, Independent Scientist, As an individual, Evidence, 12 May 2022.