The MCC has submitted feedback on the 2022/2023 Integrated Fisheries Management Plan for Pacific Herring. The main points are summarized below and the letter is provided for more details.
Strait of Georgia:
We reiterate our position that Strait of Georgia (SoG) herring are showing several signs of concern, and that these issues, when considered together, require a reduced harvest rate for 2023. We therefore urge DFO to use the HS30-60_HR10 management procedure for the 2023 fishery, and to employ the associated 4% harvest rate as the maximum harvest rate for the 2023 SoG herring fisheries.
Upper Stock Reference point:
The MCC’s position is that this species’ extraordinary ecological importance warrants an ecosystem-based approach that grows and maintains the stock in a healthy zone with a high probability. From this position, we have concerns regarding DFO’s proposed approach for establishing an Upper Stock Reference point (USR) for the Strait of Georgia, as it results in a lower standard than that applied to other regions. Reducing the difference between the USR and the limit reference point (LRP) reduces the range of stock statuses that would trigger management adjustment of harvest rates to avoid reaching LRP status, as well as the time available for the management action to have effects. We urge DFO to apply a consistent approach across SARs, and reject the application of an apparently arbitrary modifier that lowers the USR for the Strait of Georgia.