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19 March 2012The Honourable Keith AshfieldMinister of Fisheries
and Oceans200 Kent StreetOttawa, OntarioK1A 0E6
Dear Minister Ashfield,
I am writing in my capacity as President of the Canadian Society
For Ecologyand Evolution (CSEE). The 1000-strong membership of the
non-partisan CSEEincludes ecologists and evolutionary biologists
from across Canada.
The concerns expressed here are made on behalf of the CSEE. They
areinformed, in part, by the responsibilities I exercised as Chair
of the Committee onthe Status of Endangered Wildlife in Canada
(COSEWIC; 2006-2010) and asChair of the 2012 Royal Society of
CanadaExpert Panel Report entitledSustaining Canadas Marine
Biodiversity: Responding to the Challenges Posedby Climate Change,
Fisheries, and Aquaculture.
The CSEE has very grave concerns regarding the Government of
Canadasproposed changes to Section 35(1) of the Fisheries Act.
Specifically:
1. The CSEE is concerned that the proposed changes were not
informed bya full and appropriate consideration of the best
available science;
2. The CSEE is concerned that the proposed changes will prevent
Canadafrom fulfilling its national and international commitments to
sustainbiodiversity; and
3. The CSEE is concerned that the proposed changes will prevent
Canadafrom fulfilling its legislated responsibilities under the
Species at Risk Act.
Each of these concerns is elaborated upon briefly below.
Firstly, there is no evidence to suggest that the proposed
revision to the FisheriesActwas based on an appropriate level of
consultation with, and advice received
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from, DFOs Science Sector. According to the DFO website, science
is the basisfor sound decision making. DFO Science Sector provides
information on theconsequences of management and policy options,
and the likelihood of achievingpolicy objectives under alternative
management strategies and tactics.
DFOs website further notes that the incorporation of science in
decision makingis provided through a rigorous peer review process
built on the Government ofCanadas Framework for Science and
Technology Advice: Principles andGuidelines for the Effective Use
of Science and Technology Advice inGovernment Decision Makingwhich
states:
Science advice has an important role to play by contributing
togovernment decisions that serve Canadas strategic interests
andconcerns in areas such as public health and safety, food
safety,environmental protection, sustainable development,
innovation, andnational security.
Based on the assumption that your decision was not made in
violation ofdepartmental or government policy, the proposed
revisions to Section 35(1) ofthe Fisheries Actmust have been
informed by advice received by DFOs ScienceSector. In the interests
of transparency and accountability, and in the interests ofCanadian
society, we respectfully request that the science advice received
in thisregard be made publicly available without delay.
Secondly, the proposed changes to the Fisheries Actwill be
considered anabrogation of Canadas global ocean and freshwater
stewardship responsibilities.The CSEE notes the conclusion by the
Royal Society of CanadasExpert Panelthat Canada has fallen well
short of the progress made by most developednations in fulfilling
national and international commitments to sustain
marinebiodiversity and that many targets and obligations to
conserve and tosustainably use biodiversity have not been met by
Canada.
The proposed changes to the Fisheries Actwill severely impair
Canadas abilityto protect species and their habitat and will, thus,
further reduce the likelihoodthat Canada will fulfil its national
and international biodiversity commitments.
Thirdly, it is well-established in the scientific literature,
and articulated inCanadian government policy and statute, that the
protection of species habitatconstitutes the most effective means
of ensuring that species do not becomeextinct. The Species at Risk
Act(SARA), for example, acknowledges that thehabitat of species at
risk is key to their conservation.
The proposed elimination of existing habitat protection
provisions in the FisheriesActwill severely impair Canadas ability
to fulfil its legislated obligations underSARA to prevent the
extinction of aquatic wildlife species.
