Response to Letter from Serge Doucet Regional Director General
Fishing Friends –
On Jan 13 I wrote a letter to two Canadian ministers complaining about DFO’s failure to effectively manage the Miramichi’s salmon population. Many of you did the same. Most specifically my letter faulted them for not controlling the outrageous growth in the overly protected striped bass population, and failing to follow its federal mandates by not working with citizens and First Nations people to protect the salmon fishery. On March 2nd I received a response from the Regional Director General of the DFO Serge Doucet. I have conferred with a number of MSA board members including several retired fishery scientists with extensive salmon backgrounds. My response is written in italics with blue print and can found below between the lines of Mr. Doucet’s letter reproduced below.
In addition to this a group is exploring the possibility of suing DFO over these issues. If you are inclined to voice your concerns to DFO I think that is entirely appropriate. The more that DFO realizes how upset people are with the problem that they have created and failed to address the more likely we are to see some changes in their actions.
The spread sheet containing the e-mail addresses of the distribution list shown after the letter is available at this link. Mr. Doucet’s e-mail should be sent to this address Myra.Berube@dfo-mpo.gc.ca.
Thanks for reading. Brad Burns
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Office of the Honourable Joyce Murray, MP Minister Department of Fisheries and Oceans
Written by Brad Burns in response to a letter from Serge Doucet Regional Director General Canadian DFO
Dear Mr. Burns:
Thank you for your correspondence of January 16, 2023, addressed to the Honorable Joyce Murray, Minister of Fisheries, Oceans and the Canadian Coast Guard, regarding Atlantic salmon in the Miramichi River, in New Brunswick. I have been asked to respond on behalf of the Minister.
I would first like to acknowledge your interest in and commitment to Atlantic salmon. As you referenced in your message, the long-term decline of Atlantic salmon remains a concern, and Fisheries and Oceans Canada (DFO) is continuing to invest in scientific research as well as engaging with Indigenous peoples, recreational anglers, and other stakeholder groups to promote recovery.
Atlantic salmon populations, across their entire range, are affected negatively at every stage of their life cycle by a combination of factors. While different populations may face different challenges, the most common factors impacting Atlantic salmon across their Canadian range include climate change, habitat degradation, legal and illegal fisheries, and high mortality at sea. Presently, DFO is developing a Wild Atlantic Salmon Conservation Strategy in order to accelerate and coordinate conservation measures across eastern Canada by addressing key threats and working collaboratively with partners.
With respect to Atlantic salmon in the Miramichi River and the points raised in your message, it is important to note that DFO is committed to supporting sustainable and prosperous fisheries through the implementation of the Fisheries Act. The Act specifically mandates that decisions be based on the precautionary approach, principles of sustainability, and the use of robust scientific information. Additionally, climate change considerations are increasingly being integrated into scientific assessments and management decisions. The implementation of warm-water protocols for fishing in the Miramichi River reflects the need to adapt to warming conditions and mitigate the impacts on Atlantic salmon. …/2
The striped bass, which aggregate in the Miramichi River for overwintering and spawning, are critical to supporting the broader Gulf of St. Lawrence population. It remains a unique location as the only confirmed site with consistent spawning success in the region.
Mr. Doucet, what research has the DFO done, and/or what peer reviewed scientific documents can you point to that substantiate this statement? In addition to the NW Miramichi I know that the MSA has found quantities of both fry and larval striped bass in the Tabusintac and the SW Miramichi Rivers. It seems clear that striped bass are spawning at least in these areas and probably in the Kouchibouguac and other Northumberland streams also.
However, the Department continues to be mindful of interactions with Atlantic salmon. As the population of striped bass increased, DFO has taken a balanced approach to incrementally authorize the opening of the recreational fishery as well as providing access to Indigenous harvesters.
While it is impossible to find public information on the Indigenous harvest of striped bass I have been informed through a variety of channels that after five years of fishing less than half of the 50,000 fish Indigenous allotted quota is being taken each year. Since this 50,000 individual striped bass harvest hasn’t been taken in any of the last five years, why haven’t other harvesters, Indigenous or otherwise, been given the opportunity to capture and sell this resource? New Brunswick has plenty of commercial fishermen – citizens and taxpayers – who would jump at the chance to harvest and sell striped bass. The species is very desirable commercially. Why are other harvesters excluded from this fishery?
Prior to the recent striped bass population explosion no one found striped bass above the head of the tide of the Miramichi during the summer. DFO has repeatedly been asked to allow the retention of all striped bass caught in the non-tidal regions of the Miramichi during the salmon season. This would have no material effect at all on the overall striped bass population, and yet it would undoubtedly save a large amount of salmon parr from predation that they have not historically faced. What is the justification for refusing this reasonable request especially given the very low commercial harvest being taken?
When the striped bass fishery was closed DFO set a goal to restore the population to a target of some 30,000 adult fish. The population has grown to an estimate of more than 300,000 adult fish – 1,000,000 in some recent years – and we understand that DFO has now set a target of some 300,000 adult fish, a 1,000% increase over the original target. DFO has been asked to have the justification for this vastly increased target level peer reviewed by an independent source, and DFO has refused. Please supply us with the scientific justification for this increase in the target population and the reasons that DFO has refused to have these calculations peer reviewed.
Authorizations for stocking activities or experiments are assessed on a case-by-case basis under the regulatory framework of the Fisheries Act. DFO has a legal responsibility to consider factors which relate to the benefits and risks of the proposed activities on the wild Atlantic salmon population as well as on local Indigenous communities.
It is important to note that the stocking of fry and parr has been going on for 150 years on the Miramichi. In some years as many as 30,000,000 (thirty million) fry were stocked, and at various times salmon stocks from different rivers altogether including the Restigouche were introduced. During much of this time the Miramichi was world famous for its robust population of Atlantic salmon. Even in my first years on the Miramichi, just 20 years ago, the MSA was gathering several hundred wild brood fish and releasing the fry the next spring. The salmon population as recently as 2011 was doing quite well and trending in the right direction. Some experts have stated that there is no scientific justification for failing to allow sufficient quantities of fry to be stocked into the Miramichi River to make up for striped bass predation. They maintain that the prohibition simply reflects the personal prejudices of some individuals on the DFO staff. It seems odd for this attitude to prevail given the extensive use of stocking by the DFO to supplement West Coast salmon stocks. Given the over-population of striped bass, and the severely reduced Miramichi salmon spawning stock biomass, what peer reviewed scientific studies can you point to that justify the drastic reduction in allowed fry stocking on the Miramichi?
The Indigenous community has certainly not benefited from catastrophic drop in the Atlantic salmon population over the last 12 years. With the population of salmon in decline, we cannot afford to wait until the stock completely collapses before we start supplementing the salmon stocks on the Miramichi. If not a stocking program, what is DFO’s plan? Closing recreational fishing and waiting for the stocks to recover will not work as minimal mortality is occurring in the recreational fishery. If the recreational fishery was closed, then the removal of salmon would undoubtedly be higher than it is now due to poaching. Would the end of the recreational fishery for Atlantic salmon on the Miramichi and all the history, investment, jobs and lifestyles that go along with it really be an acceptable outcome for anyone?
If DFO has a plan to restore the Atlantic salmon population of the Miramichi that does not include stock supplementation I would ask that you share it with us including the amount that each of the activities that you prescribe are expected to add to the salmon population.
That said, the Miramichi Salmon Association receives numerous authorizations and scientific permits on an annual basis. These include permits for collecting smolt and broodstock as well as for the release of a limited number of fry under clear conditions. Decisions are reached after careful consideration and communicated to proponents in writing.
Thank you for sharing your thoughts on this matter. Future management decisions will continue to be informed through stakeholder and rightsholder consultations as well as current scientific information.
The current levels of permitting for fry release is far too low to have any meaningful impact on the salmon population of the Miramichi.
We can probably all agree that with the Miramichi salmon population reduced to approximately 30% of just 12 years ago, that successfully returning wild adults should be left to spawn naturally on their own. What we do have, though, is a very large number of smolts. According to studies done by the MSA and the ASF a very high percentage of these smolts are being eaten by striped bass as they drop down the river to begin their sea migration. Not allowing the wild smolts gathered three years ago at Ludlow, and grown to adult size in the Miramichi hatchery, to have been spawned last fall so that those fry could be stocked this spring in the Miramichi is a simply incomprehensible move. Can you point to any peer reviewed studies that show that stocking fry derived from adults grown from wild captured smolts pose any risks?
Mr. Doucet, the time to act positively to save the Miramichi salmon population is now. The Miramichi is the destination for approximately 90% or more of all salmon fishing trips taken in the Province of New Brunswick. There are literally hundreds of lodge and camp owners both from within the Province and non-resident who are all heavily invested in this fishery. The time is long overdue to have made some serious management changes to benefit the salmon run in this river.
DFO must authorize greatly expanded gathering of wild Miramichi smolts to grow to adulthood for spawning, allow the spawning in 2023 of the adults already held at the MSA hatchery, allow the introduction of fry on a truly meaningful scale, insure that the commercial striped bass quota is harvested in 2023, allow the removal of all striped bass caught during the summer above the head of the tide and further liberalize the recreational limits on striped bass including the expansion of the slot size and the retention of large fish.
Yours sincerely,
Serge Doucet
Regional Director General
Sincerely;
Brad Burns Recreational Fisherman, Miramichi Property Owner, Employer
Please note that the statements in this letter are from me personally and are not attributable in any way to the Miramichi Salmon Association.
CC Distribution List:
Office of the Honourable Dominic LeBlanc, M.P. Beauséjour
Office of the Honourable Ginette Petitpas Taylor, P.C., M.P. Moncton–Riverview–Dieppe
Office of the Honourable Gudie Hutchings, P.C., M.P. Long Range Mountains
Office of the Honourable René Cormier, Senator Office of the Honourable Fabian Manning, Senator Office of the Honourable Jim Quinn, Senator Office of Mr. Mark Kelloway, M.P. Parliamentary Secretary to the Minister of Fisheries, Oceans and the Canadian Coast Guard
Office of Mr. René Arseneault, M.P. Madawaska–Restigouche
Office of Ms. Jenica Atwin, M.P. Fredericton
Office of Ms. Lisa Marie Barron, M.P. Nanaimo–Ladysmith
Office of Mr. Richard Bragdon, M.P. Tobique–Mactaquac
Office of Mr. Blaine Calkins, M.P. Red Deer–Lacombe
Office of Mr. Serge Cormier, M.P. Acadie–Bathurst
Office of Ms. Caroline Desbiens, M.P.
Beauport–Côte-de-Beaupré–Île d’Orléans–Charlevoix Office of Mr. Wayne Long, M.P. Saint John–Rothesay
Office of the Honourable Rob Moore, M.P. Fundy Royal
Office of Mr. Rick Perkins, M.P. South Shore–St. Margarets Office of Mr. Jake Stewart, M.P.
Miramichi–Grand Lake
Office of Mr. John Williamson, M.P. New Brunswick Southwest
Office of Mr. Clifford Small, M.P. Coast of Bays–Central–Notre Dame
Office of the Honourable Blaine Higgs, M.L.A. Premier of New Brunswick
Office of the Honourable Mike Holland, M.L.A.
New Brunswick’s Minister of Natural Resources and Energy Development