Core issues | Food Policy for Canada

Managing fish as natural resource commodity rather than food

First Nations rights and title

Ineffectiveness of international agreements

Technological efficiencies and industrialization

Corporate control of fleet and license and quota allocations

Contaminants (plastics, industrial and agricultural chemicals, excess sediment and nutrients, acidity)

Fish for non-human food use and fish waste

Managing fish as natural resource commodity rather than food (adapted from Ahmed, 2019)

Fisheries management still primarily discusses fish as a natural resource to be managed for the purpose of economic exploitation and conservation (Berkes 2010; Olson et al. 2014). Known as the "conventional resourcist" view (Levkoe et al., 2017), the emphasis continues to be on managing harvest, with little to no interest from fisheries management on distribution or use of fish (Olson et al. 2014) – despite the fact that globally, most wild-caught fish is used for food (FAO 2001). Presently, interest in the commercial value of fish supersedes interest in fish as food.

A clear consequence of this is that market actors, particularly export actors in both the sea and inland fishery, are often favoured in the system of allocations over local community food needs and those who rely on fish as a self-provisioning strategy to assure food security and ceremony (see discussion below). Related to this is the demise or absence of local market harvest, processing and distribution infrastructure and related training, and the pressure on small local fishers to catch and move as much fish as possible, given the low percentage they receive of the catch value. In these conditions, selling into local markets is too time consuming and inefficient to be viable. Another problem emerges in the way governments allocate resources including staffing. In the face of limited staff, resources are typically allocated to commercial activity rather than self-provisioning. For example, in BC, 154 traditional First Nation shellfish harvest sites are closed by federal order due to poor water quality. In many cases, the problems are episodic but limited federal monitoring resources mean they are permanently closed (Skrypnek, 2023).

First Nations rights and title (adapted from Ahmed, 2019)

First Nations existing rights are recognized and affirmed by Section 35 of the Constitution Act, 1982. Although these rights were not explicitly defined by the Section, Supreme Court rulings such as the Sparrow Decision affirm that aboriginal peoples have priority access to fish for food, social and ceremonial purposes and fisheries regulations can not unduly restrict such rights, except under certain circumstances. As a result of this decision, the Sparrow Tests have been elaborated to give more meaning to Section 35.

The first part of the Test relates to government infringement, that governments infringe upon First Nation rights if an activity:

imposes an “undue hardship”
is considered “unreasonable”
denies the preferred way of exercising the right.

The second part of the test addresses the circumstances under which an infringement might be justified:

"it serves a “valid legislative objective,” such as “conserving and managing a natural resource”
it involves “as little infringement as possible” to achieve the intended result
it is for the purposes of expropriation and “fair compensation” is provided
the government has consulted with the Indigenous group in question about conservation measures being implemented" (The Canadian Encyclopedia)

Subsequent cases have primarily confirmed the rights affirmed under Sparrow (the Van der Peet trilogy (1996), the R. v. Gladstone (1996), the R v. Marshall (1999) and the landmark Ahousaht (2009 and subsequent dates)). The sum of all these decisions is that First Nation rights to fish for food, social and ceremonial purposes, to generate a moderate livelihood and to establish a commercial fishery are affirmed, with some specified limitations related to conservation of the resource and shared allocation. The nature of these limitations remains contested, particularly as it relates to seasonal restrictions on fishing.

Such rights have led to inter-sectoral conflict in some communities as FOC has shifted allocations to First Nations to respect the rulings and comply with the federal governments efforts on reconciliation. Many of the shifts have been the result of voluntary retirements by commercial fishers, with purchase by the state. Such re-allocations are in part recognition of the historical dispossession of First Nations through European colonialism (and there remain ongoing questions about how the new allocations continue the colonial enterprise).

There are concerns, however, that the way FOC is doing the allocations (and some of the provinces in the case of the inland recreational fishery, see Lowitt et al., 2019) is fuelling opposition among non-aboriginal fishery participants, and at the same time not meeting the moderate livelihood, food, social and ceremonial needs of First Nations. In theory, conserving should not be an issue as central to these rights is the responsibility to protect fish and fish habitat for long term sustainability (Lowitt et al., 2019). Additional measures to address these conflicts are proposed in the solutions section as well as proposals related to conservation to assure that First Nations rights are not contested based on this part of the Sparrow Test. The fall 2020 conflict in Nova Scotia highlights that FOC is not fulfilling it's obligations related to conservation and consultation under the law. States First Nations lawyer Michael (2020), "Conservation is a compelling public objective. Nevertheless, DFO must consult with First Nations before imposing limitations on treaty rights to meet that objective and must establish that its regulations infringe treaty rights as little as required. These consultations must be robust, continuing,and deep." That FOC has also been prosecuting commercial buyers of First Nations products is also clearly an infringement on these treaty rights since a moderate livelihood fishery is not possible without buyers.

While there is slow progress recognizing indigenous rights and terrestrial title, aquatic title is much further behind. The UN Convention on the Law of the Sea (UNCLOS) is currently inadequate for ocean governance (see below), but integrated oceans governance and marine spatial planning may be the future of the convention and would better facilitate indigenous governance of marine areas (Williams-Davidson, 2021).

Jurisdictional issues (adapted from analysis by Kennedy Halvorson)

See Frameworks, Governance, and Instruments, Constitutional Provisions, for a basic overview of legal approaches and jurisdictions. The main legislation, the Fisheries Act (1985), has as purposes, "(a) the proper management and control of fisheries; and (b) the conservation and protection of fish and fish habitat, including by preventing pollution. " Pertinent to biodiversity conservation, section 35 states that “no person shall carry on any work, undertaking or activity that results in the harmful alteration, disruption or destruction of fish habitat (Fisheries Act, 1985, sec 2.1; sec 35.1).

The Act dates to 1868, one of the oldest pieces of environmental legislation in Canada. It remained relatively unchanged into the 2000s, with the exception of new provisions in 1970 and 1977 that recognized the importance of preventing pollution and protecting aquatic habitats along with fish. Many economic actors had for years found it to be restrictive, lacking transparency, and inconsistently applied across regions (Imhof et al., 2021). The Harper Government contentiously revised the Act in 2012 to accommodate those concerns by decreasing the number of fish and habitats eligible for protection to only those relevant to commercial, recreational, and Indigenous fisheries (Simms, 2017). The revisions also weakened provisions on unacceptable harm to fish and habitat. Primarily targeting freshwater fisheries that might be affected by development projects, a revised section 35.1 prohibited “any work, undertaking or activity that results in serious harm to fish that are part of a commercial, recreational or Aboriginal fishery, or to fish that support such a fishery”. Serious harm here was defined as “the death of fish or any permanent alteration to, or destruction of, fish habitat” including the spawning grounds and nursery, rearing, feeding, and migration areas that the fish are directly or indirectly dependent on throughout their life.

Criticisms of these new amendments included their lack of a scientific basis, vague and easily misconstrued language, and unclear and inconsistent applications compared to the earlier relevant provisions (Simms, 2017). Critics pointed out that attempting to discern between species that support fisheries and species that do not reflects a limited understanding of how ecosystems function. The ambiguity of the phrase “serious harm” was identified as problematic as the requirement for a fish to die for the activity to be deemed harmful is a high threshold for action. The wording “permanent alteration” was also criticized as it failed to define what timespan constitutes permanency (Simms, 2017). Indeed, the court case Courtoreille v. Canada (2014) found that the 2012 amendments both increased “the risk of harm to fish” and removed protections to their habitats . A 2016 review of the Act found 90% of participants, representing the “Minister of Fisheries, Oceans and the Canadian Coast Guard, [DFO], provincial governments, Indigenous organizations, fish harvester groups, scientists, non-governmental organizations, and various industry associations”, wanted all fish and fish habitats, regardless of productivity relative to fisheries, to be considered under the Act as had previously been the case (Simms, 2017). Thirty-two recommendations came from the review, and the Act was amended again in 2019, restoring many but not all of the protections lost in 2012. Proposed changes to the Act are discussed under Solutions.

Although Fisheries and Oceans Canada (formerly Department of Fisheries and Oceans) is the lead entity governing the fishery, there are numerous and complex arrangements with transnational agencies (e.g., international treaty organizations, Great Lakes Fishery Commission, see Actors, International) provincial and territorial governments, first nations, and local communities. See also Lowitt (2021) for a more detailed breakdown.

The inland recreational fishery is particularly complex. The relations between FOC (DFO) and the provinces varies by fish species, type of fishery and province/territory (see Table 1, DFO, 2015). In some cases, FOC may have jurisdiction, but a management agreement is in place that results in shared responsibility. For the most part, the inland fishery is managed by provincial level interventions, and this explains in part the absence of good data on its state. Created by the federal Freshwater Fish Marketing Act, the Freshwater Fish Marketing Corporation (FFMC) has monopoly authority to process, distribute and market wild-caught freshwater fish in Manitoba, Saskatchewan, and the Northwest Territories to retail and foodservice suppliers in Canada and internationally. It's structure and mandate, however, is currently being reconsidered (Anderson, 2020).

Whether marine or inland fisheries, neither the federal or any provincial governments fully exhibit a nation-to-nation approach to fisheries management with First Nations. Progress has been made relative to earlier periods, but First Nations laws around the fishery have yet to be fully recognized. Governments persist with a multistakeholderism approach to consultation that renders First Nations voices one among many. Understandably, many First Nations are reluctant to participate and under such circumstances, co-management can not be achieved (Lowitt et al., 2019).

This level of complexity ultimately leads to inter-jurisdictional disputes and gaps in governance and management, all of which contributes to stock declines and reduced access to fish as food.

Ineffectiveness of international agreements

There are many international agreements that, in theory, govern the fishery on a global basis. They include the 1982 United Nations Convention on the Law of the Sea (UNCLOS), the 1995 Code of Conduct for Responsible Fisheries, the 2001 UN Fish Stocks Agreement on Straddling Stocks and Highly Migratory Fish Stocks, the 2003 Cartagena Protocol on Biosafety, and the FAO Voluntary Guidelines for Securing Sustainable Small Scale Fisheries in the context of Food Security and Poverty Eradication. But the global fishery is in trouble, with 25% of global marine fisheries considered over exploited, 50% fully exploited, and 25% not yet at maximum yield (FAO, 2011). While it could be argued the situation would be much worse without these agreements, their effectiveness remains sub-optimal (adapted from Sundar, 2017):

Most nations remain more focused on exploiting the economic value of the fishery than on conservation and the language of some of the agreements perpetuates this approach.
Deep-sea species are highly mobile and do not move consistent with economic and ecological zones
There are significant levels of illegal, unregulated and unreported fishing on the high seas, with landings in countries with minimal monitoring, at - sea processing, and sizeable dumping of by-catch
Agreements are voluntary so, for example, despite some enshrinement of the precautionary principle, it is not been effectively operationalized in most countries including Canada. Many countries, including Canada, are not respecting many elements of the agreements
Significant levels of ocean pollution (see below)

It is hoped that the 2023 UN High Seas Treaty will help solve many of these issues by creating marine protected areas, but ratification will take several years and the details have yet to be developed.

Privatization of the resource (adapted from Ahmed, 2019)

Privatization of ocean resources has been justified to prevent overfishing and reduce the number of boats on the water (Townsend and Shotton 2008), as well as reduce the 'race to fish' in a competitive fishery that incentivises overcapitalization and reduces safety at sea (Olson 2011; Sumaila 2010). The recent history of marine management has clearly moved to enclose, de-centralise and privatise the global ocean commons. Enclosure first definitively took place during the discussions of the United Nations third conference on the Law of the Sea (1973-1982), which resulted in nation-states declaring 200 mile exclusive economic zones, effectively nationalising significant segments of the oceans and all resources found within (Rogers 1995). The second wave has been less uniform across states and fisheries, the privatization of access to a defined segment of the total allowable catch (TAC) within a fishery, typically carried out through the creation of Individual Quotas (IQs) and Individual Transferable Quotas (ITQs). In general, the process has been accelerated in the absence of strong and well-funded government regulation, monitoring and enforcement, and viewed as the solution for low-cost sustainable management (Melnychuk et al. 2017; Pinkerton and Davis 2015).

Quotas are implemented by dividing the Total Allowable Catch (TAC) into parcels which are then assigned (usually free) to the first generation of fishermen at the time of implementation, typically based on past fishing history. For the first generation quotas are a boon, because fishermen gain greater security of tenure without the associated cost. Quotas have been created in several different forms, such as individual vessel quotas (IVQ), which are attached to a vessel; individual quotas (IQ) which are assigned to individuals but have limited transferability; and the most contentious form: individual transferable quotas (ITQ), which are both individually owned and fully transferable (Pinkerton and Davis 2015). ITQs are a type of quasi-private property right in which the owner or holder gains transferable withdrawal rights to the resource, but not the right to manage the fishery or exclude participants, and so do not constitute full private property rights (Ostrom 2000, 342).

However, a decrease in the number of small-boat fishing operations has not led to a decrease in the amount of fish being taken out of the ocean. In fact, the opposite effect is being seen with fewer numbers of large, industrial-scale vessels removing record numbers of fish from the ocean while the benefits from this economic activity accrue to ever fewer stakeholders and investors (McClanahan et al. 2008; Olson 2011).

Proponents of privatization through ITQs argue that the gains of economic efficiency through the reduction of the number of boats on the water, and the incentive for owners to invest in increasing value from the catch (Batstone and Sharp 1999), such as processing at sea, are desirable outcomes of the fishery that have improved safety through providing security of access to quota holders and therefore reducing the incentive to fish in dangerous conditions (Pfeiffer and Gratz 2016) and improved profitability for quota holders overall (Dewees 1998; Grafton 1996). Some analysts challenge the benefit to the fishery and question whether these changes can reasonably be attributed to the ITQ system and not other parallel factors. It is argued that they come at a steep price: significant loss of employment (Brandt and Ding 2008; Casey et. al. 1995), disproportionate loss of fishery access for small-scale fishermen (Stewart and Walshe 2008) and a breakdown in traditional circulation of capital within kinship and community relations, incentivising divestment from small coastal communities and encouraging capital out-migration to large industrial operations (St. Martin 2007; Stephenson et al., 2019).

Despite extensive criticism of this model of ocean privatization (Wiber 2000; Carothers and Chambers 2012; Ecotrust Canada and T. Buck Suzuki Foundation 2015), national governments and transnational organizations such as the Food and Agriculture Organization of the United Nations continue to encourage the ITQ system for sustainable ocean management (Townsend and Shotton 2008). Proponents even argue for further entrenching of private access rights (see Featherstone and Rogers 2008).

Technological efficiencies and industrialization (adapted from Ahmed, 2019)

Changes in motors, boats, harvesting equipment, fish tracking and processing have had a profound impact on harvests, by-catch and aquatic ecosystems, and also the communities that relied on the inshore fishery (cf. Rogers, 2020). Essentially, technological advances permitted a more industrial approach to fishing. Industrialized fishing operations shifted the balance of power from small-scale fishermen embedded within coastal communities and local food systems towards capital intensive and technologically advanced fishing operations. These technologically advanced fishing fleets had the capacity to travel long distances and store fish on board for long periods of time (Bavington 2010; Rogers 1995). They also typically used methods that were (and continue to be) much more destructive to the marine environment, such as bottom-trawling, which essentially uses large nets to scrape the ocean floor and bring up anything large enough to get caught in the net – including a large proportion (20%) of unusable by-catch (Driscoll, Robb and Bodtker 2009, 5). Such trawling also releases very significant volumes of GHGs, as much as the aviation industry (Sala et al., 2021). Globally, industrialised nations had the advantage in supporting long-distance fleets and exploiting fish stocks in regions adjacent to under-developed countries; nations such as Spain, Poland, Germany, Britain, Portugal, Russia, Japan, Canada, and the United States invested in advanced trawlers with onboard freezers, filleting machines and sonar fish finders, among other innovations (Rogers 1995, 32). Due to their capacity to travel long distances and stay at sea for months at a time, combined with open-access to the oceans, these industrial fishing operations were able to travel to the most fertile fishing grounds and exploit highly productive stocks until they were depleted before moving on to new fishing grounds (Pauly, Watson and Alder 2005). The fish caught by these operations went into capital intensive frozen fish and fish meal markets around the world, inevitably separating the geography of where the fish was caught from where it was ultimately consumed (Rogers 1995).

This industrialized system of fishing also shifts who has the opportunity to eat fish – whereas fish was previously most abundantly available to those who lived close to coastal areas and fished it for food, the product that comes out of the catch and processing of the industrial fishery is only available to those who can afford what has become an expensive protein option (Kent 2003). In addition, fish caught for fish meal simply by-passes any opportunity for human consumption and goes directly to industrialised agriculture and aquaculture operations that require a high-protein diet for land animals and farmed fish raised for human consumption (Rogers 1995, 32-33).

Although the establishment of 200-mile limits did somewhat constrain these international technological advanced fleets, as the fishery became nationalised in Canada, the Federal government invested heavily in increasing the capacity of Canadian operations to exploit fish stocks within the 200 mile economic zone. The Canadian government poured significant investments into the fishing sector, in both processing and the fishing fleet, once the international fleets had receded and Canada found its own fishing sector to be incapable of generating the kinds of revenues that international trawlers had been generating (Swenerton 1994, 34; Rogers 1995, 42).

Through this period, the Federal government attempted to address rural poverty and unsteady employment associated with these technological shifts with unemployment insurance and subsidies for the fishing sector (Bavington, 2010, 16). However, the majority of government investment went into strengthening the capacity of the offshore industrialized fleet. Such investments have also fueled corporate control.

Corporate control of fleet and license and quota allocations (adapted from Ahmed, 2019)

Haas, Edwards and Sumaila (2016) conducted a study of ITQ ownership in BC and found that in the absence of government controls, licenses and ITQs were being bought up by processing companies, who in turn leased out the licenses and quota to active fishermen. Recent investigations also suggests that corporations and investors from outside the fishery and in some cases outside Canada are also buying up quota and licenses (German et al. 2019, 262-263; Silver, February 5, 2019). Aside from reports of exorbitantly high lease prices (Simpson 2016), this practice also effectively makes fishermen price takers, because they are forced to sell all of their catch to the company that leased them the quota (Pinkerton and Edwards 2009); with the processor's need to compete for fish essentially eliminated, fishermen are forced to accept whatever price the quota owner sets. Furthermore, Pinkerton and Edwards found that even fishermen who owned quota preferred to lease their quota through processing companies:

Many quota owners prefer to lease their quota out through a processor as a broker because the processor is in a better position to get the highest price and because, as several fishermen stated, they do not want to be ‘guilted by other fishermen’ about the high lease price they are asking. Similarly, many lessee fishermen do not wish to deal directly with the quota owner because of their hostility toward the high lease prices. (Pinkerton and Edwards, 2009:709)

This puts the processing company in a position of considerable power, and creates a market in which lessees do not have full access to information – for example, they do not know what price the processor leased the quota for or whose quota they are leasing (Thorkelson February 5, 2019). Thus, fishermen are not only paying around 70% of their catch value in lease fees, they have also lost a competitive market to sell their catch to, leaving them with all of the risk of fishing and only marginal returns (Pinkerton and Edwards 2009).

From a management perspective, the transferability of quota eliminates the need for managers to intervene in assigning or re-assigning the right to fish, because it is up to the market who gets to fish – whoever can afford to buy quota. As the price of quota rises, the opportunity cost to smaller fishermen of staying in the fishery and fishing their quota versus selling their quota to a larger operation favours the exit of small-scale fishermen (Olson 2011). This effect, of consolidation and funnelling of access rights to larger efficient industrial operations, is a key design feature of ITQs; this is the effect fisheries managers and economists call 'fleet rationalization' – incentivising smaller-scale fishermen to exit the fishery in order to reduce the number of boats on the water so that only the most economically efficient operations are able to fish (Mansfield 2004b). The high cost of operation and entry, especially since the addition of quota leasing or purchase cost to the equation, has resulted in very few new entrants to the small-scale fleet (Ecotrust Canada and T. Buck. Suzuki Foundation 2015).

On the West Coast, First Nations are also affected by this as some Councils have chosen to participate in the dominant model and lease quota to the highest bidders as a revenue generating strategy, rather than look at the quota as a communal asset to be allocated within the community. The consequence is that some small to medium aboriginal fishers do not have any increased access to fish.

These problems are consistent with a wider literature that concludes that consolidation in the fisheries, while sometimes positive for individual firms, is often very negative for fishing communities (see Clay et al., 2013 for citations).

Who captures value? (adapted from Ahmed, 2019)

A report containing valuations of licenses, vessels and quota for 2016, prepared for DFO, helps to clarify these costs: as an example, the 2016 average price for a Halibut license was $64,200, the average quota price was $95/lb while the average lease price was $8.40/lb (Simpson 2016). For the same year, a report prepared for DFO found that the average ex-vessel price for Halibut (the price paid to the harvester) was $7.07/lb – leaving a potential lessee operating at an average loss of $1.33/lb in this scenario (GSGislason and Associates, 2017, 5).

Some West Coast fishers are reporting that 80% of the average landed value goes to the lease holder. At that level it is impossible to pay a decent wage to the crew and keep the boat in good repair. The economic pressures associated with the lease costs have created a new "race to fish" that was supposed to be removed by the quota system. A significant additional consequence is an aging group of fishers that have trouble attracting young people to work in the industry, or to find people with the financial resources to buy them out when they're ready to retire (Ecotrust and Suzuki, 2018). Stephenson et al. (2019) summarizes cases from across the country that demonstrate how value is exported from local communities.

Incomplete stock assessments (adapted from Ahmed, 2019)

A central premise of the Public Trust Doctrine that guides fisheries management is that good information can be collected and serve as the foundation of decision making. This premise has rarely been realized and with the transition to privatization and ITQs, the situation is likely deteriorating. ITQs are only as useful to conservation as the science used to set the TAC; in cases where the data to measure sustainable yields is inadequate or uncertain, ITQs are only marginally more sustainable than a competitive-style fishery, and both systems easily run the risk of allowing overfishing (Copes 1986). Ostrom (2000) adds to this that the creation of transferable withdrawal rights for a mobile resource such as fish, is much more complicated in practice than theory, and that mobile units are difficult to measure, creating an opportunity to over-harvest which can ultimately raise monitoring and enforcement costs.

At the core of the problem remains the direct or indirect attachment of some institutions, firms and fishers to an outdated concept: Maximum Sustainable Yield (MSY), the theory that there exists a discoverable level at which young fish of a particular species can reasonably replace older fish, and that once this level is determined, any surplus mature fish can and should be harvested, because it is assumed that above this optimal replacement rate, competition for food will naturally reduce the fish population. The concept relies on the use of mathematical modelling with simplified, single-species stock sizes and life cycles that are assumed to be predictable and tend towards equilibrium. Thus, the way that this management system aims to protect fish stocks while 'producing' fish for food and profit is to manage the "exploitative effort" on that particular stock (Acheson and Wilson 1996, 680). The human-nature relationship characterised by this management model sees managers and fishermen as existing outside the system, using science to control and exploit the resource for human benefit.

Although the single-stock MSY model has been a long-standing and compelling theory that is traced back to the 1930s by some scholars (Mesnil 2012, 473), there are several catastrophic flaws with this ideology. For one, as Finley and Orestes (2013, 248) have shown, the emergence and subsequent popularity of this theory was not based on the science of the day, but rather a political agenda by the United States to protect the right of its distant water fleets to foreign waters. Besides its somewhat dubious emergence, there are several important criticisms of the isolated stock MSY ideal. Larkin (1977) outlined these issues in his famous 'Epitaph for the Concept of Maximum Sustained Yield' : weaker, less commercially valuable stocks are not protected; maximising yield from all species simultaneously is impossible; use of accurate data and precise regulation of fishermen is necessary for MSY to function well, a condition not satisfied in practice; ecosystem relationships beyond fish populations are ignored. A related theory, that allowing too many spawners, or overescapement, is bad for the stock has also been debunked (Walters et al. 2004; Dunklin, 2005). The fundamental problem of both theories is that they are rooted in human exploitation rather than biology and ecology. Somewhat in recognition of these limitations, FOC has been moving towards ecosystem-based fisheries management (EBM) (Shelton and Sinclair 2008), taken up later in the Solutions section.

The challenges are made more acute by the FOC absence from the water. They rely more on landings and an incomplete network of reports. FOC remains seriously behind in its efforts to improve catch data and stock assessments (Commissioner of the Environment and Sustainable Development, 2023). This may in part be the result of deep cuts imposed by the Harper Government on FOC staff working on habitat protection (Sundar, 2017). Consultations with fishers and First Nations are limited now because license holders vote to determine who sits on the advisory councils and they don't necessarily elect their leaseholders who are on the water. There are also substantial differences in worldview and practice among different fishing groups regarding conservation and the ocean ecosystem that affects how discussions might unfold were advisory councils more diverse. For example, the "resourcist" views of European colonizers "is a fundamentally different perspective and relationship with nature than that held by Indigenous people" (Lovitt et al. 2019)

For the inland fishery, because of the diversity and number of water bodies, some provinces such as Ontario have gone to landscape level monitoring and assessment, sampling within so called uniform landscapes to create a picture of the entire region (Cooke and Murchie, 2013). Although sensible given resources constraints which result in a generally low level of monitoring, it's not obvious that such approaches are effective.

Fish populations have always been affected climate and ocean conditions, making stock assessment more challenging. The difficulties are likely to become more acute as the effects of climate change on ocean ecosystems accelerate (for more, see Barange et al., 2018).

Contaminants (plastics, industrial and agricultural chemicals, excess sediment and nutrients, acidity)

Contaminants are having significant negative impacts on fish and their ecosystems. Excess nutrients from sewage (treated and untreated) and agriculture, industrial and mining contaminants from direct discharge and atmospheric deposition, pharmaceutical metabolites from human and veterinary medicines, plastics and other forms of consumer trash, acidification from combustion and other processes, and coastal habitat destruction associated with urbanization and aquaculture farms are all contributing to species decline. Some of this problems are likely to increase with a changing climate (for more, see Barange et al., 2018). Although actions have been taken, they are limited relative to the scale of the problem.

Energy inefficiency

As with other parts of the food system, the fishery runs on non-renewable fuels: diesel for boats, cooling and heating systems to process and transport the fish, long distance transport in trucks to access retail markets, inefficient freezers and refrigerators in retail stores. Edible fish (in whole or in part) that is not consumed by humans is a significant part of this inefficiency. There can significant system metabolic inefficiencies when edible fish or fish parts are used for non-edible purposes, problems that intersect with processing inefficiencies and issues around by-catch. Metabolically, are fish and fish parts always assigned to their most effective (in energy and nutrition terms) purposes? Unfortunately, secondary uses of fish can drive waste among primary uses, a problem that also occurs in other parts of the food system(see Goal 5, Reducing Food Waste).

Fish for non-human food use and fish waste

Related to energy and nutritional inefficiencies, many fish are used for industrial applications (fertilizers, pharmaceuticals, process chemicals like oils and chitins), nutritional supplements, and for animal (particularly poultry and hogs), pet and aquaculture feed. By some estimates, a third of the total global catch is assigned to non-edible uses (Hardy, 1992). This is sensible for fish wastes that humans generally do not consume or damaged parts of the fish that may pose health hazards. But many fish species are caught specifically for the feed market, particularly small open ocean fish such as anchovies, herring, menhaden, capelin, pilchard, sardines, and mackerel. About 70% of fish feed comes from these sources and the other 30% from fish scraps and waste (NOAA). Although these fish are part of monitored fisheries and reproduce rapidly, there remain concerns that they are overharvested to the detriment of marine ecosystems since they are often forage feeders and serve as food sources for other organisms. They are also part of the human diet. Some analysts have concluded that 90% of feed fish are species that humans eat (Zielinski, 2017).

The positive news is that use of fish in animal feed is declining as alternative feed sources are developed and this is addressed further under solutions.

By-catch

By-catch is not well defined but typically includes non-target species (other fish, mammals, seabirds, sponges, etc) that are caught in fishing gear and discarded for economic or regulatory reasons (often dead or dying) or kept to be consumed by fishers and their families or sold into specified markets. It also includes marine organisms killed by boats and gear, often without knowledge of the fisher. Recreational catch and release programs are not considered part of by-catch.

Reducing by-catch has been a priority but it's not obvious that strategies have been successful given that monitoring and evaluation of different strategies is weak and much of the fishing gear and process is designed to capture large volumes of fish. There does appear to be some reduction in discards, associated with new regulations, some better measurement, and greater utilization of non-target fish. Economic by-catch (that isn't regulated) can be sold within the context of conservation plans, in fact some jurisdictions have attempted to create new markets for economic by-catch (Davies et al., 2009).

One study estimated by-catch from very limited data in three Atlantic (scallop dredge, lobster/crab, groundfish) and a Pacific fisheries (hake demersal trawl) and conservatively concluded that by-catch represented 8% of the total annual landings, including significant amounts of cod by-catch off the Grand Banks. Discards and unobserved mortalities were seriously underestimated and the data was collected from a limited number of gear systems. This same study estimated global by-catch rates at 40% (Davies et al., 2009).

Demand - supply coordination

As with the rest of the food system (see Goal 2, Demand Supply Coordination), the fishery is not organized around optimal consumption of fish within the context of sustainable management of the resource. Comparable to other foods where the range of food sources and varieties, breeds and cuts have been narrowed by the dominant production and marketing system, so to have we narrowed the range of fish species and parts of the fish that are popular. Salmonids (salmon and trout), grouper, cod, and tuna drive the market for farmed and wild fish. Open ocean fish (such as anchovy and menhaden) are less popular in western countries (NOAA). All this creates a mismatch between what is demanded in the marketplace and what is available for harvest. Equally significant, many fish appear to be used suboptimally relative to their dietary value (citation).