Substitution (fisheries)

"An area designated and effectively managed to protect marine ecosystems, processes, habitats, and species, which can contribute to the restoration and replenishment of resources for social, economic, and cultural enrichment."  They can include  marine reserves, fully protected marine areas, no-take zones, marine and ocean sanctuaries, and marine parks and other locally managed marine areas.

Globally, only 7% of oceans are protected, and only 3% highly protected.  A recent study suggests that 28% needs to be protected to achieve conservation goals (Sala et al., 2021). About 10 per cent of the oceans in Canada are protected, up from less than one per cent a few years ago. They are protected through a variety of legislation and mechanisms including 14 MPAs under the Oceans Act covering about 6% of Canada's oceans and shorelines (see DFO), with proposals for several more made by FOC, Parks Canada or Environment Canada.  There will be a range of location and input restrictions on fishing in most of these MPAs, though not all. The federal government announced a ban on Industrial activities in April 2019, including bottom contact fishing, bringing Canada  theoretically in line with international standards, but now the changes must be implemented. The federal government announced $800 million in funding for 4 indigenous-led conservation areas through Project Finance for Permanence (PFP),  a model bringing together Indigenous organizations, different levels of government and the philanthropic community. The four areas being implemented are: parts of the Northwest Territories;  the B.C.  Great Bear Sea; a proposed marine area in Nunavut called Qikiqtani; and the Omushkego area in Northern Ontario (Stueck and Semeniuk, 2022).

The 2019 mandate letter to the Minister of Fisheries and Oceans tasks the Minister with achieving conservation of 25% of Canada's oceans by 2025 and 30% by 2030, and with implementing the Ocean Plastics Charter and the G7 Charlevoix Blueprint for Healthy Oceans, Seas and Resilient Coastal Communities, and while there is progress on MPAs  there are few details on how much of this will be achieved. This all will require significant legislative and regulatory work. Some of the strategies addressed in these sections will help with implementation of such charters/blueprints and see also Goal 5, Food packaging and Water use, plus Goal 2 Water system coordination.

Changes to the Fisheries Act

Positive changes have recently been made to Fisheries Act, but many believe another round of amendments are required to be consistent with a sustainable fishery.  The 2019 mandate letter to the Minister of Fisheries and Oceans (and the subsequent 2021 letter) tasks the Minister with continuing implementation of the amended Fisheries Act, but there is no suggestion that it will be improved.

Although many conservation groups and First Nations were pleased with the recent changes, for the next set of improvements the following would need to be implemented (Smart, 2019; Imhof et al., 2020):

1. The language of many protections for First Nations is "may" rather than "shall".  This needs to be changed to improve protections

2. Although habitat protection and recovery provisions have improved, it is still possible for government to delay acting passed on certain economic conditions. In US legislation, the language around the need and timeline for action is more precise and consequently many more stock recovery plans have been implemented, so similar language to US provisions should be included.

3. Owner operator regulations, strengthened for the Atlantic are still weaker for BC and equivalent provisions must be put in place.  There also remain some loopholes in the owner-operator rules that must be closed.

4. There remains a lack of concrete methodologies to ensure proper monitor and enforce many core  under the Act.

5. With the 2019 changes, a return to protecting all fish and their habitats reflects an ecosystem-based approach, but the policy goal of achieving a “net gain” of fish habitat was not reinstated. There are also still challenges with interpreting what constitutes habitat alteration and disruption, as it is largely unavoidable when considering projects near aquatic environments, including conservation measures; clear guidelines for the allowable “duration, spatial extent, [and] magnitude of disruption or alteration” are necessary to improve clarity and application of the Act (Imhof et al., 2020, pg. 333). A baseline for sufficient habitat health in Canada would clarify this definition, as well as data on the short-term and long-term effects of development and conservation projects and current efficacies of the “avoidance, mitigation and offsetting measures” implemented during them (Imhof et al., 2020, pg. 333).

6. Activities that result in cumulative, negative effects on the aquatic environment also need to be, but are currently not addressed (Third et al., 2021).

7, Imhof et al. (2020) also suggest that the Fisheries Act could be further strengthened through a mandatory, public, project registry, that allows developments in or near aquatic and riparian environments to be tracked and audited by DFO, providing both guidance and compliance under the Act.

Boat and gear restrictions, progressive large fleet contractions

As allocations are shifted to the small to medium scale fishery, and as catch limitations are imposed to address stock depletion and dietary shifts, large fleets will have to progressively shrink.

Boat and gear differ by targeted species and by region.  As discussed in Core issues, for the Atlantic fishery,  90 percent of the approximately 15 000 registered fishing vessels are small to medium sized (less than 45 ft), focusing primarily on the inshore and near-shore fisheries, and about two-thirds of  landings are from pots and traps (DFO, Canadian Fishery Statistics, 2011-2012). Trawlers, seiners and dredgers are typically over 65 ft in length and are a small percentage of vessels but take a disproportionately large percentage of total landings and value.  The Pacific fishery has relatively more boats in the 45 ft plus range, and again a relatively disproportionate share of landings.  The freshwater fishery is primarily gillnet but there is limited data on boat size.

At the efficiency stage, boat and gear restrictions are linked to recovery plans.  At the substitution stage, they must be extended to take account of growing demand-supply coordination, including efforts to reduce by-catch (see below).  But, they must be tailored to individual region-fishery combinations.  They are likely to be more necessary on the BC coast than in the Atlantic.  The restrictions can be regulatory amendments to the Fisheries Act (see above).

Alternative animal and aquaculture feed

As discussed under Core Issues, a significant percentage of the catch and by-catch go to animal and aquaculture feed or for live bait.  This is sensible for species with low human demand or healthy stocks, and for processing waste but much of current consumption does not meet these criteria.  Solutions fall into two general categories: a) reducing the use of fish as feed for species that humans consume; and b) finding alternative feed sources to replace fish, particularly protein and oils.

Significant work is being done to find plant-based substitutes for fish meal and oil in aquaculture.  For example, canola has an omega-3 oil profile makes that makes it a substitute in salmonids for fish oils.  Protein levels in the meal, however, are low relative to fish meal, so research on protein concentration is underway. Anti-nutritional factors in canola must also be reduced. Canola could potentially serve as a modest replacement for fish meal in diets.

However, this only makes sense if the crush from oil pressing is the basis for the fish feed, but reports (cf. White, 2020) suggest that this is not what will happen because of the expense and complication associated with developing this specialized and very manipulated application.  Some canola varieties are being developed primarily as oils and meal for the aquaculture market.  This is inconsistent with the key concepts guiding a new food system.  Developing fish meals and oils from by-products will probably mean a lower quality feed and slower growth rates but this is consistent with a demand-supply co-ordination approach in which demand for fish is reduced (see Fish in a Sustainable Diet below).

A botanically related option is winter camelina, a member like canola of the mustard family. It produces a desirable oil for fish meal, but fits better in crop rotations, especially because winter wheat acres are in decline. The camelina can absorb excess nitrate in the soil profile following a main crop and provides good winter cover.  It also provides early spring nectar for pollinators.  Breeding work is underway to identify varieties well suited to Prairie conditions, but commercialization would be a significant challenge  because commercial seed companies are too fixated on spring canola varieties (Arnason, 2020).  As discussed under Goal 4 Genetic Engineering, and Goal 5, Protecting genetic resources, governments will have to intervene more significantly in the seed market place to shift commercial priorities.

Insects are also be used as feed, approved under the Feeds Regulations, in aquaculture systems and this is especially logical given that the dominant aquaculture species are all terrestrial insect consumers in the wild.  However, to be ecologically efficient, the substrate for rearing insects should be pre-consumer waste products (see Goal 9, Changing what we consider edible).

Reducing By-catch

Although many factors contribute to by-catch and some of them are technically modifiable (eg., net visibility, twine type, warning stimuli), the most significant factors are net length, height and depth, mesh size, time in the water (soak time) and water depth/location. Typically, the larger the fishing operation, the greater the negative impact. These latter factors, however, are unlikely to be modified by management if the same catch levels are desired (Wiedenfeld et al., 2015), but his reality progressively shifts with gradual introduction of a demand-supply co-ordination system.

Some gear has or is being banned because of by-catch, including trawling in Belize, and drift gill nets in California (taking effect in 2023). Separator trawls are being used in some fisheries to catch in different parts of the net target vs non-target species, the latter then being released rather than landed. The EU is implementing a discard ban, learning from bans implemented in Norway and Iceland, which will have the effect of reducing fishing as holds fill up with non-target species (Stokstad, 2019). If this proves a viable strategy, in concert with other actions proposed here, then it should be implemented in Canada as well.

Changes to acceptable fish processing practices

By-catch is part of a larger story of fish waste (see also Goal 5 Reducing food waste). Abdulla et al. (2013) estimated fish waste (as a percentage of what is available for consumption which includes wild and farmed fish and would not include by-catch that is returned to the ocean) at 31% over the 1988-2009 period.  This covers all aspects of the supply chain, though in subsequent analysis the research team determined that they had in general underestimated waste at processing and retail, and overestimated household waste (Gooch et al. 2019).   Globally, some 46 million tonnes of fish are wasted, about 35% of what is available for consumption (Chapman, 2019). The processing industry and their up and downstream relationships with fishers and distributors are  significant contributors to the problem, likely directly responsible for about 20% of fish waste (Chapman, 2019), globally about 20 million tonnes is processing plant waste (Ghaly et al., 2013).

According to Ghaly et al. (2013), "Processing of fish involves stunning, grading, slime removal, deheading, washing, scaling, gutting, cutting of fins, meat bone separation and steaks and fillets. During these steps significant amount of waste (20-80% depending upon the level of processing and type of fish) is generated ...." Equally important, if these stages are improperly executed, fish is wasted, or the quality of the product degrades, resulting in lower human food utilization.  Significant amounts of this waste are inedible for humans and it makes sense for them to be reprocessed for other applications (and significant R&D is being funded by Canadian contribution programs for that purpose), but the upper end of this waste means that significant amounts of human food are being lost.   As with cuts of meats, a significant problem is the focus on fish steaks and fillets (especially boneless, skinless).  Not all of the edible parts of the fish are being consumed, with significant meat losses associated with the filleting process for reasons of consumer demand, filleting difficulties and the time involved in doing a more careful separation of bone from meat.  This problem has been somewhat mitigated by the use of minced fish in fish burgers, fish sticks, canned fish, vegetable mixes and fish dumplings (Ghaly et al., 2013).  Fish stews, fish cakes, fish soups and related meals are less commonly prepared now compared to earlier periods and that results in under - utilization.  Fish heads, for example, are now considered in Canada inedible, typically accounting for 20% of the weight of the fish (Ghaly et al., 2013).

At this stage of food waste reduction (see Goal 5, Reducing Food waste), significant penalties exist for generating waste and this will encourage processors to improve  their utilization. Better tracking systems are part of the solution, but food chain and process re-engineering are also critical.  The FOC Fisheries and Aquaculture Clean Technology Adoption Program has been used by industry to help fund pollution reduction, energy efficiency and fish waste utilization projects.  While this is important, as with most contribution programs of this kind, participation is voluntary and competitive and not always well targeted to the most pressing problems (see Instruments). Government contribution programs must be reoriented to provide funding to optimize utilization for direct human consumption rather than focusing on new international market development. Price setting (see below) will also be implemented and this will also help with financing the transition.

Re-configuring industrial uses of fish

Industrial uses should be restricted to waste products once as much of the fish as possible is used for direct human consumption. As discussed in Goal 5, Reducing food waste, a key problem with current approaches is that the secondary market for waste is driving under-utilization of the primary product destined for human consumption.  In other words, we generate more waste than necessary so it can be used in secondary products.  This is irrational.

Consistent with the hierarchy set out in Goal 5, Reducing food waste, once as much as the fish as possible is separated from inedible parts, the next phase is to optimize the waste for secondary ingredients destined for human consumption. Fish waste can go to condiments such as fermented fish sauce or to highly processed human ingredients like proteins, oil, amino acids, minerals, enzymes, bio-active peptides, collagen and gelatin (Ghaly et al., 2013).  Some of these have industrial, cosmetic and health sector applications as well, but their use for such purposes should be secondary to human consumption.  As population diets shift more to whole and sustainable foods (see Goal 2, Demand - supply Coordination, Substitution, Sustainable Diets), there will be less demand for food constituents to be used in processed goods, however, there will always be a need for some level of these products.

Industrial uses for waste include animal (particularly pigs and poultry) and fish feed, fertilizer (fish emulsion and compost), processing enzymes, feedstock for bio-industrial processes and biodiesel (Ghaly et al., 2013).  Again, the demand for such uses will be reduced as more sustainable approaches accelerate and livestock and poultry populations decline.

Supporting regional processing and distribution infrastructure

Because about 80% of Canadian fish and seafood capture and production is exported, most of the support providing by governments  for processing and distribution is geared to export markets (see for example recent processor contributions from the Atlantic Fisheries Fund).  Most of the fish plants are located outside of major urban centres and there are many small to medium enterprises located in rural and coastal communities.  About 75% of processing operations have less than 100 employees (Industry Canada).  However, there has been considerable consolidation the last 30 years and a small number of large firms, with over 500 employees each, dominate shipment volume and value.

The challenge in moving to a DSC approach is how to favour the SME sector rather than contribute to increasing industry consolidation while an orderly reconfiguration is underway. The existing Canadian Fish and Seafood Opportunities Fund could be re-purposed to focus on building SME capacity rather than favouring exports. Although primarily addressing conventional export needs, a 2005 report (Pinfold and Rogers, 2005) on the Atlantic fish processing sector highlighted some of the challenges  to be resolved.  Other challenges are addressed in other parts of this section.  The following need to be addressed by a revamped Opportunities Fund (see also Goal 1, Economic Development Strategies):

1. "too many plants with too much capacity chasing too few fish" - this can easily result from DSC transition if not properly orchestrated. It results in price manipulations and infrastructure under-utilization.  Supports should disfavour large enterprises and favour SMEs, most easily by how eligibility for support is framed.  If owner-operator provisions are well implemented, than processors do not hold quota to protect their product supply unless part of a fisher ownership structure or co-operative.

2. SMEs have limited access to capital, which means most operations are very labour intensive.  That would be fine except the labour force is aging and young people aren't entering to replace them at sufficient rates.  Seasonal work is a challenge for many.

3. Most firms have cash flow problems so are forced to move inventory quickly to deal with them.

4.  Training and marketing needs are significant and will be even more acute in the transition to a DSC system.

5. Food safety / traceability and sustainable certification requirements are increasingly expensive to implement.

Price setting

Consistent with Redesign strategies to create a Demand - Supply Coordination system (see Goal 2), price setting in certain fish markets will be required at the Substitution stage.  The problem is exemplified in the late fall 2019 situation of Atlantic lobster.  A combination of growing Chinese demand, the US - China trade wars that limit US lobster sales, and Canada's reputation for quality lobster have dramatically increased sales to China, and lobster prices.  While this results in short-term windfall profits for lobster fishers, the problems that result from this are: pressures on stocks, more GHG emissions associated with air-freighted lobster to China, higher prices in domestic markets and reduced availability of local lobster in local markets.  Many analysts are highlighting the medium term risks of this situation (Mercer, 2019).

Price floors could be established in significant cases of oversupply and price ceilings in cases such as the lobster scenario described above.  As described under Goal 2, Demand Supply Coordination, Redesign, Price Setting, the Emergencies Act could be the legal foundation for such interventions since these shortages or excesses create stressful conditions on the stock or on fishing communities.

Fish in a sustainable diet

Health Canada is encouraging Canadians to consume more plant protein (see Canada's Food Guide). Animal and fish proteins play a reduced role in the most recent version of the Guide. However, for many First Nations, consuming fish is a cultural and health necessity, as it is for some ethno - racial communities where fish have historically been central to the diet.  The role of fish in the diet among different regions and groups must be articulated as part of the transition to a sustainable diet, see Goal 2, Demand Supply Coordination, Substitution, Design and promotion of a sustainable diet.  Most likely, fish consumption will need to increase in certain region/group combinations, and will have to decrease in others, with an overall decrease in consumption in line with the state of fish stocks.

During WWII, there was regional rationing based on supply considerations.  Full implementation of this approach would happen at the Redesign stage, but at the Substitution stage, there is a need for integrated fish supply information and decision making that then has an influence on distribution and consumption.  Under FOC and several provincial and territorial governments there are a range of regional committees for Integrated Fisheries Management, for sport fishing, and for the inland fishery.  What's needed in each region is an overarching body that collects data from all the sub-units and creates an integrated supply picture.  This can then be used to make supply allocation decisions, including informing export and import restrictions (see below).

Export and import restrictions

Under the Export and Import Permits Act, the federal government has the authority to restrict exports and imports based on national and economic security measures.  It also can restrict imports based on food safety concerns under the Safe Food for Canadians Act (SFCA), for example certain species of fish that are considered hazardous are not permitted for commercial import. However, neither Act as currently written provides for restrictions based on concerns for the sustainability of the fish stock.

About 80% of Canada's fresh and processed seafood is exported, with the US accounting for roughly 60% of export shipments (Sectoral Profile, 2018).  This means that there is significant room to repatriate supply to meet domestic needs as supply falls with conservation efforts.  Equally important, with global efforts to preserve fish stocks increasing, Canada may have to restrict imports to support these initiatives, meaning more domestic supply would be diverted to the domestic market.

Under free trade agreements (see Goal 10), trade of goods can be restricted for reasons of resource conservation and such restrictions have been upheld in World Trade Organization dispute rulings.  An amendment based on GATT language in Article XX (see Instruments, International Agreements, Trade Agreements) should be inserted under Sections 3(1) and 5(1) Establishment of Control Lists in the Export and Import Permits Act. The amendment could read, "“to ensure the conservation of exhaustible natural resources if such measures are made effective in conjunction with restrictions on domestic production or consumption.” This would be consistent with efforts domestically to conserve fish stocks based on the best domestic data.  For import controls, the restrictions would be placed on species of fish stocks recognized internationally as threatened.  The consequence of being put on the Control List would be that no permit for import or export would be issued.  Alternately, as the fish recovered, a limited number of permits would be allowed consistent with recovery rates.

Export and import permit restrictions would also be imposed to shift harvested seafood products to the domestic market.  In other words, in coordination with supply contraction to maintain stocks, shortages in the domestic market would be addressed by reducing exports and shifting supply to domestic requirements.  Imports that compete with domestic sources might also be restricted if they had a negative impact on price stability.

Labour force reconfiguration

As with agriculture, many fishers and fish plant workers are 55 or older and there are significant labour shortages (Sectoral Profile). Out-migration from rural and coastal communities associated with other work opportunities, seasonality of work (seasonal unemployment in the sector exceeds 20%), the structure of Employment Insurance, training and wages are all significant factors. Use of temporary worker programs has doubled since 2010. Proposals for labour force development in the  fishing sector must be integrated with strategies outlined under Goal 8, Labour Force Development as similar problems apply.

Improving performance indicators

Clay et al. (2013) reviewed fisheries-specific performance indicators and from that developed a full set of indicators that focused on traditional economic measures (what is typically measured), distributional effects (including community scale impacts), governance (including complexity, adaptability and participatory factors), stewardship (including conservation ethic and compliance), and well-being (individual and community). Stephenson et al. (2019) have similarly elaborated a very extensive set of objectives for a sustainable fishery that equally can serve as performance indicators. This integrated set of measures provides a wider understanding of what's happening after policy change than what is usually undertaken by policy units and underscores a different conception of success.

Reducing pollution

In addition to plastics and gear, a wide range of pollutants have significant negative impacts on fresh and marine fisheries.  Reducing them is an enormous topic with much of it beyond the boundaries of this site. For more on food system related interventions, see Goal 5, Water and the food system and Goal 5, Sustainable transportation and Goal 5 Food Packaging Changes.