FISH Committee Report

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Committee Report

INTRODUCTION

Sealing is a sensitive and emotional issue. For almost two decades, animal rights groups have portrayed it as an inhumane, brutal and even barbaric activity that generates little real economic activity. Images of whitecoat 1 seal pups are still displayed prominently in their literature even though the whitecoat seal hunt has been illegal in Canada since 1987.

At the other end of the scale, are people in coastal communities on Canada's Atlantic coast for whom sealing is both a tradition and an important source of income. The immediate landed value of the seal harvest may not be large compared to that of other fisheries but it is nevertheless important in regions where opportunities for other types of economic activity are limited. The image of blood on the snow may have a dramatic impact for the public at large but for sealers there is little difference between the killing of seals and the slaughter of domestic animals behind closed doors in abattoirs across the country.

These difficulties are more acute for Inuit living in Canada's northern and Arctic regions. Here, because of the region's geography and climate, other resources are few and alternative sources of income, such as tourism, are limited because of its remoteness. Seals are seen as simply a resource to be used, part of the natural cycle of life, death and survival. The people of this region have hunted seals for generations, not as an industry but for survival. Seals provided food, clothing, light, warmth and tools. In more recent times, the export of sealskin products from the North was an important source of cash that helped to underwrite a much larger subsistence economy.

Although they may not have been the intended victims of the anti-sealing campaigns of the early 1980s, there is little doubt that Inuit communities, even more than southern sealing communities were dealt a devastating blow by the loss of the market for sealskins. The people of Nunavut are slowly rebuilding a vibrant export industry based on sealskin products but they still face many hurdles, not the least of which are continuing misconceptions about the nature of the seal hunt and the sealing industry.

A new element has now been added to the debate on sealing. In 1992, the northern cod fishery was placed under a moratorium. Other groundfish fisheries followed in quick succession. Initially there was a widespread expectation that, without pressure from fishing, stocks would quickly recover, perhaps within as little as two years, and fishing would be able to resume. Seven years later, however, there have been only modest gains in the status of most groundfish stocks and some have even continued to decline. The natural inclination is to look for a cause.

During this same period, populations of seals, particularly harp seals, have increased dramatically. For many people, the equation is simple and the conclusion inescapable. Seals eat fish, including cod; there are a great many seals and not many cod: ergo, predation by seals is preventing the recovery of cod stocks. Added to this are observations that harp seals are showing signs of malnourishment as well as changes in their range and migration patterns and their feeding behaviour.

For many stakeholders, the disproportionately large number of seals compared to cod is symptomatic of an ecosystem that is badly out of balance and that needs help to correct itself. Failure to act risks the possible extinction of cod stocks and the consignment to oblivion of coastal communities whose future depends on the recovery of those stocks.

On the other hand, some observers believe just as strongly that there is no clear link between the burgeoning seal population and the failure of cod stocks to recover. They point to the fact that cod make up only a small portion of the diet of seals. When additional species are thrown into the equation, the outcome is unpredictable. If, for example, seals prey on a species that also preys on juvenile cod or that competes with cod, reducing the seal population could well further destabilize the balance of the ecosystem. Unfortunately, current science is as yet unable to provide a definitive answer.

As part of this study, the Committee had originally intended to travel to Newfoundland and Labrador to view the seal hunt firsthand in the spring of 1999. Despite considerable efforts to make arrangements, the Committee reluctantly found that it was ultimately unable to make this journey.

SCIENCE

The Size of the Northwest Atlantic Harp Seal Herd

In 1994, when the last survey of harp seal pup production was conducted, the size of the herd was estimated at 4.8 million animals. This estimate was based not on a direct count of seals but on a biological model, which incorporates the abundance of seal pups with information on the reproductive rates of female seals and the age structure of the herd. An estimate depends to some extent on the details of the model used, so that changing the model would change the estimate of the size of the herd.

The number of harp seals has been growing steadily since the early 1970s when, at fewer than 2 million animals, it was at its lowest recorded level. Since the end of the Second World War, the size of the herd had been declining because of hunting pressure.

By 1994, the seal herd had more than doubled from its low in the early 1970s, until, by 1996, the estimated size had almost tripled to somewhat over 5 million animals. Since 1996, the population has either stabilized or possibly decreased slightly.

The trends in the western Atlantic harp seal population appear to reflect harvest levels. From 1961 to 1970, while harvests were high, around 275,000, the population declined. After the introduction of quota management in 1971, harvests were smaller, around 150,000 and the harp seal herd started to slowly regain its numbers.

Largely as a result of anti-sealing campaigns by animal rights groups and the European Union ban on the importation of products made from whitecoat and blueback 2 pelts, the market for sealskins collapsed in 1983. Domestic regulations that prohibited the commercial harvest of whitecoat and blueback seals were introduced in 1987, following the 1986 report of the Malouf Royal Commission on Seals and Sealing in Canada. From 1983 to 1995, the numbers of seals harvested was well below the total allowable catch (TAC) of 186,000 animals. Harvests were as low as 20,000 and never exceeded 100,000. During this period, the harp seal herd grew more rapidly.

By 1995, the market for sealskins had improved, causing a renewed interest in sealing and, in response to the results of the 1994 survey, the TAC was increased to 250,000 in 1996. As a result, the harvest increased dramatically in 1996. For the last three years, 1997 to 1999, the TAC has been set at 275,000. According to Department of Fisheries and Oceans (DFO), the harvest averaged about 260,000 animals over the three-year period from 1996 to 1998, the highest level since the 1960s. This situation appears to have coincided with a levelling off, or even a small decrease, in the size of the herd.

The Size of the Harvest

The current TAC set by the DFO is based on the principle of "replacement yield," which is defined as the number of animals that can be taken from the population without having it decreasing in size. The replacement yield, based on the results of the 1994 survey which estimated that the harp seal population was 4.8 million and growing at an annual rate of 5%, was estimated at 286,700.3 Using this approach, DFO increased the TAC to 250,000 in 1996 and again to 275,000 for 1997, 1998 and 1999.

In addition to the Canadian harvest, there is also a West Greenland harp seal, harvest, whose last recorded catch was 75,000. Extrapolating this number forward to 1998, the Department estimates its current size to be some 85,000.

According to Dr. George Winters, Senior Fisheries Consultant, Focus Technologies Inc., the current quota of 275,000 for the Canadian zone, combined with a projected take of 75,000 to 80,000 in West Greenland, amounts to a total kill of about 350,000 to 360,000 animals. This number is lower than the replacement yield of the Northwest Atlantic harp seal population, estimated by Dr. Winters at between 400,000 and 420,000. If the assumptions are correct, with a harvest of this size, the population would continue to increase.

According to Dr. David M. Lavigne, President, International Marine Mammal Association, however, landed catches in the 1996 to 1998 period exceed even the government's highest estimate of replacement yield of 300,000. In which case, if DFO's management model is correct, the population should be declining.

Struck and Lost

The recorded catch does not account for all the seals killed in the hunt. A number of seals are "struck and lost"; that is, they are killed but cannot be recovered. The Committee heard disagreement on estimates of the numbers of seals struck and lost. Some seals are also killed incidentally in other fisheries.

According to officials from DFO, unrecovered seals make only a modest difference to the total numbers. The greater part of the hunt is conducted on the ice for "beaters," - young seals that have moulted. The Department's estimate of the numbers struck and lost in this part of the hunt is low, somewhere in the range of 1-3%. In the Arctic, where seals are hunted in open water, the proportion of unrecovered seals could be as high as 50%; however, since the contribution of this part of the hunt is small, about 5,000 animals, it does not greatly affect the overall estimates of the numbers of seals killed.

A different picture of the number of seals struck and lost was presented to the Committee by Dr. Lavigne 4 who estimated total removals in ranges that in most cases exceeded 400,000 and went up to as many as 548,903 during the period from 1996 to 1998. In the opinion of Dr. Lavigne, somewhere between 100,000 and 260,000 more harp seals (a factor of 1.3 to 1.9 times) were killed in those years than would be considered prudent under a truly precautionary approach to management.5 Total removals at this level would not only cause the present harp seal population to decline, but to decline to levels below 50% of its maximum size.

These figures were challenged by Dr. Winters, who provided an estimate of losses, based on modelling of 8%. This, he said, was consistent with empirical estimates based on data collected by DFO. A sinking loss of 8% would result in an additional 32,000 kills that would not be included in the reported statistics of an expected kill of 360,000 animals in 1999. However, about half of these unreported kills would be included in the current estimate of the natural mortality rate and even if the replacement yield were adjusted for the unreported kill, the total harvest would still be within conservation limits.

Predation by Seals and the Impact on Cod

One of the most controversial aspects of the debate on seals is whether predation by harp seals is impeding the recovery of cod stocks. None of the witnesses who appeared before the Committee claimed that seals were the cause of the collapse of cod stocks, which they clearly attributed to both foreign and domestic overfishing. However, it was noted by the Fisheries Resource Conservation Council (FRCC) in their April 1999 report "that the single cod stock in the Northwest Atlantic considered recovered, namely, the southern Newfoundland/St-Pierre Bank stock (3Ps cod), is the only stock that does not have a large number of seals occurring within its stock range."

Opinion is divided as to whether the large populations of seals, particularly harp seals but also hooded and grey seals, are significantly hindering the recovery of depleted cod stocks. There was general agreement that the issue is scientifically complex and the question is difficult to answer. Not surprisingly, then, there was a considerable divergence of opinion in the testimony presented to the Committee.

On one side of the debate is the assertion that seals eat fish, including cod, and that, since there are unprecedented numbers of seals and very low levels of cod, there is a very great likelihood that seals are significantly impeding the recovery of cod stocks. Consequently, it would be prudent to manage the harp seal herd to limit its size. This view is supported by anecdotal observations of unusual behaviour of both cod and seal, as documented in the "Efford" video.

On the other side of the debate is the belief that cod make up only a very small proportion of the diet of harp seals. Since there is no credible scientific evidence that seals are having any impact on the recovery of cod stocks, it is argued that there is no justification for measures to limit or reduce the size of the herd.

The Diet of Harp Seals

Much of the debate over the impact of seals on cod stocks centres on the difficulty of determining the amount of cod consumed by seals. Much of the information on their diet is obtained from analysis of the contents of seal stomachs. Since soft tissues are readily digested and therefore harder to identify, much of the information comes from identification of less digestible hard tissues such as otoliths.6

Many fishermen and others are convinced that seals eat the bellies of larger cod, perhaps seeking delicacies such as the liver. The "Efford" video is cited in support of this view, as it shows dramatic footage of cod with their bellies ripped open. (From a scientific point of view, this evidence is purely anecdotal and it should be pointed out that nowhere in the video are seals seen eating cod bellies.) The fact that a cod belly is composed entirely of soft tissue leads to a potential bias in the scientific results.

Even if it could be determined conclusively what fraction of a seal's diet is composed of cod, the answer could underestimate the full impact of seal predation on cod stocks, since the uneaten part of the cod carcass is discarded to rot. DFO recognizes that the consumption of soft parts is a problem in the estimation of diets. It points out that many of its samples are obtained from sealers who have removed and preserved the stomachs of seals taken from the animals while they were feeding and, as a result, some stomachs are well preserved and contain not only soft tissues but also whole fish. A large number of prey items are identified, ranging in quality from very fresh to decomposed.

Dr. Gary Stenson, Section Head, Department of Fisheries and Oceans, noted that DFO has been aware of reports of seals taking stomach contents, not only cod but also lumpfish and other species, for a number of years and has attempted to adjust for biases in estimates caused by sampling. He pointed out that there are opposing biases, as cods are fairly robust and are therefore more easily identified than other prey in stomach contents so that proportion of cod in the diet may be overestimated.

Dr. Stenson also referred to reports where seals have been observed feeding on whole cod up to 40-50 centimetres. The size range of cod seen in stomach contents also indicates that they are taking heads of a number of those fish.

A further problem is that reports on seal diets tend to be selective with respect to timing and location and thus may not be fully representative of total diet; however, DFO does attempt to cover the whole area in its sampling.

Impact on Cod Stocks

According to DFO information, an average adult harp seal consumes between 1.0 and 1.4 tonnes of food a year. DFO estimates that the proportion of commercial species, particularly cod, is about 1 to 2%. This figure is low because harp seals are a migratory species that spend much of their time in Arctic waters; thus only about 40% of their consumption is in waters where there are commercial fisheries and even here the bulk of the diet is forage fish. Thus, taking the highest estimates, consumption could amount to as much as 140,000 tonnes of cod. (DFO also reported that in recent years, the proportion of cod in the inshore diet had gone up to 10% in some bays, in some areas.)

The FRCC has also raised an alarm about the effect of seal predation on cod stocks. In a November 1998 report to the Minister of Fisheries and Oceans it stated:

We are disappointed that the effects of seal consumption could not be quantified as part of the 1998 SSRs [stock status reports] for Atlantic cod stocks. DFO analysis suggests that:

grey seals are consuming between 5,400-22,000t annually of Eastern Scotian Shelf cod (on a total biomass estimated to be as low as 32,000t);
harp seals may be consuming as much as 140,000t annually of northern cod;
seals in the northern Gulf of St. Lawrence may have consumed as much as 68,000t of cod in 1996;
seals in the southern Gulf of St. Lawrence may be consuming over 10,000t annually of cod.7

According to Mr. John Efford, the Newfoundland and Labrador Minister of Fisheries and Aquaculture, and the Newfoundland and Labrador All-party Committee, the link between seal predation and the recovery of cod stocks is clear. He stated:

The NAFO science community, in 1997, reported clearly that the seals consumed 108,000 tonnes of juvenile northern cod - those less than 40 cm - which represents 300 million fish. Had those 300 million fish had a chance of survival, whatever nature's percentage of survival is, and had they grown to the poundage at which they could be harvested commercially, how many people in Newfoundland and Labrador would have got back to work to feed their families?

Dr. Winters provided a more circumspect analysis in terms of the general relationship between the size of the harp seal population and the overall productivity of the ecosystem:

Our recommendation is that the management authorities should reconsider regulating the harp seal population at the MSY 8 level. This was the policy that was in place in the late 1970s and abrogated when the hunt was reduced in 1983, allowing the population to explode.

An MSY population has a variety of biological and conservation benefits. We've listed them there. They will bring the growth and the reproductive rates of seals to a more optimum level. They will improve the overall ecosystem yield.

We give an example in our report of the consumption of food by the biomass of harp seals there now, which is approximately 450 tonnes. They consume 7 million tonnes of fish, 16 times their own weight, and yet their surplus production - that is, their incremental addition to the ecosystem - is a mere 15,000 tonnes. The equivalent biomass of cod would consume between three to four times its weight - in other words, maybe 1.5 million to 2 million tonnes - and would produce about 100,000 tonnes of yield.

As well, there is an increased probability that depressed cod stocks would recover. There's no certainty that there is a cause and effect, but if there is one, then certainly reducing the seal populations will improve the probability of a recovery.

The maximum sustainable yield level is consistent with the United States' Marine Mammal Protection Act, in which they require that for all imports of seal products, those populations should be at an optimum production level. The MSY is an optimum production level.

Some witnesses, however, did not concede any link between the harp seal population and the recovery of cod stocks. According to Dr. Lavigne:

All scientific efforts to find an effect of seal predation on Canadian groundfish stocks have failed to show any impact. That was the conclusion of 97 scientists who signed a petition in 1995. There is still no scientific evidence to suggest that harp seals are impeding the recovery of northern cod, or any other cod stock.

This point of view was shared by the International Fund for Animal Welfare:

Very clearly, there is no scientific evidence that seals are impeding the recovery of the northern cod stock. In fact, to quote a professor from Memorial University of Newfoundland, there has never been any evidence anywhere in the world that culling a marine mammal population has benefitted the commercial fishery.

The reason is quite simple. A lot of people involved in this debate, including John Efford, would have the committee believe the northwest Atlantic operates like a teeter-totter, with harp seals on one end and codfish on the other. If we push down on the harp seal end of the teeter-totter, the codfish end is going to pop up and those fish are going to leap into the nets of fishermen.

The complexity of the ecosystem was also emphasized by another scientist, Dr. R.L. Haedrich, who argued that the wholesale removal of a top predator could push an already destabilized system into an even more precarious position. To illustrate this, he suggested that it could be argued that seals are keeping in check Arctic cod which, if released from predation pressure, would come to dominate the system. By competing in vast numbers with cod at the larval and juvenile stages, the newly dominant Arctic cod could prevent the true cod's recovery.9

THE FISHERIES RESOURCE CONSERVATION COUNCIL REPORT

On May 6, 1999, the Fisheries Resource Conservation Council (FRCC) released a report titled 1999 Conservation Requirements for the Gulf of St. Lawrence Groundfish Stocks and Cod Stocks in Divisions 2GH and 3Ps. Chapter 2 of the report addressed the issue of predation by growing herds of harp, grey and hooded seals on stocks of groundfish, particularly cod.

In the report, the Council stated that populations of harp, grey and hooded seals together kill more cod from Canadian stocks north of Halifax than any other known factor. The Council stated its conviction that seals are impeding the recovery of cod stocks:

The accumulated evidence from scientific assessments, as well as the consistent, continual, and corroborating information from fishermen throughout Atlantic Canada is such that the FRCC is convinced beyond any reasonable doubt that the conservation of groundfish stocks, most notably cod, will continue to be jeopardized if the seal herds remain at their current levels.

Reaction to the Council's report was controversial. The Council's advice, "that the seal herds be reduced by up to 50% of their current population levels," was generally taken as a wholesale recommendation to "slash" seal herds by up to 50%. While the Newfoundland and Labrador Minister of Fisheries and Aquaculture, Mr. Efford, welcomed the report, it was denounced by the IFAW and the IMMA. The IFAW described the Council's report as "more superstitious than science." At the same time, it asked for a review of the composition of the Council. The IMMA called the Council's recommendations "dangerous, [and] scientifically groundless," and asserted that the FRCC was dominated by fishing industry interests.

On May 27, 1999, the Standing Committee on Fisheries and Oceans held a hearing with members of FRCC including the Chairman, two members with scientific interests and the Acting Executive Director to examine the basis of the Council's recommendations.

After discussion with the Council members, the Committee has concluded that the advice offered by the Council is less radical and its recommendations more moderate than the way they have been characterized so far.

In Chapter 2, the Council's made its principal recommendation:

Reduce the seal herds by up to 50% of their current population levels in specific areas and use such reductions as the basis for scientific study and adaptive management.

In making this recommendation, the Council applied the "precautionary approach."10 In other words, in the absence of scientific certainty, the Council based its recommendation on the balance of evidence contained in the following considerations:

seal populations are at historically high levels and are currently near or at carrying capacity;
seal populations are currently not threatened and could be sustainable at reduced populations;
cod stocks in the Northwest Atlantic remain at low levels even after more than 6 years of moratoria and have been declared vulnerable 11 by COSEWIC 12; and,
predation by seals is the largest cause of mortality for Northwest Atlantic cod.

The witnesses clarified that the Council is not recommending a "blind rush'' to reducing seal populations far less a cull of up to 50% of the total population. Rather, it is advocating a carefully conducted scientific experiment based on reductions of seal populations in specific locations where cod stocks are especially vulnerable, such as spawning or overwintering areas. This approach is described in more detail in recommendation V of Chapter 2:

Define a limited number of experimental seal exclusion zones in each of the 2J3KL (Northern cod) fishery, the 4TVn (southern Gulf of St. Lawrence cod) fishery, and the 4RS3Pn (northern Gulf cod) fishery for the purpose of preventing the expansion of seals into the fishery, designated bay, or area. This measure is designed to protect spawning and juvenile cod concentrations and to prevent seals from inflicting high mortality.

Exclusion zones would not be whole bays, far less the whole Northwest Atlantic, but more specific and limited areas. One example of a potential exclusion zone might be Smith Sound in Trinity Bay, a fjord in eastern Newfoundland. Smith Sound is the home of the largest remaining spawning stock of northern cod. This is a stock that has been well studied and which is known to be in need of protection.

Although the Council is convinced that seal predation is inhibiting the recovery of cod stocks, Council members agreed with previous witnesses, that the effect of removing seals is unpredictable. For this reason, the Council has framed its recommendations in terms of what it describes as an "adaptive management approach." In principle, this means that, as the effects of reductions are determined, this information would be incorporated into future management plans on an ongoing basis.

Such an approach may be less problematic than an extensive cull of seal populations. Provided the number of seals culled is not massive compared to the total harvest, it is conceivable that seals killed in exclusion zones could be absorbed into existing markets without undue adverse impact. The Council admits, however, that it does not offer any advice about how a large additional seal kill could be accommodated as this is outside of its mandate.

THE ECONOMIC AND SOCIAL VALUE
OF THE SEAL HUNT

Economic Value

The Committee heard a divergence of views on the economic benefits of sealing. The Department of Fisheries and Oceans (DFO) places a value of $12 million annually on the seal hunt in Newfoundland alone.

The Government of Newfoundland has calculated the value of the 1998 harvest to the Newfoundland economy, taking into account oil, pelts and meat products from 275,000 animals processed by local companies, to be approximately $25 million. The industry employed in excess of 400 plant workers and upwards of 4,000 sealers in the province.

The IFAW, however, believes the economic value of the seal hunt to be greatly exaggerated. It pointed out that, after government subsidies had been taken into account, the true value of the hunt dropped to $2.9 million. Even this number may be an overestimate as it does not include the costs to taxpayers of such things as icebreaking and enforcement.

For Inuit of Nunavut, the economic value of the seal hunt is not measured cash income. The Nunavut Wildlife Management Board described a fur price program introduced about four years earlier to kick-start the sealing industry again. Based on a single fixed price of $30 per skin, the program was successful in rekindling interest in sealing and making it once again viable. The program has resulted in the production of up to 7,000 ringed sealskins per year with a cash value of about $200,000 and a food value of about $10 million.

Social Value

The Nunavut Wildlife Management Board explained the social value of sealing in Nunavut. Sealing is a relatively small-scale activity in this area, amounting to about 20,000 ring seals a year and a few hundred harp seals. Ringed seals are preferred both for food purposes and for skins for clothing.

The preservation of sealing is a means of protecting Inuit cultural expression and economic livelihood which offers some limited wage employment opportunities. These help independent hunters to finance the growing costs of subsistence hunting for their families. Cash income to support the cost of hunting translates to food on the table in the form of seal meat which has been proven to have extremely high nutrition value.

When the market crashed in the early 80s because of the activities of animal rights groups and the EU ban, hunters had no place to sell their skins. The Hudson Bay Company and the Co-op stopped buying skins, there was a major impact on hunters, who had earned a lot of their cash income from selling skins as a by-product of the hunt. Not only was their ability to hunt and to put food on the table affected but there were also adverse cultural, social and nutritional effects.

Sealing helps to support the family unit. The hunter kills a seal and brings it home, where the animal skin is prepared for sale. Though to some extent, the skills have survived, there has been some need for workshops where the older women could encourage the younger women to hone these skills.

Market Development

The Government of Newfoundland is optimistic about the prospect of an expanded seal industry. It believes that over the next two to three years, the industry could be worth up to $100 million, harvesting and processing as many as 400,000 animals. A wide variety of products including the more traditional meat, fur, and leather products, are now being offered along with newer products, such as protein concentrate, Omega-3 fatty acids, and other fatty acids used as health food supplements.

The Nunavut too is actively pursuing market development as part of its sealing strategy, through activities such as participation in the Montreal Fur Show (where the fur industry will be paying a special tribute to Nunavut this year) and other venues. Nunavut also advertises internationally in Red Book and participates in the fur harvesters' auction, which brings in buyers from around the world, including China and Europe.

Nunavut is also actively developing its own northern market for both local and tourist clients by promoting fur products as being both attractive and functional and linked to the traditional hunting culture. In this way, it hopes to create new local economic opportunities. Other initiatives include production and design workshops, northern photoshoots with northern models and assessment of trade opportunities. Nunavut is also looking into the feasibility of using by-products from seals in various ways, in partnerships with the private sector. We also heard from the Inuit people in Labrador who had similar concerns as those raised by Nunavut.

Public Relations

An advantage for the Nunavut sealing industry is that it has popular support from the southern public. This is largely because the Nunavut sealing industry has a strong cultural and social basis and consists of small-scale, non-industrial, subsistence-based hunting, using humane harvesting methods of which the skins are a by-product. The Nunavut sealing industry faces a dilemma, however, as, even if it uses by-products in a sustainable way, it may give the appearance of not being only for subsistence.

Nunavut has made determined efforts to educate the public about the hunt. Initiatives include the production of a Nunavut sealing video, a book, a sealskin grading manual, brochures and labelling, media relations and public presentations.

Trade Barriers and Public Education

Overcoming trade barriers is a fundamental aspect of Nunavut's strategy, and the most significant barrier is the U.S. Marine Mammal Protection Act (MMPA), since the United States is probably the best potential market for products such as sealskin coats. Although these articles are popular with Americans who attend the Montreal Fur Show, they cannot be imported into the United States because of the MMPA. The Nunavut Wildlife Management Board explained to the Committee that Nunavut is not seeking financial assistance or subsidies but rather help in removing such barriers to trade. We heard evidence that the Inuit in Alaska can market their seal products to the continental United States, whereas Canadian Inuit cannot.

Overcoming trade barriers is a concern also for the Seal Industry Development Council. Some of its efforts are directed toward identifying eliminating trade barriers such as MMPA and others, which it describes as "nuisance" barriers in Asia. The Council also pointed to the aversion to the industry that has been generated by the animal rights movement.

OPTIONS FOR THE MANAGEMENT
OF THE SEAL HERD

The minister gave you some facts and figures about the harp seal herd and the need to have that addressed immediately. I'm just going to touch briefly on the human side of it. I'm going to put a human face on it, Mr. Chairman, because this is what this is all about. This is about people, about families, about communities, and about the survival of rural Newfoundland and Labrador.13 - Mr. Roger Fitzgerald, Member, House of Assembly of Newfoundland and Labrador

There is a very genuine fear among coastal communities in Newfoundland and Labrador that the expansion of the harp seal herd threatens the recovery of cod and other groundfish stocks and thus any prospect of a return to fishing as an economic activity. This, in turn, undermines the viability of coastal communities. Without the prospect of work, the youth have no option but to leave and seek employment elsewhere. Without young people to carry on the tradition, the communities will die out and a way of life will disappear.

What should or can be done about the size of the harp seal herd? The media, in recent months, have carried reports of calls for a cull to reduce the harp seal herd and thereby improve the prospects for recovery of cod stocks; however, not one of the witnesses before the Committee spoke in favour of a massive cull. Minister Efford and members of the All-party Committee of the House of Assembly of Newfoundland and Labrador made it clear that they had not asked for an increase in the TAC for 1999.

Ms. Tina Fagan, Executive Director, Canadian Sealers Association, speaking on behalf of the Seal Industry Development Council, also made it clear that the Council does not support even an increased quota, far less a cull, until the work has been done to ensure consistent markets with acceptable price ranges. The Council registered a number of misgivings about a cull, which involved the disposal of the seals culled, the financial cost of a cull, the cost from a public relations perspective, the possibility of providing animal rights activists with a new issue, and uncertainty of the effect of cull on the viability of the seal population. It was even suggested that a cull might have a detrimental effect on other commercial fisheries without ensuring a strong recovery of cod stocks.

The IFAW opposes any commercial hunt, on the grounds this inevitably results in unsustainable kill levels, unacceptable levels of cruelty and insurmountable problems of enforcement. The IFAW pointed to species that have been destroyed in the past, such as the passenger pigeon, the great auk, the buffalo and whales, though it stressed that it is not against subsistence hunting by Aboriginal people.

There is evidence that the harp seal population is currently showing signs of stress, as a result of overpopulation. Thus, there may be some justification for a management plan that would reduce the size of the harp seal herd over time, though it is not clear what the optimum size of the seal herd should be.

It was suggested that an appropriate goal might be to control the seal population at the MSY level. Assuming a credible MSY level can be established, and given the uncertainty surrounding the total magnitude of the current harvest including the unreported catch, it is not clear at what level the TAC should be set or how long it should take to achieve the MSY level. Answering these questions will require more definitive scientific advice than is currently available.

It is evident, however, that no increase in the TAC can be implemented without ensuring that there are additional markets to absorb a greater volume of seal products without risking the markets that have already been established.

1 A young harp seal that has not begun to moult its white coat.

2 A young hooded seal that has not begun to moult its blue coat.

3 This figure is not definitive but the most probable value of estimates that fall in a range from 170,000 to 300,000.

4 Dr. Lavigne stated that his papers are subject to peer review, whereas Dr. Winters said that his papers do not undergo peer review, but are examined by another agency.

5 This is based on a Potential Biological Removal figure of 288,000 for Northwest Atlantic harp seals published in Waring et al., U.S. Atlantic Marine Mammal Stock Assessments - 1998, U.S. Department of Commerce, NOAA, NMFS, Northeast Fisheries Science Center, Woods Hole, MA.

6 Bones found in the ear of a fish.

7 Fisheries Resource Conservation Council, 1999 Conservation Requirements for Scotian Shelf and Bay of Fundy Groundfish Stocks, Redfish Stocks, Units 1-3 and 3-0, and Groundfish Stocks in Division 3Ps, Report to the Minister of Fisheries and Oceans, FRCC.98.R.6, November 1998, p. 4.

8 Maximum sustainable yield, estimated by Dr. Winters to be about 3.5 to 4 million animals.

9 R.L Haedrich, letter to the Hon. David Anderson, Minister of Fisheries and Oceans, April 12, 1999.

10 Explained in Section 30(c) of the Oceans Act as "erring on the side of caution."

11 A vulnerable species is defined by COSEWIC as a species of special concern because of characteristics that make it particularly sensitive to human activities or natural events.

12 Committee on the Status of Endangered Wildlife in Canada.

13 Canada, House of Commons, Standing Committee on Fisheries and Oceans, Minutes of Proceedings, Ottawa, April 15, 1999.