Cod, DFO, Cosewic

DFO's illegitimate 2004 "SARA consultations" of DFO & EC on "costs and benefits"of SARA Listing

*see also PARADI talk on the ethical obligations of scientists

Cod: what happened? Why?

IN A NUTSHELL
This issue seems complicated on the surface, but at the root it's simple, if not banal.
    The old saying 'a stitch in time saves nine' means "act when a problem is still small enough to be fixed". But once someone misses that first step, s/he has to be honest and say 'oops', and as long they can't say 'oops' they also can't fix the problem (because fixing it would mean admitting it was there).
The problem acquires a life of its own. It snowballs.
Like hit-and-run drivers; instead of taking a victim to hospital for a few stitches, they leave the victim to bleed to death; so when the driver is caught it's no longer just an accident, it's criminal negligence.
    Who is guilty, and when do they become guilty? First the driver. Then passengers in the car, who were innocent in the first instance, but having not reported the accident at the soonest possible time they now share the guilt for hit-and-run. Now there are more people who have something to hide. Their friends finds out and, saying nothing, also become accomplices after the fact. Friends of friends find out, and have to balance social pressure to keep quiet, against the risk of the Law finding out anyway. The problem is like a hook that keeps collecting people on it.

    The root of the problem is secrecy: the ability to keep the lid on it; that's what allowed it to snowball. Where's the ability to keep the lid on the Cod problem? • Firstly, DFO's policies that restrict information flow and prevent scientists/staffers from speaking their best wisdom. That meant credible warnings were not acted on, and Cod was fished beyond sustainability. • Secondly, COSEWIC's willingness to play along. • Thirdly, SARA gives Cabinet the ability to stack COSEWIC with people who will play ball (better chance of a soft keep-the-lid-on assessment). • Fourthly, SARA also gives Cabinet the legal tool to ignore a COSEWIC assessment (in case the problem was too big for even COSEWIC to minimise). All these deny the public's right to know. They shield management & Government from scrutiny. Democracy cannot work without accountability, and accountability is impossible without scrutiny; therefore the means of scrutiny have to be restored.

Cod management & collapse: DFO (Dept. Fisheries and Oceans)

SUMMARY:   Despite considerable good science, the fishery collapses. This was substantially an organisational failure on several levels (DFO, NAFO, democracy). Collapse is facilitated by inaction in the face of multiple credible warning signs (see graphic). That same feature of failure is recognised in other fields -- see USAF's Brigadier-General D.W. Deal's article on management lessons from the Columbia accident; a quote from K. H. Roberts is key:
    "Non-HROs [non–high-reliability organizations] reject early warning signs of quality degradation" [K.H. Roberts, quoted in: Deal, D.W. 2004. Air & Space Power Journal (Summer 2004) Vol XVIII, No. 2]
Bureaucratic structures fail to ensure that science is properly and effectively used to the public benefit -- in fact scientists are often prohibited from speaking out unless in support of official policy and its record. A spirit of wilful and unrealistic optimism at the higher levels keeps total allowable catches (TACs) high during a time when the resource was being badly overfished. A bad tradition means that catches and discards over and above the TAC are tolerated and (more importantly) ignored in calculations.
   To set the stage for long-term improvement of resource management, DFO needs (030502 to Min. Thibault) to build communications between its many bright scientists and the many bright fishermen (on some issues on which they apparently disagree, the disagreement is more apparent than real; but the critical element that unifies the perceptions was, and may still be, politically a 'hot potato' within DFO).
   That productive dialogue can't happen until scientists speak freely. At present scientists are constrained against speaking freely by the OSP (Official Spokesperson Policy, a.k.a. the Gag Rule). Dialogue between fishermen and scientists can't be replaced by dialogue between senior bureaucrats and senior fishing industry executives. To be of value to the public (which pays for them), scientists need to be able to, and to insist on their right to, speak freely. These changes would be in the public interest, and it's clear that not making these changes is absolutely counter to the public interest. [More]

Aftermath: COSEWIC, DFO, SARA and [non]Conservation

SUMMARY: DFO and Environment Canada, being the most powerful players in the supposedly scientific and apolitical COSEWIC, are in a position to influence how COSEWIC proceeds with the evaluation of the Status of Atlantic Cod. Why would they want to do that? ... designation of Cod is potentially embarrassing to the government that has managed it; therefore, avoidance of an at-risk designation is desirable for cosmetic purposes.

    COSEWIC's membership, instead of being outraged at interference (federal cabinet: Environment portfolio lobbying provincial counterparts in BC at least so that their delegates to COSEWIC will vote for deferral), plays along. Academics in the membership have 'academic freedom' and independence that should let them speak out, but, with only a few exceptions, they too are silent. Members are also silent when a senior bureaucrat lobbies against the Report in a letter to provincial supervisors of provincial delegates to COSEWIC; and also silent when Cosewic surreptitiously makes severe changes to the Report, toning it down and introducing typographical and grammatical errors that detract (though COSEWIC does issue a written apology); and also silent when COSEWIC tries to retroactively alter the Report to make it fit their 1998 designation.
   Why were they not outraged? Surely they would not say that rules don't matter. Perhaps then silence reflected a very human reaction in a difficult situation, the challenge of integrating a new fact that overturns a previous comfortable view; decompartmentalising a mind wherein one compartment has an ingrained inconsistency with another. To admit to oneself that this same committee that one has participated in and which one claims is scientific is actually substantially politically controlled is potentially traumatic; to admit that it does not follow its own rules is similarly traumatic. In such a situation, human psychology evidently over-rides logic and science.
    Result: DFO avoids the embarrassment of an "endangered" listing and has 5 more years' grace. During that 5 years Cabinet comes up with the Species-at-Risk-Act (SARA) which formalises and tightens the political grip on COSEWIC and the listing process.
    Result: Cod lose 5 years of chances for conservation that the proper listing might have helped it get.
    Result: COSEWIC demonstrates that its listing process can be dominated by politics, and science can be swept aside. If this could happen with such a high-profile species as Cod, with everybody watching, surely it must be routine for lower-profile species with few watching. [More]

SARA, the Species-At-Risk-Act:
whistling a green tune but doing nothing

Your dentist says "you need a root canal ...but hey! ... let's pretend it isn't so!"
Your accountant says "you only have $3 left ...but hey! ... let's pretend it isn't so!"
If life were like that, facts wouldn't matter.

SUMMARY: This legislation is kited as protecting endangered species, but in fact it enables the opposite. How? It gives politicians the means to avoid acknowledging a problem, to avoid taking any action that could be politically inconvenient. It gives them a legal tool to write off species by denying acknowledgement of their status on the SARA List. They have already done this. Don't forget that the collapse of the Cod stocks is one of the greatest natural resource bungles of our time, so obviously a Listing will focus attention on that. SARA is a toolbox of masks and crowbars, and is the obvious tactic of the same bureaucracy in DFO that resisted good advice in the 1980s; who blamed seals, the climate, and anything but their own intransigence in the 1990s; and who fought tooth and nail all along to avert a Listing of Cod. [See also: 2004 "consultations".] If only the energy of denial had gone into looking after the resource in the first place. [More]

... this page set is supplementary to this entry in my publications list:

REPORTS

Bell, K. N. I. 1998. Status of Atlantic Cod, Gadus morhua, in Canada: report commissioned by COSEWIC*. ≈100 pp.+8 figs., 137 refs. (Initially supported by WWF; 3 independent peer-reviewers** and numerous bureaucratic reviewers***. Accepted by COSEWIC 1998; resulted in first Canadian at-risk designation of a commercial marine fish.) (*Cosewic = [Federal] C'ttee on Status of Endangered Wildlife in Canada)
Click for HTML of version as sent to COSEWIC 980204: REPORT98 (text), Figures.
**See also: Reviews by eminent scientists. ***See Addendum in REPORT98 (text).