August 31, 2009,
1217 Rose Ann Drive,
Nanaimo, B.C., V9T 3Z4
The Hon. Gail Shea,
Minister, Fisheries and Oceans,
Dear Ms. Shea,
Re: DFO’s poor record for wild salmon protection as opposed to un-restrained support for salmon farming in B.C.
This is the perspective of two of us who have a combined experience of over 85 years in biology and oceanography – most of this time with DFO. We mention this experience because we believe that it qualifies us, quite well, to comment. We are not alone in the views we hold about the following:
A) DFO – Abandoned Mandate
Historically, we recall times when DFO stood out clearly on environmental issues. These included effective input in hearings on marine oil exploration, research and management initiatives on estuarine fish habitat, research and results application in connection with coastal logging, and strong involvement in the Site C dam proposal.
As opposed to this, DFO’s performance during the past 25 years or so, is lamentable. Considering Pacific salmon protection the following record is particularly disappointing:
1) ‘Rolling over and playing dead’ in connection with the Alcan and Nechako situation,
2) Sitting quietly by while fish-bearing streams are pre-empted for private power development in run-of-the-river projects,
3) Condoning massive gravel removal in salmon habitat in the lower Fraser River, and
4) Playing hand-maiden to the aquaculture industry.
In regard to aquaculture in coastal B.C., we are deeply concerned about the policy direction and the inadequacy of federal government science. We are concerned not only because the high profile conflict in the Broughton Archipelago area is unresolved, but because the industry apparently wishes to expand beyond where it now extensively operates.
Many knowledgeable people in universities and the public have written extensively about this issue. However, after having seen pictures of DFO’s aquaculture booth at a trade show in Norway, and after hearing your comments to Damien Gillis, we feel obliged to try to help those who would protect wild salmon. We may not understand what has caused the near collapse of the Fraser River sockeye salmon run this year. However, the specter of you at a aquaculture trade show booth in Norway while the Fraser River sockeye run ‘melts down’, has symbolism of DFO’s priority and policy that troubles us.
B) Policy Direction
The behavior of Fisheries and Oceans, Canada, (DFO) is at odds with the department’s own precautionary principle. The department behaves more like an aquaculture promotion organization than a responsibly involved fisheries research and management agency.
Several years ago the Government of Canada established the “precautionary principle” in: A Framework for the Application of Precaution in Science-based Decision Making About Risk. (Date modified: 2003-07-25). In the case of the salmon aquaculture business, this policy seems to be ‘far back in the shadows’.
In the salmon net-pen farming industry, particularly in areas such as the Broughton Archipelago, risks and impacts have been documented by research workers outside of DFO. In this situation they show that a “credible case that a risk of serious or irreversible harm exists” . We have copies of six refereed publications that support such concern. Notwithstanding the precautionary policy aspect and independent, published/refereed research that indicates risk, DFO supports expansion of the industry. Your department is failing in its mandate in three ways:
1) It does not meet the requirements of its own ‘precautionary principle’
2) It straddles two objectives:
a) Managing and protecting wild salmon and,
b) Supporting aquaculture. By the way they are being met, these objectives are in conflict.
3) While being quick to criticize outside research, DFO’s own research provides a weak and fragmentary foundation for management of aquaculture in B.C. (See “Sustainable Aquaculture Research in BC: DFO Publications Related to Fish health and Salmon Aquaculture) .
This failure is even more worrisome given that the aquaculture industry is demanding that it be allowed to move further north along the B.C. coast. If it is not allowed to ‘go north’ then it calls for permission to ‘grow bigger’ where it is. Who calls the tune here?
C) Inadequacy of DFO Science
The DFO has not carried out adequate research to permit a scientifically legitimate management role in the salmon farming industry (see “Sustainable Aquaculture Research….. Publications … 2003 -2007).” above) This list may not be up to date, however, it covers the time period in, or before which, research, relevant to aquaculture impacts and policy formulation, should have been carried out.
The list of publications includes very few papers that bear directly on the impacts, or potential impacts, of Atlantic salmon net-pens culture on juvenile pink salmon in critical areas such as the Broughton Archipelago. Of 53 titles listed, only five appear to be directly, or partly, relevant to impacts on juvenile pink salmon in the Broughton Archipelago. We are aware that there is more government and non-government research, being planned or carried out now. This is desirable. However, it is unfortunate that this increased effort was not made before the industry expansion was allowed to occur. With the history of land use conflicts that lies behind us, it is most unfortunate that we still ‘turn business loose’, and then after the fact, try to understand impacts and clean up the problems.
If the Government of Canada, through DFO, continues to require a better assessment of connection between salmon farms impacts and wild salmon population responses in areas such as the Broughton Archipelago, they must engage in ecosystem-scale research that meets or exceeds the standards that they require of others, and that:
1) Extends over a period of time that would permit analysis of the environmental variables that are considered to confound the effects of sea lice,
2) Is enough in control of the experimental situation to permit operation and closure of net pens to provide sound experimental design, and
3) That has funding and people that are independent of political or corporate control.
D) Wild Salmon – Gift of Nature
Salmon culture may now out-produce wild fish catches if simply measured in tons. However, these ‘tons’ come with a spectrum of environmental costs. Furthermore there are important elements beyond such ‘tonnage counting’ in the salmon farming debate.
Culture of farmed fish requires energy, fish food originating in other parts of the world, and it takes space that is useful for other sectors of society. Salmon farms in some locations produce layers of rotting waste below them. We know someone very well who has worked in the salmon farming business – this individual has seen this first hand. Most of the public has not seen it. If the jobs that salmon farming creates are, in the end, offset by loss of jobs involving wild salmon fisheries, their value may be a bitter illusion.
Production of wild salmon does not require all of the ‘front end’ costs associated with food production, energy consumption, freshwater diversion, … etc; that occur in salmon farming. It does, however, require two things: first that we protect their environments, and second that we have the good sense to avoid over-exploiting them. There is an additional benefit to doing these things. The efforts that we make to sustain wild salmon and their habitats also help to support an array of other wildlife. This, plus the environment itself, constitute a positive legacy, beyond the fish, for future generations. Bays full of net-pen farms with material rotting on the sea floor and “Keep Out” signs do not provide such a legacy.
It is clear that wild salmon face a daunting array of man-made environmental challenges, including: other land uses, climate change, forest loss, water abstraction, and ocean condition changes that we do not understand well. This given, your government should protect them as well as possible for as long as possible. This can be done. However, it requires a more sincere concern for wild fish than is evident to date on the part of DFO. In the long term, it requires a vision on the part of elected people and senior bureaucrats that goes beyond winning 2-4 year electoral popularity contests and serving the apparently biggest “business” on the block.
In a long term ecological context, both society and governments must soon come to the realization that human populations and activities must come into some environmentally sensible balance with the limited space and resources of the land. Humanity will not get to this state of realization and behavior with growth-driven business as its moral and intellectual flagship.
The salmon farming industry and how it is managed is an important part of our future. In this regard, the public is justified in expecting better than has been given. If nothing else, we would ask that your department carry out research that is independent, and that it begin to honor, fully, its responsibility for wild salmon protection in a manner that is above politics and short-term gain.
G. Hartman Ph.D.
C. McAllister Ph.D.
cc Prime Minister S. Harper
NDP Leader J. Leighton
Liberal Leader M. Ignatieff