August 31, 2009,
1217 Rose Ann Drive,
Nanaimo,
B.C., V9T 3Z4
The
Hon. Gail Shea,
Minister,
Fisheries and Oceans,
Parliament
Buildings,
Ottawa,
Canada.
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.
Sincerely
yours,
G.
Hartman Ph.D.
C.
McAllister Ph.D.
cc
Prime Minister S. Harper
NDP Leader J.
Leighton
Liberal Leader
M. Ignatieff
Rafe Mair
Alexandra
Morton
Paul Sprout
