alexandra morton

Dear Premier your Environment Minister is under investigation.

Dear Premier David Eby,

I am writing to inform you that your Minister of Environment and Climate Change, George Heyman and his ministry are under investigation for refusing to screen farm salmon blood for the virus PRV before it is being released by the Brown’s Bay Processing Company into the Fraser River salmon migration route in the Discovery Islands.

On June 18, 2024, the BC Ombudsperson office informed the provincial Minister of Environment George Heyman that his ministry is under investigation for refusing to test for and control the virus PRV flowing from a farm salmon processing plant.

Seven years ago I informed Minster Heyman that this blood water was infected with the foreign salmon virus PRV. First Nation leadership from the Fraser River and the public demand that the Browns Bay farm salmon processing stop releasing this virus into the ocean . Heyman promised to do so. However, an October 2023 Warning Letter to the plant by Heyman’s compliance staff reports:

“the Director did not require Brown’s Bay to test for pathogens in the effluent or take action to minimize discharge of pathogens” (Warning Letter, Oct 2023, page 9). 

WHAT!!! So, it was all a lie that your government was taking care of this?  The federal government removed ALL SALMON FARMS from the Discovery Islands and your government is allowing free flow of infected blood into the same area? For what possible reason are you being so careless?

In fact, records show the Ministry of Environment increased the bloodwater discharge rate in 2019. Then in 2023 DFO reported that young salmon placed exposed to this blood water become infected with the virus.  And still nothing was done. In fact, Heyman tried to convince me and First Nations that the effluent looks cleaner, as if viruses are visible - while never requiring the plant to even test for the virus. 

Independent scientists trace PRV genetic sequence to the North Atlantic (Science Daily) arriving at the same time as Atlantic salmon farms were established on this coast.  On May 15, 2024, Namgis First Nation announced they intend to reopen their lawsuit to stop DFO from allowing PRV-infected farm salmon into fish farms.  PRV infects most farm salmon in BC, and research shows it causes the red blood cells of Pacific salmon to rupture en masse leading to organ failure.

Unfortunately, the Ombudsperson can only make recommendations.  You can still choose to do nothing.  Clearly I have misjudged your capacity to understand the importance of wild salmon to this coast.  Now there is an investigation.  DFO science are also under investigation for disregarding the science on the impact of this virus on wild salmon.  In my view taxpayer dollars are being wasted, as scientists from leading universities and the Pacific Salmon Foundation have shown that this virus is more dangerous to Pacific salmon than to Atlantic salmon, because it was imported.  That should have been warning enough got Minister Heyman to instruct Browns Bay Packing Company to pump their waste into a tank and dispose of it properly.  

In my view it is unconscionable to allow a foreign virus to flow into the Pacific.

Alexandra Morton

 

Will Trudeau Walk the Talk... or not?

Dear Minister Jonathan Wilkinson,

I am writing to you as you are BC’s senior federal cabinet member.  In a matter of weeks your government will receive a DFO memo on what to do about salmon farms.  Prime Minister Trudeau said they needed to get out of BC waters by 2025, clearly the industry doesn’t want to go, DFO staff are dangling the possibility they will be allowed to stay another 6 years, these Norwegian-based companies keep suing their host country and so Canadians are unsure who is in charge: the prime minister, DFO bureaucrats or the industry?  On July 1 we will have our answer.

Prime Minister Trudeau made his decision on this matter in 2019 when he instructed his Minister of Fisheries in his mandate letter to transition salmon farms out of the ocean by 2025. 

Since then, approximately half the salmon farms in BC have been closed, most by First Nations (see blow).  The industry has shipped its large well boats, Viktoria Viking and Roy Kristian back to the Atlantic, as well as smaller aquaculture industry tenders.  Where the farms have been removed remarkable wild salmon rebounds are being observed. This year will be the first farm-free Fraser River sockeye and 4-year chum salmon that were not exposed to salmon farm pathogens in the Discovery Islands when they went to sea as juveniles.

July 1, 2024, all federal BC salmon farm licences will expire. New licences must be issued before then to every farm still in existence.  To align with the Prime Minister’s mandate, these new licences should provide instruction on decommissioning i.e. what level of sea floor cleanup is required, whether fish already in the farms are permitted to grow to harvest size, etc., similar to the instructions provided to Mowi and Cermaq by First Nations in the Broughton Archipelago before they removed 17 salmon farms.

Inexplicably, DFO Aquaculture staff are moving in the opposite direction as if the mandate letter to their minister is of no consequence - openly suggesting that salmon farm licences might be renewed for six years. Intended or not, these public musings dangerously mislead the aquaculture industry with serious consequence to your cabinet.

For example, over the past 4 years DFO Aquaculture staff have repeatedly invited salmon farming companies to pay for licences in the Discovery Islands before the minister repeatedly announced these licences would not be reissued.  Predictably, industry lawyers used this in defeating the Minister of Fisheries in court.  The industry paid for licences, they argued, thus creating the expectation they would receive them, and the judge seemed to agree.  I have asked DFO staff to please refrain from doing this again, but in a sense they already have.  By publicly signalling 6-year licences might be issued, as if the prime minister didn’t matter, the industry might sink costs into filling their hatcheries with eggs, rearing fry and vaccinating juveniles in anticipation of stocking marine farms six years into the future.  As the lawyers told the court - when bureaucrats create false expectations, industry invests money and your government loses in court.

Before this power struggle between DFO Aquaculture staff and the Prime Minister lands on your desk I would like to offer two considerations:

1. The stigma of your government’s reliance on science recently flagged as potentially fraudulent accompanies this decision. The entire premise of granting salmon farm licences is based on a standard of “minimal harm” to wild salmon.  A year ago, senior Canadian scientists warned that DFO science that the minister was relying on to ensure minimal harm appears to have selectively omitted data and tampered with conclusions to suggest sea lice from salmon farms are not harming young wild salmon. Internal documents attached to their letter clearly show the edits that reversed the report's original conclusion, even providing the initials of the author of these edits. This conduct lands squarely within the definition of scientific fraud.  The scientists who wrote this have published extensively on exactly this, they are tenured professors, senior editors of scientific journals, expert witnesses and work with many First Nations, but somehow the Minister of Fisheries has not seen fit to even answer them.  Their request to reanalyze the data to confirm minimal harm to wild salmon has effectively been denied.  Beyond violating the basic principle of science that any result must be reproducible, hiding evidence is not a good look for any government when the stakes are this high.

2. British Columbians are watching this closely. Can we trust our prime minister or not?  When Trudeau issues a mandate does this mean he will walk the talk? Will salmon farms be moved out of BC waters in 2025 or not?  Was his mandate letter just a political chess move he had no intention of honouring?  Or did he actually intend to follow through, but now is willing to sacrifice wild salmon because he is afraid of three Norwegian – based companies Mowi, Cermaq and Grieg?  We will have our answer by July 1, 2024 when BC salmon farm licences are reissued.  Will the new conditions of licence inform the industry on the steps required to decommission their farms? Or will the licence override Prime Minister Trudeau and provide this industry opportunity to reap profits at the expense of the public resource and beloved wild salmon?

Minister Wilkinson, you are a man of science and politics, a rare and important blend in the maelstrom of today’s world.  Globally, we have become acutely aware that our very survival depends on governments bringing industrial activity into compliance with what our planet can bear.  Your government made the decision to remove salmon farms.  Fraser River and Coastal First Nations and the Union of BC Indian chiefs successfully petitioned the court and supported the Minister of Fisheries in keeping 17 salmon farms in the Discovery Islands on the Fraser River salmon migration route closed.  When has that kind of support ever been offered to a federal government before?  

Fraudulent or not, DFO science is no longer a factor because the Prime Minister of Canada made the decision to move salmon farms out of the Pacific Ocean, similar to the U.S.  The previous Fisheries Minister was apparently working on this transition plan just before she was sacked.  Now your government has allowed uncertainty to persist right up to the deadline causing chaos for those employed by the industry and playing into the hands of this litigious industry.

Very soon it will be your turn to decide whether to honour the Prime Minister’s mandate, or go back on his promise and cave to the salmon farming industry.  Is this just a gamble?  Which is the least damaging to the Liberal Government - upsetting the Norwegian salmon farming industry, or betraying the Prime Minister’s promise to Canadians?  

 

Please confirm that you have read this and let me know if you require further information.  

Thank you and all the best,

Thank you,

Alexandra Morton

[email protected]

 

• 17 farms closed by three First Nations in the Broughton Archipelago
• 8 farms closed by Shíshálh First Nation
• 3 farms closed by Gwawa’enuxw First Nation
• 1 farm closed by Kwiakah First Nation
• 1 farm closed by Homalco First Nation
• 17 farms closed by Minister of Fisheries (salmon farmers only sued in response to these closures)

 

Minimal harm vs research fraud

February 5, 2024

Dear Minister Diane Lebouthillier,

J'espère que votre année commence bien et en bonne santé. Nous vivons certainement une période tumultueuse et j’apprécie les personnes comme vous qui ont le courage de s’engager dans un leadership en ce moment de l’histoire de l’humanité.

As I understand it, all federal salmon farm licences in BC will expire by July 1, 2024 and your department is currently modifying the conditions of the licences you will issue to marine salmon farms before then.  This is a bit confusing as Prime Minister Trudeau’s 2019 Mandate Letter, reaffirmed in 2021, included transition away from open net salmon farms by 2025 just 6 months after the licences expire.  Hopefully the new licences will provide certainty and instruction on closure of the last of the open net salmon farms in BC?   

As you prepare for this important decision, there is an issue that should probably be resolved so as to allow public confidence in your decision.

The entire premise of Canada granting salmon farms a licence to operate is based on a standard to ensure only minimal harm to wild salmon.  To carry out this policy of minimal harm Canada tasked the Canadian Science Advisory Secretariat (CSAS) to assess the level of harm caused by sea lice from salmon farms. The resulting Sea Lice CSAS concluded that salmon farms are not a significant risk to wild salmon[1].  This was surprising.  Scientists outside DFO widely report the opposite and so naturally these results elicited scrutiny.  

I reviewed internal DFO Science communications to understand how Canada’s Science Advisory Secretariat could reach this conclusion.  I found documents revealing that DFO scientists did link salmon farms to sea lice risk, but this conclusion was altered to suggest the opposite before it was included in the Sea Lice CSAS and before it reached your office.  If true, this is an act of falsification which is defined as research misconduct[2] and research fraud[3].  This is a global problem faced by regulators[4] around the world.  The definition of research fraud and misconduct includes:

• …. omitting data so that the research isn’t accurately represented in the record¹.
• Any type of research fraud usually involves publishing conclusions, or even data, that were either made up or changed.[5] 

No one wants this to be true, but the evidence is compelling. 16 senior scientists advised the Minister one year ago that there are serious problems with the Sea Lice CSAS report. On page 19 of their letter, we see how the results of the DFO sea lice study were altered internally.

If true, this activity lands squarely within the definition of research fraud - conclusions that were changed. Furthermore, these scientists warn: “statistically significant results were omitted” and that fits the definition of research misconduct.  To resolve whether the Sea Lice CSAS can be relied on to achieve Canada’s goal of minimum harm to wild salmon, the scientists requested access to the data used to produce the CSAS so that it could be reanalysed.  Open access data is a standard of science. It is accepted that scientific results that cannot be replicated are not trustworthy.   Your office has strongly adhered to this principle in other science disputes.

The test for misconduct and fraud hinges on whether reinserting the omitted data reverses the conclusion of the Sea Lice CSAS.  Specific to your June decision - would you, could you reissue licences to open net salmon farms if your science advisory secretariat concluded that farm lice are a significant risk of harm to young wild salmon?  This critical measure of harm is embedded in the data used by the Sea Lice CSAS.

Inexplicably, the scientists’ request was met with silence from the previous minister.

What began as omission of significant data and the appearance of government tampering with scientific results, has escalated to blocking resolution of this serious matter by the office of the minister.  How is the possible?  I am bringing this to your attention 5 months ahead of your decision how to renew salmon farm licences in BC providing enough time for reanalysis of the Sea Lice CSAS data by the 16 scientists who brought this to the attention of your office.   You will see in their letter they are leaders in Canadian fisheries science, from our top universities, serving on the editorial boards of international and Canadian scientific journals and working with First Nation governments.  They have published decades of research into impact of industrial aquaculture lice on wild salmon.  I don’t see how you can make your decision without knowing the result of reinstating the omitted data.

Wild salmon are elemental to the ongoing production of clean air, water and food by BC ecosystems and so Canada’s judgement on which risks these fish must endure has far-reaching consequences.

You will know better than me how this should be resolved.

Thank you for considering this matter.

Alexandra Morton

[1] “No statistically significant association was observed between infestation pressure attributable to Atlantic Salmon farms and the probability of L. salmonis infestations on wild juvenile Chum and Pink salmon in Clayoquot Sound, Quatsino Sound, Discovery Islands, and Broughton Archipelago” page 23, 4^th paragraph

[2] https://ori.hhs.gov/definition-research-misconduct

[3] https://scientific-publishing.webshop.elsevier.com/manuscript-review/research-fraud-falsification-and-fabrication-research-data/

[4] https://theconversation.com/scientific-fraud-is-rising-and-automated-systems-wont-stop-it-we-need-research-detectives-206235

[5] https://scientific-publishing.webshop.elsevier.com/manuscript-review/research-fraud-falsification-and-fabrication-research-data/

Dear Minister you cannot un-know the disease findings by First Nations

Dear Minister Diane Lebouthillier,

Thank you for your willingness to travel to BC and meet with myself and many others.  Not an easy trip in winter.  I greatly regret not being able to take you up on your offer to meet, it seems my grandchildren passed me a cold.

My exposure to salmon farms began in 1989 when, as a resident of the Broughton Archipelago, the first salmon farms moved into the area where I was doing research on whales. I thought the industry was a good idea - take pressure off wild salmon while providing jobs. I took a job on a farm.  But as a scientist living in the area, I saw the biological evidence of impact.  I have now spent 35 years publishing on this impact and more recently on the impact of removing salmon farms.  I would like to offer three considerations.

Biological

When Chief Rick Johnson, Ḵwiḵwa̱sut'inux̱w Ha̱xwa'mis First Nation, submitted his application to intervene in support of the Minister of Fisheries closing salmon farms on the Fraser River migration route, he attached collaborative scientific results from his Nation, two other nations, DFO and the Pacific Salmon Foundation.

The number of pathogens tested for, the number of samples, the multi-year study duration, the number of farms and the tests showing the escape of these pathogens into the waters of his territory is unprecedented - globally.  Previously, even DFO was not permitted this level of access to farm salmon. The work reveals viruses, some identified as Atlantic salmon specific, can are replicating in the marine feedlot-type environment at levels known to trigger novel, virulent mutations. Dangerously amplified levels of endemic bacteria that have been over-exposed to antibiotics are also being released. According to DFO and Canadian university research, these industrial aquaculture pathogens are wafting out of the pens, passing over the gills of wild fish as they breathe, entering their bloodstream and triggering an immune system response - disease. 

To put this in context, what the poultry industry is doing to contain avian flu is impossible in marine salmon farms. There is no barn door to close, no walls or even a floor.  One might be tempted to ignore Chief Johnson’s affidavit as unpublished.  However, this is DFO science.   Even as Mowi and Cermaq, I am sure, did their best to prevent release of pathogens as they face further closures by other First Nations, the First Nations doing this work are now keenly aware of the industry’s capacity, or not, to achieve this.  Legal implications of enormous magnitude are suddenly presenting as salmon farm pathogens are essentially “fingerprinted” and now followed through the marine environment by leading Canadian Universities.

Private Fishery?

 As you prepare to decide which fishery to protect, I offer the following. In 1984, Canada commissioned the legal opinion of Bruce Wildsmith.  He told Canada that federal regulation of salmon farms did not appear to be supported by Canadian legislation.  The issues he identified were left unresolved when the federal government responded by transferring salmon aquaculture regulation to the provinces where they were dubbed “farms”.  However, Morton vs Canada 2009, determined that salmon farmers require a fishing licence to recapture escaped farm salmon, unlike the farmer who does not need a hunting licence to fetch stray cattle.  The cattle belong to the farmer, not so the fish in the pens.  

Salmon are a federally regulated fish and salmon “farms” exist in federal jurisdiction (the ocean) and so it was established that salmon farms are a “fishery” albeit a private fishery, (as the companies do not allow anyone else to fish in their pens). Morton vs Canada 2009 handed salmon farm regulation back to the federal government, but only in British Columbia, even though federal laws should apply coast-to-coast and private fisheries are not supported by the Fisheries Act. 

The legal grey area in which salmon farms exist can be seen on the boats transporting salmon to and from the farms.  Every commercial vessel packing fish in BC must openly display a licence number on the wheelhouse, except vessels transporting salmon for Cermaq, Mowi, Grieg and Creative Salmon.  Why?  Are farm salmon packers unlicenced because DFO does not have the regulatory power to issue private fishery licences?  Your office has remained silent on this question for several decades.

Impact of Salmon Farm Closures on Communities?

 Seventeen salmon farms were closed in the Broughton Archipelago. Have you spoken the chiefs, mayors, Area Representative for Alert Bay, Port McNeill and Sointula, the communities closest to these farms, to ask for evidence that these closures have impacted the economies of these small coastal communities?  Employees at the Mowi processing plant in Port Hardy would be affected by further closure of Mowi farms, but has anyone briefed you on the potential of that plant processing the recently exploding pink salmon returns to the area, the shrimp locally fished or other species?  Is this plant unable to pivot similar to what the Walcan Plant accomplished when the industry withdrew their contract?  I believe only minimal processing is done at this plant, could it be upgraded to value-added processing when the transition to wild fisheries is made?

The salmon farming industry  depends on a long supply chain with many weak links, including “acute shortage” of wild fishmeal and oil, foreign grain production threatened by rapid global warming and it attempts to replace carbon-neutral migrations of wild fish with high carbon producing transport of feed, smolts, and product.

In closing, I would like to suggest that you speak at length with the three First Nations who initiated salmon farm closures in the Broughton.  They have done the research required to evaluate and validate the Minister's decision in the Discovery Islands, they closed the farms without being sued, their communities have absorbed the loss of jobs successfully and they are ground-truthing what happens when salmon farms are closed for the first time in the history of salmon farming.

This summer will be the 1st return of Fraser River sockeye salmon that were not exposed to salmon farms in the Discovery Islands when they went to sea as juveniles. 

Merci encore pour l'opportunité de communiquer avec vous.

Meilleurs vœux à vous et à votre famille pour la nouvelle année.

Alexandra Morton

Broughton Archipelago - now farm salmon-free north of Knights Inlet

The Fish Are Talking - Thank you Trudeau and Ministers

Open Letter to Prime Minister Trudeau and Fisheries Ministers past and present:

August 14, 2023

Dear Prime Minister Trudeau, Joyce Murray, Bernadette Jordan and Minister of Fisheries Diane Lebouthillier,

I am writing to thank you for your roles in what is rapidly becoming one of the most remarkable environmental successes we have seen in this country. The pink salmon returning to southern BC are not only making a comeback, they are making history.  In the last few days, the Pacific Salmon Commission has reported the largest number of pink salmon ever caught in DFO test sets along northeastern Vancouver Island.  The increase over the last three generations is jaw-dropping!

This is not entirely a mystery. This generation of pink salmon was protected from exposure to salmon farms by the Prime Minister’s mandate to remove salmon farms from the BC coast, and by then Minister Bernadette Jordan’s 2020 prohibition on restocking farms in the Discovery Islands. When Joyce Murray took over the portfolio, she maintained the prohibition. And so these pink salmon that are returning in historic numbers went to sea as juveniles in 2022 when all the salmon farms in the Discovery Islands had been closed by the federal Liberal government.

 In my recent paper with Dr. Rick Routledge, Effect of government removal of salmon farms on sea lice infestation of juvenile wild salmon in the Discovery Islands (in press), I examined this generation of pink salmon as they swam through the region. They looked healthier than they have since I began studying them in 2005. Sea lice infestation on this generation was 96% lower than in 2020 when eight salmon farms were operating in the Discovery Islands.

This astonishing pink salmon rebound after salmon farm removal is not a one-off event. 

In 2003, following a profound pink salmon crash, the Province of BC enacted the Broughton Archipelago Action Plan wherein adult farm salmon were prohibited on the Broughton pink salmon migration route for one year.  That generation of pink salmon survival surged to 34%[1]!  Typical pink salmon survival is 2-5%. 

In 2022, the pink salmon returning to the Ahta River increased 10-fold in a single generation after the salmon farms near that river had been removed by the Broughton Archipelago Transition Initiative.

Also of note, the 2023 Fraser River sockeye test fishery is showing a remarkable increase in over the previous 3 generations.  These sockeye passed through the Discovery Islands as juveniles in 2021, when all the salmon farms in along the narrow channels had been removed.  DFO has increased their preseason estimate of the Early Stuart sockeye return by 50%! This population had to navigate the devastating Big Bar slide and yet their offspring are showing an uptick in survival!

I understand there will be claims all of this is a coincidence, unrelated to your efforts to remove salmon farms.  However, it would be wrong to ignore the repeated strength of the growing evidence that removing salmon farms increases wild salmon – first by the Province of BC, then the Broughton First Nations, and now your government which removed salmon farms from the Fraser River salmon migration route. It will be important for you to review returns for Quatsino, Gold River, the Central Coast, Port Hardy and Clayoquot Sound to determine if those heavily-farmed regions have enjoyed the same remarkable rebound.

Thank you to each of you for your role in allowing this generous fish to reach the open ocean - the fish who feed the trees that are drawing the dangerous levels of carbon out of the atmosphere. This is shaping up to become the greatest environmental success of any Canadian government. 

With gratitude,

Alexandra Morton

[1] Beamish et al 2006

Removing Salmon Farms Saves Wild Salmon

A short video with the crew I work with to monitor the health of young wild salmon in the Discovery Islands since 2005

 

 

Is this Research Fraud?

Dear Dr. Simon Jones,

I write to you again regarding scientific conclusions that you provided on impact of the salmon farming industry that do not appear to be supported by your own research. 

While you continue to refuse to answer my letters, they provide a public record of DFO Aquaculture’s suppression of scientific evidence of the risk from salmon farms to wild salmon, should an audit occur.  Today, the salmon farming industry is aggressively pursuing the Minister of Fisheries for not relying on what appears to be manipulated science, some of it yours, and this is a serious threat to wild salmon.  

Below is the evidence that you misrepresented findings by your lab on the threat of sea lice released by the industry’s hydrogen peroxide de-licing treatments.  Your conclusions were used by the salmon farming companies to satisfy their Condition of Licence 6.13.  Five months later, DFO staff reviewed ATIP material I requested that included internal comms on this research, appear to have recognized your conclusions were misstated, and wrote media lines correcting your work in case media got wind of this. 

The evidence

The 2020 condition of licence s.6.13 required the companies to conduct research into whether hydrogen peroxide treatments used to dislodge sea lice from farm salmon was releasing sea lice into the ocean that were capable of infecting wild salmon.  You entered ACRDP agreement 21-P-01 with Cermaq, Grieg and the BC Salmon Farmers Association to complete this study. 

On May 31, 2022, the day before the study was due, Cermaq sent an email to DFO veterinarian Dr. Laura Sitter titled “Smon Jones ACRDP Presentation to AMD Staff” stating, “Here is the Cermaq summary for the ACRDP project conducted by Simon Jones.”  Attached was PDF “2022-05-30 Condition 6.13”.

This PDF states: “The conclusions from the above studies showed that laboratory treatment with 500 and 1500 ppm H₂0₂ caused: …. Significant reduction in infectivity of adult female L. salmonis [salmon lice].” This suggests that the lice released after hydrogen peroxide (H₂0₂) treatments would not infect young wild salmon and so were not a threat.

However, the data provided to you by your staff Eliah Kim on April 1, 2022, does not support this conclusion.  In some trials it was the opposite – there were more treated than untreated lice infecting young salmon.  

Despite this, Mowi and Cermaq used the conclusions you provided, that H₂0₂ treatments significantly reduced sea lice capacity to reattach to salmon.  This matters to wild salmon because these treatments may dislodge millions of sea lice into the ocean.

Then in October 2022, DFO Communications was reviewing an ATIP containing the ACRDP 21-P-01 results that was about to be released to me.  They sought a second opinion on your conclusions.  DFO epidemiologist, Dr. Derek Price described the results of your work as “inconclusive” not “significant”:

“The hydrogen peroxide exposure studies were conducted through an ACRDP partnership between DFO Science (Simon Jones) and the BC Salmon Farmer's Association. The results of these studies agree with existing scientific literature that sea lice are immobilized for several hours after treatment with hydrogen peroxide. The studies also suggested reattachment is unlikely, but the results were inconclusive...”

This means Dr. Price does not agree with your interpretation of your data and it means that when millions of farm lice are broadcast from treatment vessels into wild salmon habitat DFO doesn’t know what will happen.

The difference between “significant” and “inconclusive” looms large for the salmon farming companies using BC waters. DFO veterinarian Dr Laura Sitter looked at the study and recommended “…filtration should be considered as a mitigation on vessels performing hydrogen peroxide treatments…” (Nov 14, 2022)

However, filtration of H₂0₂ effluent is problematic for the industry. The window of time between removing the lice and killing the farm salmon is slim.  If the tanks are not purged immediately at the end of a treatment, the farm salmon may be burned alive.  Filtration slows purging, lowering risk for wild salmon, but elevating risk for the farm salmon.   

Your interpretation of your results could lull managers into thinking further filtration is unnecessary.  Good for the salmon farmers, risky for wild salmon.

These internal communications suggest that senior DFO management staff in the Pacific Region know that ACRDP 21-P-01 contains overstated, inaccurate conclusions and that the hydrogen peroxide lice treatment effluent does pose a threat to young wild salmon.  Whether they did anything about it is unknown.

I recommend that your research reported via ACRDP 21-P-01 as submitted by Mowi and Cermaq to DFO in compliance with their 2020 Licence be evaluated using the international principles of research fraud. It is a simple checklist.  Were results suppressed that altered the conclusion, benefitted the salmon farming industry and put wild salmon are risk?  Here is a link to the documents I have described.  Please note this document contains an email from Jay Parsons that includes his recommendation that DFO not release internal communications about development of your CSAS sea lice science.  However, it was released to me and 16 independent scientists who objected to your conclusions where you ignored some results which happened to benefit the salmon farming industry.  

I have copied First Nation leaders who are receiving information from you on the impact of farm lice on the wild salmon that they are responsible for as they pass through their territory.  If they want wild salmon to survive, I believe an audit of the information you are providing to them is essential to their achieving their goals.

Respectfully,

 

Alexandra Morton

Recent Evidence DFO science fraud

May 5, 2023

Dear Minister Joyce Murray;

Every measure that protects life in the ocean is so critical.

I have copied you and your staff on my emails to DFO regulators and scientists, but with all you must deal with I am not sure the overarching pattern is clear.  The evidence of out-of-control regulatory capture is inescapable.  As well, there is an urgent need to apply the international definition of “research fraud” to the record that exists within some DFO science groups.  The department must reconcile why DFO labs are reporting opposite conclusions.  The salmon farming industry cannot be both low and high risk to wild salmon.  This dichotomy has put you at legal risk and has destroyed public confidence.

Regulatory capture. I hope you will consider the sequence of events below, just one of many incidents, that suggests some DFO staff are so responsive to the needs of the salmon farming industry, that regulations are being manipulated in a way that defeats the intent to protect wild fish.

For the past 16 weeks senior DFO management has refused to answer a simple question.  Which licence was used to determine Cermaq would not be charged for a breach of licence (reported by DFO staff) just prior to awarding that farm a near 50% production increase?  Was the licence in effect at the time of the breach upheld?  Or was it the licence issued 3 months later, edited to provide relief from the specific condition that had been breached?  

Initially, I was told the answer would be forthcoming.  When it was not, and I contacted the senior staff who had reported the Bawden farm was in compliance, I was instructed to solely address my question to the Director of Aquaculture.  Months of silence later, I was told to solely direct my question to the Regional Director General. After 30 more days of silence, she informed me that my communications might be ignored because an unspecified email from me, on an unspecified date had not met DFO values.  My request for the email she was referring to has been met with ongoing silence.  Now I understand the RDG is on vacation until retirement and the question remains unanswered. 

The Director of Aquaculture, Brenda McCorquodale and RDG, Rebecca Reid do not want to answer how was a salmon farm owned by the Mitsubishi Corporation was not charged for violating the laws of its host country and then granted an increase in production which the company had been urgently requesting. 

As they attempt to avoid one question, they have raised a larger one - has the right of Canadians to know what their government is doing been forfeited at the whim of a bureaucrat?  While my emails are considered a breach of DFO values, a DFO scientist is reporting her staff are suffering “character assassination” from within DFO.

Regarding the evidence of science fraud.  The record provides substantive evidence strongly suggesting falsification of some DFO scientific research.  Falsification is defined as omission of results that significantly alter the conclusion of the research. Each of the examples I have encountered via the Access to Information Act, has significantly benefited the salmon farming companies using BC waters.  A few examples:

• 2016 - Dr. Kyle Garver received results from Dr. Espen Rimstad’s lab in Norway. The virus PRV found in BC is a disease agent. Section 56 of the FGR prohibits transfer of fish infected with a disease agent. Mowi told the court if  prohibited from transferring farm salmon from PRV infected hatcheries, they would be “severely” impacted (s.11, p82s).  Mowi co-funds and co-publishes with Garver on papers that ignore the Norwegian results repeating that PRV is not causing disease.  A DFO lab, independent of industry, reporting the opposite, PRV is a disease agent is ignored.  PRV is known to have originated in the north Atlantic, arriving in BC concurrently with 30 million Atlantic salmon eggs.  Because it has never been designated as a disease agent ORV has been allowed to spread to wild salmon, causing reduced survival of Pacific salmon.

• 2019 Cermaq was never charged when the heavily restricted anti-lice drug Lufeneron was found by DFO staff on the sea floor in Clayoquot Sound in a 1.5km radius around a farm that did not have permission for this drug. The public was never warned even though Health Canada refuses to permit this drug for lice treatment in sea pens due to human health concerns.  A farm salmon treated with this drug in a hatchery cannot be consumed for 12 months due to its persistence.

• 2022 DFO research demonstrating that Tenacibaculum, found in most salmon farms, is a disease agent has been repeatedly wiped from the DFO record. As a result, it is also spreading to wild salmon and may have killed up to 56% of young Fraser sockeye migrating through salmon farms in the Discovery islands.

• 2022 - Dr. Simon Jones provided Mowi with a favourable conclusion that hydrogen peroxide treatment significantly reduces sea lice infectivity, even though his staff reported the opposite. Mowi and Cermaq provided this false result to DFO to satisfy a condition of their licence to farm salmon in BC.

• 2022 - Dr. Kyle Garver terminated his investigation into persistence of the virus PRV in farm salmon processing plant effluent when his lab reported that young salmon exposed to this effluent were becoming infected.  Provincial Minister George Heyman, in charge of regulating the effluent from these plants, was never informed.   As a result while 15 salmon farms were closed in the Discovery Islands, the impact of the industry continues via the effluent from the farm salmon processing plant on the Fraser salmon migration route.

• 2023 - Mowi told the RDG to be sure to use an upcoming sea lice CSAS to soften regulations because regulations were impacting their financial performance. Tasked with writing this CSAS Dr. Simon Jones crossed out the sentence written by his staff that implicated salmon farms in lice infections on young wild salmon, and Jones wrote in a sentence stating the opposite. This edit carried over into the 2023 sea lice CSAS.  When 16 Canadian scientists provided you with this evidence and requested access to the data Simon Jones to confirm his findings, they were silently refused. 

Because scientists in your department are publishing opposite conclusions, i.e., salmon farms are both low and high risk - you are forced to ignore a portion of DFO science every time you make a decision about the salmon farming industry.  This is exposing you to repeat legal challenge.  

The 2023 sea lice CSAS is a good example. Over a dozen BC scientists have researched impact of salmon farms on sea lice infection of young wild salmon.  The outlier nature of Dr. Jones’ conclusions would require transparency to be accepted.  Yet the supporting data remains confidential, and the evidence of result tampering is undeniable.  The 2023 sea lice CSAS is confirmation that DFO science is not to be trusted.

It’s the same with the CSAS results for Tenacibaculum and PRV.  A review of edits to the many drafts of these CSAS documents reveals repeat wiping from the record of all evidence that these common farm salmon pathogens are harming Pacific salmon exposed to the farms. 

The core problem is that farm salmon pathogens cannot be regulated to protect wild fish because the economic viability of the salmon farming industry depends on releasing its waste into wild fish habitat. 

I certainly commend your efforts to date, but someone needs to directly address the issues of fraud and regulatory capture in DFO as the current behaviour is unacceptable in a democratic government.  There must be consequences for crossing out inconvenient results and refusing answer simple questions why multinational corporations are not being charged.

Thank you for considering this evidence,

Alexandra Morton

DFO Science, Fraud, Integrity?

To:

The Hon. Jonathan Wilkinson, Minister Natural Resources  

Dr Paul Snelgrove Departmental Science Advisor for BC

Estelle Couture, National Manager Canadian Science Advisory Secretariat (CSAS)

Alain Magnan, BC Coordinator Canadian Science Advisory Secretariat (CSAS)

I am writing to you to request your assistance in upholding scientific integrity in the government of Canada.  Prime Minister Trudeau has expressed that he wants Canadians to trust science as a core principle of his government.  A DFO Sea Lice report was published on the Canadian Science Advisory Secretariat website January 2023.  Sixteen non-government Canadian scientists wrote to Minister of Fisheries, Joyce Murray warning that this report omitted key results which reversed the conclusions. Thus this appears to meet the international standard of “research fraud”. 

I am bringing this to your attention because Fisheries and Oceans Canada does not appear structured to deal with this in house.  Prime Minister Trudeau may need you to weigh in here.

Briefly, the Canadian Science Advisory Secretariat posted a study authored by employees of DFO Aquaculture Management and Science that reports no significant link between salmon farms and the harmful impact of sea lice infestations on wild salmon.  While the report claims to have found “no statistically significant association” between farm lice and lice on the young wild salmon, internal documents reveal that there were “significant” results, but they were omitted, which reversed the conclusions which originally did link salmon farms and wild salmon lice infestations.

Furthermore, internal documents show that Dr. Simon Jones received the analysis for this report from a junior scientist in his lab including a table highlighting 15 “significant” results in bold text between sea lice released from salmon farms and wild salmon lice infestations in Clayoquot Sound, Quatsino, Discovery Islands and the Broughton Archipelago.  Dr. Jones (identified by his initials in the “comment”) appears to cross out the sentence reporting this connection and a new sentence is added that completely changes the conclusions.  

The January 30, 2023 letter from sixteen highly qualified scientists includes this evidence and they state “statistically significant results were omitted”. 

 As you may be aware, this conduct lands squarely within the definition of “research fraud”.

Elsevier, one of the biggest publishers of scientific journals in the world, states:

 “Falsification includes changing or omitting data or results in such a way that the research is not accurately represented. A person might falsify data to make it fit with the desired end result of a study. Both fabrication and falsification are serious forms of misconduct because they result in a scientific record that does not accurately reflect observed truth.”

 This situation has enormous ramifications for wild salmon, one of Canada’s most treasured natural resources and for the integrity of the Trudeau government.  This Sea Lice CSAS was released just days before Fisheries Minister Joyce Murray’s decision was due - whether to reinstate salmon farms on the Fraser salmon migration route.  The BC Salmon Farmers put out a release on it and the Sea Lice CSAS is being described as “
” by the local Strathcona Regional District Board, who are tasked to approve or not the restarting of salmon farms in the Discovery Islands.  That board cannot be expected to evaluate whether this government report is fraud or not.   Furthermore, the Sea Lice CSAS affects decisions on all BC salmon farm licence renewals.

Following conversations with many colleagues, I would like to offer a path forward to restore trust and protect Canada’s Pacific wild salmon.

• Honour the request of the 16 academics. Immediately provide all the industry data used in the Sea Lice CSAS for reanalysis.  A core principle of science requires results to hold up to the standard of reproducibility.
• Given the evidence that research fraud was committed - suspend the DFO Sea Lice report by removing it from the Canadian Science Advisory Secretariat website until such time the re-analysis and an explanation from the DFO science team is forth coming. It is urgent that this document be removed prior to any decisions to pre-empt its use in a legal challenge to the minister’s decision.
• Suspend Dr. Simon Jones from his position as a DFO senior “Aquaculture Regulatory Scientist” until the issue of omitting the significant results is resolved, at which time he could be reinstated, or fired.  There are other DFO scientists who put their name to this document, despite receiving the original results including Dr. Derek Price, and Dr Stewart Johnson and also senior bureaucrat Jay Parsons.
• Issue a statement on the CSAS website to disregard this paper so that regional and First Nation governments who are depending on DFO science to evaluate the risks/benefits of approving renewal of salmon farms licences understand that they cannot rely on the DFO Sea Lice CSAS at this time.

In closing, I know what I am asking is difficult, but I cannot stress enough, that the tampering evident in this Sea Lice CSAS is not an isolated episode within the DFO Aquaculture and Science division.  This CSAS report is dated Aug 2, 2022 and yet it was not posted on the CSAS website until days before the Discovery Islands salmon farm decision was due and now even after the Minister has been informed, it remains as DFO science.  

Thank you for reviewing this matter,

 

Alexandra Morton

Independent Scientist  

Author JS, Jones, Simon, crosses out sentence reporting salmon farms are linked to sea lice infection in young wild salmon

Another Episode of Concern DFO Aquaculture

Dear Fisheries Minister Joyce Murray,

Before bringing forward another episode of concern regarding the integrity of your aquaculture staff here’s a recap:

• Your senior virologist Dr. Kyle Garver continues to state the virus PRV from Norway does not cause disease, even though he has test results from Norway reporting the opposite.

• When Garver found “live” PRV virus is still being dumped into the Fraser sockeye migration route from farm salmon processing plants in 2022, he terminated this study and apparently no report was sent to the minister in charge, George Heyman, or you.

• In a project with Cermaq, Garver reports that while this virus is in virtually all salmon farms, it is not coming from the farm hatcheries… but provides no test results for the hatcheries to support this.

• Your Director of Aquaculture Management Division, Brenda McCorquodale, has refused for 30 days to say which version of licence was used to excuse Cermaq for a significant breach of licence March 2022.  Within two weeks of this incident, DFO staff built a loophole into the new licence, which was issued in June and then Cermaq was found to be incompliance and was granted nearly double the production at that site.

• Your senior parasitologist, Dr. Simon Jones, authored a report for the Canadian Science Advice Secretariat that appears to have reversed the results produced by a junior scientist in his lab, to conclude salmon farms are not responsible for the heavy lice infestations harming young wild salmon for the past 22 years. 

Now…

The Aquaculture licence issued in 2020 required testing on the effect of H₂0₂ (hydrogen peroxide) de-lousing bath treatments on sea lice (s6.13).  Experiments were conducted in Dr. Simon Jones’ lab with industry collaboration - ACRDP 21-P-01, “Fitness consequences of bath exposure to hydrogen peroxide in salmon lice”.

April 1, 2022, Dr. Jones received the results from the technician hired to perform the experiments.  Adult female sea lice were exposed to concentrations of H₂0₂ ranging from 0 - 1500ppm (parts per million), then put in tanks with young salmon and the fish were examined daily to count how many of the lice had managed to attach to them. There were 2000 sea lice, 294 fish, 15 trials, over 2 experiments.

Results

• the lice recovered from H₂0₂ exposure in 18-24 hours
• the treated lice were capable of infecting salmon
• The number of lice on the salmon declined daily, whether they had been exposed to H₂0₂ or not
• Experiment #1 - the number of lice per fish was not significantly different across all the H₂0₂ concentrations, i.e., the drug appeared to have no effect
• Experiment #2 - there were significantly fewer lice per fish for the weaker drug concentration (500ppm) but “no other differences were significant. (see document)

 

“Conclusions”

“Laboratory treatment with 500 or 1500 mg/L of H₂0₂  caused …  significant reduction in infectivity of adult female L. salmonis”

This is not true.

Just like the recent Sea Lice CSAS and public reporting on virulence of PRV, these conclusions are not supported by DFO’s own evidence.

May 31, 2022, one day before it was due, Mowi and Cermaq sent these conclusions back to DFO stating “We trust this satisfies condition of licence 6.13”…treatment with 500 and 1500ppm H₂0₂ caused significant reduction in infectivity of adult female L. salmonis.” [See document]

Condition of Licence 6.13 stated the report must meet “the satisfaction of the Department”.   The circular path of this work ensured this outcome. 

1. DFO required industry to study the effectiveness of H₂0₂ on sea lice control
2. DFO did the study for industry
3. Industry sent the study back to DFO
4. DFO accepted the result

Minister Murray, in my investigations it appears that without Dr. Kyle Garver and Dr. Simon Jones there is no DFO science to support the conclusion that salmon farms are low risk to wild salmon.  Furthermore, if your Aquaculture Management Division had properly investigated the March 2, 2022 breach of licence by Cermaq (reported by the DFO veterinarian), it would have been simple to answer – which licence was used to find Cermaq was in compliance – the one in effect at the time of the sea lice incident, or the one that came into effect 3 months later that had been edited coincidentally to specifically to protect industry from this violation?

I feel I should give you a few days to absorb this new information on the behaviour of your staff, before I provide the next report.  Meanwhile, you are deciding whether to reinstate salmon farms in the Discovery Islands and reissue licences coastwide, based on the conclusions of Drs. Jones and Garver.

All the best,

Alexandra Morton

                     Aqua Tromoy docked at salmon farm. This is one of the boats doing the H₂0₂ bath treatments.  Farm salmon are pumped into the boat, soaked in the drug and returned to the farm, releasing the hydrogen peroxide into the ocean