The impact of the December 2020 Minister’s decision to honour First Nation requests to prohibit salmon farm restocking is having a significant positive impact. Sea lice infection of wild salmon in the Discovery Islands is very low compared to years where more salmon farms were active, particularly in Okisollo and Nodales Channels (green circle on right). The highest average infection per region this spring is .4 lice per juvenile salmon. This is approximately 90% lower than last year. To be sure of this number we need to wait for the next round of sampling because 2020 lice counts did not start until the 3rd week of May. In the graph above we see there are approximately 4xs more lice in the areas where salmon farms are still operating.
The study is divided into three regions:
Okisollo, the green circle on the right on the map, receives ocean currents from the east and so this area is in the path of sea lice larvae drifting out of the Cermaq Raza Island salmon farm. This site has been empty as of April 25 (according to Cermaq website), so it will be interesting to see lice numbers on young wild salmon in the Okisollo region next week.
Mid Discovery Islands, the green circle in the middle of the map, is protect by land on all sides from currents flowing out of operating salmon farms. The graph indicates an average of less than .1 louse per fish.
Western Discovery Islands, the green circle on the left, has four salmon farms still operating. Lice numbers on wild salmon are similar to Okisollo. However, they are still very low, and it will be interesting to view fish in this region next week.
Methods
50 salmon (pink and chum) were caught at each site on April 6 and April 25 (no fish were found at the sample site furthest to the east in Okisollo, Cyrus Rocks, on April 6). The fish were captured by beach seine and preserved individually in a whirlpak bag. Sea lice were identified with a 30x dissecting microscope and identified by life-stage (copepodite, chalimus A, chalimus b, preadult or adult), the, copepodite, preadult and adult stages (motile-lice) were further identified to sex and species (Lepeophtheirus salmonis or Caligus clemensi). Each fish was identified by species, measured and weighed. DNA samples were collected.
We don’t expect to see sockeye salmon migrating through this area until the 3rd week in May. I will be examining those fish alive. They will be the offspring from the adults that entered the Fraser River in 2019, the lowest return on record at that time.
SALMON FARMS – Discovery Islands
In 2021 five salmon farms are operating in the Discovery Islands. As of April 25, there are only four. In 2020 there were ten (see map below). The most critical area appears to be the Okisollo and Nodales Channel region (red circle below), because these channels are so narrow, so many young salmon use those waterways and because so many salmon farms have operated in that area in the past.
FARM LICE
All but one salmon farm (off Port Hardy) is currently reporting sea lice numbers below the federal threshold of three motile-stage (adult) lice. First Nations in the Broughton and Clayoquot Sound are demanding levels lower than this to protect collapsing wild salmon populations. I hope we can believe these farm numbers, as research published in 2020 reports that the fish farm companies using BC to grow Atlantic salmon fail to report up to 50% of their lice (Godwin et al 2020[i]). This is a critical year for wild and farm salmon. Many wild salmon runs are on the verge of extinction and the Minister of Fisheries and First Nations are severely reducing the number of farm salmon in BC waters.
To date I have only reported on sea lice numbers on juvenile pink and chum salmon in the Discovery Islands. The young sockeye have not arrived yet. The reduction from 10 to 4 salmon farms and complete removal of the farms from Okisollo and Nodales Channels appears to be having a significant positive effect. This work is ongoing through June.
Of all the things I describe about salmon farming in my new book Not on My Watch, the disease outbreaks, sea lice infestations, subversion of science, rubber-kneed politicians, catastrophic damage to wild salmon, the First Nation uprising... the one thing the industry has managed to respond to is my description of being followed by a company called Black Cube.
They complain that when I describe how Mowi hired a company called Black Cube to follow me that I describe what world knows as Black Cube. See below a screenshot of their somewhat sinister website. As you will see below, a business licence was issued for Black Cube to operate in Campbell River just before guys in boats with black windows (pictures below) started following me. Mowi admitted that they had hired a company called Black Cube but they claim, it was not THE Black Cube... Why not just hire an already existing Campbell River security firm? Why was a licence purchased for a new company called Black Cube?
If you call yourself Black Cube and you act like Black Cube, is it any wonder that people think that you are Black Cube?
In addition to Black Cube, I describe how:
DFO threatened to arrest me for collecting lice-encrusted fish they asked me to catch for them,
the Province of BC tried to pass a law - anyone testing farm animals for disease would be fined $75,000 and two years in prison - when I detected a reportable virus in farm salmon,
the Canadian Food inspection Agency refused to allow a lab to send me test result of BC farm salmon that I had paid for
and when the industry moved into the 100 year old floathouse community of Echo Bay, the Province of BC decided tenures would be granted to salmon farmers, but not to local residents and so our floathouses became illegal and our town was extinguished.
This is how salmon farming got into BC waters - NOT ON MY WATCH
Below is the summary of all lice numbers reported on Atlantic salmon farms throughout BC (Figure 1). The data comes from the Mowi, Cermaq and Grieg websites. Only salmon farms that are certified, or where certification is pending are reported weekly. This leaves quite a few farms that are reported only monthly. Some certified farms are also skipping reporting in some weeks. Notably Mowi’s Chancellor Channel site in the Discovery Islands, which has undergone two sea lice treatments this year and entered the juvenile outmigration period over the limit and out of compliance with its licence, has not reported since March 28. All the farms in Sechelt Inlet (Grieg Seafood) are reported as fallow.
On the second page is data from the 1st week of juvenile wild salmon sampling in the Discovery Islands (Figure 2). Most of the salmon farms in the Discovery Islands are empty. According to the Minister of Fisheries this is permanent for all but two sites which Mowi is fighting to restock one more time to be emptied permanently by June 2022.
Farm lice
Figure 1: The purple line is the number of adult-stage lice in the farms off Port Hardy. Sea lice there continue to rise above the level considered safe, by the provincial and federal governments, for wild salmon (dotted line). The blue line rising rapidly is the number of lice in farms on the central coast near Klemtu. Third highest, the green line, is the Discovery Island farms that are still stocked. Not visible yet are the juvenile lice on farms in Quatsino. All four of these regions are used exclusively by Mowi, with the exception of one Cermaq farm in the Discovery Islands that is in the process of harvesting.
Sea lice on young pink and chum salmon in Discovery Islands April 6, 2021
Figure 2: The six blue and grey dots are where we are catching young pink and chum salmon and counting lice on them. No fish were found at Cyrus Rocks this week. The red dots are farms that currently have Atlantic salmon in them. While the wild salmon are generally moving from the right to the left, there are many small salmon streams in this area, so I don’t know if the fish I examined traveled through the entire region or entered the ocean near the site where they were caught.
The most important information here is not only the number of lice, but also how old the lice are. Decades of research show that the youngest lice (orange bar) occur near active salmon farms. How close the orange bars are to the red dots tells us whether the farm is infecting the wild salmon.
Findings at each sample site
Upper Okisollo – there were 9 lice total on 50 fish. Last year the average infection in this location reached 9 lice per fish. While there are no active farms currently in Okisollo, ocean currents move logs and debris quickly from the Raza Island area into Okisollo. This means both fish and larval lice are also moving in this current. Most of the lice on fish caught in Okisollo are older lice, which suggests they did not get infected locally, that they arrived already carrying lice.
Nodales – there was on 1 louse total on 50 fish and it was an older louse suggesting the fish had picked it up a week or so before.
Knox Bay – no lice!
Shorter Point – This sample site is in a channel with two active salmon farms. The youngest stage of lice dominated the infection of the young pink and chum salmon suggesting the infection occurred in that location.
Blenkinsop Bay – This site is close to two active farms and the sea lice were the youngest stages.
Summary
These fish, caught on April 6, were tiny - average length 35mm. Their bellies still show the seam where their yolk sac recently protruded. They have not been in saltwater for very long. Water temperature was low ~ 8oC and salinity was also fairly low ~29 ppt (parts per thousands). Both will rise through the spring speeding up sea lice reproduction. Data will be collected every other week.
Mowi had their delousing ship Aqua Tromoy working in the area from February until recently.
Because the Minister of Fisheries has prohibited restocking of salmon farms in the Discovery Islands, there are ~ 5 million fewer Atlantic salmon in the region this spring than other years. For example, last year there were four farms operating in just Okisollo Channel, which is now farm-free. As a result, lice levels are very low and young wild salmon look good. However, signature farm lice infections are occurring where wild salmon get close to an operating farm.
Young pink and chum salmon move through the region slowly and we will keep an eye on them over the next three months. We will see if Mowi can bend their lice curve back downward. This work covers only sea lice, not the spread of viruses and bacteria we know are also being released by salmon farms.
The data below comes from the websites of Mowi, Cermaq and Grieg. This is self – reporting. We know this reporting can be 50% lower than is actually occurring in the farms but it is informative[1].
The dotted line is the threshold put in place by the Province of BC in 2003 to protect wild salmon - 3 motile or adult stage lice per farm salmon. Companies were meant to keep their lice per salmon below this line. However, similar to everywhere in the world that this industry operates, sea lice on farm salmon in BC are becoming resistant to the drugs used to kill them and this means no company has reliably controlled their lice since 2015. When sea lice on salmon farms rise, young wild salmon die.
To help the farmers stay in compliance with the regulations senior DFO management gave the companies some relief. On March 1, 2020 Conditions of Licence issued by the federal government allowed each farm to exceed the longstanding threshold for 6 weeks every time the average number of adult-stage (motile) lice per farm salmon rises above 3. I fought this has hard as I could, but DFO management was determined to lower the bar so the farmers could not be prosecuted for damaging levels of sea lice. Last year 99% of young sockeye were heavily infected in the Discovery Islands, and we could not find these fish again further along on their migration route. Here is a report I put together on Download Sea Lice 2020
This year many of the most infected farms have new younger fish and so fortunately lice numbers are lower, but there are several hot spots.
Figure 1: The average number of sea lice per farm salmon has been lowered in the Discovery Islands since very high levels over the winter, but we see the green line is trending upwards again. As well, lice numbers are rising dangerously in the farms off Port Hardy including Bull Harbour. Both of these areas are on the Fraser River salmon migration route.
Figure 2: This is the average number of lice per farm, colour – coded by company. Mowi is currently reporting three farms above the threshold. These are the farms off Port Hardy.
Figure 3: This is the average number of juvenile (attached stages) which will molt into the motile stages that are counted within two weeks. This stage of lice is unregulated. These extremely high numbers are in Quatsino Sound at the Mowi farms Koskimo, Mahatta West and Monday Rocks farms. If Mowi doesn't get these lice numbers down right away they will heavily infect any wild salmon trying to migrate out of Quatsino Sound.
Sea lice infection at salmon farms in 2020 destroyed a very high proportion of the young salmon that were trying to get to sea. These fish will not return to spawn. photo Tavish Campbell
I have read 12 years of your internal conversations about how you and your predecessors have suppressed the growing evidence that salmon farming is causing serious harm to wild salmon. Your emails are available through the Access to Information Act. I have come to the following conclusions:
· You were given an impossible mandate, · You have gone too far in favour of the aquaculture side of that mandate · Fraser sockeye and other salmon runs will go extinct very soon if you are allowed to continue on your current path · You are now a threat to the integrity of the Minister of Fisheries The record reveals a bureaucracy that appears to have repeatedly sought to influence decisions by withholding critical information from the Minister of Fisheries and others. In 2012, Justice Bruce Cohen warned us of your “divided loyalties”. Below are just three examples where senior DFO management shielded the salmon farming industry from implication in catastrophic impacts on Fraser sockeye by withholding specific DFO science. You protected the industry and, in the process, put the wild salmon and all that rely on them at significant risk.
1- Findings on Fraser Sockeye prespawn mortality - suppressed
In 2009 the Fraser River sockeye collapsed, the Harper government called the Cohen inquiry into their 18-year decline and DFO scientist Dr. Kristi Miller had the only hard evidence on the cause.
Miller detected a leukemia virus response in the immune systems of the 100,000s of sockeye dying in the river just before spawning. Other DFO scientists published in the journal CANCER RESEARCH[1] that Salmon Leukemia virus had spread through all the Chinook salmon farms in the Discovery Islands and the Broughton Archipelago throughout the 1990s.
When Miller asked to test farm salmon in the Discovery Islands to learn if they were the source of the virus killing the sockeye, her request was denied, her research defunded and Regional Director of Science, Laura Richards, prohibited Miller from attending university think tanks on the cause of the Fraser sockeye collapse. Security guards flanked Miller when she arrived to testify at the Cohen Commission preventing contact with the public; she was prohibited from speaking with the media.
Luckily for Canadians, as salmon leukemia virus came under scrutiny in the Miller lab, the salmon farming industry quietly removed all large Chinook farms from the Discovery Islands. Prespawn mortality in Fraser sockeye declined. Lawyers for both the BC Salmon Farmers Association and Canada objected strongly to my report on Miller’s findings to the Cohen Commission [2]. But it was accepted into the record [3]. However, DFO halted the investigation into the link between salmon leukemia virus in salmon farms and the 18-year decline of the Fraser sockeye salmon.
2 - Impacts of sea lice on sockeye - withheld
Since 2015, the salmon farming industry has not been able to reliably control the sea lice breeding in their farms due to evolving drug resistance in farm lice populations. As a result, widespread lethal lice infections of juvenile salmon runs have occurred over the past four years. In 2019, in response to the lowest Fraser River sockeye return in the history of Canada and the ongoing media depicting the sea louse outbreaks, the Minister of Fisheries instructed senior management to tighten the sea lice Conditions of Licence. He formed the Fish Health Technical Working Group FHTWG, of which I was a member, to advise this process.
Dr Carmel Lowe, Director of Science and co-chair of the FHTWG was told that all materials provided to us had to be vetted by deputy Minister Timothy Sargent, and they withheld a paper critical to the discussion published by senior DFO scientist Dr. Simon Jones. The paper revealed that infection with just 10 sea lice causes “profound” physical impact on young sockeye salmon [4]. This information would have made it apparent that strict measures to reduce sea lice numbers in salmon farms were urgently required to protect the collapsing Fraser sockeye runs.
Dr. Simon Jones attended some of the meetings and also remained silent on his findings.
Although DFO staff expected and were preparing for a sea lice CSAS to inform the Minister on the risk of sea lice in salmon farms to sockeye, as per Cohen Commission Recommendation #19, it was cancelled. Therefore, when Minister Bernadette Jordan made her decision on September 28, that salmon farms were minimal risk to Fraser sockeye, she did not have the most critical findings by scientists that strongly suggested the opposite.
On March 1, 2020 Allison Webb, director of the DFO aquaculture management division issued the new fin fish Conditions of Licence requested by Minister Wilkinson, and gave the salmon farming companies permission to repeatedly have unlimited lice numbers in the farms for six weeks every time a farm exceeds the lice threshold that was set by the Province of BC in 2003 to protect wild salmon, including within the critical March 1 – June 30 juvenile salmon out migration period.
Tragically, 50% of Discovery Island farms used this and exceeded the lice threshold. 99% of the young sockeye exposed to these farms were infected at levels that Simon Jones' research makes clear was extremely damaging. These new regulations apparently helped the salmon farming industry remain “in compliance,” but sacrificed a generation of Fraser sockeye. These “regulations” remain in place. Already this month two salmon farms in the Discovery Islands exceeded the threshold and the sockeye migrating this year are the offspring of the 2019 brood year - lowest in the history of Canada (until 2020).
As well, in 2020, Dr. Simon Jones authored a briefing on sea lice science for the consultations between Holmalco, Klahoose, Komoks and Tla'amin and the Minister of Fisheries and withheld his findings that infection with just 10 sea lice causes profound damage to young sockeye [5].
3 -Mouthrot impact on Fraser sockeye - withheld
Oct 22, 2020, Dr. Carmel Lowe received information from a joint Pacific Salmon Foundation/DFO study that the bacteria Tenacibaculum is drifting out of salmon farms infecting Fraser River sockeye smolts in the Discovery Islands [6]. This bacteria is indisputably widespread in salmon farms where it is causing mouthrot.
On Nov 3, 2020, Carmel Lowe alerted the BC Salmon Farmer’s Association that this research should be a concern to the industry because it indicates that a pathogen from their farms appears to be causing “poor health outcomes” for wild salmon and reducing sockeye, Chinook and coho salmon populations that migrate through the Discovery Islands [6].
This research reports that information they collected suggests that Tenacibaculum wafting out of salmon farms may be causing an 87.9% reduction in sockeye smolt survival in the Discovery Islands [6].
While senior DFO management briefed the salmon farmers on these alarming findings, they withheld this information from the fall 2020 consultations that were underway between their minister and Holmalco, Klahoose, Komoks, Kwiakah, Tla'amin, We Wai Kai and Wei Wai Kum regarding DFO renewal of 19 federal salmon farm licences in their territories. The day before the Minister had to make her decision due to the expiry date of the Discovery Island licences, out Director General says "I feel like this issue should be raised to the DM [Deputy Minister] asap, given the current context". You think?
According to the record, the above information was not provided to the Minister of Fisheries until potentially hours before the decision deadline, or not at all. Further research reports that this pathogen is not only in marine salmon farms, it is in farm salmon hatcheries [8]. Because PSF/DFO research indicates that Tenacibaculum infection from salmon farms may substantially reduce wild salmon populations, the transfer of infected farm salmon into marine pens should have been prohibited under section 56 Fisheries (General) Regulation. Is this regulation being observed?
Conclusions
These are just three of many examples where senior DFO management withheld critical information which served to protect the salmon farming industry while causing Fraser River sockeye and other salmon severe harm. Only 27 Fraser sockeye salmon returned to Shuswap Lake last fall. These fish could not possibly be closer to extinction. This spring young salmon leaving all southcoast rivers will be exposed to high doses of Tenacibaculum, PRV, sea lice and other pathogens [8] as they pass salmon farms and the record suggests that DFO senior management is allowing this to happen despite having information on the risks.
If the Minister had been informed that sea lice are causing acute and profound damage to young wild salmon, would the companies have been issued licences with no restriction on sea louse infections for 6 week periods of time? Already this year two of the salmon farms in the Discovery Islands has exceeded the sea lice threshold considered safe for young wild salmon, even as MOWI who owns the farms is going to court to fight the Minister of Fisheries to put more farm salmon into this region. Do her lawyers have the DFO paper reporting the severe impact this will have on the highly endangered sockeye? It is only March. As water temperature and salinity increase, the lice in these farms will accelerate reproduction.
In my view, you compromised both the Sept 28, 2020 Cohen recommendation decision and the Dec 18 federal licence decision by withholding critical DFO science.
Your conduct has also crippled the salmon farming industry. You removed any incentive from the industry to meet the standards Canadians expect to protect wild salmon and thus you have made the industry wholly dependent on your capacity to suppress science. Had your approach been more responsible (honest), BC would have a flourishing wild salmon economy and be a leader in the more sustainable methods of farming salmon that have captured global investment.
Given how entrenched this behaviour has become, I believe early retirement or transfer away from decisions affecting wild salmon will have to come to a significant number of senior staff.
It is a hard path, but the record preserved in the Access to Information Act cannot be ignored. Specifically, that senior DFO management have relentlessly suppressed the evidence that salmon farms are implicated in significant harm to wild salmon and this has heavily damaged some of the most important salmon runs in Canada. You have not been alone in this, substantive evidence also exists regarding senior staff in the provincial Ministry of Agriculture and the Canadian Food Inspection Agency.
I will be publishing many more examples in greater next week with citations.
Recommendations
Going forward, my recommendations are:
Remove senior management involved in the many acts of suppression of science from any position with any influence (direct or indirect) on wild salmon.
Extend an invitation to First Nations to fill DFO director-level positions affecting wild salmon.
Create a new position – Director of Wild Salmon, Pacific Region – and fund it generously to hit the ground running, in partnership with First Nations, to harness the remarkable DFO science that allows the salmon immune system to tell us how and where we are destroying them,
Take immediate highly strategic action, truly science-based, balanced with traditional knowledge to provide immediate relief to wild salmon to rescue them from the edge of extinction based on what we already know.
My greatest respect and thanks to the First Nations, who at great cost, have blocked restocking of high-impact salmon farms in the Broughton Archipelago and Discovery Islands and to the provincial and federal leaders who listened to these nations. As a result of these actions, wild salmon in some regions of eastern Vancouver Island have a fighting chance at survival this spring. As well, this will provide incentive for the rise of a different kind of aquaculture, one with a long-term future.
The document below was sent to DFO's new Senior Aquaculture Management Coordinator. This is the story of what happened when the Minister of Fisheries told DFO to make fish farm sea lice regulations stronger and they got weaker.
Below are DFO's own words taken from 2,500 pages of internal documents. I acknowledge the effort of DFO field staff, biologists, conservation & protection officers and others who are trying to navigate what appears to be an impossible situation that has reached a breaking point.
I can see a path through this highly damaging state of chaos, but DFO’s compass must be re-calibrated to establish the health of wild salmon as true north.
For the record:
How the Minister of Fisheries Tried to Protect Wild Salmon and We Lost a Generation of Sockeye
Information derived from A-2020-00026 (2,253 pages)
Summary – citations below this section
A memo to Director General, Pacific, Rebecca Reid, frames why salmon farm Conditions of Licence (CoLs) were updated in 2020. In 2019 Fisheries Minister Jonathan Wilkinson recognized there was a serious problem with sea lice infections in BC salmon farms impacting juvenile wild salmon, that this problem was not going away, that media interested had been sustained for over 3 years and that changes to this aspect of salmon farm management were urgently required.
Wilkinson announced that salmon farming Conditions of Licence would be improved before the next wild salmon outmigration in March 2020 - two years before all salmon farms licences expire coastwide in 2022, which was the natural time to change these CoLs. The minister wanted the CoLs opened immediately for revision due to urgent conservation concerns to increase enforceability of farm lice limits that had been established in 2003 in response to the first lice outbreaks documented in the Broughton Archipelago.
A group of scientists, industry veterinarians, DFO staff and First Nation delegates were invited to join the minister’s Fish Health Technical Working Group (FH TWG) to provide advice on redrafting the salmon farm CoLs. It was a volunteer position. Tables were created comparing the new and old CoLs, listing the advice from different sources. Everything provided to the Fish Health Group had to be directly approved by the deputy Minister Timothy Sargent. Months into the process, staff were told not to share the portion of this table that listed all the FH TWG advice that had been ignored.
Some DFO staff were acutely aware of the sea lice problem and they knew how to achieve industry compliance. They recommended that any farm that exceeded lice limits should have future production reduced, a mandatory fallowing period of several months, and should be subjected to a review of whether the licence would be rescinded. All these ideas were blocked.
Other staff were involved in protecting the industry by lowering requirements to the point that the farms were able to comply. They reported this as “erring on the side of caution,” meaning fewer farms would break the rules if the rules were weaker.
DFO staff repeatedly warned senior management that First Nations and ENGOs were not going to accept the new CoL’s, but they admitted the new CoL’s would avoid causing “an unhappy industry”. DFO staff were operating on the understanding that there would be CSAS done to review the impact of farm-origin sea lice on juvenile wild salmon to support the hard decisions they faced, as they were caught between conservation and facilitating industry, but this CSAS was quietly cancelled.
No one acknowledged the 2018 published DFO research that experimentally recorded acute stress in young sockeye infected with sea lice. One of the DFO authors of this paper was tapped to produce sea lice briefings for First Nations and others. He never mentioned the impact of sea lice on Fraser sockeye. As well, none of the regional directors, including the Science Director mentioned this work, which raises the question: were they hiding it, or were they so unaware of DFO science that they did not know about it? Was this paper the reason the CSAS on sea lice could not go forward, because to omit it would have been one of the more identifiable catastrophic flaws in the CSAS process and to include it would undermine all the efforts to downplay the role of farm lice in the collapse of the Fraser River sockeye salmon? Certain Dr. Simon Jones who was author of both the research and sea lice briefings knew about this.
There were other examples of DFO’s failure/refusal to accept the science on sea lice impact. A DFO veterinarian told ENGOs that there is no evidence that Caligus sea lice cause harm to wild salmon and therefore zero regulation of this species would be considered. Days later this same person admitted to having read Dr. Sean Godwin’s work on the negative impact of Caligus on young Fraser River sockeye, but he chose to simply discount it.
While this conversation was going on, the Minister of Fisheries was announcing that the 2019 Fraser River sockeye return had fallen to the lowest level in the history of Canada, far lower than had triggered the Cohen Commission in 2009. Fraser sockeye were on a steep extinction trend and DFO was ignoring and hiding the science that would have allowed them to reach the open ocean and have a fighting chance at survival.
The most revealing discussion was around creation of a sea lice farm threshold, i.e. the number of lice per fish x the number of fish in each farm. This was seen as critical by some staff because some farms had 600,000 fish and others might have one million. Ultimately it was the number of larval lice pouring out of each farm that decided the fate of young wild salmon. The negotiation started at 1.5 million adult stage lice per farm, 2.5 million was considered the hard line, but even3 million was rejected by industry as too strict. As the BC Salmon Farmers Association put it over time this limit would result in smaller farms in contrast to the global trend for larger farms. Meanwhile the First Nations of the Broughton Archipelago wrote to DFO and said Mowi and Cermaq had agreed to farm thresholds.
On December 4, 2019, the BC Salmon Farmers Association asked to review the proposed CoLs. Version 10 of sea lice CoLs appears in the record at this time and contains the first mention of the 42-day window during which each farm could be infected with an unlimited number of sea lice with no consequences. This 42-day window would be allowed repeatedly for each growout. So, in reality the farms only had to briefly report low lice numbers and they would be released from any limit for another 6 weeks. We know from Godwin et al 2020 that industry underreports it’s lice by up to 50%[1]. The industry also complained about the cost and effort of counting their lice in advance of the juvenile outmigration, which was required for proactive action to ensure the farms did not kill wild salmon, particularly at the beginning of the migration in March and April when the wild fish are smallest and most vulnerable.
On January 29, 2020, Allison Webb wrote to Rebecca Reid “we need direction on changes on sea lice where there are diametrically opposing views – industry on one side and FN/ENGO on other”. Kerra Shaw writes “senior management did NOT support some of the things we told the group [FH TWG] we were recommending...”.
Senior management clearly sided with industry, removed the farm threshold, removed the mandatory fallow, and production cuts and allowed the industry to repeatedly exceed the current lice limits as many times as they wanted as young wild salmon coastwide tried to make it to sea past the farms. As a result, in the spring of 2020 half the salmon farms in the Discovery Islands exceeded the 2013 lice limit considered safe for wild salmon, 99% of young sockeye were infected at levels that DFO’s own science stated would have caused them acute and profound damage. It was the worst sea lice outbreak recorded since 2004 and Canada lost the majority of young Fraser sockeye, as well as, most of the pink and chum salmon that migrated through Okisollo Channel in the Discovery Islands that year.
This record informs us that DFO field staff tried to honour the intent of Minister Jonathan Wilkinson to open the salmon farming Conditions of Licence two years early and insert strong protection measures, but their efforts were discarded in favour of industry-friendly Conditions that resulted in the loss of the generation of Fraser sockeye salmon that migrated to sea through the Discovery Islands in 2020. Ultimately this contributed to the industry’s loss of 19 farms in the Discovery Islands.
Industry complains that the public’s lack of trust in DFO is hurting them but in reality, it is the distrust of the salmon farming industry that is hurting the relationship between DFO and the people of Canada. (Pg 172)
Citations for the material presented above.
DFO staff knew sea lice in salmon farms were a serious problem
A May 2017 internal report muses “what’s the chance of litigation if DFO does not do something” about the rising lice problem. (Pg 57)
June 2017, an internal DFO document titled Sea Lice Management Considerations to Guide Potential Changes – June 2017 states “serious fish health issues may occur when salmon are heavily infected by sea lice.”(Pg 148)It says that transmission of lice from farms to young wild salmon has to be controlled and this will require a more effective response from DFO.
DFO’s aversion to non-DFO science crops up in a comment to remove mention of Dr. Marty Krkosek’s work. (Pg 153)
In a 2019 meeting with environmental groups, DFO states the sea lice species Caligus has not been demonstrated to impact salmon, but two days later DFO Dr. Zac Waddington admits that he has seen Dr. Sean Godwin publications on Caligus impact on young Fraser sockeye and choses to ignore it. (Pg 181)
Bernie Taekema drafted enforcement options with escalating production reduction based on how many sea lice the farm was infected with, including ordering the farm to remain fallow through the next juvenile outmigration period. (Pg 631) In October 2019, the suggestion appeared that lice numbers should not be calculated per fish, but rather per farm. The first limit proposed was 1 million motile lice per farm. (Pg 644)
On that same day Dr. Sonja Saksida writes – “... we need to figure out how to apply the consequence of non compliance. It’s pretty apparent the original way did not work... we have to put in some teeth ” and suggests that the licences be pulled from farms that do not comply with lice limits, and as well as the companies should be hit with a 20% decrease in future production in that farm. Bernie Taekema responds, “The consequence section is getting tricky”. (Pg 400)
Dr. Simon Jones weighs in saying that they know that elevated lice numbers on salmon farms results in high infection of juvenile wild salmon, that there is no point in even counting lice on wild salmon anymore. (Pg 403)
Jan 6 table titled Results of Consultations... CoLs: states “No evidence that Caligus cause harm to wild fish.” “No correlation between wild and farmed sea lice levels has been found... (Pg 1265)
Derek Price points out that after a hydrogen peroxide delousing bath treatment, the attached stages of sea lice remain on the farm fish, keeping the infestation going and so multiple baths are required, but for a number of reasons farms can’t do this. (Pg 1197)
The Sea lice CSAS that never was
Adrienne Paylor, Regional Director of Aquaculture Environmental operations filed a request for a CSAS on sea lice to be used to update the Conditions of Licence (CoLs). She notes that the 2012 CSAS on sea lice was inadequate and that the new Sea lice CSAS would support the Pacific Aquaculture Regulations. She highlights that as an “IMPORTANT” issue to the public. (Pg 360)
Sept 15, 2019, Adrienne Paylor repeats that she has been pushing for a science Risk Assessment on sea lice impact on sockeye, but “nothing has been done.” (Pg 409)
On October 2, Kerra Shaw pushes for sea lice questions in time for the October sea lice CSAS submission deadline. (Pg 626) On October 3 she writes to Dr. Simon Jones asking for two hours of his time to hammer out the right questions for the CSAS. Jones writes back, send me your questions and I will try to get back to you, Shaw responds that she wasn’t looking for his answers, she wanted to work with him to shape the questions. (Pg 653)
Jan 6 – In the Results of Consultations and Recommendations on Changes to Sea Lice COL: (Pg 1266)
Industry response to having to count lice in every pen “some concerns with work load...” Re culling “No-DFO does not have the authority to require killing of fish REDACTED Causes economic loss and there are animal welfare considerations”
“The current CSAS request for more sea lice analysis which could result in requirement to test wild salmon in 2022 licence renewal”
No Caligus regulation required “ Caligus come and go with herring and salinity ... No evidence that Caligus cause harm to wild fish
Industry concerned that additional pre-migration monitoring might increase work load...
No to removal of adult farm salmon from next migration window if sea lice threshold exceeds continuously for 90 days
Re bioassays “vets sensitive to DFO interfering with the practice of medicine”
Fish Health meetings
October 17, 2019, Kerra Shaw writes that the Deputy Minister (Timothy Sargent) is “currently approving everything we share at the FH Technical Working Group...” (Pg 704)
Pg 1271 – “Things we heard from the FH TWG but will not be incorporated” in response to sea lice exceedances
Ticketable offences
Forced culling
Reducing tonnage
Managing Caligus
Mandatory poor performer culling
Jan 7 Carmel Lowe writes to Kerra Shaw suggesting that the FH TWG not be informed that the above recommendations would not be applied (Pg 1279).
Jan 29 Allison Webb writes to Rebecca Reid “The timing was made more difficult by on-going discussion with the FH TWG that was required as input to the consultations which took place into mid-January... we need direction on changes on sea lice where there are diametrically opposing views – industry on one side and FN/ENGO on other”. (Pg 1811)
Simon Jones
On November 1, 2018, Drs Simon Jones, Kyle Garver and Amy Long of the DFO Pacific Biological Station had a scientific paper accepted by the Journal of Aquatic Animal Health paper stating that sea lice cause “profound physiological impact to Sockeye Salmon...”[2] the infected sockeye became lethargic, suffering significantly more than young Atlantic salmon.
Six months later on May 22, 2019, Simon Jones sent a presentation to Lesley MacDougall, Science Coordinator of Fisheries and Oceans Canada, Ottawa, titled “An Overview of Sea Lice Research in BC” (Pg 670). It presents an infographic suggesting Atlantic salmon are more susceptible to sea lice than all Pacific salmon. However, while he states in the presentation that 75% of 135g sockeye would survive infection with 50-60 lice, it remains silent on his published finding that 10 sea lice caused acute and profound stress in a 91g sockeye.
On September 28, 2020 DFO published a website on the impacts of salmon farms on Fraser sockeye stating that “Atlantic salmon are generally more susceptible to sea lice than Pacific salmon species,” when the paper co-published by Simon Jones in 2018 said pretty much the opposite: “Furthermore, Sockeye Salmon have been shown to be more susceptible than Atlantic Salmon to L. salmonis infections and the resultant physiological impacts.”[3]
Condition of Licence edits
October 15, “.. may not use mechanical and bath treatment options during out-migration window unless a majority of the sea lice can be captured and removed...” (Pg 702)
Nov 1, 2019, Daniel Tomlinson, fishery officer, says “The language is awkward... the licence states that you must NOT exceed under any circumstance but... only if you exceed really badly these will be a defined consequence and almost accepts the continuation of the offence. I would suggest that is sea lice is a biologically important issue, they should be below the threshold or the existence of the farm/licence be reviewed.” (the rest is redacted). (Pg 795)
Nov 14, Kerra Shaw points out that if only 1.5 million motile sea lice (Leps) were allowed in a farm, “I think we have to assume many more farms would be out of compliance...” (Pg 874)
Nov 26, a presentation to the salmon farming industry gives a summary of lice exceedances 2011-2019 and the planned “updates” to Conditions of Licence; page 948 shows the upward lice trend across all farms and years. It says all lice must be captured during well-boat and mechanical treatment, and it includes a farm lice threshold as well as an individual fish lice threshold (pg 951).
The salmon farmers pushed back on a proposed 60-day fallow period between growouts in a letter to Director General, Pacific Region, Rebecca Reid (pg 957).
December 4, 2020 the BCSFA writes to Adrienne Paylor to say that they met “to review the proposed changes to the marine finfish aquaculture licences...” but “is unable to approve any changes to the licences until draft language has been made available for consideration. (pg 1005). This is odd language as it is hard to see how they met to review the changes without a some of the proposed changes to review. Two pages later in the ATIP, Version 10 of sea lice CoLs appears and it contains the disastrous 42-day time period (Pg 1007).
Page 1063 Kerra Shaw writes DFO National HQ is trying to get aquaculture an exemption from the US prohibition on killing marine mammals.
Dec 18 Howie Manchester, DFO Aquatic Science Biologist, DFO, says “If we wanted to error on the side of caution (not having farms exceed farm threshold before fish threshold) 2.5 million (lice) might be a compromise... but I don’t think we should budge beyond 2.5 million.” (Pg 1174)
Jan 6, 2020 “AMD proposes an initial implementation of a farm threshold of 3 million, which will not lead to many additional farm exceedances... while still limiting farm-generated plumes and allows for future adjustment in 2022 or beyond. Needs senior management decision.”(Pg 1265)
Jan 8 Draft Memorandum to Regional Director states First Nation advice consistently included moving the industry to land. Notes biggest industry pushback is the farm level threshold. The pros of adding the threshold include “better risk management, increased enforceability, and alignment with FN and ENG recommendations” “Cons include unhappy industry” and nothing else. If threshold not included, “allows time for CSAS to occur which will focus on the link between sea lice and wild salmon” (Pg 1289)
BCSFA says farm threshold will result in smaller farms in contrast to global trend for larger farms. (Pg 1352)
Jan 14 Broughton Nations write to Todd Johansson, Aquaculture Management that Mowi and Cermaq have agreed to farm – specific thresholds that reflect proximity to other farms, natal streams, health of Pacific salmon and will be annually adjusted (Pg 1379)
Draft memo to the Deputy Minister states Industry is strongly opposed to farm thresholds and FN and ENGOs are strongly supportive. (Pg 1429)
Jan 29 Krista Sandberg looks at 2019 data and says that a 3 million lice threshold is going to be pretty tough for industry to meet. (Pg 1805)
Feb 17 DFO told the BCSFA “which COL have been dropped from the licences... will probably relieve some of the stress.” (Pg 2061) one of the things dropped was the farm threshold
Feb 17 Memorandum to Rebecca Reid “ENGOs and FN are likely to react adversely to the proposed changes as not being precautionary enough to protect wild salmon.” (Pg 2104)
Broughton farms never exceeded 3 motile lice limit after the First Nation occupation (Pg 1121).
Conclusion
Industry says lack of trust in DFO is hurting them, the way I see it a lack of trust in the salmon farming industry is hurting DFO (Pg 172).
Thank you again for your decision to respect First Nations and remove salmon farms from the Discovery Islands over the next 18 months. I can see from local and international media and social media that this decision is both widely applauded and fiercely attacked. As much of this, good and bad, will be directed at you, it is important that you are warned about the defensive alliance of senior bureaucrats and scientists that surround the salmon farming industry within DFO. Their allegiance to the industry is stronger than their allegiance to your office. “Divided loyalties” Justice Bruce Cohen called it. They are as much a risk to your government as they are to wild salmon.
Your instinct will be to disregard my warning, no minister wants to hear that they cannot trust their staff. I understand. Fortunately, you don’t have to believe me. Canadians are extremely fortunate that a number of scientists, lawyers, environmentalists and First Nation members and chiefs are challenging the misinformation coming from DFO and the Provincial Ministry of Agriculture. In some cases, they have risked their careers to do this. They provide both evidence of the lies, but also the path to reinstating DFO as a leading agency capable of restoring the great fisheries of Canada. Listening to them will benefit your government enormously.
I believe, previous Minister of Fisheries, Jonathan Wilkinson, began this process, but perhaps it was more than he dared see to completion. Wilkinson made a point of talking to people who are on the frontlines of revealing the true impact of salmon farms and now your parliamentary secretary, Terry Beech, and MLA Fin Donnelly are picking up where he left off. You are going to hear things that are simply unbelievable. For example, the aquaculture loyalists within DFO will tell you that the virus PRV in most salmon farms is endemic and low risk, while other scientists, including some of your own, will tell you it arrived from the North Atlantic during the import of 30 million Atlantic salmon eggs and is causing heart damage in sockeye and massive cell rupture in Chinook salmon. Your lawyers and industry lawyers have sat together in courtrooms fighting First Nation and my lawyers to allow this virus to spread uncontrolled through wild salmon. This will be hard to accept.
You won’t hear anything from your aquaculture-allied staff about the bacteria Tenacibaculum, the cause of mouthrot, pouring out of salmon farms, over the gills of wild salmon, despite heavy antibiotic use, in the most critical wild salmon habitat. This is unconscionable given what we know about the virulence that develops in feedlot pathogens and their risk to wildlife and human health.
I was selected to examine the impact of salmon farming on Fraser River sockeye by Justice Bruce Cohen and with my lawyers Greg McDade and Lisa Glowacki sifted through the .5 million DFO documents provided to the Cohen Inquiry. This is where I picked up the thread of unethical abusive pressure applied to anyone in DFO who dares speak the truth about the impact of salmon farms. This is the same scenario that led to the collapse of the North Atlantic cod. DFO told DFO scientist Ransom Myers not tell the public that DFO’s fishing policy was driving one of the largest human food resources to extinction. He told me DFO is a criminal organization. Indeed, managing ocean fisheries to extinction should be viewed as a crime.
In 2019/20, your staff conducted “consultation” with several First Nations regarding new conditions of salmon farm licences. These nations asked me to sit in and I heard your staff tell them that stickleback, not salmon farms, are likely causing sea lice outbreaks on young wild salmon and that wild salmon are resistant to lice infection. I sat at your Fish Health Table over the winter of 2019/2020 to discuss what regulations would best protect wild salmon from farm lice. And I read your September 28, 2020 announcement that salmon farms are low risk to sockeye salmon in the Discovery Islands, as per Cohen recommendation #19. On that website someone in DFO wrote that Atlantic salmon are more susceptible to sea lice than most Pacific salmon. And yet, scientists within your department knew that sockeye are more susceptible to sea lice than Atlantic salmon. One of the scientists involved in this work sat at the Fish Health table and never mentioned this. Your representatives consulting with First Nations in 2019, never mentioned this work. It was not until the Discovery Island consultations that one of your veterinarians slipped this paper into the flood of documents provided to the nations and that is where I found it. However, it was not included in the sea lice presentation by your staff to the First Nation leadership.
This DFO sea lice paper acknowledges the contributions of Marine Harvest (MOWI) and Greig Seafood. This suggests that these companies, also at the Minister’s Fish Health table, knew the impact their rising lice infections were having on the collapsing Fraser River sockeye salmon populations and they said nothing.
After all these meetings, on March 1, 2020, your staff gave Mowi, Grieg and Cermaq permission for unlimited lice infections for 6 weeks every time they exceeded the limits set to protect wild salmon. As a result, these three companies were immune to charges last spring while Canadians lost a significant portion of the Fraser sockeye, Nootka chum and many other runs of wild salmon.
The problem you and your staff are facing is that the DFO policy to promote salmon farms is completely at odds with responsible wild fisheries management. They cannot control their lice, bacteria or viruses in open net pens. I believe this is why those who wrote the Constitution of Canada frowned on private fisheries - which salmon farms are. You can see the outcome of government protection of this private fishery in Norway where they sacrificed their wild salmon for salmon farms. Members of the Norwegian government came to Canada twice to warn us about this industry, Jon Lilletun, Parliamentary Committee on the Environment in 1991, and Georg Fredrik Rieber-Mohn, former attorney general of Norway in 2010.
DFO has become a division of the aquaculture industry, sharing staff, principles and the suppression of damaging information. As Justice Cohen recommended, I believe you will have to create a Regional Director of Wild Salmon to uphold management of wild fisheries. Whoever inhabits this position will have to understand the powerful science in your genomic lab - the key to restoring wild salmon-, be closely connected with First Nation leadership so as to work seamlessly with their fishery departments and have an awareness of the minefield that your department has become for anyone trying to maintain wild salmon.
I would like to offer a pathway through the scandal bubbling to the surface as we lose one of the most important global fish stocks.
Take the genomic science your department is developing to First Nations. Initiate highly coordinated sampling and enumeration of wild salmon as they migrate, and collection of environmental data on each habitat they pass through. Run these samples through your genomic lab run by Dr. Kristi Miller and make the fish and environment data generated open access, inviting the highly skilled fishery modellers in Canadian universities to find the pulse. Why have Canada’s wild salmon runs become unpredictable. Once we learn what the extinction drivers are, First Nations and municipal governments can work in concert with DFO to alleviate what stressors can be removed. The extraordinary power of this science allows us to ask the fish whether each intervention reduced the stress or not by reading their immune systems. In this way, the fish themselves become the ultimate authority. Making the data open access will guard against biased interpretation, i.e. the transparency your department already strives for.
However, none of this will work if you allow the culture of suppression to continue in DFO. I believe your BC Regional Director of Science, and your Science coordinator must be replaced. It is unforgiveable that in the face of extinction of the Fraser sockeye salmon that they did not bring forward the research warning us that the rising lice infections in the farms would have catastrophic impact on the sockeye.
As well, your aquaculture managers spread across BC, Ottawa and eastern Canada, should have zero influence on publication of research, research funding and access to facilities, such as the high-biosecurity tanks required to fully understand the impact of amplified aquaculture pathogens on wild salmon. I have read 10,000s of pages of internal DFO correspondence through the Freedom of Information Act and so I know what is going on. For example, in 2018 your Director of Science lost all the money to enumerate wild salmon and was never able to account for where it went. Thankfully your Regional Director stepped in at the last moment and found funds.
For example, research defining PRV as a disease agent and thus captured under s. 56 of the Fisheries (General) Regulations, sat on a desk in Ottawa for 7 years as the virus spread from salmon farms into wild salmon.
For example, your CSAS process edited out information that would have altered your September 28, 2020 announcement and classified salmon farms as high-risk to wild salmon.
Aquaculture has an important role, but DFO has destroyed its future in BC. If there had been strong regulation to protect wild fish, we would be the leaders in closed containment. Instead, the Canadians pioneering landbased fish farming have suffered under the shadow of three Norwegian operators. These foreign companies are facing charges in several countries across two continents for acting as a “cartel.” Mowi is facing loss of farms in Scotland due to environmental damages, charges by Chilean authorities for over production, as well as a $6 million fine for escapes and the highest cost for sea lice treatments in Norway in its history. This is an industry in chaos as it resists maturing into closed systems. Both the US Hedge Fund and Oslo stock analysists recommend purchase of landbased salmon farmer stocks. While here in BC the three Norwegian companies insist that they can’t evolve, they are determined to use the cheapest, dirtiest form of growing fish. BC is now producing the lowest grade salmon – neither wild, nor landbased.
I think the Canadian Pension Fund should rethink its heavy investment (5th biggest investor) in Mowi as this company is showing no capacity to keep up with the trend to isolate salmon farms from the wild fisheries it is damaging.
Minister Bernadette Jordan you have taken a brave step that no other Minister of Fisheries anywhere in the world has dared take. I see that you are also making strides to recover the North Atlantic cod. I certainly did not expect this when Trudeau appointed you as our Fisheries Minister. I thought you were too far removed from BC to understand the terrible situation here. I was wrong. You will face the wrath of the salmon farming industry, and you deserve all the support we can provide. We have everything we need to restore wild salmon and likely all the herring impacted by this industry and develop a highly successful landbased aquaculture industry. All we have ever needed is the political will.
The operation of eighteen salmon farm sites in the Discovery Islands region is under review through DFO consultation with 7 Nations that have overlapping territories in the Discovery Islands; Kwiakah, We Wai Kai, We Wai Kum (Laich-kwil-tach Nations) and Komox, Homalco, Klahoose, and Tla’amin. All the federal licences of these farms which are owned by Mowi, Cermaq and Grieg expire on December 18, 2020. DFO has to consult with the nations whose territories are being used by these companies.
The following farms are under review. Farms in grey are sites that have been inactive for ~ 5 years or longer. Each farm holds 600,000 – 1,000,000 Atlantic salmon, except for Yellow Island and Doctor Bay, size unknown, species Chinook and possibly Coho.
121059 Phillips Arm, Mowi 121058 Brent Island, Okisollo Channel, Cermaq 121057 Raza Island, Raza Passage, Cermaq
121056 Dunsterville Bay, Hoskyn Channel 121055 Sonora Island, Okisollo Channel, Mowi 121054 Bickley Bay, East Thurlow Island 121053 Thurlow Point South, Nodales Channel 121052 Brougham Point, East Thurlow Island 121051 Read Island, Bear Bay 121050 Cyrus Rocks, Okisollo Channel 121049 Young Passage, Sonora Island 121047 Doctor Bay, West Redonda Island, 622335 British Columbia Ltd. 121046 Yellow Island, Discovery Passage, Yellow Island Aquaculture (1994) Ltd. 121045 Barnes Bay, Sonora Island, Grieg 121044 Sonora Pt., Nodales Channel, Mowi 121043 Venture Point, Sonora Island, Cermaq 121042 Chancellor Channel, West Thurlow Island, Mowi 121041 Lees Bay, N. Shore, West Thurlow Island, Mowi
The area under consultation is roughly DFO Management Area 13, however, three salmon farms on Johnstone Strait, yellow dots (Map 1), were omitted from the consultation because DFO appears to be using its Fish Health Surveillance zone- 3-2.
Farm names, including 2 farms that appear to have had their licences cancelled, Farside and Egerton Creek, because they are not included in the consultations.
In terms of impact on migrating wild salmon, there is no biological reason to omit Shaw, Althorpe and Hardwicke. The majority of the farms in the Discovery Islands are owned by Mowi, Norwegian-based, largest salmon farming company in the world. Next is Cermaq, Norwegian – based company owned by Mitsubishi. One site is owned by Grieg Seafood, a Norwegian family engaged primarily in shipping. As well, there are two single farm companies that raise Pacific salmon presenting a different set of risks, i.e. switching to Pacific salmon is not a solution as genetic pollution becomes a serious problem, as Norway knows.
The 18 farms included in the consultation include 7 farms that have been inactive for ~ 5 years or more (black), 8 active farms (red). The 2 most southern farms are smaller farms. The primary impact on Fraser salmon is the 6 active Atlantic salmon farms.
Most of the sites are currently reporting over the 3 motile lice limit that was set by the Province of BC 15 years ago, as safe for wild salmon. This limit is only in effect March – June, which DFO considers the juvenile wild salmon outmigration time period, although in reality, the migration period is much longer, extending into September in some regions and some Coho and Chinook remain in coastal waters over the winter. Fraser sockeye appear to migrate the fastest and pass through the Discovery Islands from late May – June. However, high lice numbers now mean that the industry has a lot of work to do coast wide to get their lice under control before March. The federal government removed the incentive for the industry to reduce its impact on wild salmon by granting them unlimited lice numbers for 42 days every spring as the last of BC's young wild salmon struggle to get to sea through fish farm clusters throughout southern BC.
Broughton Archipelago
Of note, in the Broughton Archipelago, where First Nations have taken over the authority of removing and managing salmon farms from DFO, none of the farms have been over the 3 motile lice limit for this entire year. Broughton Nations have taken a much stricter approach to sea lice than DFO in hopes of protecting their highly damaged wild salmon returns during the last few years that they are allowing these farms to operate in their territories. While DFO is allowing the salmon farming industry to have an unlimited number of lice for 6 weeks during the juvenile salmon outmigrations in other territories, Broughton Nations do not allow this and industry has complied. It is likely that the salmon farming industry does not have enough boats to delouse all their farms and perhaps the industry is prioritizing stricter delousing in regions where they are concerned that First Nations will order their removal. 60% of juvenile salmon leaving Broughton Rivers were completely uninfected with sea lice, whereas 99% of juvenile sockeye that swam through the DI last spring were infected at levels we know will reduce their survival.
Options to protect the 2021 juvenile salmon out-migration from farm lice
The area of greatest impact on the 2021 juvenile salmon is Okisollo Channel. This is because it is a small area that young Pacific salmon aggregate in and three different companies operate 4 farms there. The smaller the area, the less dilution of the waste that is coming out of these farms and so the bigger the dose of bacteria, viruses and sea lice. Salmon farms are super-shedders and their impact is greatest in confined waters like the narrow, short Okisollo Channel. It is the difference between standing a football field away from a COVID positive person and sitting in a small room with the same infected person.
When my team and I sample for sea lice research, we always find a lot of young wild fish in Okisollo. It is part of their natural migration route and there is nothing we can do to keep them out of there. While all the Discovery Island farms are exposing young wild salmon to unnatural pathogen loads, Okisollo is the worst due to the number of farms, how confined an area it is and how many young wild salmon congregate there. We can't move the wild salmon, but we can move the salmon farms to stop the dangerous spread of industrial infections into wild populations.
Young sockeye migrating past salmon farm in Okisollo Channel, pass through the industrial biological waste from this operation.
Protective measures
Removing the 5 farms that have been inactive for years will sound good, but will do nothing to protect wild salmon.
Best option – remove all salmon farms from the Discovery Islands by March 1, 2021. This would give the extremely weak Fraser sockeye salmon the best chance of getting to sea
Second best remove all farms from Okisollo Channel by March 1, 2020 and apply the measures below to all remaining sites:
Remove the 42-day unlimited lice condition of Licence 7(c) granted on March 1, 2020 in the DFO Conditions of Licence March 1 Aquaculture This condition is a strong signal of "regulatory capture" meaning that while this keeps the salmon farming industry "in compliance" with their conditions of licence, it kills wild salmon. This is DFO at its worst.
Require weekly sea lice counts that include all lice life stages, not just “motile” (adult) stages so that we can see lice numbers building before they reach adult stages and begin reproducing and killing young salmon, and if the juvenile stage lice start escalating out of control - cull, not harvest the farm before the lice reach adult stages and start releasing larval lice into BC's biggest wild salmon migration route.
DFO and First Nation joint oversight of industry lice counts, because recent published scientific paper reports that if we let industry count sea lice on their own, they under count the lice by up to 50%, which delays treatment and kills wild salmon.
Agree on a lice limit that considers not only how many lice per farm salmon, but also how many farms are in the entire area. The more farm salmon, the lower the lice limit per fish. So if there is 1 farm in a region or 4 farms in a region the total lice in the water has to be the same, i.e. if there are 4 farms there needs to 1/4 the allowable lice on each farm, than if there was only 1 farm in the region.
As soon as any farm goes over the limit, the entire farm must be culled (not harvested as that takes weeks)
Prohibit wellboat delousing from releasing any effluent into the Discovery Islands during the spring out-migration. This is going to require third party monitoring as industry is saying different things about these boats 1.) that they cannot catch all their lice (Nov 1, 2019, DFO Fish Health Meeting) 2.) that they do catch all the lice coming off farm salmon during treatments (various presentations to First nations). So we won't know which is the truth unless we look for ourselves.
Research earlier this year off Port hardy found an average of 42 newly hatched sea lice on young sockeye salmon near the Mowi delousing vessel Aqua Tromoy during sea lice treatments. As this is 4 times higher than ever seen before in 20 years of sea lice research in BC, precautionary measures have to include restricting operation of these well boats.
I have the greatest respect for the seven First Nations who are in consultation with DFO over the future of wild salmon on the coast of BC.