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 even 3 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).
[1] https://esajournals.onlinelibrary.wiley.com/doi/abs/10.1002/eap.2226
[2] https://pubmed.ncbi.nlm.nih.gov/30566268/
[3] https://www.dfo-mpo.gc.ca/cohen/recherche-aquaculture-research-eng.html
This is the outcome of the salmon farm Conditions of Licence issued March 1, 2020
[1] https://pubmed.ncbi.nlm.nih.gov/30566268/
[2] https://www.dfo-mpo.gc.ca/cohen/recherche-aquaculture-research-eng.html