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 One might be tempted to ignore Chief Johnson’s affidavit as unpublished.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