Canada’s Response to Piscine Reovirus in BC
Briefing to Canada’s Chief Science Advisor, Dr. Mona Nemer, April 23, 2018
Alexandra Morton, independent Biologist
The evidence below is DFO’s own words: internal correspondence acquired through Freedom of Information requests. When I read these documents, they suggest that people in government knew for over a decade that the salmon disease HSMI occurs in BC and thus there was an understanding that piscine reovirus is a disease agent, which should have triggered Section 56, Fishery (General) Regulations. All farm salmon should have been screened for piscine reovirus and infected stocks prohibited from entering marine pens.
However, instead there is the appearance of government and the salmon farming industry collaborating to cover up the problem that PRV presents: that an industry with an 80% infection rate cannot operate legally in a country that prohibits infected fish from entering the ocean. Government/industry collaborative research teams never diagnosed HSMI despite unlimited access to BC farm salmon, but when a team of scientists that was industry – free was finally given access to the salmon in the farms they diagnosed the disease HSMI immediately.
My co-authors and I were the first to publish on the presence of PRV in BC. We report evidence that the virus originated in Norway and entered BC waters recently.1 We also report that PRV is spreading to wild salmon, and that it appears to reduce their ability to swim upriver to spawn,2 a finding echoed by other research3. There are only three groups publishing on PRV in BC and two are in close agreement.
Clearly, DFO is struggling with its mandate to sustain wild fish as evidenced by steeply declining fishing openings and the rising number of salmon populations recommended for listing under the Species-at-Risk Act. Of paramount concern, because the laws of Canada were not used to guide response to the discovery of HSMI in BC farm salmon, wild salmon have been unnecessarily exposed to high levels of this aquaculture-source virus for at least eight years and likely much longer since the arrival Atlantic salmon farming in the early 1990s.
I understand these are serious allegations of significant public interest. Others and myself have provided this information in varying formats to several levels of government without adequate response. Case in point, the Minister of Fisheries still refuses to test farm salmon hatcheries for PRV despite clear evidence that PRV is a disease agent and thus, by law, must test them.
Minister LeBlanc has gone so far as to ignore a Federal Court decision that he must test farm salmon for PRV prior to issuing transfer licences. This is unreasonable. It has been suggested to me that he is simply not aware that he is a co-defendant with Cermaq and Marine Harvest to get around the laws of Canada and allow Atlantic salmon infected with a highly contagious disease agent into BC waters. I can only suggest that he has lost control of his department to regulatory capture by industry at enormous expense to Canadians.
Allowing a foreign salmon blood virus to pour into Canada’s most productive salmon habitat seems a terrible consequence “divided loyalties” which Justice Bruce Cohen warned of, if DFO continued to be saddled with the dual mandate to “conserve wild stocks and to promote the salmon-farming industry.”4 Six years after the Cohen Commission into the decline of the Fraser River sockeye salmon have collapsed further, with no visible response from the Trudeau government.
This is how Canada lost its extremely valuable North Atlantic cod fishery5, by DFO ignoring its own scientists when policy and fact are at odds.
Brief Background
Heart and Skeletal Muscle Inflammation, HSMI, is a contagious salmon disease that spread through the Norwegian salmon farming industry for 10 years (1999-2010) before piscine reovirus (PRV) was identified as the causative agent (Palacious et al. 2010). During those 10 years, ~ 30 million Atlantic salmon eggs were imported into BC by the salmon farming industry with no understanding that PRV existed. While there is no clear record of import of salmon eggs directly from Norway into BC, MOWI is a strain of Norwegian farmed Atlantic salmon and is the most common farm salmon in BC6. Thus millions of eggs were imported indirectly from Norway into BC with no screening for PRV, as the virus was spreading rapidly in Norway in salmon farms owned by the same companies as currently operate in BC. Marine Harvest lists HSMI as one of the top three most damaging diseases to their worldwide production in recent years7. Marine Harvest is the largest salmon farming company in the world and in BC. Companies with Norwegian head offices run all the Atlantic salmon farms in BC Cermaq, Grieg Seafood and Marine Harvest. The strain of piscine reovirus genotyped in BC to date is considered Norwegian.8
Section 56 of Canada’s Fishery (General) Regulations prohibits transfer of fish infected with a disease agent into Canadian waters. PRV is a disease agent. The industry admits 80% of BC farm salmon are infected with PRV9 and that their industry would be “severely” impacted if they were not allowed to transfer PRV- infected fish into marine grow-out sites10. A 2009 BC Supreme Court decision ruled that it is the same ocean inside fish farm pens as outside11, which means Section 56 applies to marine salmon farms.
A Federal Court ruling instructed the Minister of Fisheries and Oceans to screen farm salmon smolts for PRV prior to issuing licences to transfer them from freshwater landbased hatcheries into marine pens12. Fisheries Minister Dominic LeBlanc refuses to acknowledge this ruling. The DFO bureaucracy continues to respond to PRV as if it was harmless. The evidence below suggests that this view was manufactured. As a result, there are now two more lawsuits against Fisheries Minister Dominic LeBlanc to once again try to get him to follow the law, which would protect wild salmon.
Citizens are using their own resources to make the Minister of Fisheries to obey the law.
Key revelation time line
These ATIP documents reveal that as the disease HSMI was repeatedly discovered by provincial and federal scientists in BC, industry exerted influence suppressing this finding and the Minister of Fisheries followed suit by refusing to uphold the law. DFO will not screen farm salmon for the virus known to cause HSMI and allows transfer of infected farm stock into Canadian marine waters.
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2008: HSMI diagnostic symptoms were identified in BC farmed Atlantic salmon by the provincial government fish pathologist at the BC Animal Health Centre (AHC) who conducts the farm salmon health audits.
Instead of reporting HSMI, a fish disease sweeping through fish farms in Norway, he consulted with industry. The industry veterinarians assured the AHC that it is not HSMI saying that the fish in the farms are behaving normally13. Norwegian companies run all the Atlantic salmon farms in BC and so are very familiar with HSMI. They do not use fish behaviour as part of the HSMI diagnostic in Norway as it is unreliable. HSMI was not reported, not even to the Cohen Commission into the decline of the Fraser River sockeye salmon.
2010: The Cohen Commission releases the AHC farm salmon disease records. I note mention of HSMI diagnostic lesions in some of the reports to industry and I start getting salmon from BC tested for PRV in 2012.
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2013: The AHC and Dr. Kristi Miller (DFO) received samples in 2013 from an Atlantic salmon farm, Venture Point, owned by Cermaq in the Discovery Islands. Miller diagnoses HSMI in that farm confirmed by eight qualified international salmon veterinarians. The AHC did not diagnose HSMI.
I co-publish the first scientific paper on PRV in BC reporting evidence that the virus was imported recently from Norway14.
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2015: A Federal Court decision rules that the Minister of Fisheries must screen farm salmon smolts for PRV prior to issuing licences for transfer into marine pens (2015 FC 575). Minister Dominic LeBlanc refuses to comply and with Marine Harvest, appeals this decision. Hearing date is set for May 2016.
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2014-2016: Three scientific papers are co-authored by DFO/AHC/Marine Harvest, which collectively suggest that HSMI does not occur in BC and that PRV is endemic to BC15. My co-authors and I point out flaws in Siah et al 2015, they respond publishing a correction admitting that they had “overstated” the evidence that PRV is endemic to BC16. My co-authors and I then publish a Formal Comment on Siah et al, presenting the evidence once again that PRV originated from Norway17.
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2016: Dr. Miller holds a technical briefing in May announcing the discovery of HSMI in a BC salmon farm. Industry is allowed to edit the DFO press release and downgrades “discovery” to, “potential evidence”. DFO presses pause on their appeal of the lawsuit and Marine Harvest follows suit.
Immediately after the briefing, AHC pathologist, Dr. Gary Marty emails Dr. Miller requesting credit for the discovery of HSMI in BC in 200818. This is a stunning reversal of the conclusion he co-published with DFO and Marine Harvest only a few months earlier in the scientific journal PloS One that HSMI does not occur in BC:
“Western North American PRV Fails to Cause HSMI”
Despite a DFO science discovery that PRV is causing HSMI in BC, the Minister of Fisheries still refuses to follow the law and refuses to test for PRV. I file a second lawsuit against for not screening farm salmon for PRV prior to transfer into marine pens. Marine Harvest petitions the court to join the Minister as a co-defendant and reveals that 5/6 of their hatcheries are infected with PRV and that their industry would be “severely” impacted if prohibited from transferring PRV-infected fish into marine pens19. Cermaq also joins a co-defendant.
This bears repeating. The Minister’s entire stance that PRV is harmless in BC is undermined by his own scientist. Marine Harvest admits 5/6 of their hatcheries are infected with PRV and the Minister still will not obey the laws of Canada or the federal court. As a result, Marine Harvest and the two other companies continue to put farm salmon into BC marine pens with no screening.
July 1, 2016, DFO grants the heavily PRV-infected salmon farming industry long-term licences to encourage investment20.
6. 2018: Namgis First Nation sues the Minister of Fisheries and Marine Harvest to stop the transfer of PRV-infected farm salmon into their territory.
The ATIPS
The highly redacted 2,914 page combined ATIPS A2016-203 and A2015-00948 chronicle DFO’s response to repeated discoveries of heart and skeletal muscle inflammation (HSMI) in BC farm salmon and the ongoing, 8-year internal suppression of this discovery.
Among these documents is the editing of an extremely rushed DFO risk assessment on HSMI (a CSAS document) produced in September 2015 with contributions from Miller, Marty and other DFO scientists21.
Here we see editing that purges evidence of HSMI from the document, despite attempts to reinstate it.22
In the end the CSAS document puts forward a conclusion that many knew was wrong, that “HSMI has not been reported in BC farm salmon”.23
The stated purpose of this CSAS was to support expansion of the industry, a direct benefit to the salmon farming industry and, in fact, DFO uses the CSAS document immediately on its completion to support their decision to licence another salmon farm in BC in Sept. 201524.
Today, DFO is proposing to hand fish disease testing to the Canadian Food Inspection Agency (CFIA), which has no mandate to protect wild fish.
A single sentence in a DFO draft “Questions and Answers” document provides the pivotal evidence that DFO had identified the problem:
“Eliminating PRV thus would be very difficult if not impossible,25
If PRV can’t be eliminated and 80% of the industry is infected and DFO’s mandate is
to promote salmon farming, the laws of Canada have to be subverted.
The evidence HSMI found in BC, but not reported
In 2016, Dr. Kristi Miller held a technical briefing on the discovery of HSMI in a BC Atlantic salmon farm. Immediately, Dr. Gary Marty, a pathologist working for the BC Animal Health Centre (AHC) in charge of farm salmon health audits for the province of BC and DFO, wrote her an email suggesting that he should have been given credit for discovering HSMI in BC farm salmon. This email appears to reverse the conclusion published by Dr. Gary Marty with industry, that HSMI does not occur in BC and therefore PRV is harmless to Pacific salmon and not a disease agent, and thus it would follow that screening for PRV is unnecessary as per section 56 of the fishery (General) Regulations.
“In February 2008, [REDACTED] provided BC vets a continuing education session that summarized the pathology of emerging European diseases in farmed Atlantic salmon. When she showed images of HSMI, I immediately recognized the lesions as similar to what I had been seeing microscopically in some BC fish” 26
The AHC decides not to diagnose HSMI after consulting with the industry.
“However, the aquaculture veterinarians said that they were not seeing a clinical pattern that was consistent with Norwegian HSMI (all the Atlantic salmon companies have Norwegian connection, so I assume that they are well aware of the clinical signs of HSMI). Therefore, we decided that what I was seeing was probably not the same as Norwegian HSMI. ”
Despite detecting an emerging disease causing significant losses to the global salmon farming industry, the AHC decides not collect skeletal muscle samples, which are required to diagnose HSMI, until 201427. Other than the company veterinarians, the AHC lab had exclusive access to the salmon in the farms and without skeletal muscle it would be impossible to diagnose HSMI in the farms.
Dr. Kristi Miller of the Strategic Salmon Health Initiative (SSHI) was given a brief window of access to farm salmon and immediately diagnosed HSMI. Dr. Marty goes on in his email to her.
“I do not want the SSHI to be seen as a project that takes credit for discoveries that were previously reported by other scientists. My understanding is that the SSHI team confirmed the presence of a disease that has long been detected in BC”24
In 201428 and 2015,29 Dr. Marty co-published two scientific papers with Marine Harvest stating that he did not find the disease HSMI in BC. In those papers he does not discuss that his method of diagnosing HSMI is different than what the international scientific community uses - that they decided to add a behavioural component to the published diagnostic for HSMI. Complete and thorough reporting of methods used is an immutable principle of science.
While the international scientific community diagnoses HSMI based solely on specific damage to the heart and skeletal muscle (lesions), Dr. Marty requires both the lesions and “clinical signs (e.g., fish are lethargic, eat poorly, and growth is slower than normal).” See excerpts of his email describing this in Appendix 1.
If Dr. Marty had adhered to the published, international definition of HSMI
(Kongtorp et al 2004, Mikalsen et al 2012, Palacios et al 2010, Biering and Garseth 2012) HSMI would have been reported in BC in 2008 and in 2010, when PRV was discovered as the cause of HSMI, PRV would have been designated a disease agent and farm salmon infected with this virus would have been prohibited from transfer into marine pens as per section 56 of the Fishery (General) Regulations and millions of wild salmon would not have been exposed to high levels of this virus from salmon farms year after year for the past 8 years.
If a Norwegian strain of PRV is found to reduce fitness of Pacific salmon, as suggested in two papers already, the cumulative impact of not reporting HSMI in 2008 could be significant, even catastrophic to wild salmon and Canada, as the country becomes vulnerable to lawsuits from wild salmon interests.
Dr. Marty is emphatic that he reported HSMI diagnostic lesions in BC farm salmon in 2013. He simply did not call it HSMI because the fish were reportedly not seen to be lethargic. He is very clear “these fish has inflammation of the heart and skeletal muscle, which are two features of HSMI.”30 In fact, those are the features that the rest of the world uses to diagnose HSMI.
While Dr. Marty suggests the behaviour of Atlantic farm salmon was inconsistent with the disease HSMI, i.) behaviour is not a published diagnostic for HSMI ii) it is unclear how this behavioural component of the diagnostic was collected, and iii) the record challenges the view that lethargy and emaciation are not occurring in BC farm salmon.
Who believes it is HSMI?
The opposing diagnoses between Miller and Marty caused internal DFO dialogue between senior bureaucrats as they tried to figure out which team to believe.
Dr. Marty writes “... the SSHI team [Miller] seems to be using a case definition for HSMI that is different from the HSMI case definition used over the past decade by the BC veterinarians.” (email to Miller and Brian Riddell May 23, 2016).
Dr. Miller writes “... Hugh Ferguson was the first pathologist to describe this disease in Scotland ... He is absolutely sure about this being HSMI, as are the Norwegians we consulted ... both experts on this disease...”31
Wayne Moore (Director General DFO) writes: “When I look at the ICES fact sheet on HSMI it would seem to support Kristi [Miller] and her team’s view that a diagnosis of
HSMI is based on a histological examination of changes in heart and skeletal muscle. No discussion about other clinical signs... What is the source of the contention?” (May 19, 2016 email to Jay Parsons, Stewart Johnson, Kyle Garver, Kristi Miller)32
Dr. Stewart Johnson (part of Dr. Marty’s team) casts doubt “I am not sure all of the epidemiologists on Kristi’s team would agree that it is HSMI (due to lack of clinical signs) although everyone agrees that lesions look like those seen in outbreaks of HSMI in Norway” (May 19, 2016 email to Heather Wood, Carmel Lowe, Mark Saunders)33.
Rebecca Reid (Regional Director DFO Pacific Region) writes to senior management about Dr. Miller’s findings “Results have been reviewed and conclusions are supported by 8 vets from Canada and Europe”34
Stewart Johnson persists: “At this point there is no agreement on a case definition of HSMI in BC... However, without clinical disease... it can be argued that the situation in BC differs from Norwegian HSMI, which makes calling it HSMI problematic for some” (May 19, 2016 email from Stewart Johnson to Jay Parsons, Carmel Lowe, Mark Saunders, Kim Houston)35
May 20, 2016 DFO technical Briefing with Drs. Miller and Riddell “Our two pathologists...identified a specific pattern of heart and skeletal muscle lesions that are diagnostic of heart and skeletal muscle inflammatory disease... And the piscine Reo-Virus was statistically associated with the development of the heart lesions.”
This is an important finding that informs us that not only did PRV exist in these fish; there was more virus in tissue where the lesions occurred than in healthy tissue.
Clinical evidence: does it exist in BC or not?
While Drs. Gary Marty and Stewart Johnson suggest there is no “clinical” evidence of HSMI in BC farm salmon, i.e. lethargy and emaciation, the following statements, despite extensive redaction, suggest otherwise.
“As for clinical signs, [redacted] as the veterinary sampler hired by our program wrote down the clinical data at the time of collection, and her notes do show [the next 8 lines of text - redacted] This is something that our program will further investigate.” (May 20, 2016 email from Kristi Miller to redacted recipients).36
The DFO Questions and Answers document on HSMI originally stated –
“As well, clinical signs of disease were observed over the same period, including slow swimming, fish off feed, chronic low-level elevation of mortality, and evidence of heart failure.”
However, Mark Higgins (Head of DFO Aquatic Animal Health Section), inserts a comment at the end of the above sentence and writes - “I think this sentence should be removed or changed as you do (next 6-7 lines of text - redacted).”37
While Dr. Miller was trying to communicate to DFO that the fish farm where HSMI was confirmed were exhibiting ‘slow swimming” and were “off-feed” Gary Marty is quoted shortly after she went public with the HSMI announcement saying,
“the fish that were identified in a study by Fisheries and Ocean’s Canada’s (DFO) Dr. Kristi Miller did not show signs of lethargy and poor eating.” 38
However, in communications with me, Dr. Marty states he has “not physically gone to ‘the BC salmon farms where fish with HSMI-like lesions are coming from” (email to me Dec 19, 2016). This suggests he is relying on second hand information, perhaps from the company vets. So in the case of the Atlantic salmon in the Venture Point farm in the Discovery Islands Dr. Marty, appears to say there is no clinical evidence of HSMI, while Dr. Miller who sent her own team members to the farm reports there is clinical evidence.
Visually, there appear to be many lethargic farm salmon lying motionless on the surface of the pens in many fish farms on the BC coast. (Venture Point 2016)
Can DFO diagnose HSMI in farm salmon?
The DFO effort to detect HSMI appears flawed and contradictory.
In August 2015, Mark Higgins writes: “PRV is a virus that seems to be ubiquitous, but
does not cause disease, hence we are only looking at the occurrences of PRV”39
Dr. Marty says the opposite: ”So even as PRV was linked to HSMI and HSMI became one the most problematic diseases in Norway – Canada did not check any fish with heart disease for PRV since 2009.”40 (2013 presentation at a science meeting in Port Townsend, WA)
Dr. Miller states: “It would have been impossible to report HSMI from any fish prior to April 2014 as there was NO skeletal muscle tissue and NO pancreas tissue, which are required to differentiate HSMI, CMS and PD”41
So Higgins (DFO) seems to say that DFO only tests for PRV not HSMI, Marty says where he finds heart lesions, he does not test for PRV and Miller says DFO couldn’t diagnose HSMI prior to 2014 because no one had the right samples. Wouldn’t it have made sense to at least collect the proper samples after recognizing the strong possibility that one of the most impactful salmon diseases known was occurring in BC in salmon farms among Canada’s wild salmon?
Where Miller’s team diagnosed HSMI, the AHC did not. Miller published her results without industry co-authors, Dr. Marty published with industry co-authors.
Perhaps the most alarming internal communication appears in a July 29, 2016 draft update on Aquaculture and Disease Related Research (Pacific Region)42 Dr. Miller reports an update on research into a jaundice condition in farmed Chinook salmon in Clayoquot Sound,
“The study showed that the disease was likely infectious, most likely viral in origin. Microbe monitoring established an association of the disease with PRV, ... Unfortunately this was the first reported detection of PRV in BC, and the histopathologist from the province convinced the industry not to sign off on the report (after many iterations) if PRV was to be included in the analyses”
A scientist doing pathology on farm salmon for the province of BC convinced industry not to allow the first report on PRV in BC to become public. And furthermore, evidence that PRV was associated with a new infectious disease in farmed Chinook salmon, in a region where wild Chinook salmon are in inexplicable decline was suppressed.
Salmon farming industry introduces doubt
When it was decided that Dr. Miller’s HSMI findings would be made public via a DFO technical briefing, perhaps due to the imminent appeal hearing that hinged on whether PRV is a disease agent in BC, the accompanying DFO press release went through substantive edits that removed certainty and introduced doubt.
May 17, 2016 Dr. Miller edits DFO press release – she strikes out “Preliminary finding” and inserts “First diagnosis” her comment defending this is completely redacted.43
On May 18, the press release reads: “First Diagnosis of Heart and Skeletal Muscle Inflammation (HSMI) in Atlantic salmon at a BC fish farm”44
Wayne Moore (Director General, DFO) writes: “Where are we landing on language... Potential detection, Discovery... Confirmed...” (email to Jay Parsons)45
Heather Woods writes: “Industry would also like to be kept in the loop on media lines and messaging” (May 18 email to Rebecca Reid).
On May 19, Stewart Johnson writes: “I spoke with Heather Woods (Senior DFO Policy Analyst) and she mentioned that the news release that is being used is the one that was revised by DFO, industry reps and others...”46
The press release went out: “Potential Diagnosis of Heart and Skeletal Muscle Inflammation in Atlantic Salmon at a B.C. Fish Farm”
Despite senior DFO staff knowing there was international consensus that the diagnosis was confirmed the finding was downgraded to a “potential” finding after editing by industry.
Minister of Fisheries fails to test for PRV
Despite confirmation by DFO science, that HSMI is occurring in BC and the 2015 Federal Court ruling that farm salmon must be tested for piscine reovirus before transfer into marine pens, DFO still refuses to this day to test farm salmon for piscine reovirus before transfer into marine pens.
July 22, 2016, “DFO’s Introductions and Transfers Committee (ITC) is not requiring testing for PRV or HSMI as part of applications to transfer salmon at this time. The department does not gather information on the presence of PRV or HSMI in relation to salmon transfers” (letter to Alexandra Morton from the DFO Introductions and Transfers Committee).
It is hard to view any of this as in the public interest, or in line with Minister LeBlanc’s mandate letter. To not gather information on one of the most damaging diseases in the global salmon farming industry does serve industry, but does not serve the public interest, “Divided loyalties”?
Because the 2015 court decision ruled that “the weight of evidence before this Court supports the view that PRV is the viral precursor to HSMI” and the Fisheries (General) Regulations section 56 prohibits transfer of fish with an infectious disease agent into Canada’s marine waters, the Minister of Fisheries and Oceans Canada appears to be breaking the law by not testing for PRV and thereby threatening wild salmon with a foreign virus47 that is highly prevalent in BC farm salmon48.
On October 12, 2016 I filed a Notice of Application against the Minister of Fisheries, Oceans, and the Canadian Coast Guard for not testing for this disease agent, “... that may be harmful to the protection and conservation of fish” as per section 56 of the Fisheries (General) Regulations.49
2017, my co-authors and I publish on the spread of PRV from salmon farms into wild salmon50 showing that significantly more wild salmon are PRV positive if they are exposed vs. less exposed to salmon farms and that infection may inhibit successful upstream spawning migration. Furthermore, we show that infection levels in farmed and wild salmon are linked.
Building misleading evidence in the scientific literature
Three scientific papers co-authored by government and industry collectively build a scientific basis suggesting that PRV is not a disease agent, that HSMI does not occur in BC, and that PRV is not from Norway, but all three fail to disclose their reliance on the novel, unpublished AHC diagnostic for HSMI. Clear description of methods is a founding principle of science. This is the only way results between studies can be compared. By not revealing their method, it is assumed they used the international HSMI diagnostic, however, had they used the international diagnostic, their conclusion on whether PRV is a disease agent or not would have been opposite.
2014 paper in Journal of Fish Disease51
Piscine reovirus in wild and farmed salmonids in British Columbia, Canada: 1974– 2013
G D Marty, D B Morrison, J Bidulka, T Joseph and A Siah
Journal of Fish Disease 2014
On May 28, 2014, Dr. Marty and others (including Dr. Morrison, whose salary is paid by Marine Harvest) submitted the above titled paper to the Journal of Fish Disease.52 It states:
“In British Columbia, the western most province of Canada, HSMI is not known to occur.”
However, we know that 6 years earlier Dr. Marty stated he recognized HSMI lesions in BC farm salmon53. These authors make no mention of this observation. They do not report their novel diagnostic method. They do not explain why they felt this method was superior to what all others reporting on HSMI use. This omission leaves readers to understand their diagnostics for HSMI were consistent with Kongtorp et al 2004.
This paper was summarized by the BC Centre for Aquatic Health Sciences:
“Importantly, the study confirms that the fish that carry PRV did not show any signs of disease, such as heart and skeletal muscle inflammation.” (https://bccahs.wordpress.com/tag/gary-marty/)
“We are happy to see that in B.C. piscine reovirus appears to be a harmless virus that’s commonly found in fish in the Pacific Northwest,” says Clare Backman, a biologist at Marine Harvest Canada.” https://bccahs.wordpress.com/tag/gary- marty/
Even if the authors did not find HSMI in this study, Dr. Marty knew that diagnostic HSMI lesions were occurring in BC farm salmon since at least 2008 and this is critical information that should have been referenced in the paper with an explanation why they chose not to call it HSMI, and a description of their unique, unpublished diagnostic method.
2015 Paper in PLOS ONE54
Piscine Reovirus: Genomic and Molecular Phylogenetic Analysis from Farmed and Wild Salmonids Collected on the Canada/US Pacific Coast
Ahmed Siah, Diane B. Morrison, Elena Fringuelli, Paul Savage, Zina Richmond, Robert Johns, Maureen K. Purcell, Stewart C. Johnson, Sonja M. Saksida
Co-authors from the Province of BC, DFO, US Government and Marine Harvest state
“... the Pacific Coast of North America, a region where HSMI has never been reported.”
However, in the email excerpted in Appendix 1 one of the authors of this paper states:
“I provided public information about inflammation in the heart and skeletal muscle of BC fish that was reported up to three years before Friday’s press release [May 2016]. This includes information what was reported in 2013 based on examination of fish from the same farm and same outbreak as that reported in the [Miller] press release. The information reported publicly in 2013 included, “these fish had inflammation of the heart and skeletal muscle, which are two features of HSMI.”
Again, there is no mention in the method section of this paper that they used the unpublished, AHC, unique diagnostic for HSMI and gave no explanation as to why they felt this diagnostic was superior to the one used by all other research teams internationally.
2016 Paper in PLOS ONE55
Piscine Orthoreovirus from Western North America Is Transmissible to Atlantic Salmon and Sockeye Salmon but Fails to Cause Heart and Skeletal Muscle Inflammation
Kyle A. Garver, Stewart C. Johnson, Mark P. Polinski, Julia C. Bradshaw, Gary D. Marty, Heindrich N. Snyman, Diane B. Morrison, Jon Richard56
This paper, submitted August 2015, includes among the authors, Dr. Marty (AHC) and Diane Morrison (Marine Harvest), as well as, senior DFO scientists Drs. Kyle Garver and Stewart Johnson and states:
“Western North American PRV Fails to Cause HSMI” as a heading on every page. “...western North America – a region now considered endemic for PRV but without
manifestation of HSMI ”
“...there is no known occurrence of HSMI [in western North America]”
However, in August 24, 2015, Dr. Marty wrote to Dr. Stewart Johnson, one of the co-authors: “I first identified HSMI-like lesions 7 years ago, in 2008.” 57 Therefore, their paper should have included why these HSMI-like lesions were not considered HSMI.
During the editing of this paper Gary Marty makes a “comment” “... we have rare cases of farmed Atlantic salmon in BC that have heart and skeletal muscle lesions but come from farms that do not have clinical signs consistent with the Norwegian description of HSMI. ”58 Dr. Marty thus appears to have used his novel HSMI diagnostic, which requires “clinical signs”, provided by the company veterinarians, but they do not reveal or describe this in their methods.
In the review received from PloS One, reviewer #1 finds the “The conclusions of the authors is premature.”59 Indeed, just a few months later DFO held a technical briefing on HSMI in BC farmed salmon, confirmed by 8 international veterinarians.
Norwegian collaborator express doubts regarding sockeye resistance to PRV
Dr. Kyle Garver, DFO Pacific Biological Station, lead author of the above paper, formed a collaborative relationship with Dr. Espen Rimstad from the Norwegian University of Life Sciences, and shared samples of BC piscine reovirus with him. When Rimstad reviewed the above paper stating that sockeye salmon became infected with PRV, with no immune response, Rimstad expresses considerable doubt.
The material below is from ATIP A-2016-01101.
The conversation begins in February 2015 with Espen Rimstad (Norwegian virologist) writing to Kyle Garver, (DFO virologist at the DFO Pacific Biological Station in Nanaimo) saying he is ready to receive PRV-infected blood samples. Rimstad states:
“The overall question is study whether the Canadian PRV induces HSMI or not”
He requests that the samples not be frozen as that is “tough for the viability of the virus”
The samples of PRV from BC arrive in good condition to Rimstad’s lab in Norway. Rimstad expresses surprise at the amount of PRV in Garver’s samples saying:
“We have almost never found Ct values below 15-16!”
The lower the Ct value, the more virus is present.
Garver writes to Rimstad on May 29, 2015:
“PRV really doesn’t seem to elicit or trigger an antiviral response” i.e. PRV doesn’t activate an immune response in Pacific salmon.
Rimstad answers that he finds it “Strange” that there is no antiviral response in sockeye to PRV.
“my first reaction would be: are you sure that the virus infects the fish” Rimstad goes on to say:
“Secondly, if the virus replicates well – and there is no [immune] response – you would perhaps expect the virus titer would skyrocketing – what should stop it from that?”
November 13, 2015 – Rimstad writes to Garver again, prefacing his comments with the statement that this is a “friendly inquiry”
“I am not convinced your Sockeye got infected with PRV”
“Without innate antiviral response there will be nothing stopping PRV from replicating or spreading in the Sockeye. Why did the virus titre in the Sockeye go down? If the Sockeye does not have any antiviral response, there is nothing stopping the virus from replicating, i.e. the titer should skyrocket, and not go down”
Rimstad proposes that Garver’s conclusions are inaccurate because the sockeye were not actually infected, i.e. it was not in their blood cells, but rather just adhered to the outside of the cells and thus this was not a real test of whether PRV causes disease in sockeye.
“As you see, I still have trouble to understand how the virus can replicate without the appearance of innate response from the cell... I hope I didn’t discourage you from publishing this stuff.”
Garver had already submitted his paper for review at PLOS ONE. It was accepted on Dec 14, 2015 without addressing Rimstad’s concerns and published in January 2016. In this paper he reports that PRV infects and replicates in sockeye, without causing disease. Marine Harvest is a co-author.
“Western North American PRV Fails to Cause HSMI“
April 2016, Rimstad says they would like to inform Garver on the outcome of the experimental challenge with the PRV from BC. His description of the results is redacted, but Rimstad goes on to say:
“I would not recommend to use energy about the question if PRV causes HSMI or not (i.e. if you need additional factors or not) we have firm evidence that this is not necessary.”
Rimstad says they should do the experiment again and make changes to the sampling schedule.
Nov 30 2016, Rimstad tells Garver he is going to attend the SFU Speaking for the Salmon Scientists Think Tank in January 2017 and asks Garver if he can present the preliminary test results run in Norway
Garver answers “I would caution against presenting the preliminary test at this time... It is also highly probably that the preliminary results would be picked up and distributed on a blog without sufficient context or worse a misinterpretation.”
These results, which have never been published, are of national interest.
Canadian Science Advisory Secretariat (CSAS) - HSMI
In 2015, DFO decided they needed to create a decision document on whether piscine reovirus and its associated disease, HSMI posed a threat to BC wild salmon.
In August 2015, Lesley MacDougall (CSAS) writes: To support the assessment of applications to transfer fish from hatcheries to net-pens, DFO Aquaculture and Fisheries Management has requested that DFO Science Branch provide advice regarding the potential impacts of transferring Piscine Reovirus (PRV) positive fish to the marine environment, particularly with respect to the potential for development of HSMI or other diseases.” 60
They are given 3 weeks to complete this – very rushed. Stewart Johnson is identified as the “lead”.
The completed CSAS document states:
“Given its lack of known association with disease on the West Coast, PRV is a virus that has not been routinely tested for by Aquaculture Management Division.”
“Assuming a similar presentation of HSMI in BC farmed Atlantic salmon as seen in Norway, veterinarians and/or government Audit Programs would have identified HSMI if present”
Is this an accurate representation of the state of knowledge at that time, and was the AHC government audit program collecting the samples required to identify HSMI?
Dr. Miller provided comments on various drafts
“... it would have been impossible to report HSMI from any fish prior to April of 2014 as there was NO skeletal muscle tissue and NO pancreas tissue, which are required to differentiate HSMI, CMS and PD. You need to clarify this, as it is a very important point.”61
“The description of the ‘clinical pattern’ needs to be included here – for some reason it was removed. What this really should say is that there were not clinical data available to assess whether these could be HSMI.62”
On Aug 19 the following text is deleted: “Additional information is needed from the
histopathologists who have examined these samples to understand how existing
cardiomyopathies and muscular pathologies are differentially diagnosed from HSMI
”63
Dr. Ian Keith (Field Ops Veterinarian, DFO) writes to Marilyn Hargreaves, (DFO): “... there are
no observations of weakness or reduced appetite on the farms in BC...”64
Dr. Miller writes: “Given that my previous comments had not had time to be incorporated, I
went through the entire document and made changes where I thought necessary...”
Five of her comments were redacted from the ATIP so we don’t know if these contributions made it into the final version, but it seems unlikely that comments that became public in the CSAS would have been redacted. As this CSAS document was being written, she was confirming HSMI in a BC salmon farm called Venture Point owned by Cermaq, sited in the Discovery Islands, Dr. Marty of the AHC also examined these fish he states that he also found HSMI lesions in these fish, although he never reported them in the papers he published. (See appendix one).
Miller writes to Carmel Lowe (DFO Regional Director of Science) and Mark Saunders: “I need to meet with both of you first thing next week” 65
Lowe asks Miller “what is the subject you wish to discuss” Miller answers “I want to discuss prv/hsmi CSAS.”
On August 26, 2015, Miller writes to one of the pathologists she is working with who diagnosed HSMI, Dr. Hugh Ferguson: “Given that I am a reviewer on the CSAS, and Ian Keith is a co-author, I asked him to ensure that the others writing the document were aware of these results, and I brought this up to my managers so that they were aware.”66
So everyone writing the DFO assessment of the impact of PRV in BC should have been aware that HSMI had been found in an Atlantic salmon farm.
The following text was deleted from a draft:
“There are. However, various reports of lesions that share similarities to those
described for HSMI, CMS, PD and the recently described disease of rainbow trout.”67
Despite Miller’s effort to inform Dr. Ian Keith (Senior DFO veterinarian), Carmel Lowe (Regional Director, Science, Pacific Region at DFO), all the authors of the study about HSMI and protect the integrity of DFO the published CSAS states:
“HSMI has not been reported on BC salmon farms” Sept 16, 2015, Michelle Rainer (DFO Communications Advisor) –
“I fiddled with the wording so it doesn’t say we test for HSMI, just that we would detect it if it were present.”68
However we know the AHC did not collect the proper samples to make this diagnosis until 2014 and then continued to use an published method of diagnosing HSMI, which required second hand information from the salmon farm veterinarians.
Sept 14, 2015 “Draft Media lines – CSAS Assessment on the impact of Piscine Reovirus” “Desired Sound bite”
“There is a low likelihood that the presence of PRV in farmed salmon would have a significant impact on wild Pacific salmon populations”
“HSMI has not been found in farmed salmon in BC. DFO’s strict audit requirements and monitoring programs would ensure detection of HSMI, were it present”69
In fact, DFO’s audit requirements failed to detect HSMI. It took a DFO research lab to diagnose HSMI, which they did immediately once they had access to the salmon in the farms.
Lawsuits
2013 I file a lawsuit with Ecojustice over the transfer of piscine reovirus infected farm salmon from a Marine Harvest hatchery, into a BC marine fish farm off Port Hardy, because such transfers appear to be an abdication of DFO’s mandate to protect wild fish and a violation of federal law, specifically section 56 of the Fishery (General) Regulations70.
2015 On May 6, 2015 I won. The Honourable Mr. Justice Rennie handed down decision 2015 FC 575 - DFO was unlawfully allowing the transfer of farmed salmon carrying diseases with the potential to 'severely impact' the wild fishery into salmon farms on the BC coast [72].
Rennie ruled that DFO was abdicating its legal responsibility to protect and conserve wild fish by handing off decisions about transferring fish with diseases to the salmon farming industry [83].
“The evidence, suggests that the disease agent (PRV) may be harmful to the protection and conservation of fish, and therefore a “lack of full scientific certainty should not be used a reason for postponing measures to prevent environmental degradation” [45]
The Minister sheltered behind Marine Harvest's evidence [37]
The point is that assertions made in order to bolster the reasonableness of the
Minister’s exercise of discretion cannot be made without evidence. [38] What the Minister cannot do is make unsupported statements of science.[39]
Federal Court Decision 2015 FC 575 http://alexandramorton.typepad.com/T-789- 13%20-%20Judgment%20and%20Reasons%20copy.pdf
2016 DFO and Marine Harvest appealed this decision, but adjourned their appeal in May 2016 just days before the hearing in advance of the DFO technical briefing on the discovery of HSMI in a salmon farm in the Discovery Islands. The appeal was officially dropped 7 months later.
I file another lawsuit against the Minister of Fisheries71 because he continues to refuse to screen juvenile farm salmon for PRV prior to issuing licences to transfer these fish into marine pens throughout wild salmon marine habitat, exposing wild salmon to high levels of this Norwegian virus72.
Marine Harvest and Cermaq petition the court to join the Minister as co-defendants, providing statements that their industry would be “severely” impacted if they were
not allowed to transfer PRV-infected fish into marine farms. Marine Harvest reveals that 5/6 of its hatcheries are infected with PRV.
This case has not been heard yet.
2018 The Namgis Nation filed a Notice of Application in Federal Court seeking a judicial review of the Minister of Fisheries policy not to test farmed salmon for the blood virus, piscine reovirus (PRV) prior to transfer into their territory.
“‘Namgis’ application for judicial review states that the Minister’s decision not to test farmed Atlantic salmon for PRV is unlawful, made in bad faith, and threatens irreparable harm to the already extremely depleted wild salmon populations in their territory, a resource that has sustained them for millennia. Furthermore, ‘Namgis states that the Minister’s PRV policy threatens the ongoing process of reconciliation in Canada.”
This application included an interlocutory injunction against the immediate transfer of Marine Harvest Atlantic salmon smolts into the Swanson Island farm in ‘Namgis’ territory.
This injunction was denied, but Justice Manson ruled that the way Fisheries and Oceans Canada and the aquaculture industry conduct themselves with respect to PRV constitutes a serious risk of irreparable harm on a number of fronts, including impacts to severely depleted salmon stocks and impacts to indigenous rights to fish.
Mr. Justice Manson noted that the lack of meaningful consultation with ‘Namgis was “particularly compelling with respect to irreparable harm”, but he ruled against ‘Namgis’ because Marine Harvest estimated that it could lose $2 million if the injunction was granted.
In my view, this matter would not be in court if Dr. Gary Marty had revealed the existence of HSMI lesions in farm salmon in 2008 and had included these observations in the subsequent scientific papers co-published with Marine Harvest.
The conclusions co-published with Marine Harvest set the premise for DFO’s refusal to recognize PRV as a disease agent, and thus the transfer of tens of millions of PRV- infected farm salmon into BC marine waters has occurred in violation of the laws of Canada.
Most troubling is the evidence that suppression of PRV began when it was first detected by DFO:
“The study showed that the disease was likely infectious, most likely viral in origin, Microbe monitoring established an association of the disease with PRV, but was not designed to establish what the nature of the relationship with PRV may be (cause,
opportunistic, co-infection, or other). Unfortunately this was the first detection of PRV in BC, and the hisopathologist from the province convinced the industry not to sign off on the report (after many iterations) if PRV was to be included in the analyses...” (Dr. Miller, SSHI page 59 of ATIP A-2016-01097).
Summary
The inability of the DFO audit program to detect HSMI vs. a DFO research lab’s immediate diagnosis reveals that there is a problem. The Minister of Fisheries’ refusal to abide by the laws of Canada also suggests there is a problem and the ongoing collapse of wild salmon stocks confirms there is a problem.
It would be difficult to read the internal DFO debate on piscine reovirus without a sense that the salmon farming industry is influencing DFO away from the regulations that are in its way. The industry has a big problem. If the laws of Canada had been enforced, an industry that is 80% infected with a prohibited pathogen has no place in Canadian waters.
The ‘Namgis’ are suing the Minister of Fisheries to stop the transfer of Atlantic salmon carrying PRV, a reasonable request when the wild salmon in their territory are among the most heavily PRV-infected on the BC coast73 and collapsing.
Amid this turmoil, a research team within DFO is developing extremely powerful tools such as genomic profiling, high-throughput microbe detection and virus disease detection that will significantly advance efforts restore wild salmon. However, it is increasingly apparent that the salmon farming industry views this lab as a threat. This first became apparent when the lab detected a mortality related signature in the millions of dying Fraser River sockeye that led to the request to test farm salmon for salmon leukemia virus. At that point Dr. Miller became a poster scientist for government muzzling of scientists74. We still have not heard what virus is linked to the epidemic prespawn mortality in Fraser sockeye75.
Consider Canada’s potential. If First Nation fisheries teams and others sampled wild salmon in a precise, coordinated manner throughout BC and these samples were provided to DFO’s genomic lab, cutting-edge research tools could be used to ask the salmon where they are running into trouble. We could use this information to strategically adapt our behaviour. In subsequent years we could ask the fish – did we make it better for you or not and the fish could tell us. This dialogue between people and fish would be unprecedented and extraordinarily powerful.
The world would come to Canada to ask how did you do this?
In addition to publishing on aquaculture viruses, I have researched the impact of salmon farm-origin sea lice on wild salmon for 18 years76. The same obfuscation by
the same players replays annually. The international community of scientists studying sea lice finds Canada amusing.
Salmon farming violates natural laws beginning with holding large populations of fish stationary while excluding predators that work to effectively control the spread of disease. Salmon farmers are such a powerful lobby that they have sidestepped the ongoing series of government recommendations made over the past 30 years that would have eased them to towards sustainability. As a result, the industry is now in serious trouble - they refused every door to a solution.
Washington State recognized the problem and acted. BC is the last region in the western North Pacific where marine Atlantic salmon farming is allowed.
The solution is to work with Canadians to take advantage of the new era of closed containment aquaculture and apply the made-in-Canada science to harness the power and resilience of wild salmon to restore them to the benefit of whales, climate change, the economy, reconciliation and humanity.
APPENDIX 1 – colour emphasis added
Excerpts of email sent by Gary Marty on May 23, 2016 that explains that he found HSMI in BC farm salmon in 2013, but did not report it because he uses a different definition of HSMI, than appears in the scientific literature. This email means DFO and the Province of BC knew HSMI lesions were occurring in BC farm salmon since 2013.
“I provided public information about inflammation in the heart and skeletal muscle of BC fish that was reported up to three years before Friday’s press release. This includes information what was reported in 2013 based on examination of fish from the same farm and same outbreak as that reported in the press release [announcing Miller’s diagnosis of HSMI]. The information reported publicly in 2013 included, “these fish had inflammation of the heart and skeletal muscle, which are two features of HSMI...
My understanding from our meeting on Wednesday is that the pathologists (Ferguson, DiCicco and Marty [Gary Marty] ) agree that the fish from the affected farm had inflammation of the heart and skeletal muscle, and we agree that these are the two morphological features of HSMI. The only difference is that the SSHI team seems to be using a case definition for HSMI that is different from the HSMI case definition used over the past decade by the BC veterinarians, which could be stated this way:
BC veterinarians - HSMI is diagnosed based on characteristic abnormalities in the heart and muscle, AND characteristic clinical signs (e.g. fish are lethargic, eat poorly, and growth is slower than normal).
SSHI researchers – HSMI is diagnosed based on characteristic abnormalities in the heart and muscle...
...I do not want the SSHI to be seen as a project that takes credit for discoveries that were previously reported by other scientists. My understanding is that the SSHI team confirmed the presence of a disease that has long been detected in BC. And, microscopic features of the 2013 outbreak report by DFO last Friday were first reported publicly by another researcher (me) in 2013. Reports from 2013 and 2015 have described disease in the heart and muscle of BC farmed Atlantic salmon, and pathologists at Wednesday’s meeting seemed to agree that it is the same disease as reported in the DFO press release. However, the BC disease was not previously called HSMI. What seems to be new is that the SSHI team now calls the BC disease HSMI” 77
1 https://virologyj.biomedcentral.com/articles/10.1186/1743-422X-10-230
2 http://journals.plos.org/plosone/article?id=10.1371/journal.pone.0188793
3 https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4227861/ 4http://www.cohencommission.ca/en/pdf/FinalReport/CohenCommissionFinalReport_Vol03 _02.pdf#zoom=100)
5 http://www.nrcresearchpress.com/doi/pdf/10.1139/f97-051
6 https://www.ncbi.nlm.nih.gov/pubmed/15670130
7 http://marineharvest.com/investor/annual-reports/
8 https://virologyj.biomedcentral.com/articles/10.1186/1743-422X-10-230 https://vimeo.com/70399899
9 http://marineharvest.ca/globalassets/canada/pdf/other-pdfs/piscine-reovirus-prv- information-sheet_gary-marty_2013.pdf
10 2017 01 20 - MR of Marine Harvest for Party Status.pdf
11 2009 BCSC 136
12 2015 FC 575
13 ATIP A2016-203, page 998 - May 21, 2016 email from Gary Marty
14 https://virologyj.biomedcentral.com/articles/10.1186/1743-422X-10-230
15 https://www.ncbi.nlm.nih.gov/pubmed/25048977 http://journals.plos.org/plosone/article/file?id=10.1371/journal.pone.0146229&type=printa ble
http://journals.plos.org/plosone/article?id=10.1371/journal.pone.0141475
16 http://journals.plos.org/plosone/article?id=10.1371/journal.pone.0164926
17 http://journals.plos.org/plosone/article?id=10.1371/journal.pone.0188690
18 ATIP A2016-203, pages 1010-1012
19 Court documents provided in application to join Minister of Fisheries as a codefendants
20 https://www.voyageforsalmon.ca/critics-say-fish-farm-licence-extension-reckless/
21 http://www.dfo-mpo.gc.ca/csas-sccs/publications/scr-rs/2015/2015_037-eng.html
22 ATIP A2015-00948
23 http://publications.gc.ca/collections/collection_2016/mpo-dfo/Fs70-7-2015-037-eng.pdf 24 ATIP A2015-00948 page 1793
25 ATIP A2016-203 Pg 227
26 ATIP A2016-203 Pg 999
27 ATIP A2016-203 Pg 761
28 https://www.ncbi.nlm.nih.gov/pubmed/25048977
29 http://journals.plos.org/plosone/article?id=10.1371/journal.pone.0146229
30 ATIP A2016-203 Pg 999
31 ATIP A2016-203 Pg 974
32 ATIP A2016-203 Pg 877
33 ATIP A2016-203 Pg 886
34 ATIP A2016-203 Pg 646
35 ATIP A2016-203 Pg 859
36 ATIP A2016-203 Pg 974
37 ATIP A2016-203 Pg 289
38 https://www.undercurrentnews.com/2016/06/06/british-columbia-scientist-rules-out- hsmi-disease-in-canadian-farmed-salmon/
39 ATIP A2015-00948 Pg 726
40 2013 presentation by Dr. Marty Port Townsend, Wa
41 ATIP A2015-00948 Pg 1016
42 ATIP A-2016-01097 Pg 5
43 ATIP A2016-203 Pg 669
44 ATIP A2016-203 Pg 750
45 ATIP A2016-203 Pg 713
46 ATIP A2016-203 Pg 858
47 https://virologyj.biomedcentral.com/articles/10.1186/1743-422X-10-230
48 http://marineharvest.ca/globalassets/canada/pdf/other-pdfs/piscine-reovirus-prv- information-sheet_gary-marty_2013.pdf
49 http://www.ecojustice.ca/pressrelease/minister-of-fisheries-and-oceans-sued-for-putting- wild-salmon-at-risk/
50 http://journals.plos.org/plosone/article?id=10.1371/journal.pone.0188793
51 https://www.ncbi.nlm.nih.gov/pubmed/25048977
52 http://bcsalmonfarmers.ca/wp-content/uploads/2015/02/PRV_Study_2014JFDarchival.pdf 53 ATIP A2016-203, pages 1010-1012
54 http://journals.plos.org/plosone/article?id=10.1371/journal.pone.0141475
55 http://journals.plos.org/plosone/article?id=10.1371/journal.pone.0146229
56 http://journals.plos.org/plosone/article?id=10.1371/journal.pone.0146229
57 ATIP A2015-00948 Pg 1,536
58 ATIP A2015-00948 Pg 1480
59 ATIP A-2015-00948 page 2524
60 ATIP A2015-00948 Pg 767
61 ATIP A2015-00948 Pg 1016
62 ATIP A2015-00948 Pg 2363
63 ATIP A2015-00948 Pg 1691
64 ATIP A2015-00948 Pg 2377
65 ATIP A2015-00948 Pg 1427
66 ATIP A2015-00948 Pg 1820
67 ATIP A2015-00948 Pg 2255
68 ATIP A2015-00948 Pg 2440
69 ATIP A2015-00948 Pg 2438
70 https://www.ecojustice.ca/pressrelease/morton-ecojustice-launch-lawsuit-over-transfer- of-diseased-salmon/
71 https://www.ecojustice.ca/wp-content/uploads/2016/10/2016-10-12-Notice-of- Application-Filed.pdf
72 https://www.ecojustice.ca/pressrelease/minister-of-fisheries-and-oceans-sued-for- putting-wild-salmon-at-risk/
73 http://journals.plos.org/plosone/article?id=10.1371/journal.pone.0188793 74http://www.vancouversun.com/technology/Ottawa+silences+scientist+over+West+Coast+ salmon+study/5162745/story.html
ATIP A2015-00948 Pg 825
75 http://science.sciencemag.org/content/331/6014/214 76 http://www.alexandramorton.ca/the-science/
77 ATIP A2016-203 Pg 842