Dear Timothy Sargent:
I am writing to you about a MEMORANDUM TO THE MINISTER titled Proposed Enhancements to Sea Lice Management in British Columbia that you appear to have signed with Kevin Stringer earlier this year.
This MEMORANDUM TO THE MINISTER recommends that the salmon farming industry Conditions of Licence (COLs) regarding sea louse control need to be strengthen due elevated risk to juvenile wild salmon. It states that the following steps are required to open the existing salmon farming licences and make necessary changes:
- A conservation concern has to be identified
- Or industry has to volunteer changes
I am writing because you omitted two other options:
- “A Direct order from the Minister of Fisheries and Oceans”
- Changing the Discovery Island Licences which are expiring this month
Two years ago, before the images of lice-eaten wild salmon in Clayoquot Sound streamed out on the internet, members of your staff were already trying to deal with what they considered a serious threat to wild salmon fisheries. In 2017, they drafted: Amending Sea Lice Licence Conditions to Better Manage Sea lice Threshold Exceedences (see below). They were clearly concerned that current conditions are too weak to make the salmon farming companies reduce their lice loads to meet the government threshold required to protect wild salmon.
They list 5 methods to re-open existing salmon farming Licences and strengthen them. Disturbingly, they note that one of the problems they faced is lack of support from DFO science. This is true. Despite dozens of scientific publications on the serious impact of sea lice from BC salmon farms on wild salmon, DFO continues to blame the tiny stickleback and the weather (Nov 21, 2019 meeting with First Nations). I never understood why DFO science remains unresponsive to the scientific the evidence until reading this internal memo. It would appear that as long as DFO science maintains that the salmon farms are not responsible for the devastating sea louse outbreaks on young wild salmon, it is difficult to open the Conditions of Licence to make sea lice regulations enforceable. This is very similar to the DFO science outlier position that PRV is not a disease agent and thus not subject to s56(b) FGR.
The specific reason I am writing to you is that this 2017 internal document offers two methods that could have been used two years ago to strengthen the sea louse Conditions of Licence that would have prevented the damage done to wild salmon runs in 2018 and 2019. These were omitted from your Memorandum to the Minister. I want to make sure that you and others are aware of them.
- Since the Discovery Islands fish farm licences expire every December, new conditions can be inserted immediately to protect Fraser River and other stocks.
- The 2017 internal document warns that this might trigger a judicial review as ENGOs or FNs “may have the position that all farms need the same requirement.” Good point, but 2019 is the lowest salmon return in the history of this country and you have a duty to Canadians not to allow these fish to go extinct.
- A “Direct order from the Minister of Fisheries”
A Direct order from the Minister of Fisheries is all that is needed to install enforceable regulations on all BC salmon farms to protect wild salmon fisheries. This should have been brought to the attention of then Minister of Fisheries, Jonathan Wilkinson.
As well, now that we know that the sea louse regulations for the farms in the Discovery Islands can be strengthened immediately, that needs to happen, because your own scientists are warning Fraser River sockeye are threatened with extinction.
It’s seems simple. If the farm exceeds the limit, impose a fine large enough that it becomes economically critical for the company to deal with it or they lose their license. The new Minister of Fisheries, Bernadette Jordan, needs to know that all we need to stop the loss of wild salmon fisheries to sea lice from salmon farms is a “Direct Order” from her.
I want to thank the members of your staff who are clearly trying to live up to the mandate that Canadians expect from DFO and who seem prepared to handle the changes to the Conditions of Licence.
Please advise when you have informed Minister Jordan and tasked your staff to strengthen the Conditions of Licence of the Discovery Island farms.
Thank you,
Alexandra Morton
Cc:
Adrienne Paylor
Dr. Ian Keith
Kerra Shaw
Joe Knight
Neil Jensen
Download A-2019-00392-Amending Sea lice COL 2017