Dear Senior DFO staff,
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.
Juvenile Sockeye Salmon Discovery Islands 2020 Heavily Infected
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.
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.
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.
Alexandra Morton
Independent Biologist
www.AlexandraMorton.ca
[1] https://pubmed.ncbi.nlm.nih.gov/2386969/
https://cancerres.aacrjournals.org/content/52/23/6496
[3] https://alexandramorton.typepad.com/alexandra_morton/2021/03/what-happened-to-the-fraser-sockeye-morton-submission-to-cohen-inquiry.html
[5] Download SL presentation_LM_sj
[6] A-2020-01561
[7] A-2020-01561
[8] https://www.nature.com/articles/s41598-020-78978-9