February 5, 2024
Dear Minister Diane Lebouthillier,
J'espère que votre année commence bien et en bonne santé. Nous vivons certainement une période tumultueuse et j’apprécie les personnes comme vous qui ont le courage de s’engager dans un leadership en ce moment de l’histoire de l’humanité.
As I understand it, all federal salmon farm licences in BC will expire by July 1, 2024 and your department is currently modifying the conditions of the licences you will issue to marine salmon farms before then. This is a bit confusing as Prime Minister Trudeau’s 2019 Mandate Letter, reaffirmed in 2021, included transition away from open net salmon farms by 2025 just 6 months after the licences expire. Hopefully the new licences will provide certainty and instruction on closure of the last of the open net salmon farms in BC?
As you prepare for this important decision, there is an issue that should probably be resolved so as to allow public confidence in your decision.
The entire premise of Canada granting salmon farms a licence to operate is based on a standard to ensure only minimal harm to wild salmon. To carry out this policy of minimal harm Canada tasked the Canadian Science Advisory Secretariat (CSAS) to assess the level of harm caused by sea lice from salmon farms. The resulting Sea Lice CSAS concluded that salmon farms are not a significant risk to wild salmon[1]. This was surprising. Scientists outside DFO widely report the opposite and so naturally these results elicited scrutiny.
I reviewed internal DFO Science communications to understand how Canada’s Science Advisory Secretariat could reach this conclusion. I found documents revealing that DFO scientists did link salmon farms to sea lice risk, but this conclusion was altered to suggest the opposite before it was included in the Sea Lice CSAS and before it reached your office. If true, this is an act of falsification which is defined as research misconduct[2] and research fraud[3]. This is a global problem faced by regulators[4] around the world. The definition of research fraud and misconduct includes:
- …. omitting data so that the research isn’t accurately represented in the record1.
- Any type of research fraud usually involves publishing conclusions, or even data, that were either made up or changed.[5]
No one wants this to be true, but the evidence is compelling. 16 senior scientists advised the Minister one year ago that there are serious problems with the Sea Lice CSAS report. On page 19 of their letter, we see how the results of the DFO sea lice study were altered internally.
If true, this activity lands squarely within the definition of research fraud - conclusions that were changed. Furthermore, these scientists warn: “statistically significant results were omitted” and that fits the definition of research misconduct. To resolve whether the Sea Lice CSAS can be relied on to achieve Canada’s goal of minimum harm to wild salmon, the scientists requested access to the data used to produce the CSAS so that it could be reanalysed. Open access data is a standard of science. It is accepted that scientific results that cannot be replicated are not trustworthy. Your office has strongly adhered to this principle in other science disputes.
The test for misconduct and fraud hinges on whether reinserting the omitted data reverses the conclusion of the Sea Lice CSAS. Specific to your June decision - would you, could you reissue licences to open net salmon farms if your science advisory secretariat concluded that farm lice are a significant risk of harm to young wild salmon? This critical measure of harm is embedded in the data used by the Sea Lice CSAS.
Inexplicably, the scientists’ request was met with silence from the previous minister.
What began as omission of significant data and the appearance of government tampering with scientific results, has escalated to blocking resolution of this serious matter by the office of the minister. How is the possible? I am bringing this to your attention 5 months ahead of your decision how to renew salmon farm licences in BC providing enough time for reanalysis of the Sea Lice CSAS data by the 16 scientists who brought this to the attention of your office. You will see in their letter they are leaders in Canadian fisheries science, from our top universities, serving on the editorial boards of international and Canadian scientific journals and working with First Nation governments. They have published decades of research into impact of industrial aquaculture lice on wild salmon. I don’t see how you can make your decision without knowing the result of reinstating the omitted data.
Wild salmon are elemental to the ongoing production of clean air, water and food by BC ecosystems and so Canada’s judgement on which risks these fish must endure has far-reaching consequences.
You will know better than me how this should be resolved.
Thank you for considering this matter.
Alexandra Morton
[1] “No statistically significant association was observed between infestation pressure attributable to Atlantic Salmon farms and the probability of L. salmonis infestations on wild juvenile Chum and Pink salmon in Clayoquot Sound, Quatsino Sound, Discovery Islands, and Broughton Archipelago” page 23, 4th paragraph
[2] https://ori.hhs.gov/definition-research-misconduct
[3] https://scientific-publishing.webshop.elsevier.com/manuscript-review/research-fraud-falsification-and-fabrication-research-data/
[4] https://theconversation.com/scientific-fraud-is-rising-and-automated-systems-wont-stop-it-we-need-research-detectives-206235
[5] https://scientific-publishing.webshop.elsevier.com/manuscript-review/research-fraud-falsification-and-fabrication-research-data/