Animal Advocates Watchdog

A letter to the Premier: Atlantic Salmon fish farms in BC waters

----- Original Message -----
From: Rafe Mair
To: judy@animaladvocates.com
Sent: Wednesday, December 08, 2004 4:49 PM
Subject: A letter to the Premier

I thought you should have a copy of the submission on fish farms I made, at his request, to the Premier. This contains opinions of the top scientists in the world and has been ignored, as have all other such presentations to this government.

View the letter here: http://www.rafeonline.com/fish/

I think it important that everyone in the Province understands that opposition to the government policy on fish farms is not some anti-government propaganda but based upon the best science in the world. As you will see, the government and the fish farming industry have been challenged to produce a single independent scientist to challenge the ones I and others have presented and they are utterly unable to do so - because there are none.

I believe it's critical that you not only read and consider this presentation but do as I have done - forward the link to everyone in your address book.

If you haven't been to Rafeonline.com lately please know that all my editorials are available at no charge.

Have a safe and happy holiday season.

Sincerely,

Rafe Mair
Host - the Rafe Mair Show
AM600, Vancouver, BC
www.rafeonline.com

The Letter
September 21, 2004

Dear Premier,

Thank you for giving me the opportunity to address the question of Atlantic Salmon fish farms in BC waters. I believe that you have been badly misinformed on this issue and that had you had time to examine it, as you did the Kemano Completion Project, you would seen that the threat of fish farms to our wild salmon is infinitely more serious.

As you know, I am no scientist. I am, however, a lawyer used to examining evidence and in my respectful opinion the present policy towards fish farms is dead wrong. On all the key points, environmental, financial and health the policy not only fails to make its case but the independent evidence is clearly against it.

I have confined this report to but two concerns – the escape of Atlantic salmon and their impact on native BC salmon and the impact of sea lice on migrating Chum and Pink Salmon, especially the latter, although contributors touch upon with other aspects. This means that I have not dealt with other important matters such as waste from the farms, impact of farms on other sea life, spread of disease or the healthiness of the product itself.

I do want to make just this comment myself. I have no political agenda and I’m not against aquaculture. Indeed, when Environment Minister in 1978-9 I encouraged the notion. I became concerned with Atlantic salmon fish farms back in the early 90s when the Department of Fisheries & Oceans declared that they couldn’t escape, if they didn’t, they couldn’t survive on the wild, if they did escape and survive they couldn’t enter BC Rivers, if they did all things they couldn’t spawn and if they did all those things, DFO could destroy the run (I believed the last statement given DFO’s record)

Briefly, on the question of the impact of sea lice, this came to my attention through friends in Scotland and Ireland and through first class fly-fishing publications. Then I heard from Alexander Morton.

You will no doubt hear from the industry and the likes of Patrick Moore that Alexandra Morton is not a fish biologist and this is true. Her science is no less accurate for that as Dr John Volpe and others will point out. The important thing is that not only is she a scientist, her methodology and findings have been peer reviewed and published in scientific journals. The sea lice issue is vexing because it has been settled in Norway, Scotland and Ireland that the impact is there such that in those jurisdictions extremely strict regulations have been implemented as to the number of sea lice per farmed fish is permissible – and these rules are strictly enforced. A louse is a louse whether it’s in the Atlantic or the Pacific. Indeed, the European findings are all the more frightening because the migrating salmon affected there are Atlantic Salmon and Sea Trout (Salmo Trutta) and the smolts are considerably larger, thus more robust, than the Chums and Pinks affected here.

On the question of escapes, the problem here is different from Europe where escaped Atlantic Salmon can and do breed with wild salmon and, if I might resort to scientific words, bugger up the gene pool. Atlantics, while they do not breed with Pacific Salmon, do occupy the spawning beds, are spawning there, with it only remaining to be seen if their progeny return to the river and themselves spawn.

Do not be fooled, Premier, by the statements that we tried to plant Atlantic Salmon here in the past and failed. Dr Volpe can, if you wish, deal with that succinctly and with finality.

I think, as I said, Premier, that you have been very badly advised. This is, of course, an occupational hazard of being Premier when you must accept what Ministries say. You will remember when we fought the Kemano Completion Project that it became abundantly clear that the Department of Fisheries and Oceans had become politicized with all the fine scientists that had cast doubt on the project having been sent packing one way or another. You will see reference to this in the presentation of Dr. Neil Frazer. (They were dubbed the “dissident scientists” by Alcan, a sobriquet they proudly bore). The DFO remains politicized and in fact has the mandate to promote aquaculture while, supposedly, protecting the wild salmon. I simply cannot believe that if you had been in full possession of the facts that this situation would have reached this sorry pass.

I believe that if the onus is properly placed, namely that the fish farm industry must prove beyond a reasonable doubt the safety of their industry, they would fail miserably. It is wrong that the onus is placed upon the public.

In the submissions, and in this foreword, I have added emphasis and said so – otherwise the emphasis is of the author himself.

I leave the subject with some names of scientists, fish biologists, you can easily contact. These are all independent of both industry and government. Your government and the industry have not, despite considerable urging, been able to come up with one independent scientist to contradict them.

Dr. Daniel Pauly (UBC Fisheries--- named by "Science" as one of 50 most influential scientists in the world)

Dr. Brian Riddell (Science Advisor, Pacific Fisheries Resource
Conservation Council- chaired by John Fraser who has peer reviewed Alexandra Morton’s research and findings.)

Dr Patrick Gargan (from Galway, Ireland who is responsible for dealing with the sea-lice problem there and who has peer reviewed Alexandra Morton’s research and findings) and with whom I have spent a number of hours privately.

In the interests of the Province we both love so much, I beg you to re-consider your government’s position.

Sincerely,

Rafe Mair

PS – There remains the question of how this presentation should be dealt with. All of the evidence I have presented is in published form so can hardly be considered confidential. On the other hand, it’s only fair that in light of your kindness in agreeing to accept my presentation, that I not make it public until you have had a fair chance to assess it. Would October 31 next seem fair to you?

Table of Contents
1. Precautionary Principle – letter from the Honourable John Fraser

2. Presentation of Alexandra Morton

3.Presentation of Dr John Volpe

4. Presentation by Dr. Neil Frazer

1. Precautionary Principle – letter from the Honourable John Fraser, Chairman of the Pacific Fisheries Resource Conservation Council to the Honourable Geoff Regan, Minister of Fisheries and Oceans of May, 2004
Precautionary Measures
While scientific proof is not yet absolute there is extremely suggestive circumstantial evidence that sea lice are associated with salmon farming. The Council believes that sea lice were associated with the decline observed in the Broughton pink salmon. Guidance on how to deal with the level of uncertainty faced in this case comes from the concept of the “Precautionary Approach/Principle.” This precautionary approach is a distinctive approach to managing threats of serious or irreversible harm where there is scientific uncertainty. The precautionary approach recognizes that the absence of full scientific certainty shall not be used as a reason to postpone decisions where there is a risk of serious or irreversible harm. Even though scientific information may be inconclusive, decisions have to be made to meet society’s expectations that risks be addressed. Once decisions are made they should be evaluated in light of evolving science and society’s chosen level of protection. When managing the oceans and its resources, Canada’s Oceans Act prescribes that the precautionary approach be applied.

The PFRCC recognizes the great difficulty, perhaps impossibility, of arriving at absolute scientific certainty regarding the cause of the pink salmon collapse.

The PFRCC recommends that the time for action is now. While recognizing that some may argue that more study be done prior to implementing any measures to protect juvenile pink salmon passage, the PFRCC concludes that such a strategy may lead to irreparable harm to the Broughton Archipelago pink salmon stocks.

The PFRCC recommends that Canada and BC undertake urgent actions to maximize the chance of safe passage of fish through the Broughton Archipelago during April 2003.

***

2. Presentation of Alexandra Morton
Curriculum Vitae of Alexandra Bryant Morton

Chronology

1957 Born in Connecticut, U.S.A.

1977- 1978 Volunteered at the Human/Dolphin Society with Dr. J.C. Lilly cataloged 2,000 audio recordings of dolphins (Tursiops truncatus)

1977 – Graduated Magna cum Laude from the American University in Washington D.C. with Bachelor of Science

1978-1979 Worked for Dr. Sam Ridgeway at Navel Oceans Systems Center on correlation of sound production of dolphins to physiological states.

Initiated long term field study in the Broughton Archipelago. Commence daily records on cetacean activity, begin 24h/d underwater acoustic monitoring continuing to present to aid in detection of marine mammals.

Expanded killer whale work to include influx of thousands of Pacific white-sided dolphins

Observe arrival of first salmon aquaculture farm

1997 Become Canadian Citizen

1999 Co-found Broughton Archipelago Stewardship Alliance with Eric Nelson and Kate Pinnsonault to hire and educate local people to assess, monitor, recommend restoration and restore small salmon-bearing creeks in the Broughton Archipelago.

2002 – Certified as a Registered Professional Biologist #1414

Presentation
The Trouble with Sea lice and Salmon Farms

The sea lice situation is very simple. Salmon farms have given sea lice a place to spend the winter that they didn’t have before. Naturally the sea lice which ride in from the open ocean on spawning salmon die when the fish enters fresh water. The species of lice of concern can only survive on a salmon, but there are so few wild salmon inshore during the winter that these sea lice have no place to over -winter. As a result no matter how many sea lice come in on the wild fish, they have no place to live and decline to near zero over the winter.

Today, sea lice infect farm salmon as the wild adult salmon migrate past the farms. Unfortunately salmon farms are ideal habitat for sea lice, a kind of winter lice spa. The high density and stationary farm salmon allow the lice to spread, just like head lice on school children packed into classrooms. To make matters worse the lights farmers use to increase the growth rates of their fish also stimulates lice growth and reproduction.

So come springtime, the lice in the farms are producing billions of larvae and the young wild salmon going to sea are thus infected. If the farms are lined up one after the other in long, narrow channels used by juvenile salmon, like in the Broughton, the lice numbers build up to absolutely deadly and unnatural levels.

To make matters worse our chum and pink salmon enter sea water much smaller than any other salmonid. So while it takes 11 lice to kill an Atlantic salmon, it appears to take 1-2 to kill a young pink or chum salmon. I am publishing a paper on this. When the salmon farmers use drugs to kill lice they cannot kill all of them, and because the pinks and chums are so susceptible, even “significantly” reducing lice is most likely completely useless. It doesn’t matter if a fish dies of 60 lice or 1, they are just as dead.

Furthermore the drugs used to kill sea lice also kills the young salmon’s food (published research) and will almost certainly affect the abundant shrimp and prawns (as it does lobster on the east coast). Shrimp and prawns fuel a prosperous fishery in BC, and specifically in the Brougthon. This is an issue building steam as prawns and shrimp vanish near farms using anti-lice drugs and the fishermen are certainly noticing.

The salmon farmers are being dishonest, denying the link between their farms, sea lice and the wild salmon collapses near their farms. They know this has happened in Norway where companies like Stolt adhere to very strict laws about sea lice. In Norway an operator with more then 0.5 female lice per fish is fined $10,000s daily, and will loose his license to operate and go to jail if he doesn’t comply. So for Stolt to line Tribune channel with enormous farms and then say they are not the problem is deceitful at best. From the MAFF sea lice counts we know there are farms in the Brougthon with an average of 10 sea lice per fish. For this they would be in jail in Norway. I believe they almost certainly know it won’t be long before the pinks and chums are gone and the problem solved.

Then DFO arrives on the scene. There are two teams within DFO. The Beamish team has made brilliant use of the wrong fishing gear, in the wrong place, at the wrong time to go out and find no lice. In Norway the trawl nets Beamish uses are known to remove lice by tumbling the fish down the nets’ tube. So they designed a “fish lift” to solve this. Other researchers in BC are using this state-of-the-art net, but not Beamish. Beamish has gone on to say fish with lice are more robust then ones without lice. This is ludicrous, denying a body of published science. I do not know why this eminent scientist wishes to destroy his credibility at this stage in his career, but among sea lice researchers worldwide he is a joke.

Then there is the Hargreaves DFO group using methods which do not de-scale, de-louse the fish. This team arrives early in the year when the sea lice picture is most clear. Not surprisingly my numbers and theirs match perfectly, because we are looking at the same fish. Therefore DFO is having increasing difficulty saying my work is flawed. Unfortunately their analysis to date has been clumsy.

One very important thing about sea lice is that you can tell how old they are. When you find lots of baby lice, you know you are near the mother lice. What other researchers outside of DFO have done is compare where the baby lice are to where the farms are and bingo the baby lice are reliably right at the farms. If you take the farm salmon out of the pens, the baby lice vanish from that site. If you go to an area where they are no farms, there are also no baby lice.

What DFO has failed to grasp is that this science has gotten away from them. Generally fish research is so expensive no one does it but DFO and we have to trust them. But sea lice are really easy and inexpensive to study and there is a small army of researchers earning their degrees doing just that. As a result an avalanche of peer-reviewed published science is coming which makes it very, very clear sea lice are coming from the farms and killing wild fish. DFO is the only group finding “opposite” results worldwide. And right behind this should come the lawsuits for destruction of the commons.

DFO can play games in the media about how difficult sea lice are to study and how they think the salt in the oceans is making lice etc., but they are increasingly inching further out on a limb that will not support them. Even the conflicting data from the two teams within DFO is going to cause them problems. In fact DFO is widely divided over this issue with enormous dissention in the ranks.

Now… once we prove sea lice are being enhanced and spread by farms to wild salmon, a Pandora’s Box of pestilence will be traced from farms to wild fish including the viral outbreaks of IHN. IHN is within the rabies family, it has been allowed to proliferate on salmon farms at levels and in places never recorded in natural conditions and in the viral world this opens the door wide to mutations. Just as the Avian flu is worrisome because mutation is expected which allow it to affect humans more than it has, farmed IHN is a great concern.

The solution to all these problems is so easily reached. Just separate the wild and farmed salmon and their pathogens….completely. Since we cannot move the wild fish, just move the farm fish into closed containment. Then both the wild salmon industries and the farmed can flourish. We can have both, why would we choose not to?

PUBLICATION RECORD

Refereed Publications

Morton, A. B., 1986. Sound and behavioral correlation in captive Orcinus orca. In: Kirkevold, B.C. and Lockhard, J.S. (eds.) Behavioral biology of killer whales. Alan R. Liss, Inc. New York. Pp. 303-333.

Morton, A.B. 1990. A quantitative comparison of the behaviour of resident and transient forms of the killer whale off the central British Columbia coast. Report of the International Whaling Commission. (special issue 12): 245-248.

Morton, A.B. 2000. Occurrence, photo-identification and prey of Pacific white-sided dolphins (Lagenorhyncus obliquidens) in the Broughton Archipelago, Canada 1985-1997. Marine Mammal Science. 16(1):80-93.

Morton, A.B. and Helena, H.K. 2002. Displacement of Orcinus orca by high amplitude sound in British Columbia, Canada. ICES Journal of Marine Science.

Morton, A.B. and Volpe J. 2002 A description of escaped farmed Atlantic salmon Salmo salar captures and their characteristics in one Pacific salmon fishery area in British Columbia Canada, in 2000. Alaska Fishery Research Bulletin, 9: 102-109.

Ford, J.K.B., G. Ellis, L. Barret-Lennard, A.B. Morton, R. Palm and K.C. Balcomb. Diet Specialization in two sympatric populations of killer whales (Orcinus orca) in coastal British Columbia and adjacent waters. Canadian Journal

Morton, A.B., and Williams R in press Infestation of the sea louse Lepeophtheirus salmonis (Krøyer) on juvenile pink salmon Oncorhynchus gorbuscha (Walbaum) in British Columbia,

Morton, A.B., Routledge, R., Peet, C. and Ladwig, A 20004 Sea lice, Lepeophtheirus salmonis, infection rates on juvenile chum and pink salmon in the nearshore marine environment in British Columbia, spring 2002 CJFAS

Non-refereed Publications

Morton, A.B. 1994/5 The Impact of fish farms on Marine Mammals, B.C. Marine Mammal Journal vol.2

Other

Morton, A.B. 1985. Humpback Retunion International Wildlife Sept/Oct.

Morton, A.B. 1987. Into the World of Orcas, International Wildlife.

Morton, A.B. 1987. The return of the humpback, Beautiful B.C.

Morton, A.B. 1990. The Play’s the Thing. Nature Canada.

Morton, A.B. 1990. Life Afloat on the B.C. Coast. Canadian Geographic

Morton, A.B. 1994. These Whales Have Gotten to Know Me, Smithsonian Magazine Nov.

Morton, A.B. 1996. “Dances with Dolphins”, Equinox. June

Morton, A.B. 1996. Salmon Farming’s Hidden Harm. Earth Island Insitute. Summer

Morton, A.B. 1996. Fish Farming – Growing too Fast? BBC Wildlife October

Morton, A.B. 1997 – present. From the Archipelago Wave-length Magazine regular column

Morton, A.B. 1997. Where the wild dolphins play. California Wild

Morton, A.B. 1998. Strangers on the shore. B.B.C. Wildlife July

Books

Morton, A.B. 1991 Siwiti – A Whale’s Story. Orca Books, Victoria

Morton, A.B. 1993. In the Company of Whales, from the Diary of a Whale Watcher. Orca Books Victoria,

Morton, A.B, 1998. Life Among the Whales. In: Intimate Nature. Chapter. Ballantine Books New York

Morton, A.B. and Bill Proctor. 1998. Heart of the Raincoast. Horsdal and Schubart , Victoria

Morton, A.B. 2002 Listening to Whales, Random House, New York April 2002

Research Projects

1984 – present long term monitoring of archipelago ecosystem with daily data collection on marine mammal presence and area usage and local rainfall.

1984 – present Record killer whale acoustics with concurrent voice track describing whale identification, behaviour and circumstances to create database large enough to find relationships between calls and other parameters. Photo-identification done on the whales and sent to Department of Fisheries and Oceans database on killer populations in British Columbia

1987 – present Initiated photo-identification of Pacific White-sided dolphins to examine social structure and site fidelity. Currently have records on 940 individual dolphins. Make recordings of these dolphins to conduct analysis similar to killer whale work. Finding an extraordinary repertoire.

August 2000 – Responded to fishermen’s reports of unusual numbers of Atlantic salmon in commercial catch by interviewing every commercial fisherman in range at every fishing opening to count 10,240 Atlantic salmon and examine stomach contents in 800 of these fish. (Paper with Dr. John Volpe under review)

2001-2002 – Responded to commercial shrimp fishermen’s report of unprecedented occurrence of an eye affixing copepod on sole by-catch. Collecting samples and shipping to interested expert in Mississippi for co-publication on this anomaly near salmon aquaculture pens.

- Responded to unprecedented appearance of lethal sea louse levels on juvenile pink salmon by finding an expert scientist partner, to study epidemic. (publication in progress).

2002- present – Initiate work on bacterial colonies beneath salmon aquaculture pens to create project with interested microbiologists (funding applications underway)

Government position

1996 – 1999 Representative and alternative representative for Broughton Archipelago, Malcolm Island and part of Cormorant Island (Area A) on Mount Waddington Community Resource Board.

***

3.Presentation of Dr John Volpe
Curriculum Vitae

John P. Volpe, Ph.D.

Department of Biological Sciences University of Alberta Edmonton, Alberta Canada T6G 2E9

Tel. (780) 492 3308 Fax (780) 492 9234 jvolpe@ualberta.ca

Education

Ph.D. Invasion Ecology. University of Victoria 2001

M.Sc. Molecular Ecology and Evolution. University of Guelph 1994

B.Sc. Zoology (Honours). University of Guelph 1991

Relevant Work History

Assistant Professor Biological Sciences, University of Alberta. 2001 - present

Lecturer ES400D Biotic Invasions. Developed and delivered this full credit, one-time offering. School of Environmental Studies, U. of Victoria, Sept. 2000.

Fisheries Biologist Management, conservation and restoration of B.C.’s freshwater fish. British Columbia Ministry of Environment, Lands & Parks, Fisheries Branch. Victoria, British Columbia 1995 - 1996

Research Interests

Ecology and social structure of marine-derived food production systems Ecology, evolution and biocultural impacts of marine introduced species affecting food production Marine restoration and relationships between measures of biodiversity and ecosystem function & resilience

Publications (graduate students in bold)

Peer-reviewed articles submitted, in review or in press

(A1) Volpe, J.P., B.R. Anholt, B.W. Glickman, D.W. Rimmer. Native juvenile salmonids do not constitute biological resistance to the colonization of Atlantic salmon in a British Columbia river: Implications for invasion. Transaction of the American Fisheries Society. In review

(A2) Krkosek, M., M.A. Lewis and J.P. Volpe. Fish Farms, Sea Lice, and Infestations of Wild Salmonids. Proceedings of the Royal Society of London, Series B. In review

(A3) R. Naylor, M. Mangel, K. Hindar, I. Fleming, S. Williams, J.P. Volpe, F. Whoriskey, A. Cooper, D. Kelso, J. Eagle, R. Goldburg, Fugitive Salmon: A Framework for Assessing Risks of Escaped Fish from Aquaculture. BioScience. Submitted

(A4) Volpe, J.P. Slow ecology. Conservation Biology. In prep.

(A5) Volpe, J.P. Johnson’s Grand Theory. Book review: Imperfect Symmetry: Thermodynamics in Ecology and Evolution by Lionel Johnson. Fish and Fisheries. In print.

Current Research Interests

Principal research interests in my lab are i) Ecological studies of food production systems, particularly aqua- and mariculture. These food production systems often include cryptic natural and social subsidies not reflected in the market value of products. I and my students are interested in quantifying these overlooked costs of production and finding ways for these to be realistically reflected in natural resource economies. The array of implications associated with aquaculture escaped Atlantic salmon in BC is a particular focus of the lab ii) Use of aquatic and marine bioinvasions to investigate processes affecting abundance, distribution and adaptive responses of organisms. Current studies examine invasions at multiple levels of organization, from individual based adaptive behavioural responses to shifts in selection regimes affecting population dynamics and genetic structure to large scale changes in ecosystem functions. The role of introduced brook trout in structuring population dynamics of rocky mountain rivers and defining interactions between Japanese oyster and eel grass beds are currently being investigated. Other ongoing research projects include the management of apex aquatic predators (walleye, pike) in large Alberta lakes and quantifying effects of culverts on boreal forest Arctic grayling population structure.

Presentation – Q & A with Rafe Mair
Rafe Mair - would you comment on the question of escaped Atlantic salmon

Dr. John Volpe: This is based upon 1% of BC rivers surveyed and of these, 1% of the river itself is surveyed. The clear assumption is that the numbers of escapes in BC rivers is bound to be considerably be more if proper surveys were done.

Three (3) systems to date have been documented (by me) to support juvenile, wild reared Atlantic salmon (AS) (two of which had multiple year classes). (emphasis mine-RM)

Over the past five years, river surveys in BC have been "haphazard" at best. Since I am no longer doing structured surveys, DFO no longer needs to be able to deflect those data and so have suspended any active work (a survey will only be taken when reports from the field are numerous enough that they cannot be ignored).

The states of Washington and Alaska, both of them being “high contracting parties” when the Salmon Treaty is debated, are initiating active AS survey programs in response to increasing numbers of AS in their waters.

Peer reviewed research now in the public and scientific record demonstrates:
- escapees can and do spawn
- wild reared juveniles successfully compete against and thus negatively affect native species
- impacts are density dependent (increases of Atlantic Salmon in BC waters increases their impact
The only real question is: what is the critical abundance after which damages are irreparable?

RM what about the question of sea lice?

JV Voluminous evidence documents salmon farm-derived sea lice as the major contributing factor responsible for local extinctions of European salmonids. This has been demonstrated in Norway, Scotland and the Republic of Ireland. BC wild salmon populations are at even greater risk because

i) farms are at much higher density here than in Europe therefore the "lice load" per unit area is much higher here than there. The farm configuration in BC would never be allowed in Norway or Scotland. The clustered array of farms is seen as necessary by farmers because all materials must be transported via marine vessels, which is very expensive. In other areas, terrestrial transport is an option therefore the farms can be spread out, allowing the lice/escapee/toxin/sewage footprint of individual farms not to overlap. The tendency to cluster farms in BC will only become greater as the price of salmon continues to fall in the face of increasing production (Chile and Norway, see economics section below) - this will undoubtedly lead to disaster. (Emphasis mine-RM)

ii) Pacific salmonid smolts, when they migrate and run the gauntlet of fish farms are much smaller in size (particularly chum and pinks), therefore because of their smaller size it takes fewer lice to injure kill an individual. Therefore, obviously, the more lice in the water + more susceptible species = gloom and doom

It must be noted that all government (DFO)/industry science to date has been explicitly designed not to test the hypothesis of farms as the major lice source. It’s as if they don’t want to know the truth.

RM - What about Social / Economic considerations?

JV - The contribution to the provincial GDP of the BC salmon farming industry is 8% while commercial and marine sport fisheries/processing contribute 50% therefore we risk 50% to save 8% (These numbers come from the Canadian Centre for Policy Alternatives and are available from their web page in a document authored by Dale Marshall). At the same time, foreign (Chile and Norway) production continues to climb steeply. Salmon (both farmed and wild) is worth ~ 20% of its value from a decade ago.
Therefore farmers must find ways of off-loading as much production cost as possible to remain viable. This has lead to tighter clustering of farms (see above), robotic farms in Clayoquot Sound, rationalization of the workforce etc. The big push to Prince Rupert is necessary to maintain the economy of scale to be competitive as Chile is about to double (author’s emphasis) production and drive the salmon price even lower! But in Chile because there are simply no environmental or worker safeguards, production cost is rock bottom. Chile has just announced a major markets initiative that will see Chilean salmon "invade" Canadian stores. This is essentially another off-shore / cheaper production scenario we have seen so many times before, except here the governments seem married to the idea of battling to the very end and the last salmon.

RM - Could you verify Alexandra Morton’s science?

JV - Hers is simply the most credible science available. This is not my opinion but that of the scientific community. (Emphasis mine-RM) Unlike her critics, Alex publishes in peer-reviewed journals, not on the web. To date, her work (and only hers) has stood up to robust independent scrutiny. (Emphasis mine - RM)

RM - Could you comment on the statements of Atlantic Salmon escapes, three according to the Hon. John Van Dongen, and two fish according to the Hon. Stan Hagen?

The journal Nature (the most prestigious scientific journal in the world) published last year that in Norway (where real, active escape monitoring occurs) approximately 2 million Atlantic salmon escape annually. And yet here, where the same companies operate, using the same technologies in almost identical physical environments, we have 2 or 3 escapees only....? If this were true the operations officers for these companies would be camped out here to find out our secret.....
I can't make a more quantitative statement than this, because there is simply no work going on to assay how many are escaping (and so if you chose to challenge these dolts (regrettably, he refers to Ministers Van Dongen and Hagen – RM) who throw out these ridiculous numbers and stood up and said "no, there are one million salmon escaping from BC farms annually", there are no data available to counter it and you both would be on equal (ie. non-existent) scientific footing).

4. Presentation by Dr. Neil Frazer
Curriculum vitae for Neil Frazer

Neil Frazer was born in Comox on Vancouver Island in 1948. Neil earned an engineering degree from the University of British Columbia, and a PhD in geophysics from Princeton University. He is currently a professor of geophysics at the University of Hawaii at Manoa. In Hawaii, a kayak is his vessel, but for the past ten summers Neil has used small open motorboats to explore the outer coasts and the inlets from Puget Sound to Glacier Bay.. Neil lives in Kailua, Hawaii with his wife and their three teenage children

Sea lice and science: notes for Rafe Mair
Summary: DFO should be stripped of any responsibility for fisheries science. In regard to salmon farms and sea lice, DFO has misled the public and their elected representatives in at least three fundamental ways:

(a) by pretending that the burden of proof is on the side that says sea lice transfer from farm to wild rather than on the side that says they don’t,

(b) by doing junk science, and

(c) by not supporting other scientists like Alexandra Morton and John Volpe who are doing the scientific work that DFO ought to have done. (Emphasis mine – RM)

1. How did you get involved in this?

I’m a scientist, but my hobby is travelling the coast. I’ve been all over the Broughton Archipelago, for example. In 2001 when DFO’s Don Noakes said DFO didn’t have the vessels to sample pink salmon in the Broughton I had to laugh. Some years ago I explored most of the Broughton in a 15’ boat.

The first sea lice epidemic in the Broughton (at least the first one we are aware of) was a chance for DFO to do a beautiful piece of science at very low cost. If they had done it they would have been heros. Sea lice transfer from farm fish to juvenile salmonids had been well known in Europe for over a decade, but was difficult to study because wild Atlantic salmon aren’t numerous, and wild, sea-run trout live their lives in coastal waters.

The epidemic in the Broughton was a terrific scientific opportunity because the salmon were pink salmon fry, which are small and easy to catch, there were millions of them, and they were migrating down inlets past the farms. All DFO had to do was sample above and below the farms, which is what Alexandra Morton subsequently did.

It’s unheard of for scientists to pass up a chance to do a beautiful piece of science at very low cost—especially when it’s the type of science that their mandate requires. When this happens, it almost always means that the institution they work for is rotten at the top.

The DFO guys did everything they could to avoid doing the obvious research: they delayed three weeks, they showed up with the wrong equipment; they sampled in the wrong places. Children might have done a better job. Don Noakes led this sham investigation, but Dick Beamish contributed to it. The only hero was the pathologist who refused to sign off on Beamish’s sea lice counts because “These fish were gathered in an unscientific manner.” (Emphasis mine – RM)

If DFO leadership had any scientific integrity Don Noakes (then director of PBS), Dick Beamish (former director of PBS) and Laura Richards (Regional Director of Science) would have been fired, and Wendy Watson-Wright (ADM for Science) would have offered her resignation to the Minister. In fact, nothing happened.

Another thing that got my attention was DFO’s attempts to halt and then discredit the research of John Volpe when Volpe was a graduate student at University of Victoria. For example: Volpe had been promised Atlantic salmon from PBS, and at the last minute Don Noakes, then the director of PBS, refused to give Volpe the salmon. Volpe had to begin his research from scratch at another location. In science one never interferes with the research of someone else’s graduate student, especially in such a way.

In these two affairs DFO scientific leadership has shamed the many honest scientists who work at DFO, it has shamed Canada, and it has shamed science. Noakes is gone, but Beamish, Richards, and Watson-Wright remain. They should be dismissed and replaced by people with no connection to DFO and impeccable reputations for research.

Since you can’t have orcas without salmon, Alexandra Morton’s reaction to all this was to stop studying orcas and begin studying sea lice. My reaction was to read the science on sea lice and to work on theories of parasite transfer between wild fish and farm fish. (On a personal note, I happen to be a tenured professor, and BC taxpayers paid for my education through government scholarships. I am not an environmentalist, and I have never received funding from any environmental organization.)

2. What else do you have against DFO?

For years DFO scientific leadership has allowed the salmon farming industry to fool the public, and has misled the public itself, by chanting that there is no proof of disease transfer from farm fish to wild fish. DFO had a duty to point out that, since elementary biology tells us to expect transfer, the burden of proof is on those who say it won’t happen, not the other way around. DFO also had a duty to either perform the obvious experiments to study transfer (I’ve written about these elsewhere) or at least admit that these experiments had not been done.

With regard to its communications to the public regarding salmon farming, DFO science leadership is like the guy who stops at a bar on the way home and loses his house in a poker game. When he gets home his wife asks him why he’s late and he says that he stopped at the bar. What he says is partly true, but it is not the important part of the truth.

DFO science leadership deserves public ridicule. They have had every chance to do the right thing, and they have consistently not done so. When politicians attempt to use government scientists to deceive the public, the scientists are supposed to protest or resign. (Emphasis added – RM) The education and all the professional activity of government scientists is paid for by the public, which asks only that they work on things they think are important, and tell the truth.

3. What about sea lice?

First lets look at theory

It’s a mathematical certainty that putting farm fish in the water will cause wild fish to decline through infections—we know this without ever putting a fish in the water—the only interesting questions are which infections and how much decline and when it will happen. The chain of causation goes like this:

Putting more fish into the ocean means more parasites per fish (because you’ve increased the spatial density of fish in the ocean) and more predation on wild fish (wild fish with more infection are weaker, and thus slower) and lower levels of wild fish. This would be true even if you put every farm fish in its own cage and separated them by miles. When you put thousands of farm fish in one cage, trouble from infection is very likely, though you still don’t know when it will happen.

Now lets look at experience

OK, so we know before ever putting a fish in the water that we are going to have disease problems, and transfer to wild fish is very likely, but without experience we don’t know exactly what form the disease will take or when it will hit. (Atlantic salmon had 217 known diseases at last count.) That’s where experience enters: from experience in Norway, Scotland and Western Ireland DFO knew that that sea lice is a huge problem. (They also knew that IHN is a big one, BKD is a big one, furunculosis is a big one.)

My point is that anyone who had been reading the scientific literature knew fifteen years ago that sea lice would be a problem for farm fish and that transfer was almost certainly harming wild fish. In other words DFO knew that sea lice would be a problem in BC even before salmon farming cranked up here. They knew that transfer from farm to wild would happen.

Example: sea lice at the Burdwoods salmon farm in July 2004

Paid spokespeople for the salmon farmers say that nobody visited that farm to investigate, which is not true. My wife and I visited that farm two days before the Greenpeace protest. The manager gave us a tour and we chatted with him and his assistant for over an hour. He confirmed that his fish have lice. He said that there were 660,000 fish on his farm and, in a sample of twenty fish, some fish had lice and one fish had five lice with eggs.

4. So what?

OK, lets do the math for some very conservative assumptions:

(a) one oviparous (i.e. egg-carrying) louse for every four fish

(b) 500,000 fish per farm

(c) 1000 eggs/louse/month

(d) 25 farms in the Broughton

The number of sea lice larvae going into the water per month is therefore (0.25)(500,000)(1000)(25) = 3.1 billion larvae/month.

Assume that only ten percent of those larvae survive to the copepodid stage at which they can infect fish. You still have 300 million copepodids going into the water every month, and most of them are going into the water right on the migration routes of juvenile wild salmon. It is unscientific to propose that the juvenile wild salmon migrating past farms are going to escape infestation unless you have very strong evidence for such a surprising result. Remember, the lice on the farm fish are the immediate descendants of lice transferred from the immediate ancestors of the juvenile wild salmon. The sea lice in question are specialized to salmonids, but they don’t care which species of salmon they infect.

We only know about pink salmon in the Broughton because pinks are easy to study (they emerge in the millions and they are easy to catch) but it is unscientific to suppose that coho and chinook are not being affected unless you have evidence for such a surprising result. Being relatively large compared to pink fry, chinook and coho juvenile will likely not die as a direct result of lice infestation, but they will be weakened and more vulnerable to predators. That is elementary biology. When juvenile chinook and coho salmon are infested, lice breed on them and put even more eggs into the water, so later-migrating juveniles have even more lice to contend with.

5. What about escapes?

This is John Volpe’s specialty, but I will give you my views. Yearly escapes of Atlantic salmon from BC salmon farms constitute a de facto bioinvasion as well as an ongoing sequence of introductions. Volpe et al. (2000) found juvenile Atlantic salmon of two year classes in BC's Tsitika river, showing that escaped Atlantics are capable of spawning under natural conditions in at least some Pacific streams. A consequence of their discovery is that that the probability P of colonization by Atlantic salmon in any given year is nonzero. By an elementary calculation the probability of colonization over n years is given by 1-(1-P)n which converges to 1 in the limit of large n. As very few streams in BC are carefully checked for Atlantic spawners, this probability calculation is retrospective as well as prospective. In other words, since farmed Atlantic salmon have been escaping in BC for over 16 years, the probability that they have already colonized is 1-(1-P)16. For example, if P is 1%, the chance that Atlantics have already colonized in BC is 15%, and if P is 2%, the chance that they have already colonized is 27%. (Emphasis mine – RM)

Bioinvasion by Atlantics, even in small numbers, is unlikely to benefit Pacific salmon. Spawned-out Atlantic salmon, known as kelts, may overwinter in rivers, creating further potential for pathogen transmission to emerging Pacific fry with naive immune systems. In a worst-case scenario Atlantic salmon may become carriers of an infection to which they are immune but to which Pacific salmon are not immune. This type of thing has been known to happen with introduced species of birds, for example.

6. Notes on people and their qualifications

Qualifications aren’t important for researchers like Alexandra Morton because research has to stand up to review by other scientists in order to be published. (Emphasis mine – RM) However, who you work for is important: University scientists are promoted depending on the esteem in which they are held by their fellow scientists, and little else. Industry scientists are promoted based on their contribution to the profits of that industry. How government scientists are promoted depends on the integrity of their leadership.

Since DFO has on many occasions punished scientists for publishing opinions contrary to those of the minister, the leadership of DFO can fairly be described as lacking scientific integrity.

Let’s look at some of the players.

Patrick Moore

Pat Moore is a paid public relations person for the salmon farming industry. Pat is paid to emphasize the part of the story that benefits his client. If Pat worked for tobacco companies, he would no doubt go around saying that there is a lower incidence of Parkinson’s disease in smokers, while failing to add that smoking promotes many kinds of cancers and greatly lowers life expectancy.

Alexandra Morton

Dislikes working on sea lice, and would stop in a moment if she could. If DFO science were not corrupted by politics, she would still be studying whales full time. Instead she is doing DFO science’s job for it. She has no PhD and no institutional affiliation, so her science has to be even better than usual to get accepted. It has been accepted; there is nothing left for her to prove. I’ve read her manuscripts in draft, and I think they are excellent by any standard. (Emphasis mine – RM)

John Volpe

He’s a scientific hero. DFO tried to sabotage and discredit his research, and he refused to be intimidated. I’ve read his papers and I think they are excellent. (Emphasis added – RM)

What about administrators? Although qualifications aren’t important for researchers (because their work is reviewed by other scientists) qualifications are important for those who administer science because (a) the public has trouble judging science, and (b) science administrators make important funding and personnel decisions which are seldom reviewed. The most important qualification for a science administrator is an excellent research record, as manifested by either fundamental discoveries or many peer-review publications. Of course a science administrator must have other talents, but without a good research record he or she will not enjoy the respect needed to attract good people to his organization, nor will he have the courage to stand up to politicians who try to capture his organization to support a political agenda. The lack of scientific qualifications of top DFO science personnel explains the worthlessness of DFO’s work on salmon farming and the capture of DFO science by the salmon farming industry. (Emphasis mine – RM)

Wendy Watson-Wright

DFO’s Assistant Deputy Minister for Science, in other words, chief scientist of DFO. Her qualifications: a Bachelor’s in Phys. Ed., a Masters in Exercise Physiology, and a PhD in Physiology. Watson-Wright should be replaced by someone with an excellent research record in fisheries science who has had no previous connection with DFO.

Laura Richards

DFO’s regional director of Science. Having a PhD and co-authoring a few papers does not qualify you to manage science. Richards should be replaced by someone with an excellent research record who has never worked for DFO.

Donald J. Noakes

Why was a guy with a degree in computer science (not biology) and only six first-author publications appointed director of what was once the most highly regard fisheries research institute in the world? This is highly unusual in science.

The most reasonable explanation is that Dick Beamish, the director of PBS before Noakes, didn’t want to be in the position of having to feed the public a lot of baloney about salmon farming, so, around 1992 he stepped down and let Noakes take his place. Noakes was Beamish’s friend; they cultivated rhododendrons and collected beanie babies together.

Noakes had gone straight into DFO from graduate school in engineering, so he was never part of an organization that valued scientific integrity. What he understood was sales engineering, in which you use the science you know to sell your product. He was a sales engineer for salmon farming.

Dick Beamish

Many publications. Order of Canada for research on acid rain done in his youth. Beamish has worked very hard at not being involved with aquaculture because he knows that if he is forced to say the kinds of things that the politicians want him to say, his scientific reputation will go straight into the toilet. The important thing is this: He’s the one scientist at DFO that the politicians could not have ignored or discredited if he had read them the elementary science on sea-cage salmon farming. Noakes was his protégé, but Beamish failed to restrain Noakes or protest Noakes’ actions. He cooperated with Noakes on the sham investigation of the sea lice epidemic in the Broughton. For the last fifteen years, at least, Beamish has taken the easy road by going along with the politicians. They rewarded him with the resources to continue his research on coho and climate. (He made a Faustian bargain and now the devil has come for his soul in the form of politicians who want him to lie for them.) It’s probably impossible to fire someone with the Order of Canada, so Beamish should be forcibly retired.

The scientists at DFO now “studying” the Broughton sea lice (Dick Beamish and Brent Hargreaves) are smart guys. They know that the sea lice on pink salmon fry in the Broughton almost certainly come from salmon farms. But they also know (see my remark above) that absolute proof is astonishingly difficult to get in science. This gives them lots of room to wiggle and protect the industry by doing inconclusive studies. Dragging around in the center of the inlets with a big trawl, for example, as Dick Beamish does. Brent Hargreaves notes that Alexandra Morton did not account for variations in salinity, and sea lice epidemics have not occurred on Muchalat Inlet. They ought to know that just because you don’t get an epidemic every time doesn’t mean epidemics are unlikely. For example, if you dress in black from head to toe and walk down the middle of the highway at night you may survive several nights, but that does not mean your activity is prudent.

It’s not possible to do good science when one is worried about protecting an industry. When I spoke recently with DFO’s Brent Hargreaves about his research on sea lice he said “You can’t shut down a multimillion dollar industry just because somebody waves a placard.” The fact that the industry, and its wealth would be a consideration shows that he isn’t really doing science. When you do science, you can’t think about who will be harmed by your research and you can’t think about the money; you have to just think about the science. (Emphasis mine – RM)

The irony is that DFO’s denial of the inevitability of disease has hurt the salmon farming industry itself. Tremendous numbers of farm fish have been lost to disease simply because farms were sited on the principal migration routes of wild salmon.

7. Why salmon farming?

South American people are poor. We buy their fish cheap and sell them to rich North Americans for a fat profit. The problem is North Americans aren’t familiar with South American fish and they don’t like eating little fish. So we grind up those little fish and feed them to farm salmon and then sell the farm salmon to North Americans. The protein conversion ratios are terrible, but one can still make a profit. The irony is that when you farm big fish by feeding them little fish, you concentrate the toxins. The smallest fish are really the safest ones to eat. Therefore, by farming salmon we starve South Americans and poison North Americans. Does this make sense for a province with valuable wild salmon that are increasing in value every year?

8. What should be done?

Strip DFO of any responsibility for science. Fund fisheries science through NSERC or some other independent body.

Communities and First Nations should have veto power over aquaculture. When different communities try different things, they learn from each others successes and mistakes. In science this is known as the robustness of distributed adaptive systems. It’s the opposite of having decisions about salmon farming centralized in Victoria and Ottawa.

Research open-ecosystem aquaculture. These are systems in which predators are not excluded, so that disease control is quick and inexpensive.

Put to rest the myth that fresh fish is better than frozen. Fish properly frozen at sea is better than fresh fish more than twelve hours old. The best chefs are finding this out, but myths die hard. BC’s wild fish are a tremendously valuable economic resource, and they are becoming more valuable every year. It is not an accident that prices for wild salmon have risen.

9. How did we get into such a horrible place?

DFO was created to bring scientists under the control of politicians. Prior to the creation of DFO, funding for fisheries science was funded through the Fisheries Research Board, an independent body of eminent scientists. (Emphasis added)

10. Why haven’t more scientists spoken out?

DFO is enormously powerful. You can’t take a fish out of the ocean without a permit from DFO. If scientists spent their time correcting nonsense statements by politicians, they would never have time to get any work done. The best Canadian fisheries scientists gave up on DFO in the 1980’s I think. (Note from RM -Premier, this goes back to the Kemano Completion Plan discussed above) They are just waiting for it to self-destruct.

Most biologists work for one government or another. They all have mortgages.

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A letter to the Premier: Atlantic Salmon fish farms in BC waters
Wild Salmon depend on removal of salmon farms from Broughton Archipelago!

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