Dear Judge Cohen,
You are searching for the truth on why the 10 million sockeye did not return to the Fraser last fall, and why they have been dwindling for the last 10-15 years in spite of commercial fishermen being essentially tied to the docks. You are looking for ways to better manage them in future, and as such, are investigating current management regimes by DFO among other concerns relating to fish and fish habitat and rising sea temperatures. You invite public input that might help you understand what is going on , and what needs to be done and not done. I live here, and I have witnessed the behavior of the DFO in relation to fish farms vs the wild resource for the last 15 years, and neither respect nor trust is possible for this agency whose identification with the industry has led to its betrayal of our wild fisheries and the public trust. Let me count the ways:
DFO has consistently ignored the peril escaped Atlantics by the millions represent to the wild fisheries via introduced disease, such as the dread Norwegian fish virus ISA, that imploded the industry in Chile, and has now infected New Brunswick, and is otherwise sweeping the fish farming world. Fatal to salmon and herring and with unknown effects on other species, once introduced into our waters it is there to stay. ISA is now hanging over BC like a drawn sword because DFO and the Province refuse to halt the import of foreign eggs proven to carry it. How can our wild salmon survive such governance?
In the matter of escaped Atlantics, Mary Ellen Walling of the BC Fishfarmers Association wrote in the Times Colonist last Aug 11th, that Atlantics have failed to establish themselves on the BC coast, when in fact they are being caught in commercial fisheries from here to Alaska. A study by John Volpe of UVIC between 1998 and 2000, found farmed Atlantics in over 80 Vancouver Island rivers. In three of those, the Tsitika, Adams, and Armor De Cosmos, he found a total of 153 juvenile Atlantics that proved by lab analysis to be born in the wild, not escaped from the farms. The total number of Atlantics that could be breeding in our rivers is impossible to know, as funding for research is minimal to non-existent.
The growing presence of escaped Atlantics in our rivers are a direct threat to wild salmon via exotic or enhanced disease introduction and competition for food and habitat. This is especially applicable because Atlantic fry are bigger than native fry and more aggressive, and the adults do not die like Pacific salmon after spawning, but live to go back to sea and return again to spawn for several years. Atlantic fry also grow faster than native fry and hold longer in fresh water, and could during this time be preying on the wild native fry in lakes and rivers and then as they hold in the estuaries acclimatizing to salt water before heading out to sea. Why allow the risk of ISA? Why allow the danger of escapees in our rivers?
In its new proposed regulations, DFO has even put the fish farming industry above the laws of the Fisheries Act that govern and restrain the rest of us. Its new regulations would protect under the Fisheries Act "the alteration and destruction of fish habitat", and "the deposit of deleterious substances into the ocean". They would also legalize the industry's illegal consumption of millions of juvenile wild salmon, herring, sablefish and cod that swim into the net pens and not out again, and as well, the taking of any bird or animal that interferes with the success of the operation. Considering each farm can hold a quarter million hungry fish, I consider DFO's special protection of the industry's illegal bycatch a direct hit on the sustainability of our wild fisheries.
DFO's new regulations under its truncated environmental assessment frameworks are reactive rather than proactive, and its proposed "mitigation" of harmful consequences are a mirage. For instance, how could the arrival of the dread new fish virus ISA, and its thenceforth destructive presence in our waters be "mitigated" ? Or, how could the industry's intention to produce genetically modified, or worse, genetically engineered salmon, and the awful consequences of their subsequent accidental or deliberate release into the ocean, be "mitigated" ? And now we have the industry's refusal to release its disease and sea lice data with the apparent approval, even collusion, of the DFO. Do you not see how it is that we now consider the DFO to be perhaps the greatest threat our wild salmon face?
I have watched and listened and observed the disintegration of sound management under the hands of the DFO ever since it became infatuated with the expansion and 'success' of industrial fish farming in our waters. It is a blind and dangerous infatuation that must not be allowed to continue. Around the world, independent science concurs that open net-cage regimes are deadly to the wild resource. In Ireland their famous wild trout are but shadows of the past; in Norway they having to sterilize their rivers in efforts to combat disease introduced by escaped farmed fish, and their wild runs are dwindling. Sea lice there are now out of control, having become immune to Slice, the pesticide of choice. Everywhere today, the factory farming of salmon, as in the factory farming of anything, is upping pestilence and disease and destroying existing wild fisheries. In the matter of sea lice immunity, DFO is scrambling to have Health Canada design several new drugs to use alternatively for sea lice control. These would not be tested for interactive effects in the marine environment, nor for interactions on the food product itself. There is a paucity of credibility in every claim to benignity made by the industry and government together.
For instance, Slice, a toxic nerve poison, was banned for use in water or on human food before the advent of fish farming, but was then allowed for "emergency" use, which has continued 24/7 ever since. Its use does not legitimize its safety, yet Health Canada, on complaint from the industry that it was losing profits under the 68 day withdrawal period between treatment and slaughter of their fish, this summer removed the waiting time completely. Period. Yet it could not provide any data to support its removal of the waiting time. Does this sound like responsible management, and respect for human health and our glorious self-renewing wild fisheries?
The extraordinary return of sockeye this year shows how resilient are our wild fish, and that with due respect they could once again uphold coastal communities as they have since history began. Their amazing return also shows we know beans about how the ocean works, and that just as the ocean gives, so can it take away, and therefore that constant vigilance and the precautionary principle must be applied to their management. Their magnificent return does not exonerate the industry of harm. Many sockeye stocks within and without the Fraser are still down unaccountably, and it could well be disease from the farms sited in their migration routes that are doing them in.
This foreign owned industry in our waters has no business hiding from its host country information critical to the safety of our wild resource. DFOs apparent collusion with its refusal is untenable, and I implore you to find the truth that will set our wild salmon free from the industry's currently destructive regimes. With a multitude of others who care, I especially ask that you require the industry to release its disease records, all of them, from current back into the early 1990s when a dangerous strain of IHN was escalating in the farms. It is absolutely essential to finding the truth necessary to protect our wild fisheries.
Given the world-wide experience of their harm to existing fisheries, it is obvious the only place for farming Atlantic salmon is on land in closed containment systems that keep the farmed absolutely apart from the wild. Other nations do not have our magnificent five races of wild Pacific salmon coming home in staggered glory to feed man and nature freely and forever given due respect. We so blessed should not engage in competing for dominance on the world stage with factory farming, as has obviously taken hold at the political level in Canada.
We should instead, (if at all engaging in an industry that takes 2x the wild fish of other species to grow 1x of farmed product), engage in a modest Canadian owned and community involved industry that is respectful of our wild salmon and the golden chain of life they uphold. We should send the arrogant Norwegian industry home, and instead give encouragement to the Canadian closed containment industry that lacks only government boosting to succeed. It already has successful systems spurned by the Province and Ottawa that are taking off wildly in China. A responsible, diligent, Canadian owned, community involved industry might well fit in with the nature of things and a future worth having.
That is about all I have to say. I think the reform or dismissal of the DFO would largely solve the crisis facing our wild salmon and wild fishermen today.
Respectfully yours, and wishing you the courage and wisdom necessary to see our wild salmon saved.