Submission 0322-RUSSELL

Submitter: Mary Russell

Community: Port Hardy

Date Submitted: October 26, 2023

DFO’s draft new regulations for the aquaculture industry would loosen the bonds of environmental constraint on the industry and harmonize the various regulatory agencies, ministries and governments of Canada towards the goal of expanding aquaculture. Doing so could prevent the public from gaining the knowledge necessary to take corrective action. The decision to administer the regulations through Memoranda of Understanding emphasizes their lack democracy and accountability. It is hoped that the commission can rectify this state of affairs.

I find DFO’s draft new regulations for the industry terrifying, in that not only are the bonds of environmental constraints being loosened for the industry, but DFO is expressly “playing a lead role” in a stated objective to bring all regulatory agencies, ministries and levels of government across Canada into “harmonization” with its own agenda and stated goal– that open net-cage fish farming regimes in our waters shall expand mightily and shall ‘succeed’, period.

Throughout this document, DFO cites its goal to smooth the way for the industry to prosper, and one way this will be achieved is via ‘liaison’ between it and other governments and agencies across the country. I find this liaison between DFO and other regulatory bodies disturbing, for these could be subverted towards DFO’s goals for the industry, as seems to have already happened in Health Canada’s handling of Slice, and in Environment Canada’s truncating of reasonable Environmental Assessment processes. It seems to me this unnatural liaison could effectively tie the hands of intervention and public knowledge necessary to corrective action. Liaisons have apparently already been forged between DFO and Health Canada, Environment Canada, the Canadian Food Inspection Agency, and the Organic Standards Board. (In liaison with the OSB, the DFO has drafted regulations for the industry that would grant it Organic privilege, although by definition, the factory farming of anything precludes certification, and current fish farming regimes are a worst-case example of the ills of the practice.

Finally, DFO would have its new regulations administered via “MOUs” –those slippery, amorphous communications that allowed Ottawa and the Province to deflect public concerns one to the other and do nothing when the Province was in charge of the industry. I consider administration via MOUs to be DFO’s finishing touch to regulations devoid of democracy and accountability, and a terrible state of affairs I hope shall be redeemed under your investigation.

And should this rightful liberation come to pass, I have to say it will also be due to the enduring courage and limitless patience of our heroine of the Broughton, Alexandra Morton, whose science stands the test of time and the highest scientific scrutiny, and commonsense stands by her side as well, unbowed by the slings and arrows of political decisions.

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