Submission 0053-WOODWORTH

Submitter: Sabra Woodworth

Community: North Vancouver

Date Submitted: June 3, 2023

Provincial authorities appear to have failed to implement the recommendations of the 2000 and 2004 reports of the Auditor General of Canada. Now that the federal government is set to resume management of the aquaculture industry, the precautionary principle must be invoked to stop further risk to wild salmon on their migratory routes by moving fish farms onto land.

It has been noted that when the moratorium on fish farming was lifted by the Campbell government in 2002, the then minister John Van Dongen said:

“… B.C. now has the most comprehensive regulatory framework in the world, including science-based standards to protect the environment.”

“… We’ve worked very hard on these regulations to ensure that they do a proper job of protecting the environment in British Columbia… we are confident the regulations will do that and we are confident we have a regulation in place that is leading edge in the world.”

This suggests that in the two years since the Auditor General of Canada’s report in December 2000 on The Effects of Salmon Farming in British Columbia on the Management of Wild Salmon Stocks, the provincial government had implemented the recommendations of said report. However, one wonders whether provincial authorities had even read that report, for the subsequent Auditor General’s report of 2004 re-asserts the very same recommendations from 2000, noting the weakness of the provincial government’s coordination with federal fisheries re “inadequate” “regulatory approvals, enforcement, and monitoring of salmon aquaculture operations. This includes approving aquaculture site applications, assessing cumulative effects, and monitoring salmon aquaculture operations to prevent harmful destruction of habitat.”

It’s so easy to claim that all is right with the world when that is precisely what everyone wants to believe.

Both the 2000 and the 2004 recommendations follow:

2000: Chapter 30—Fisheries and Oceans—The Effects of Salmon Farming in British Columbia on the Management of Wild Salmon Stocks
Main Points
30.1 Fisheries and Oceans is managing the salmon farming industry on the basis that it poses an overall low risk to wild salmon and habitat. However, the Department is not fully meeting its legislative obligations under the Fisheries Act to protect wild Pacific salmon stocks and habitat from the effects of salmon farming. We found that the Department:

is not fully carrying out its current regulatory responsibilities to enforce the Fisheries Act with respect to salmon farming operations;
is engaged in research and is working with the Province of British Columbia (B.C.) to develop a regulatory framework for salmon farming, but there are shortfalls in research and monitoring to assess the effects of salmon farming operations; and
has not put in place a formal plan for managing risks and for assessing the potential cumulative environmental effects of proposals for new sites, should the decision be made to expand the industry.
30.2 There is an urgent need for the Department to address these shortcomings in consultations with the Province if their goal of ensuring the co-existence of sustainable salmon fishing with the farming industry is to be achieved. The Department has recently obtained additional funds, which it plans to use to respond to industry and public concerns. Some projects include habitat management, further study on the environmental effects of aquaculture operations on fish habitat, and the effects of farmed and wild stock interaction. The Department has also notified the Province of B.C. and the salmon farming industry that it intends to begin assessing all fish farm operations to ensure that they are in compliance with the Fisheries Act.

Background and other observations
30.3 This is our third audit since 1997 of the Department’s Pacific salmon management programs. In previous chapters we reported on habitat protection and management of the salmon fisheries. We found that loss of salmon habitat continued and that some wild salmon stocks were declining. Salmon farming has the potential to create additional stress on wild salmon stocks over time, especially if the industry expands. We found that the Department has not developed a plan to evaluate and manage the risks in the long term.

30.4 Reaching conclusions on the effects of salmon farming is difficult because there have been few scientific studies that apply directly to the B.C. situation. Recent scientific evidence of escaped Atlantic salmon reproducing in B.C. streams, and the potential for expansion of the industry, are raising new questions regarding effects on wild salmon stocks, including the cumulative effects on the environment and fisheries resources.

30.5 Atlantic salmon are raised initially in freshwater hatcheries, and at the juvenile stage they are transferred to open net pens in marine coastal waters in B.C. to complete their growth. They are harvested as adult salmon. It is while they are being reared in open net pens that possible interactions with wild salmon and their habitat can occur. Furthermore, open net pens are vulnerable to damage, which can result in escapes of farmed salmon.

2004 October Report of the Commissioner of the Environment and Sustainable Development

Chapter 5—Fisheries and Oceans Canada—Salmon Stocks, Habitat, and Aquaculture
Main Points
5.1 Overall, we are not satisfied with the progress made by Fisheries and Oceans Canada in responding to the recommendations we made in the three previous audits in 1997, 1999, and 2000. While many stocks are abundant, some Atlantic and Pacific salmon stocks are in trouble. We continued to identify significant gaps in managing risks.

The Department has not finalized the Wild Salmon Policy, which would set out clear objectives and guiding principles. The policy would also bring together biological, economic, and social factors—for fisheries and resource management, habitat protection, and salmon enhancement.
There are shortcomings in information on salmon stocks and habitat and scientific knowledge on the potential environmental effects of salmon aquaculture in aquatic ecosystems.
There are weaknesses in regulatory approvals, enforcement, and monitoring of salmon aquaculture operations. This includes approving aquaculture site applications, assessing cumulative effects, and monitoring salmon aquaculture operations to prevent harmful destruction of habitat.
There has been inadequate co-ordination between federal and provincial governments in managing fish habitat, undertaking research, approving aquaculture site applications, and sharing information.
Wild salmon and their habitat
The purpose of policy is to provide a broad framework for a shared vision to guide decisions and activities. Canada’s policy on salmon and salmon aquaculture should set clear objectives for managing both wild and farmed salmon and the interactions between them. At the federal level, Fisheries and Oceans Canada has been struggling since 2000 to finalize a wild salmon policy designed to conserve the genetic diversity of wild salmon and protect their habitat. Stakeholders have called for the policy to be finalized to clarify how conservation should be implemented and how fisheries should be managed. At the provincial level, British Columbia does not have a clear vision and an overarching strategy for wild salmon sustainability.

Two of our three audits noted gaps in policy implementation. Fisheries and Oceans Canada, for example, has never reported on the status of fish habitat conservation in Canada or assessed the effectiveness of its Habitat Policy. These continue to be significant challenges for the Department. Similarly, reporting by provincial ministries and agencies in British Columbia on performance relating to sustaining wild salmon is weak.

Insert 5.1—Lack of monitoring to prevent a harmful alteration, disruption, or destruction of habitat from salmon aquaculture operations
In November 2000, British Columbia referred an application to renew the tenure of a salmon aquaculture site to Fisheries and Oceans Canada for review. The Department was required to conduct an environmental assessment of the site.

Earlier in the summer of 2000, provincial officials had identified environmental concerns with the salmon aquaculture site. An initial environmental screening completed by the Department in June 2001 concluded that the existing site was causing significant adverse environmental effects. There was a significant build-up of organic waste material on the ocean bottom beside the facility. The sediment was black, sludge-like, and had a strong sulphide smell; there was a layer of fish feed found on top of the sediment.

In January 2002, the Department notified the operator of the site that a harmful alteration, disruption, or destruction of habitat had occurred, in violation of section 35(1) of the Fisheries Act. However, it did not take any enforcement action. In October 2003, it granted a ministerial authorization for the destruction of habitat under section 35(2) of the Act and accepted a remediation plan proposed by the operator.

= = = =
Given that the handing over of management of salmon aquaculture by the federal government to the provincial government has now been deemed inappropriate, and the federal government is to resume responsibility for this dysfunctionally managed business, perhaps we need to be thinking of how the precautionary principle might at this very late date be invoked to STOP further risk to our wild salmon on their migratory routes and make these farms truly a matter of agricultural policy ON LAND.

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