Submission 0840-LOWERY

Submitter: Brennan Lowery

Community: Burnaby

Date Submitted: October 3, 2023

Aquaculture-related pathogens, though lacking in data for the 2009 sockeye decline, adversely affect wild salmon populations throughout British Columbia and should be more intensively researched.

Summary: Aquaculture-related pathogens, though lacking in data for the 2009 sockeye decline, adversely affect wild salmon populations throughout British Columbia and should be more intensively researched. Part of the problem is the design of current fish farm health management guidelines, which must clarify policy goals and require fish health-promoting practices. As aquaculture grows more prevalent in the salmon economy, the Commission is uniquely positioned to encourage a more sustainable scenario in which government, fish farms, and the public coordinate efforts to deepen ecological understanding, adjust regulatory policy, and incentivize improved environmental performance in the industry.

Esteemed Commissioner Cohen,
As the Commission concludes, I would like to stress the role of aquaculture in future sockeye governance. Although other factors, such as 2007 marine conditions and climate change, have been more strongly linked to the 2009 sockeye declines in the Fraser River, the role of pathogens from fish farms should not be ignored. In order to improve management for the ecosystem, government, business, and the public, I urge the Commission to consider the following aspects of aquaculture’s ecological effects, health regulation regime, and potential for sustainable change.
Firstly, the deficiencies in information regarding pathogen transmission between fish farms and wild salmon must be addressed. As the Commission has found, the effects of aquaculture on Fraser River sockeye are still poorly understood. Nonetheless, disease prevails in many fish farms and has impacted wild stocks elsewhere. Across the Pacific Coast, outbreaks of sea lice (Lepeophtheirus salmonis) have affected many fish farms and spread to wild populations (Krkosek, Connors, Morton, Lewis, Dill, & Hilborn, 2011). For example, high incidences of sea lice in farms of the Broughton Archipelago corresponded with declines in wild salmon populations as large as sevenfold in recent years (Connors, Krkosek, Ford, & Dill, 2010).
Though this relationship is well researched for Pink and Coho stocks, a vast data gap for Fraser River sockeye infestations must be filled (Krkosek et. al., 2011). Of the two pathogens recently observed in sockeye, Parvicapsula Minibicornis affects large groups of the Fraser River stock but its levels in cultured fish is unknown (Atkinson, Jones, Adlard, & Bartholomew, 2011). The other, Ichthyophtheirus multifillis, has been detected in upper areas of the watershed, but it is unclear whether aquaculture is related to its prevalence (Traxler & McDonald, 1988). To understand aquaculture’s role in these pathogens, research must be directed towards farm infection levels and the mechanisms of transmission to wild sockeye (Stephen, DiCicco, & Munk, 2008). Therefore, it is recommended that the Commission urge government and private foundations to make grant funds available for deeper research on this relationship.
Secondly, the Commission should turn its attention to the inadequacy of current aquaculture health management policy. The regime that regulates fish farm health standards, the B.C. Ministry of Agriculture and Lands (BCMAL) Fish Health Program, does not regulate the ecosystem-wide effects of pathogens and farm practices that prevent disease (Stephen, DiCicco, & Munk, 2008). Instead, aquaculture health standards are very loosely defined, leaving each farm’s Fish Health Management Plan up to the operator’s discretion and focusing on disease outbreaks instead of overall fish health (Stephen et. al., 2008). Though the program regularly audits each fish farm, they only scan for a handful of diseases and ignore potential effects on wild salmon (Stephen et. al., 2008). The shortcomings of this regulatory process helped create the vast data gap surrounding the 2009 sockeye decline and possibly allowed unmonitored pathogens to slip between the nets.
Behind this program is a legal framework which fails to establish permissible thresholds for disease and overlooks small but continuous transmissions to the ecosystem (Stephen et. al., 2008). More effective disease prevention programs have succeeded by setting such thresholds and enforcing prevention protocol, such as adequate spacing, UV treatment of freshwater-phase tanks, disinfection of well boats, viral screening of smolts, intergenerational separation of fish, and even vaccination (Robertsen, 2011). As Robertsen (2011) demonstrates, a regime of this kind in Norway resulted in the virtual disappearance of infectious salmon anemia (ISA) in 1994. In contrast, The Fish Health Program rests on a vague legal framework that ignores the ecosystem effects of pathogens and fish health measures (Stephen et. al., 2008). For that reason, the Commission should push for the improvement of relevant policy on two levels. First, it is recommended that the aquaculture health regulation regime be redesigned to include acceptable thresholds of a wider list of pathogens and to introduce requirements for facilities based on fish health promotion. Though the practicality of regulatory tightening is limited given the industry’s political influence, industry capture can be hemmed in by well-enforced policies. Also, the Program should offer educational resources to farms which disseminate best practice, and recognize industry performance with awards to encourage health-promoting procedures.
A final concern is the changing nature of the salmon market. The 2009 decline was framed by the growth of aquaculture in British Columbia and worldwide (Stephen et. al., 2008). As wild stocks decline and the global demand for fish protein grows, provincial aquaculture is predicted to increase (Stephen et. al., 2008; Krkosek et. al., 2011). This means that fish farms will be an increasingly important component of salmon economics and conservation. In the dialogue about sustainable fisheries, aquaculture can be a potential source for solutions. As cultured salmon outpace wild catches in the province, fish farms and government must consider the broader ecosystem implications of their practices (Krkosek et. al., 2011). The industry must begin pursuing eco-certification that accounts for disease prevention and other practices, but it must be pushed by the public through demand for more sustainable fish products. Salmon farmers are ultimately responsible to consumers, who have the power to demand greater standards for farmed salmon via certification programs on the governmental and private level. It is recommended that the Commission push for certification programs to recognize industry leaders and incentivize all fish farms to pursue membership.
In conclusion, I submit to the Commissioner one final thought. As this inquiry applies the lessons it has learned, it must be remembered that the salmon upon which the province’s ecological and economic well-being depend are vulnerable to many forces, but they are most susceptible to the decisions that your Commission are able to influence. In order for the entire social-ecological system to be more resilient to debilitating events of this kind, its leaders must understand how ecosystems, humanity, and the structures which govern them influence one another. But they can only make good decisions if you, who possess such important knowledge, effectively impart that understanding onto them. Respectfully,

Brennan Lowery
Masters’ Candidate, Resource and Environmental Management
Simon Fraser University


Atkinson, S., Jones, S., Adlard, R., & Bartholomew, J. (2011). Geographical and host distribution patterns of parvicapsula minibicornis (myxozoa) small subunit ribosomal RNA genetic types. Parasitology, 138(8), 969-978.

Bradford, M. J., & Patterson, D. A. (2010). Infection of gill and kidney of Fraser river sockeye salmon, oncorhynchus nerka (walbaum), by parvicapsula minibicornis and its effect on host physiology. Journal of Fish Diseases, 33(9), 769-779.

Connors, B., Krkosek, M., Ford, J., & Dill, L. (2010). Coho salmon productivity in relation to salmon lice from infected prey and salmon farms. Journal of Applied Ecology, 47(6), 1372-1377.

Krkosek, M., Connors, B. M., Morton, A., Lewis, M. A., Dill, L. M., & Hilborn, R. (2011). Effects of parasites from salmon farms on productivity of wild salmon. Proceedings of the National Academy of Sciences of the United States of America, 108(35), 14700-14704.

Robertsen, B. (2011). Can we get the upper hand on viral diseases in aquaculture of Atlantic salmon? Aquaculture Research, 42, 125-131.

Stephen, C., DiCicco, E., & Munk, B. (2008). British Columbia’s fish health regulatory framework’s contribution to sustainability goals related to salmon aquaculture. Ecohealth, 5(4), 472-481.

Traxler, G. S., & McDonald, T. E. (1998). Ichthyophthirius multifiliis (ich) epizootics in spawning sockeye salmon in British Columbia, Canada. Journal of Aquatic Animal Health, 10(2), 143-151.

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