Save Our Fish Foundation
c/o Odlum Brown Ltd.
1800 - 609 Granville St.
P.O. Box 10012, Pacific Centre
Vancouver, B.C. V7Y 1A3
Presentation by the Save Our Fish Foundation
to the
Leggatt Inquiry into Salmon Farming in British Columbia
Vancouver, B.C. October 9, 2001.
The Save Our Fish Foundation [SOFF] is a small organization with limited funding but a
large conscience and a strong will to speak out on behalf of fisheries resources and their
habitats. To cite our Mission Statement: “SOFF is dedicated to the protection, preservation, and
enhancement of British Columbia’s fish resource, on behalf of future generations for whom we
hold this birthright in trust”.
SOFF is guardedly supportive of fish farming. SOFF is cognizant of the enormous
economic benefits that can flow from a healthy fish farming industry. However, SOFF is well
aware that costs can be transferred from salmon farms to wild salmon stocks and their habitats
as a result of poor husbandry and lax stewardship. These costs and risks have not been
properly assessed or evaluated. Accordingly, SOFF’s support for salmon farming is conditional.
SOFF wants assurance that:
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sustainability1 be the vision that guides the management and further
development of salmon farming in BC;
the precautionary principle2 be the over-riding standard for management
of salmon farming;
farmed Atlantic salmon be neutered;
transgenics not be permitted;
regulation of the operation of the fish farming industry be comprehensive,
covering all risk factors;
the level of scientific research be appropriate to the risk inherent in this
new industry that has demonstrated the capacity to impinge on natural
eco-systems;
monitoring the operations of fish farms be thorough, consistent and to a
science-based standard;
penalties for violations be at a level that stimulates compliance;
The term sustainability is deemed to include ecological, economic and social sustainability.
The precautionary principle requires, inter alia:
- avoidance of changes that are not potentially reversible;
- identify and take measures to avoid undesirable outcomes;
- initiate corrective measures without delay;
- give priority to conserving the productive capacity of the resource where the likely
impact on the resource is uncertain;
- appropriate placement of the burden of proof.
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no new licences be issued or expansion of current farms be permitted
until there is capacity in the field to properly monitor and enforce
regulations;
new salmon farming licences that may be issued at some future time be
restricted to farming Pacific salmon species.
SOFF wants the stewards of renewable natural resources, the federal and provincial
governments, to fulfill their responsibilities wisely and effectively. Currently, the responses of
politicians and the fish farming industry to questions are frustrating. These responses assure us
that “all is under control”, or, “we have policies in place”, or, “we are even now planning to move
on this matter” and so forth. These responses are repeated over and over again, like a mantra.
Like a mantra, they resolve nothing. They do, however, stimulate public mistrust about the
motives of the industry and politicians. Many ask, for example, is DFO a conservation agency or
a development agency? It is questionable whether DFO staff are clear on the answer. The
dichotomy within governments is not limited to philosophy or strategy; it is implicit in funding
priorities. It is no secret that neither the provincial nor the federal governments have sufficient
staff in the field to do a proper job of monitoring and enforcement or undertake a comprehensive
scientific research program. Given the present financial climate it seems unlikely that there will
be much positive change in this situation in the near future.
I want to refer to closing comments I made over 25 years ago in an address to the
Northwest Chapter of the North American Fisheries Society in 1976. At the time I was in the
throes of planning the Pacific Salmonid Enhancement Program, better known today as the SEP.
I quote:
“In the long term, perhaps the richest tide of public benefits will flow from the
sustained commitment of the energies and creative talents of fisheries scientists to the
application of enhancement technology. Very rapidly this technology will develop and
grow. New knowledge will burst forth. New techniques will be developed. Old problems
will be resolved (and new ones created). Almost assuredly, salmonid enhancement will
carry fisheries resource management from fish ranching to the next stage, fish farming,
as breakthroughs in disease control, nutritional balance, food costs, genetics and
improved rearing techniques are achieved. Ultimately, the program should evolve into a
significant contributor to production of protein food in a world where supply of protein
food may be of critical importance.
The honing of technical capabilities is highly predictable. The honing of
managerial skills needed to ensure that the products of technology are wisely used is,
however, less clear.” End of quote.
The reason I raise this matter is that, never did I imagine that Atlantic salmon would be
the animal of choice for the salmon farms on this coast. The Fisheries Research Board of
Canada’s scientists of my day were opposed to the idea of introducing exotic species such as
Atlantic salmon to the Pacific. Fisheries Research Board scientists in my time had moved a
considerable distance from the enthusiasm of early 20th Century fisheries scientists to transplant
every conceivable fish species regionally, provincially and nationally. While there were
substantial transplants in the 1950’s, 1960’s and 1970’s, the pace slowed as the realization
grew that there are serious risks entailed and the dimensions and consequences of those risks
was unknown. The dimensions and consequences of risks remains uncertain to this day.
Section 5 of the 1988 Canada/British Columbia Memorandum of Understanding [MOU]
on Aquaculture Development committed both levels of government to recognize the need for
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orderly and responsible growth and development of aquaculture. This was to be done in order to
minimize the adverse effects of aquaculture on fish health, fish stocks, fish habitat and fishing
activities. Criteria and standards, the exchange of technical information and, yes, regulations,
were pledged as the tools of choice to achieve this end.
There are fine words in the 1988 MOU all aimed at ensuring there will be no harm to wild
salmon and their habitats. What is so profoundly disappointing, however, is that in actual
practice the risks inherent in salmon farming have been downplayed, if not ignored.
Consequently, risks have been foisted onto the natural ecosystem and, most particularly the
wild salmon. Why should that be? Government research funding until now has largely gone into
improving the efficiency of salmon farming. Reducing the risk to wild salmon up to now has
been limited by governments and the fish farming industry to denial that there is a problem and,
claims that even if there are problems they aren’t serious. And, even if the problems are serious
they are planning to deal with them. Voodoo science still plays a dominant role. The spirit of the
1988 MOU is vapourized.
Only very recently has the federal government directed research funds [$12.5 million
nationally] to what the Minister of Fisheries & Oceans described in a recent letter to SOFF as
supporting, I quote “priority research such as near-field and far-field effects of fish farms on
benthic habitat” end of quote. How much of that funding is committed to Pacific Region issues is
unclear. It is to be hoped that at the very least, adequate funding will be dedicated to a
comprehensive risk assessment study. Moreover, that the issuance of new salmon farming
licences will be held in abeyance pending the outcome of such a study and until competent
monitoring and enforcement capacity is actually in the field, not just on paper.
SOFF believes that there must be a much larger degree of certainty that wild fish and
their habitats will not be adversely affected before the salmon farming industry is allowed to
expand. In the meantime, precautionary measures must be introduced to ensure that the
birthing of this new industry is not the death knell of the old.
From another perspective, an international scientist, Dr. Helgi Thorarensen of Iceland,
posed important questions at the Aquaculture and Protection of Wild Salmon Workshop of
March 2, 2000 convened at Simon Fraser University. He asked, and I paraphrase him, Why
have we in B.C. turned to Atlantic salmon for our fish farms when Pacific salmon are unique in
the fish farming industry? Why, he asked, do we choose to compete against the many other fish
farming nations with a product identical to theirs when we can do so with a unique British
Columbia product and do so with less biological risk? These are good questions that remain to
be answered.
I think many will remember the Klondyke fever that pervaded the development of salmon
farming in the early and middle 1980’s. Unbounded optimism ruled. Much of that optimism was
misplaced and gave rise to serious problems that we live with today. There are more than
enough danger signals to warrant a precautionary approach to the reform of current practices
and control of future growth. However, SOFF has profound concern that an inheritance of
unrestrained optimism may still guide political decisions to this day.
It is unclear why a provincial government that has promised to end subsidies would want
to continue to subsidize the salmon farming industry or even contemplate subsidizing its
expansion. Alienation of property from public use without adequate rent; allowing waste disposal
from farms to despoil natural habitat that is common property; funding research to improve
operational efficiency; and, the assumption of major environmental expenses are examples,
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SOFF suggests, of undesirable subsidies. Given the new provincial government’s stated
commitment to end old ways of doing business, it is timely to initiate significant changes.
The provincial government should move more quickly towards setting out new
scientifically based standards and criteria designed to minimize the risks and costs to wild
salmon. The provincial government should put in place the capacity to properly monitor and
enforce. The provincial government should only licence new farms that have the capacity and
the will to meet those new scientifically based standards and criteria and then, only when it has
the ability to properly monitor and enforce. The provincial government should suspend or revoke
the licences of currently operating companies that fail to meet those new standards and criteria.
It is timely for the federal government to significantly expand scientific research
dedicated to protecting natural eco-systems, starting with a comprehensive risk analysis study.
This should be followed by implementing science-based regulations that puts the protection of
wild fish first and foremost. The federal government must radically improve its capacity to
consistently monitor fish farms and enforce regulations. It is imperative that the Federal
Department of Fisheries and Oceans honour its primary mandate, which is to conserve and
protect the wild stocks of salmon, as well as all other fish species.
There should be no expansion of the salmon farming industry until improvements that
ensure the safety of wild salmon have been implemented and proven. This means that existing
fish farm practices must be required to consistently meet science-based standards to ensure
that wild salmon and their habitats are not adversely affected.
Let me reiterate that SOFF is guardedly supportive of the salmon farming industry, but
only if it is wisely administered. Unfortunately, there is little evidence that at this time either
government will manage wisely. I can do no better than to repeat my closing statement of 1976
that I referred to earlier in this talk: “The honing of technical capabilities is highly predictable.
The honing of managerial skills needed to ensure that the products of technology are wisely
used is, however, less clear”.
Thank you for allowing the Save Our Fish Foundation to present its views on this very
important matter.