It’s not that simple. Movement of fish, regardless of size, is not a decision farming companies can make on their own. All fish movements require a transfer permit from Fisheries and Oceans Canada. A committee called the “Introductions and Transfer Committee” (ITC) is charged with doing a risk assessment on each application. A series of factors are considered, including guidelines outlined by the National Aquatic Animal Health Program.

There is also a maximum biomass (number of fish) that is allocated to each producing site through the licence to operate. Companies do not have the authority to exceed that biomass by adding additional fish from another location unless an amendment to their licence is granted. License amendments are complex and can take upwards to a year to process.

The life cycle of a salmon from egg to harvest is about three years total; but when considering broodstock management, required in egg production, overall production planning requires 5 – 7 years.

Companies must consider the significant husbandry and feed costs for maintaining these populations. Their freshwater hatcheries currently hold large numbers of eggs and smolts that were designated for the Discovery Island farms. Smolts require saltwater to fulfill their life cycle; they cannot complete their life cycle at a freshwater hatchery. This replicates how salmon thrive in the wild – spending the first part of their lives in freshwater lakes and streams before migration to the ocean. Unfortunately, even if companies were granted permits to move their fish, they have very little space at existing saltwater growout facilities for most of these smolts. With no locations to transfer them to, companies have no alternative but to euthanize them.

It is anticipated that 10.7 million fish will have to be euthanized.

The difference is a significant financial one. If the 10.7 million salmon were able to grow out and reach harvest size, the return to the companies would be about $105 million. Instead, with current book value and costs of euthanizing the fish factored in, the total loss for salmon farming companies will be over $170 million.

In 2009, Canada established the Cohen Commission of Inquiry into the Decline of Sockeye Salmon in the Fraser River. The goal was to investigate the decline of sockeye salmon stocks and provide recommendations.

The commission’s final report, The Uncertain Future of Fraser River Sockeye, includes 75 recommendations on a range of issues: 13 focussed on aquaculture, 19 on Habitat, 15 on Fisheries Management, 8 on Wild Salmon Policy, and 20 on Science.

The most important to salmon farming in the Discovery Islands was Recommendation 19.

Actual Wording: Recommendation 19.

On September 30, 2020, the Minister of Fisheries and Oceans should prohibit net-pen salmon farming in the Discovery Islands (fish health sub-zone 3-2) unless he or she is satisfied that such farms pose at most a minimal risk of serious harm to the health of migrating Fraser River sockeye salmon. The Minister’s decision should summarize the information relied on and include detailed reasons. The decision should be published on the Department of Fisheries and Oceans’ website.

DFO’s work to inform this recommendation can be found here.

The Cohen Commission was an Inquiry into the Decline of Sockeye Salmon in the Fraser River and it’s goal was to investigate the decline of sockeye salmon stocks and provide recommendations.

The scientific research and risk assessments completed by DFO in response to recommendation 19 focused on the risk of marine net-pen salmon farms in the Discovery Island area to migrating Fraser River Sockeye salmon.

The assessments concluded that the pathogens found in Atlantic salmon farms in the Discovery Islands area pose no more than a minimal risk to migrating Fraser River Sockeye salmon.

More detailed information on the risk assessment process can be found here.

When the Cohen Commission recommendations were made, DFO had just completed a CSAS peer review process on sea lice (2012). Science advice from this process included several measures that have since been initiated and implemented through DFO management and science activities.

Further from DFO’s website: More than 15 years of intensive research evaluating the effects of farmed-derived sea lice on wild salmon in Canada have resulted in substantial improvements in our knowledge of sea lice biology (genetics, life history, distribution, abundances, and tolerances) and of the relative susceptibility and resistance of Pacific salmon species to sea lice.

The 2012 assessment provided scientific advice on sea lice management measures, monitoring, and interactions between cultured and wild fish. Sea lice dynamics are influenced by salinity and water temperature (which affect survival, growth, development rate, and reproductive success of sea lice), water movement (tides and currents), behaviour of infective larval stages and motile pre-adult and adult stages, and the abundance and proximity of suitable fish hosts.

Additionally, there is a wide range of susceptibilities to sea lice infestation among Pacific salmon species; and Atlantic salmon are generally more susceptible to sea lice infestation than Pacific salmon species. Scientists have has demonstrated that risk posed by sea lice to wild salmon diminishes with increased fish size. Laboratory study results indicate both size and species-specific resistance to sea lice in juvenile salmon, and laboratory studies have also shown that lethal sea lice numbers is species and size dependent. The data from these lab studies provides an opportunity to better understand natural infections, and the development of lethal infection density thresholds could potentially be useful as a management tool.

Despite this body of work, DFO has now committed to completing a risk assessment focused on sea lice.

Salmon farm conditions of license were reviewed and updated by Fisheries and Oceans Canada in 2020. They specify area-based and site-specific sea lice monitoring requirements for each farm. In general, the sea lice-related conditions of license divide each year into 3 sea lice monitoring ‘windows’ defined by the out-migration pattern of the juvenile salmon:¹

• Non-migration Window: July 1 – January 31
• Pre-migration Window: February 1 – February 29
• Out-migration Window: March 1 – June 30

During the non-migration period, each farm must conduct a sea lice count on the farmed salmon at least once per month – and submit the results to DFO by the 15th of the following month. If the count exceeds the threshold of 3 motile sea lice per fish, the farm must notify DFO within 7 days – and conduct sea lice counts every 2 weeks thereafter as long the the count continues to exceed 3 lice per fish.²

During the pre-migration window, 2 sea lice counts must be conducted – with results submitted to DFO within 48 hours of each counting event. If either of these counts reveal over 3 motile sea lice per fish, DFO must be notified – and presented with a plan describing the measures that will be taken to ensure that sea lice levels are below the threshold level by the start of the out-migration window. In addition, sea lice counts must be conducted every 2 weeks thereafter as long as sea lice levels continue to exceed 3 lice per fish.³

During the out-migration window, sea lice counts must be conducted within the first week of the window – and once every 2 weeks thereafter. The results of each counting event must be submitted to DFO by the 15th of the following month. If the sea lice count exceeds the threshold of 3 lice per fish, DFO must be notified within 48 hours – and a plan must be presented describing the sea lice management measures that will be undertaken to reduce sea lice levels below the threshold level within 42 days.⁴

¹ Fisheries and Oceans Canada. Marine Finfish Aquaculture License conditions. Section 6.1. p. 10. https://www.pac.dfo-mpo.gc.ca/aquaculture/licence-permis/docs/licence-cond-permis-mar/licence-cond-permis-mar-eng.pdf
² Ibid. Section 6.4. p. 11
³ Ibid. Section 6.5. p. 11
⁴ Ibid. Section 6.7. p. 12