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August 20, 2020

Prime Minister’s Office of Canada

Langevin Block

Ottawa, ON K1A 0A2

Attention: The Right Honourable Justin Trudeau, Prime Minister

Premier’s Office of British Columbia

West Annex, Parliament Buildings

Victoria, BC V8V 1X4

Attention: The Honourable John Horgan, Premier of B.C.

Dear Prime Minister and Premier,

On behalf of the 70 diverse members of the BC Salmon Farmers Association, I am responding to last week’s letter from Wild First.ca and other parties regarding the future of salmon farming in BC. Our membership includes salmon farmers, seafood value chain participants, Indigenous organizations and local governments.

It is helpful to understand where we share common ground with the letter’s signatories. The entire salmon farming industry in BC shares the signatories’ “deep concern for the survival of wild salmon.” Where we differ is our view on the role salmon farming plays in that survival.

In a call for removal of BC’s salmon farms, the letter focuses entirely upon sea lice numbers on wild salmon during one migratory season, and makes an unsupported claim that those numbers are due to salmon farms. Yet there is simply no evidence to support the petition’s claim that higher-than-normal sea lice numbers on wild salmon are due to salmon farms. It is misleading and irresponsible to suggest this correlation without considering other factors that influence sea lice levels, such as:

  • Number of wild salmon returning to spawn. Repeated studies have shown that adult Pacific salmon returning from the open ocean in the summer and fall bring high levels of sea lice[1]. These sea lice and their offspring infect juvenile Pacific salmon when the returning adults and juveniles share similar habitats during the juvenile out-migration.
  • Number of wild salmon and other host species residing in coastal waters throughout the year. Resident Chinook and coho salmon, as well as other host species such as herring, create a year-round source of sea lice in coastal waters.
  • Annual variability in climatic and oceanic conditions. Sea lice thrive in warm, salty water. Therefore, sea lice counts tend to be higher in years where lower freshwater snow-pack or winter precipitation results in less fresh, cold water running into the ocean in the spring. Warm sea surface temperatures in the open ocean, as have been noted off BC’s coast recently[2], will also create optimal conditions for sea lice.

Each year, the interaction of these factors significantly impacts the size of sea lice populations inhabiting BC’s coastal waters – which, in turn, impacts the number of sea lice found on both wild and farmed salmon.

BC salmon farmers support ongoing scientific investigation of sea lice population dynamics to better inform their management practices. Each year BC salmon farmers engage an independent third-party professional biologist to monitor wild juvenile salmon for the presence of sea lice before and after they swim past salmon farms during the spring out-migration, in several regions of coastal BC. During their sampling in the mid-coast region this year, approximately 30 km from the nearest salmon farm, they found historically higher numbers of lice on wild juvenile salmon.  These high counts are likely due to optimal ocean conditions and higher sea lice numbers on returning wild salmon[3]. Further, their report from the Discovery Islands region[4], shows that the number of sea lice on pink and chum salmon (the species actively out-migrating during the sampling period) were similar in both the pre- and post- farm location samples – in some cases rising slightly, in other cases declining. Some of the highest levels of sea lice were found in the Broughton area where salmon farms have been removed[5].

The BC salmon farming industry acknowledges the challenges that come with higher than usual lice levels on wild returning adults and juvenile salmon, and takes full responsibility for the management of our stocks to reduce further impacts.  High sea lice levels on farms, acquired from the environment, threatens the health and safety of our fish, and poses the potential to transfer lice from farms back to wild fish. It is our goal to manage sea lice levels to ensure we keep both farmed and wild stocks safe. And science has shown that this goal is achievable[6]. We do this with an industry-wide integrated pest management approach that involves multiple steps and on-going collaboration:

  • Prevention – We site farms to minimize sea lice transfers. Locations are approved by Fisheries and Oceans Canada. We use best practices in animal husbandry to maintain low lice levels. We strive to take an area-based management approach, coordinating the management of all farms in an area collectively.
  • Monitoring – We monitor the presence of sea lice as part of a farm’s routine operations, increasing the frequency of lice monitoring during wild salmon migratory periods.
  • Regulation – Fisheries & Oceans Canada’s regulatory oversight is rigorous and requires salmon farmers to keep the numbers of sea lice below a particular threshold (three motile sea lice per fish), above which a mandated response is required.
  • Response – We have multiple tools[7] to keep sea lice numbers low and respond when they increase. Options include freshwater baths in wellboats, hydrolicers (pressurized water to remove lice), medicinal treatments (Interox-Parmove 50® (hydrogen peroxide) or Slice® (emamectin benzoate)), or even full harvest-out of a farm

We are committed to doing that work effectively, and have invested millions of dollars in cutting-edge technologies for that in recent years:

  • In 2018, Mowi Canada West launched a $2.7-million Hydrolicer;
  • In 2019, Cermaq Canada launched a $12-million Hydrolicer;
  • In 2019, Mowi Canada West launched the $30-million Aqua Tromov, a 77-metre wellboat;
  • In spring 2020, Grieg Seafood launched the $40-million, 70-metre Ronja Islander wellboat.

All ocean-based salmon farmers in BC continue to invest in research, new equipment, and processes to manage sea lice effectively. Several innovative research and development projects are underway, including investigations of potential for semi-closed containment (SCC) and floating, fully-closed containment (CC) systems, as well as off-shore systems. For example, Cermaq Canada is currently assembling a floating semi-closed containment system in Port Alberni, BC. This system will be deployed in Clayoquot Sound within the traditional territory of the Ahousaht First Nation, and be a testing ground for this new technology. Grieg Seafood has also installed SCC systems for testing at two of its Sunshine Coast farms. SCC systems are equipped with technological barriers to protect farm-raised fish from sea lice but to also inhibit the transfer of fish and potential pathogens to the outside environment during the ocean grow-out phase.

It is also important to note that the Cohen Commission did not simply call for removal of salmon farms from the Discovery Island’s area by September 30 of this year. Rather, the Commission recommended that salmon farms should be prohibited in the area by that date if the DFO cannot confidently say the risk of serious harm to wild stocks is minimal.

We have confidence in the expertise of the DFO in their ongoing evaluation of wild and farmed salmon interactions in the Discovery Islands, and will await a final decision to come. And we are confident that farmed and wild salmon populations are sharing, and can continue to share, marine waters with minimal impacts from interactions.

We are proud that salmon farming is among the food production sectors both your governments have declared as essential during this pandemic crisis, and take seriously the responsibility to do our part to ensure Canada’s food supply remains strong.

In typical times, we produce three-quarters of the salmon harvested in the province each year – some 6.5 million meals worth each week. We do this work while supporting about 7,000 well-paying, year-round, and sustainable jobs, most of them in rural Vancouver Island communities. We have sustained this employment level during the COVID-19 pandemic. And most of the salmon that our members farm are raised in partnership with a local First Nation.

The science tells us that done responsibly, salmon farming does not negatively impact wild fish populations. Indeed, we play a role in protecting wild salmon by providing a responsibly-raised alternative to eating wild fish. I would be pleased to engage your offices about this matter at any time.

Kind regards,

John Paul Fraser,

Executive Director

CC:

  • Mike Griswold, Vice-President, Gulf Trollers Association
  • Daniel Billy, Elder, We Wai Kai First Nation
  • The Most Rev’d Melissa Skelton, Archbishop, Bishop of the Diocese of New Westminster, Anglican Church of Canada
  • Tony Allard, Chair, Wild Salmon Forever; CEO, Good Hope Cannery
  • Willie Mitchell, President/Partner, Tofino Resort + Marina
  • S. Blair Odney, President, Pacific Mountain Regional Council, United Church of Canada
  • Dane Chauvel, Founder & CEO, Organic Ocean
  • Ed Bianchi, Program Manager, Kairos Canada
  • Kathy Scarfo, West Coast Trollers Association
  • Greg Gower, Area G Advisors
  • Hayley Shephard, Owner/Operator, Seasmoke Whale Watching
  • Richard Hagensen, Chair, Council of Canadians Campbell River Chapter
  • The Right Reverend David TJ Lehmann, Bishop, Diocese of Caledonia, Anglican Church of Canada
  • Joy Thorkelson, President UFAWU – Unifor
  • Garry Henckel, Captain, Aboriginal Journeys Whale Watching & Grizzly Bear Tours
  • Dave Mackay, President, BC Northern Trollers Association Area F
  • Sarah King, Head of Oceans & Plastics Campaign Greenpeace Canada
  • Darrel McEachern, President, Areas D & E Gillnetters Associations
  • Carol Brown, President, Prince Rupert Environmental Society
  • Chris Ashton, President, Area B Seine Association
  • Hannah Askew, Executive Director, Sierra Club BC
  • Stan Proboszcz, Science and Campaign Advisor, Watershed Watch Salmon Society
  • Sonia Strobel, Co-founder & CEO Skipper, Otto Community Supported Fishery
  • Alexandra Morton, Pacific Coast Wild Salmon Society
  • Sid Keay, Duncanby Lodge
  • Christianne Wilhelmson, Executive Director, Georgia Strait Alliance
  • Chris Genovali, Executive Director, Raincoast Conservation Foundation
  • Bonny Glambeck and Dan Lewis, Clayoquot Action
  • Tim & Kelli McGrady, Co-owners, Farewell Harbour Lodge
  • Karen Wristen, Executive Director, Living Oceans Society
  • Jenn Broom, Ocean Light II Adventures
  • Jeh Custerra, Friends of Clayoquot Sound
  • Greg Knox, SkeenaWild Conservation Trust
  • Randy Burke, Captain/Director, Bluewater Adventures
  • Kurt Beardslee, Executive Director, Wild Fish Conservancy
  • Pat Moss, Chair, Friends of Wild Salmon
  • Jay Ritchlin, Director-General, Western Canada David Suzuki Foundation

[1] Beamish et al. 2005. Sea lice on adult Pacific salmon in the coastal waters of central BC, Canada. Fisheries Research. 

[2] CBC News, September 2019. Marine Heat Wave, BC Coast.

[3] Wild Juvenile Salmonid Monitoring Program 2020 – Quatsino Sound. Mainstream Biological Consulting.

[4] Wild Juvenile Salmonid Monitoring Program 2020 – Discovery Islands, BC. Mainstream Biological Consulting.

[5] https://twitter.com/mainstreambio/status/1292924946272772096.

[6] Rogers et al. 2013. Modeling Parasite Dynamics on Farmed Salmon for Precautionary Conservation Management of Wild Salmon. PLoS ONE.

[7] Vancouver Sun, November 2018. Hydrolicer.