CP32-93-2012-3-eng.pdf

Cohen Commission of Inquiry into the Decline of Sockeye Salmon in the Fraser River • Volume 3
Aquaculture Review (SAR) prepared by the BC
Environmental Assessment Office. The SAR
concluded that salmon farming presented a “low
overall risk to the environment.” 36 In response
to the 49 SAR recommendations, the province
enacted legislation and regulations and set up
policies and procedures for the management of
salmon farms. 37
For practical reasons, in December 2010, when
DFO took over as the primary regulator for BC
aquaculture, it adopted many of the procedures,
practices, and systems – with some variations and
improvements – that the province already had in
place. For example, DFO implemented a system
using a combination of industry self-reporting
and government audits that was similar to the
provincial system for monitoring salmon farms. 38
It continued to use the diagnostic laboratory run
by the BC Animal Health Centre in Abbotsford for
analyzing fish samples collected as part of DFO
audits of salmon farms. 39 As well, DFO adopted
the siting criteria established after the SAR and
implemented a similar application process to
that formerly used under the provincial regime
(though it has delayed any significant decisions
about new applications until it has had the opportunity
to consider the recommendations of this
Inquiry). 40 DFO also chose to maintain the status
quo by licensing, without further review, all of the
approximately 120 net-pen salmon farms then
licensed by the province. 41
It has now been 15 years since the SAR. In
reviewing the state of aquaculture regulation, my
mandate is much more specific than the SAR.
I have been tasked with identifying recommendations
for the future sustainability of the Fraser
River sockeye salmon fishery, not the broader
environmental, social, and economic impact of
aquaculture. I have had the benefit of testimony
about how the system is working – in particular, its
achievements and its shortcomings in protecting
Fraser River sockeye.
My review of the regulatory system for salmon
farms and the state of knowledge about the effects
of salmon farms on Fraser River sockeye has led
me to make recommendations in two areas: fish
health data from salmon farms; and minimizing
risks and uncertainty. I make related scientific research
recommendations concerning the health of
Fraser River sockeye salmon later in this chapter.
Fish health data from
salmon farms
The SAR recommended that British Columbia
improve the quality and accessibility of information
about fish health from salmon farms. Toward that
end, in October 2003, the province completed a fish
health database and required industry to self-report
information to that database. It used information
in the database to generate quarterly and annual
reports. Public access to this information occurred
through summaries in the annual reports. 42
Information held in this fish health database
formed the basis for Technical Report 5A, Salmon
Farms and Sockeye Information. As I describe in
Volume 2, Chapter 5, Findings, I accept the evidence
of Dr. Josh Korman (author of Technical Report 5A,
Salmon Farms and Sockeye Information),
Dr. Donald Noakes (author of Technical Report 5C,
Noakes Salmon Farms Investigation), and
Dr. Craig Stephen (lead author of Technical
Report 1A, Enhancement Facility Diseases) that the
quality and quantity (in terms of breadth of data
collected) of the fish health database are impressive,
especially when compared with monitoring
programs in other sectors. 43 However, I also accept
Dr. Korman’s evidence that the short data record
(from 2004 to 2010) means that the statistical power
of that data to show relationships (if they exist)
between salmon farm variables and measures
of sockeye health or productivity is “very low.”
Additionally, I accept the evidence of Dr. Korman
and Dr. Lawrence Dill (author of Technical
Report 5D, Dill Salmon Farms Investigation) that
this limitation in the data should disappear with
another 10 years of data collection. 44
Transparency and accessibility of fish health
data from salmon farms have been topics of
considerable controversy. In the past, the public and
non-government / non-industry scientists have not
been given access to the raw data in the fish health
database. Instead, they have been given summaries
of overall fish health in the provincial annual
reports. As I describe in Volume 1, Chapter 8,
Salmon farm management, I received many public
submissions about a lack of transparency in the
provision of information about salmon farms to
the public. As well, non-government researchers
told me of the difficulties they faced in accessing
data about fish farms. 45 A salmon-farming industry
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