CP32-93-2012-3-eng.pdf

Cohen Commission of Inquiry into the Decline of Sockeye Salmon in the Fraser River • Volume 3
(See the discussion in Volume 1, Chapter 9, Fish
health management.)
Further, Dr. Kent said a devastating disease
could sweep through a wild population, killing
large numbers of wild fish without scientists being
aware of it. 60 And, as I discussed in Volume 2,
Chapter 3, Other investigations, other scientific
investigations into the causes of the decline of
Fraser River sockeye (such as the June 2010
Pacific Salmon Commission workshop) identified
pathogens and disease as strong contenders for
causes of the decline. Irrespective of whether
the source of any particular disease is a fish farm
or wild fish, the potential for disease to cause
significant population declines indicates “serious
harm.” If a disease were to wipe out a vulnerable
stock of Fraser River sockeye, such harm could
also be irreversible.
I therefore conclude that the potential harm
posed to Fraser River sockeye salmon from
salmon farms is serious or irreversible. Disease
transfer occurs between wild and farmed fish, and
I am satisfied that salmon farms along the sockeye
migration route have the potential to introduce
exotic diseases and to exacerbate endemic diseases
that could have a negative impact on Fraser
River sockeye.
Do current management measures ensure
that the risk of serious or irreversible harm
is minimal
Having concluded that there is some (at present
unquantifiable) likelihood of harm to Fraser River
sockeye from salmon farms, and that the potential
harm is of a serious or irreversible nature, the next
question is whether current management measures
ensure that the risk of harm is minimal. As I noted
above, based on the information before me, British
Columbians will not tolerate more than a minimal
risk of serious harm to Fraser River sockeye from
salmon farms.
DFO’s Wild Salmon Policy indicates that
the risks to wild stocks from salmon farming are
mitigated through measures such as improved
cage structure, proper farm siting, and Fish Health
Management Plans (FHMPs). 61 I heard little
evidence on improved cage structures; however,
I infer they may reduce the risk of Atlantic salmon
escapes, though, as stated above, Atlantic salmon
escapes do not pose a risk of serious harm to Fraser
River sockeye.
For farm siting to mitigate risks to Fraser River
sockeye, consideration must be given to the Fraser
sockeye migration route and the potential negative
cumulative effects to sockeye from migrating past
multiple salmon farms. In my view, proper farm
siting holds the potential to address the risks of
disease and pathogen transfer that salmon farms
pose to Fraser River sockeye because it can address
issues of increased risk that come with the proximity
of Fraser River sockeye to a fish farm. However,
as described below, current siting practices need to
be revised to achieve this result.
When salmon farmers apply for new aquaculture
sites, DFO and the province apply siting
criteria to screen out unsuitable applications. In
early 2000, the province established the current
siting criteria in consultation with DFO. These siting
criteria do not explicitly require consideration of
Fraser River sockeye migration routes. Instead,
they state that salmon farms should not be located
within 1 km of the mouth of a “salmonid bearing
stream determined as significant.” 62 However, this
criterion has little relevance to the protection of
Fraser River sockeye because it does not address
the risk to migrating sockeye beyond 1 km of the
mouth of the Fraser River. Of greater concern to
Fraser River sockeye are the narrow passages along
the smolt outmigration route, particularly through
the Discovery Islands, where the wild smolts are
brought into close contact with salmon farms,
thereby increasing the potential for disease transfer
between farmed and wild fish. In my view, the risk
of serious harm that salmon farms pose to Fraser
River sockeye along their entire migration route –
not just 1 km from the mouth of the river – needs to
be considered and reflected in siting criteria.
In testimony, DFO management staff said
that the siting criteria could be revised. 63 As
these criteria have been in use for several years,
they may not reflect the most recent scientific
knowledge about the risks posed to wild stocks by
salmon farms. They should be updated to reflect
the best available science as well as input from
First Nations and stakeholders affected by the
siting of fish farms.
DFO witnesses told me that, although not
mentioned in the siting criteria, sockeye migration
routes and the potential for disease and pathogen
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