CP32-93-2012-3-eng.pdf

Cohen Commission of Inquiry into the Decline of Sockeye Salmon in the Fraser River • Volume 3
Given the risk of serious harm posed by salmon
farms to Fraser River sockeye, DFO needs to ensure
that existing farm sites conform to the most up-todate
knowledge to ensure that risks are minimal.
I note that, in about 2005, when DFO established
thresholds of compliance for benthic impact from
salmon farms, it did not apply that standard retroactively
to existing sites. 73 Similarly, the regional
director general of DFO’s Pacific Region told me
that new standards put in place by DFO for site
selection under the Pacific Aquaculture Regulatory
Program would apply only to new salmon farm
sites, not those originally licensed under the provincial
regulatory regime. 74 These examples cause
me concern. They provide little confidence that the
most up-to-date standards and practices are being
applied to all salmon farms potentially affecting
Fraser River sockeye, irrespective of when the farm
site first became operational. If siting measures
are to serve as a useful tool to minimize the risk of
serious harm to Fraser River sockeye, they must be
adaptive to new scientific information. If new information
reveals that existing farm locations pose
more than a minimal risk of serious harm to Fraser
River sockeye, those farms should be removed.
For the “proper farm siting” mentioned in the
Wild Salmon Policy to effectively minimize the risk
of serious or irreversible harm to Fraser River sockeye,
DFO needs to focus on the following measures:
• Protection of Fraser River sockeye from
negative impact along their entire migratory route.
Special consideration should be given to areas
such as the Discovery Islands, where Fraser River
sockeye come into proximity to salmon farms.
• Protection of Fraser River sockeye from
the potential negative cumulative effects of
swimming past multiple farms sited on their
entire migration route.
• Frequent and regular revision of siting criteria
to account for new scientific information about
the risk of fish farms to Fraser River sockeye.
• Retroactive application of revised siting criteria
to existing sites, even if it entails removing or
relocating salmon farms off the Fraser River
sockeye migration route.
In short, siting should be approached with
the goal of the Wild Salmon Policy in mind: restoring
and maintaining healthy and diverse salmon
populations and their habitats for the benefit and
enjoyment of the people of Canada in perpetuity.
DFO should seek to approve the best sites to avoid
negative impact on wild stocks, such as Fraser
River sockeye, rather than the best sites to produce
farmed salmon.
DFO also needs to take steps to minimize
the scientific uncertainty about salmon farms
and to re-evaluate its mitigation measures
as that uncertainty diminishes. A 2003 Privy
Council of Canada document, A Framework for
the Application of Precaution in Science-Based
Decision Making about Risk, makes these useful
points about resolving scientific uncertainty in
applying precaution:
• To resolve scientific uncertainty, research
and scientific monitoring are key parts of the
application of precaution.
• The responsibility for producing scientific data
may shift among governments, industry, or
other proponents.
• Where scientific information is inconclusive,
decisions still have to be made to “meet society’s
expectations about enhancing living standards
and addressing the potential for risks.” 75
Data presented during this Inquiry did not
show that salmon farms were having a significant
negative impact on Fraser River sockeye. However,
as noted above, the statistical power of the database
(containing fish health data from 2004 to 2010) was
too low to rule out significant negative impact. 76
I accept the evidence of Dr. Korman and Dr. Dill
that scientists need another 10 years of regulatory
data (until at least mid-2020) before they can more
confidently identify any relationships that may exist.
As well, other than a few studies related to sea lice
(mostly in species other than sockeye), DFO has not
completed research into the effects of diseases and
pathogens from salmon farms on wild Fraser River
sockeye. Nor has DFO done any research into the
cumulative effects on sockeye of having multiple
salmon farms sited on their migration route. In sum,
there are insufficient data (almost no data) to evaluate
cause and effect relationships, and insufficient
data (in terms of a time series of fish health data) to
look for correlations between fish farm factors and
measures of sockeye health such as productivity. As
a result, significant scientific uncertainty remains
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