Thank you for allowing me to participate.

While Fisheries and Oceans Canada characterizes its regulation of salmon farms as rigorous and tells Canadians that these regulations support the health of wild fish, this is not entirely accurate, on three substantive issues: bycatch in the farms, sea lice proliferation on farmed salmon and the spread of piscine orthoreovirus.

With regard to bycatch, in January of 2012, I charged Marine Harvest under the Fisheries Act for illegal possession of juvenile wild salmon and herring. The Department of Justice assumed these charges and prosecuted Marine Harvest. The case number is 14891-1. Marine Harvest pleaded guilty and was fined $4,000. With each grow-out, Marine Harvest is making approximately $24 million per farm. I don't think the fine of $4,000 was enough to solve this problem.

Beginning in 2017, first nations and others began boarding salmon farms in British Columbia and putting underwater cameras into the pens. These cameras captured the images of thousands of herring in each of the 10 or more pens in all the farms between Campbell River and Alert Bay and in Clayoquot Sound on the west coast of Vancouver Island.

The farmers and DFO refused to say whether these fish were released or not. People filmed large schools of herring in farms long after the Atlantic salmon had been harvested. There was no explanation as to why these fish were being held and what their fate was. The salmon farming industry is an unregulated herring fishery. We don't know if DFO is allowed to release these fish, because they have now been exposed to the sea lice and pathogens in the farms.

Now, to focus on sea lice for a moment, 19 years ago I reported sea louse outbreaks in wild salmon near salmon farms, as has happened everywhere else in the world where this industry operates among wild salmon, yet this year, we experienced the worst sea louse outbreak on young salmon in the history of this industry. In 19 years, there really has not been enough progress.

I did a freedom of information request on DFO communications regarding the sea louse outbreaks in the last few years, and in document A-2018-00799, the reason for the outbreaks becomes clear: DFO veterinarians report that the drugs they've been using in the farms no longer work. Everybody knew this was going to happen, because drug resistance development in sea lice has happened everywhere farms are operating in the world.

Importantly, internal emails chronicle DFO veterinarians struggling to make the companies comply, because they could see that wild salmon conservation units of concern were being killed by the lice coming out of the farms. Cermaq, in this case, promised to borrow equipment from Marine Harvest to wash off the lice, but then that equipment wasn't available. They said they would harvest the fish, but that took so long that the entire outmigration period of March to June passed, and they still had not harvested all their fish.

Senior conservation and protection staff were contacted because people wanted to charge the farms. DFO wanted to charge the farms for not complying, but this senior conservation and protection staff member said that because of the way the conditions of licence are written, the rules were unenforceable. Basically, the company just has to have a plan and then execute the plan, but it doesn't matter if the plan was carried out at the right time or if it worked. He recommended to senior staff that this regulation be tightened up and gave them specific instructions, but it was not done in 2018. We had another outbreak this last year, so it didn't happen in 2019 either.

I don't consider this to be just a mistake when senior staff have ignored their own staff's recommendation that these regulations be changed.

The final point is on this piscine orthoreovirus. It's a disease agent. Under Canadian law, paragraph 56(b) of the Fishery (General) Regulations, transfer of fish infected with a disease agent is not permitted in Canada, but the Minister of Fisheries and Oceans refuses to acknowledge this law. I have won two lawsuits now against the Minister of Fisheries and Oceans.

The 'Namgis First Nation also has won a lawsuit against the Minister of Fisheries and Oceans, saying that it is unlawful to not be screening farmed salmon for PRV.

On February 4, the Federal Court gave Minister Wilkinson, our current minister, a four-month extension to comply with the most recent court win. However, on June 4 the minister announced that they had made a decision and asked us to review the new regulations that he would like to insert under section 56. This new regulation would weaken the current regulation. It would allow infected fish to go into the water through a complicated assessment process that is so difficult for them to understand that the document actually suggests that DFO might have to go to the Department of Justice to determine on specific transfers if it is thought that there might be a medium risk to wild fish. It's a change in the regulation that seems to make it very difficult for them to consider how they would go forward.

DFO research reports that PRV appears to cause acute disease in chinook salmon. We know that chinook salmon stocks are collapsing on the southern B.C. coast, where all the farms are. We know that the southern resident orcas are going extinct because of a lack of chinook, so it's a looming problem for British Columbia.

In summary, I just want to say that these three regulatory failures—sea lice, bycatch and control of disease going into these farms—are resulting in the overfishing of herring populations that are currently under protection from other forms of fishing. These failures are causing the death of the majority of outmigrating juvenile wild salmon wherever the salmon farms lose control of their lice, as well as the steady leakage of a disease agent known to impact wild salmon species, which is pushing them towards the endangered and threatened status that they increasingly have.

My recommendation is that this industry finally be mandated to move into closed containment, because I suspect that the reason for non-compliance and the softness of the regulations is that the industry cannot be run in a profitable manner under Canadian laws. For example, the law says that there are to be no diseased fish going into the farms and that you have to kill your fish if you can't control the lice. This is what the law basically is saying, but nobody will enforce it because I don't think the companies can then actually make a profit under Canadian law. That's why we have this regulatory problem.

Thank you so much.

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