Rafe Mair Open letter to Premier of BC Gordon Campbell

The matter of fish farming is important to everyone.
Few people have paid as much attention to it as CKBD
600AM open line host RAFE MAIR, who also happens to be
Minster of the Environment in the Bill Bennett Socred
government in 1978/79 before he left politics to become
an open line radio host.
I have discussed and been against fish farming for
years.  With my limited background of a year in
Veterinary medicine and three years working for Health
of Animals and testing cattle in three provinces for
Bangs Disease (Brucellosis Abortus), it was still a
no-brainer for anyone to realize that concentrations of
penned fish had to affect the wild salmon stocks in BC.
The following rather long letter from the former
Environment Minister Rafe Mair to the Premier of
British Columbia, Gordon Campbell has to be read by
anyone interested in the survival of wild salmon.
Many of those of you in the 80 some odd countries this
newsletter goes to are from Oregon, Washington and
Alaska and I assure you that this letter is important
to your fisheries as well.  As they say, there is no
such thing as a "no pissing" area in a swimming pool.
Anything that happens in BC waters will affect
Washington and Alaska.
In 1998, a reader of this newsletter and documentary
maker, Michael Letzring did a documentary on the
economic return of a King Salmon to the Alaska economy.
The conclusion was that a wild salmon caught by a
sports angler contributed some $1,050 to the Alaska
Economy and I would have to believe it when you see 500
fishermen fishing the Kenai River SW of Anchorage at
the same time. Anglers come from around the world to
fish the Kenai and of course they come from around the
world to fish the waters of BC in places like Rivers
The figure for the same salmon caught by a commercial
boat in Alaska was something like $25.00 to $50.00
depending on the size.
Rafe's open line program can be heard daily around the
world on the internet from 8:30 AM to 10:30 AM
(Vancouver or Los Angeles Time) Monday to Friday at
23 years ago it was my honour to be his guest host for
three weeks.
Please read the letter.  I have left the premier's
address and Rafe's address visible to your eye if you
wish to comment to either of them.  The David Hancock
in the address of David Hancock of
www.hancockwildlife.org.  David was one of the earliest
biologists who set out to save the Bald Eagle and has
lectured on Eagles around the world.  He helped set up
the Stellar Sea Lion Exhibit at the San Diego Zoo and
Sea Bird Exhibit at the Bronx Zoo.  He was also
partially instrumental and on the boat that first
re-introduced the sea otters to BC waters back in 1969.
David Hancock has published some 400 books on wildlife,
fishing, lumbering and other ecological issues and Rafe
Mair's book on Fly fishing which is an informative and
hilarious read.
I think they call it six degrees of separation. We are
all involved in this.  If the wild salmon disappear,
our Orcas (killer whales) are in danger.  If the salmon
disappear, our coastal grizzly and black bear
population is at risk.  If the salmon disappear, one of
the candidates for the BC Animal Mascot, the Spirit
Bear could disappear. If the wild salmon in BC
disappear, our Brackendale and Harrison Bald Eagles
will diminish.  Spawning salmon are the bread and
butter and means of survival of otters, bears, eagles,
cougars and another 100 species who fatten up and make
it through the winter on salmon who spawn and die.  A
fisherman may have a bad year if there are few salmon.
Thousands of animals will die without a salmon run.
This has gone to some 20,000 people.  I have copied
some names and addresses which is something I never do
but in this case, the people copied are those that
should be able to make a difference. in the long run.
david ingram
Following is the  Rafe Mair LLB letter to Gordon
Campbell, Prime Minster of British Columbia.
Letter to the Premier on Fish Farms
I thought you should read the submission on fish farms
I made, at his request, to the Premier. This contains
opinions of the top scientists in the world and has
been ignored, as have all other such presentations to
this government.
I think it important that everyone in the Province
understands that opposition to the government policy on
fish farms is not some anti-government propaganda but
based upon the best science in the world. As you will
see, the government and the fish farming industry have
been challenged to produce a single independent
scientist to challenge the ones I and others have
presented and they are utterly unable to do so -
because there are none.
I believe it's critical that you not only read and
consider this presentation but do as I have done - send
it to everyone in your address book.
Rafe Mair
Host - the Rafe Mair Show AM600, Vancouver, B.C.
The Letter
September 21, 2004
Dear Premier,
Thank you for giving me the opportunity to address the
question of Atlantic Salmon fish farms in BC waters. I
believe that you have been badly misinformed on this
issue and that had you had time to examine it, as you
did the Kemano Completion Project, you would seen that
the threat of fish farms to our wild salmon is
infinitely more serious.
As you know, I am no scientist. I am, however, a lawyer
used to examining evidence and in my respectful opinion
the present policy towards fish farms is dead wrong. On
all the key points, environmental, financial and health
the policy not only fails to make its case but the
independent evidence is clearly against it.
I have confined this report to but two concerns – the
escape of Atlantic salmon and their impact on native BC
salmon and the impact of sea lice on migrating Chum and
Pink Salmon, especially the latter, although
contributors touch upon with other aspects. This means
that I have not dealt with other important matters such
as waste from the farms, impact of farms on other sea
life, spread of disease or the healthiness of the
product itself.
I do want to make just this comment myself. I have no
political agenda and I’m not against aquaculture.
Indeed, when Environment Minister in 1978-9 I
encouraged the notion. I became concerned with Atlantic
salmon fish farms back in the early 90s when the
Department of Fisheries & Oceans declared that they
couldn’t escape, if they didn’t, they couldn’t survive
on the wild, if they did escape and survive they couldn
’t enter BC Rivers, if they did all things they couldn’
t spawn and if they did all those things, DFO could
destroy the run (I believed the last statement given
DFO’s record)
Briefly, on the question of the impact of sea lice,
this came to my attention through friends in Scotland
and Ireland and through first class fly-fishing
publications. Then I heard from Alexander Morton.
You will no doubt hear from the industry and the likes
of Patrick Moore that Alexandra Morton is not a fish
biologist and this is true. Her science is no less
accurate for that as Dr John Volpe and others will
point out. The important thing is that not only is she
a scientist, her methodology and findings have been
peer reviewed and published in scientific journals. The
sea lice issue is vexing because it has been settled in
Norway, Scotland and Ireland that the impact is there
such that in those jurisdictions extremely strict
regulations have been implemented as to the number of
sea lice per farmed fish is permissible – and these
rules are strictly enforced. A louse is a louse whether
it’s in the Atlantic or the Pacific. Indeed, the
European findings are all the more frightening because
the migrating salmon affected there are Atlantic Salmon
and Sea Trout (Salmo Trutta) and the smolts are
considerably larger, thus more robust, than the Chums
and Pinks affected here.
On the question of escapes, the problem here is
different from Europe where escaped Atlantic Salmon can
and do breed with wild salmon and, if I might resort to
scientific words, bugger up the gene pool. Atlantics,
while they do not breed with Pacific Salmon, do occupy
the spawning beds, are spawning there, with it only
remaining to be seen if their progeny return to the
river and themselves spawn.
Do not be fooled, Premier, by the statements that we
tried to plant Atlantic Salmon here in the past and
failed. Dr Volpe can, if you wish, deal with that
succinctly and with finality.
I think, as I said, Premier, that you have been very
badly advised. This is, of course, an occupational
hazard of being Premier when you must accept what
Ministries say. You will remember when we fought the
Kemano Completion Project that it became abundantly
clear that the Department of Fisheries and Oceans had
become politicized with all the fine scientists that
had cast doubt on the project having been sent packing
one way or another. You will see reference to this in
the presentation of Dr. Neil Frazer. (They were dubbed
the “dissident scientists” by Alcan, a sobriquet they
proudly bore). The DFO remains politicized and in fact
has the mandate to promote aquaculture while,
supposedly, protecting the wild salmon. I simply cannot
believe that if you had been in full possession of the
facts that this situation would have reached this sorry
I believe that if the onus is properly placed, namely
that the fish farm industry must prove beyond a
reasonable doubt the safety of their industry, they
would fail miserably. It is wrong that the onus is
placed upon the public.
In the submissions, and in this foreword, I have added
emphasis and said so – otherwise the emphasis is of the
author himself.
I leave the subject with some names of scientists, fish
biologists, you can easily contact. These are all
independent of both industry and government. Your
government and the industry have not, despite
considerable urging, been able to come up with one
independent scientist to contradict them.
Dr. Daniel Pauly (UBC Fisheries--- named by "Science"
as one of 50 most influential scientists in the world)
Dr. Brian Riddell (Science Advisor, Pacific Fisheries
Conservation Council- chaired by John Fraser who has
peer reviewed Alexandra Morton’s research and
Dr Patrick Gargan (from Galway, Ireland who is
responsible for dealing with the sea-lice problem there
and who has peer reviewed Alexandra Morton’s research
and findings) and with whom I have spent a number of
hours privately.
In the interests of the Province we both love so much,
I beg you to re-consider your government’s position.
Rafe Mair
PS – There remains the question of how this
presentation should be dealt with. All of the evidence
I have presented is in published form so can hardly be
considered confidential. On the other hand, it’s only
fair that in light of your kindness in agreeing to
accept my presentation, that I not make it public until
you have had a fair chance to assess it. Would October
31 next seem fair to you?
Table of Contents
1. Precautionary Principle – letter from the Honourable
John Fraser
2. Presentation of Alexandra Morton
3.Presentation of Dr John Volpe
4. Presentation by Dr. Neil Frazer
1. Precautionary Principle – letter from the Honourable
John Fraser, Chairman of the Pacific Fisheries Resource
Conservation Council to the Honourable Geoff Regan,
Minister of Fisheries and Oceans of May, 2004
Precautionary Measures
While scientific proof is not yet absolute there is
extremely suggestive circumstantial evidence that sea
lice are associated with salmon farming. The Council
believes that sea lice were associated with the decline
observed in the Broughton pink salmon. Guidance on how
to deal with the level of uncertainty faced in this
case comes from the concept of the “Precautionary
Approach/Principle.” This precautionary approach is a
distinctive approach to managing threats of serious or
irreversible harm where there is scientific
uncertainty. The precautionary approach recognizes that
the absence of full scientific certainty shall not be
used as a reason to postpone decisions where there is a
risk of serious or irreversible harm. Even though
scientific information may be inconclusive, decisions
have to be made to meet society’s expectations that
risks be addressed. Once decisions are made they should
be evaluated in light of evolving science and society’s
chosen level of protection. When managing the oceans
and its resources, Canada’s Oceans Act prescribes that
the precautionary approach be applied.
The PFRCC recognizes the great difficulty, perhaps
impossibility, of arriving at absolute scientific
certainty regarding the cause of the pink salmon
The PFRCC recommends that the time for action is now.
While recognizing that some may argue that more study
be done prior to implementing any measures to protect
juvenile pink salmon passage, the PFRCC concludes that
such a strategy may lead to irreparable harm to the
Broughton Archipelago pink salmon stocks.
The PFRCC recommends that Canada and BC undertake
urgent actions to maximize the chance of safe passage
of fish through the Broughton Archipelago during April
2. Presentation of Alexandra Morton
Curriculum Vitae of Alexandra Bryant Morton
1957 Born in Connecticut, U.S.A.
1977- 1978 Volunteered at the Human/Dolphin Society
with Dr. J.C. Lilly catalogued 2,000 audio recordings
of dolphins (Tursiops truncatus)
1977 – Graduated Magna cum Laude from the American
University in Washington D.C. with Bachelor of Science
1978-1979 Worked for Dr. Sam Ridgeway at Navel Oceans
Systems Center on correlation of sound production of
dolphins to physiological states.
Initiated long term field study in the Broughton
Archipelago. Commence daily records on cetacean
activity, begin 24h/d underwater acoustic monitoring
continuing to present to aid in detection of marine
Expanded killer whale work to include influx of
thousands of Pacific white-sided dolphins
Observe arrival of first salmon aquaculture farm
1997 Become Canadian Citizen
1999 Co-found Broughton Archipelago Stewardship
Alliance with Eric Nelson and Kate Pinnsonault to hire
and educate local people to assess, monitor, recommend
restoration and restore small salmon-bearing creeks in
the Broughton Archipelago.
2002 – Certified as a Registered Professional Biologist
The Trouble with Sea lice and Salmon Farms
The sea lice situation is very simple. Salmon farms
have given sea lice a place to spend the winter that
they didn’t have before. Naturally the sea lice which
ride in from the open ocean on spawning salmon die when
the fish enters fresh water. The species of lice of
concern can only survive on a salmon, but there are so
few wild salmon inshore during the winter that these
sea lice have no place to over -winter. As a result no
matter how many sea lice come in on the wild fish, they
have no place to live and decline to near zero over the
Today, sea lice infect farm salmon as the wild adult
salmon migrate past the farms. Unfortunately salmon
farms are ideal habitat for sea lice, a kind of winter
lice spa. The high density and stationary farm salmon
allow the lice to spread, just like head lice on school
children packed into classrooms. To make matters worse
the lights farmers use to increase the growth rates of
their fish also stimulates lice growth and
So come springtime, the lice in the farms are producing
billions of larvae and the young wild salmon going to
sea are thus infected. If the farms are lined up one
after the other in long, narrow channels used by
juvenile salmon, like in the Broughton, the lice
numbers build up to absolutely deadly and unnatural
To make matters worse our chum and pink salmon enter
sea water much smaller than any other salmonid. So
while it takes 11 lice to kill an Atlantic salmon, it
appears to take 1-2 to kill a young pink or chum
salmon. I am publishing a paper on this. When the
salmon farmers use drugs to kill lice they cannot kill
all of them, and because the pinks and chums are so
susceptible, even “significantly” reducing lice is most
likely completely useless. It doesn’t matter if a fish
dies of 60 lice or 1, they are just as dead.
Furthermore the drugs used to kill sea lice also kills
the young salmon’s food (published research) and will
almost certainly affect the abundant shrimp and prawns
(as it does lobster on the east coast). Shrimp and
prawns fuel a prosperous fishery in BC, and
specifically in the Broughton. This is an issue
building steam as prawns and shrimp vanish near farms
using anti-lice drugs and the fishermen are certainly
The salmon farmers are being dishonest, denying the
link between their farms, sea lice and the wild salmon
collapses near their farms. They know this has happened
in Norway where companies like Stolt adhere to very
strict laws about sea lice. In Norway an operator with
more then 0.5 female lice per fish is fined $10,000s
daily, and will loose his license to operate and go to
jail if he doesn’t comply. So for Stolt to line Tribune
channel with enormous farms and then say they are not
the problem is deceitful at best. From the MAFF sea
lice counts we know there are farms in the Broughton
with an average of 10 sea lice per fish. For this they
would be in jail in Norway. I believe they almost
certainly know it won’t be long before the pinks and
chums are gone and the problem solved.
Then DFO arrives on the scene. There are two teams
within DFO. The Beamish team has made brilliant use of
the wrong fishing gear, in the wrong place, at the
wrong time to go out and find no lice. In Norway the
trawl nets Beamish uses are known to remove lice by
tumbling the fish down the nets’ tube. So they designed
a “fish lift” to solve this. Other researchers in BC
are using this state-of-the-art net, but not Beamish.
Beamish has gone on to say fish with lice are more
robust then ones without lice. This is ludicrous,
denying a body of published science. I do not know why
this eminent scientist wishes to destroy his
credibility at this stage in his career, but among sea
lice researchers worldwide he is a joke.
Then there is the Hargreaves DFO group using methods
which do not de-scale, de-louse the fish. This team
arrives early in the year when the sea lice picture is
most clear. Not surprisingly my numbers and theirs
match perfectly, because we are looking at the same
fish. Therefore DFO is having increasing difficulty
saying my work is flawed. Unfortunately their analysis
to date has been clumsy.
One very important thing about sea lice is that you can
tell how old they are. When you find lots of baby lice,
you know you are near the mother lice. What other
researchers outside of DFO have done is compare where
the baby lice are to where the farms are and bingo the
baby lice are reliably right at the farms. If you take
the farm salmon out of the pens, the baby lice vanish
from that site. If you go to an area where they are no
farms, there are also no baby lice.
What DFO has failed to grasp is that this science has
gotten away from them. Generally fish research is so
expensive no one does it but DFO and we have to trust
them. But sea lice are really easy and inexpensive to
study and there is a small army of researchers earning
their degrees doing just that. As a result an avalanche
of peer-reviewed published science is coming which
makes it very, very clear sea lice are coming from the
farms and killing wild fish. DFO is the only group
finding “opposite” results worldwide. And right behind
this should come the lawsuits for destruction of the
DFO can play games in the media about how difficult sea
lice are to study and how they think the salt in the
oceans is making lice etc., but they are increasingly
inching further out on a limb that will not support
them. Even the conflicting data from the two teams
within DFO is going to cause them problems. In fact DFO
is widely divided over this issue with enormous
dissention in the ranks.
Now… once we prove sea lice are being enhanced and
spread by farms to wild salmon, a Pandora’s Box of
pestilence will be traced from farms to wild fish
including the viral outbreaks of IHN. IHN is within the
rabies family, it has been allowed to proliferate on
salmon farms at levels and in places never recorded in
natural conditions and in the viral world this opens
the door wide to mutations. Just as the Avian flu is
worrisome because mutation is expected which allow it
to affect humans more than it has, farmed IHN is a
great concern.
The solution to all these problems is so easily
reached. Just separate the wild and farmed salmon and
their pathogens….completely. Since we cannot move the
wild fish, just move the farm fish into closed
containment. Then both the wild salmon industries and
the farmed can flourish. We can have both, why would we
choose not to?
Refereed Publications
Morton, A. B., 1986. Sound and behavioral correlation
in captive Orcinus orca. In: Kirkevold, B.C. and
Lockhard, J.S. (eds.) Behavioral biology of killer
whales. Alan R. Liss, Inc. New York. Pp. 303-333.
Morton, A.B. 1990. A quantitative comparison of the
behaviour of resident and transient forms of the killer
whale off the central British Columbia coast. Report of
the International Whaling Commission. (special issue
12): 245-248.
Morton, A.B. 2000. Occurrence, photo-identification and
prey of Pacific white-sided dolphins (Lagenorhyncus
obliquidens) in the Broughton Archipelago, Canada
1985-1997. Marine Mammal Science. 16(1):80-93.
Morton, A.B. and Helena, H.K. 2002. Displacement of
Orcinus orca by high amplitude sound in British
Columbia, Canada. ICES Journal of Marine Science.
Morton, A.B. and Volpe J. 2002 A description of escaped
farmed Atlantic salmon Salmo salar captures and their
characteristics in one Pacific salmon fishery area in
British Columbia Canada, in 2000. Alaska Fishery
Research Bulletin, 9: 102-109.
Ford, J.K.B., G. Ellis, L. Barret-Lennard, A.B. Morton,
R. Palm and K.C. Balcomb. Diet Specialization in two
sympatric populations of killer whales (Orcinus orca)
in coastal British Columbia and adjacent waters.
Canadian Journal
Morton, A.B., and Williams R in press Infestation of
the sea louse Lepeophtheirus salmonis (Krøyer) on
juvenile pink salmon Oncorhynchus gorbuscha (Walbaum)
in British Columbia,
Morton, A.B., Routledge, R., Peet, C. and Ladwig, A
20004 Sea lice, Lepeophtheirus salmonis, infection
rates on juvenile chum and pink salmon in the near
shore marine environment in British Columbia, spring
2002 CJFAS
Non-refereed Publications
Morton, A.B. 1994/5 The Impact of fish farms on Marine
Mammals, B.C. Marine Mammal Journal vol.2
Morton, A.B. 1985. Humpback Retunion International
Wildlife Sept/Oct.
Morton, A.B. 1987. Into the World of Orcas,
International Wildlife.
Morton, A.B. 1987. The return of the humpback,
Beautiful B.C.
Morton, A.B. 1990. The Play’s the Thing. Nature Canada.
Morton, A.B. 1990. Life Afloat on the B.C. Coast.
Canadian Geographic
Morton, A.B. 1994. These Whales Have Gotten to Know Me,
Smithsonian Magazine Nov.
Morton, A.B. 1996. “Dances with Dolphins”, Equinox.
Morton, A.B. 1996. Salmon Farming’s Hidden Harm. Earth
Island Institute. Summer
Morton, A.B. 1996. Fish Farming – Growing too Fast? BBC
Wildlife October
Morton, A.B. 1997 – present. From the Archipelago
Wave-length Magazine regular column
Morton, A.B. 1997. Where the wild dolphins play.
California Wild
Morton, A.B. 1998. Strangers on the shore. B.B.C.
Wildlife July
Morton, A.B. 1991 Siwiti – A Whale’s Story. Orca Books,
Morton, A.B. 1993. In the Company of Whales, from the
Diary of a Whale Watcher. Orca Books Victoria,
Morton, A.B, 1998. Life Among the Whales. In: Intimate
Nature. Chapter. Ballantine Books New York
Morton, A.B. and Bill Proctor. 1998. Heart of the
Raincoast. Horsdal and Schubart , Victoria
Morton, A.B. 2002 Listening to Whales, Random House,
New York April 2002
Research Projects
1984 – present long term monitoring of archipelago
ecosystem with daily data collection on marine mammal
presence and area usage and local rainfall.
1984 – present Record killer whale acoustics with
concurrent voice track describing whale identification,
behaviour and circumstances to create database large
enough to find relationships between calls and other
parameters. Photo-identification done on the whales and
sent to Department of Fisheries and Oceans database on
killer populations in British Columbia
1987 – present Initiated photo-identification of
Pacific White-sided dolphins to examine social
structure and site fidelity. Currently have records on
940 individual dolphins. Make recordings of these
dolphins to conduct analysis similar to killer whale
work. Finding an extraordinary repertoire.
August 2000 – Responded to fishermen’s reports of
unusual numbers of Atlantic salmon in commercial catch
by interviewing every commercial fisherman in range at
every fishing opening to count 10,240 Atlantic salmon
and examine stomach contents in 800 of these fish.
(Paper with Dr. John Volpe under review)
2001-2002 – Responded to commercial shrimp fishermen’s
report of unprecedented occurrence of an eye affixing
copepod on sole by-catch. Collecting samples and
shipping to interested expert in Mississippi for
co-publication on this anomaly near salmon aquaculture
- Responded to unprecedented appearance of lethal sea
louse levels on juvenile pink salmon by finding an
expert scientist partner, to study epidemic.
(publication in progress).
2002- present – Initiate work on bacterial colonies
beneath salmon aquaculture pens to create project with
interested microbiologists (funding applications
Government position
1996 – 1999 Representative and alternative
representative for Broughton Archipelago, Malcolm
Island and part of Cormorant Island (Area A) on Mount
Waddington Community Resource Board.
3.Presentation of Dr John Volpe
Curriculum Vitae
John P. Volpe, Ph.D.
Department of Biological Sciences University of Alberta
Edmonton, Alberta Canada T6G 2E9
Tel. (780) 492 3308 Fax (780) 492 9234
jvolpe at ualberta.ca
Ph.D. Invasion Ecology. University of Victoria 2001
M.Sc. Molecular Ecology and Evolution. University of
Guelph 1994
B.Sc. Zoology (Honours). University of Guelph 1991
Relevant Work History
Assistant Professor Biological Sciences, University of
Alberta. 2001 - present
Lecturer ES400D Biotic Invasions. Developed and
delivered this full credit, one-time offering. School
of Environmental Studies, U. of Victoria, Sept. 2000.
Fisheries Biologist Management, conservation and
restoration of B.C.’s freshwater fish. British Columbia
Ministry of Environment, Lands & Parks, Fisheries
Branch. Victoria, British Columbia 1995 - 1996
Research Interests
Ecology and social structure of marine-derived food
production systems Ecology, evolution and biocultural
impacts of marine introduced species affecting food
production Marine restoration and relationships between
measures of biodiversity and ecosystem function &
Publications (graduate students in bold)
Peer-reviewed articles submitted, in review or in press
(A1) Volpe, J.P., B.R. Anholt, B.W. Glickman, D.W.
Rimmer. Native juvenile salmonids do not constitute
biological resistance to the colonization of Atlantic
salmon in a British Columbia river: Implications for
invasion. Transaction of the American Fisheries
Society. In review
(A2) Krkosek, M., M.A. Lewis and J.P. Volpe. Fish
Farms, Sea Lice, and Infestations of Wild Salmonids.
Proceedings of the Royal Society of London, Series B.
In review
(A3) R. Naylor, M. Mangel, K. Hindar, I. Fleming, S.
Williams, J.P. Volpe, F. Whoriskey, A. Cooper, D.
Kelso, J. Eagle, R. Goldburg, Fugitive Salmon: A
Framework for Assessing Risks of Escaped Fish from
Aquaculture. BioScience. Submitted
(A4) Volpe, J.P. Slow ecology. Conservation Biology. In
(A5) Volpe, J.P. Johnson’s Grand Theory. Book review:
Imperfect Symmetry: Thermodynamics in Ecology and
Evolution by Lionel Johnson. Fish and Fisheries. In
Current Research Interests
Principal research interests in my lab are i)
Ecological studies of food production systems,
particularly aqua- and mariculture. These food
production systems often include cryptic natural and
social subsidies not reflected in the market value of
products. I and my students are interested in
quantifying these overlooked costs of production and
finding ways for these to be realistically reflected in
natural resource economies. The array of implications
associated with aquaculture escaped Atlantic salmon in
BC is a particular focus of the lab ii) Use of aquatic
and marine bioinvasions to investigate processes
affecting abundance, distribution and adaptive
responses of organisms. Current studies examine
invasions at multiple levels of organization, from
individual based adaptive behavioural responses to
shifts in selection regimes affecting population
dynamics and genetic structure to large scale changes
in ecosystem functions. The role of introduced brook
trout in structuring population dynamics of rocky
mountain rivers and defining interactions between
Japanese oyster and eel grass beds are currently being
investigated. Other ongoing research projects include
the management of apex aquatic predators (walleye,
pike) in large Alberta lakes and quantifying effects of
culverts on boreal forest Arctic grayling population
Presentation – Q & A with Rafe Mair
Rafe Mair - would you comment on the question of
escaped Atlantic salmon
Dr. John Volpe: This is based upon 1% of BC rivers
surveyed and of these, 1% of the river itself is
surveyed. The clear assumption is that the numbers of
escapes in BC rivers is bound to be considerably be
more if proper surveys were done.
Three (3) systems to date have been documented (by me)
to support juvenile, wild reared Atlantic salmon (AS)
(two of which had multiple year classes). (emphasis
Over the past five years, river surveys in BC have been
"haphazard" at best. Since I am no longer doing
structured surveys, DFO no longer needs to be able to
deflect those data and so have suspended any active
work (a survey will only be taken when reports from the
field are numerous enough that they cannot be ignored).
The states of Washington and Alaska, both of them being
“high contracting parties” when the Salmon Treaty is
debated, are initiating active AS survey programs in
response to increasing numbers of AS in their waters.
Peer reviewed research now in the public and scientific
record demonstrates:
- escapees can and do spawn
- wild reared juveniles successfully compete against
and thus negatively affect native species
- impacts are density dependent (increases of Atlantic
Salmon in BC waters increases their impact
The only real question is: what is the critical
abundance after which damages are irreparable?
RM what about the question of sea lice?
JV Voluminous evidence documents salmon farm-derived
sea lice as the major contributing factor responsible
for local extinctions of European salmonids. This has
been demonstrated in Norway, Scotland and the Republic
of Ireland. BC wild salmon populations are at even
greater risk because
i) farms are at much higher density here than in Europe
therefore the "lice load" per unit area is much higher
here than there. The farm configuration in BC would
never be allowed in Norway or Scotland. The clustered
array of farms is seen as necessary by farmers because
all materials must be transported via marine vessels,
which is very expensive. In other areas, terrestrial
transport is an option therefore the farms can be
spread out, allowing the lice/escapee/toxin/sewage
footprint of individual farms not to overlap. The
tendency to cluster farms in BC will only become
greater as the price of salmon continues to fall in the
face of increasing production (Chile and Norway, see
economics section below) - this will undoubtedly lead
to disaster. (Emphasis mine-RM)
ii) Pacific salmonid smolts, when they migrate and run
the gauntlet of fish farms are much smaller in size
(particularly chum and pinks), therefore because of
their smaller size it takes fewer lice to injure kill
an individual. Therefore, obviously, the more lice in
the water + more susceptible species = gloom and doom
It must be noted that all government (DFO)/industry
science to date has been explicitly designed not to
test the hypothesis of farms as the major lice source.
It’s as if they don’t want to know the truth.
RM - What about Social / Economic considerations?
JV - The contribution to the provincial GDP of the BC
salmon farming industry is 8% while commercial and
marine sport fisheries/processing contribute 50%
therefore we risk 50% to save 8% (These numbers come
from the Canadian Centre for Policy Alternatives and
are available from their web page in a document
authored by Dale Marshall). At the same time, foreign
(Chile and Norway) production continues to climb
steeply. Salmon (both farmed and wild) is worth ~ 20%
of its value from a decade ago.
Therefore farmers must find ways of off-loading as much
production cost as possible to remain viable. This has
lead to tighter clustering of farms (see above),
robotic farms in Clayoquot Sound, rationalization of
the workforce etc. The big push to Prince Rupert is
necessary to maintain the economy of scale to be
competitive as Chile is about to double (author’s
emphasis) production and drive the salmon price even
lower! But in Chile because there are simply no
environmental or worker safeguards, production cost is
rock bottom. Chile has just announced a major markets
initiative that will see Chilean salmon "invade"
Canadian stores. This is essentially another off-shore
/ cheaper production scenario we have seen so many
times before, except here the governments seem married
to the idea of battling to the very end and the last
RM - Could you verify Alexandra Morton’s science?
JV - Hers is simply the most credible science
available. This is not my opinion but that of the
scientific community. (Emphasis mine-RM) Unlike her
critics, Alex publishes in peer-reviewed journals, not
on the web. To date, her work (and only hers) has stood
up to robust independent scrutiny. (Emphasis mine - RM)
RM - Could you comment on the statements of Atlantic
Salmon escapes, three according to the Hon. John Van
Dongen, and two fish according to the Hon. Stan Hagen?
The journal Nature (the most prestigious scientific
journal in the world) published last year that in
Norway (where real, active escape monitoring occurs)
approximately 2 million Atlantic salmon escape
annually. And yet here, where the same companies
operate, using the same technologies in almost
identical physical environments, we have 2 or 3
escapees only....? If this were true the operations
officers for these companies would be camped out here
to find out our secret.....
I can't make a more quantitative statement than this,
because there is simply no work going on to assay how
many are escaping (and so if you chose to challenge
these dolts (regrettably, he refers to Ministers Van
Dongen and Hagen – RM) who throw out these ridiculous
numbers and stood up and said "no, there are one
million salmon escaping from BC farms annually", there
are no data available to counter it and you both would
be on equal (ie. non-existent) scientific footing).
4. Presentation by Dr. Neil Frazer
Curriculum vitae for Neil Frazer
Neil Frazer was born in Comox on Vancouver Island in
1948. Neil earned an engineering degree from the
University of British Columbia, and a PhD in geophysics
from Princeton University. He is currently a professor
of geophysics at the University of Hawaii at Manoa. In
Hawaii, a kayak is his vessel, but for the past ten
summers Neil has used small open motorboats to explore
the outer coasts and the inlets from Puget Sound to
Glacier Bay.. Neil lives in Kailua, Hawaii with his
wife and their three teenage children
Sea lice and science: notes for Rafe Mair
Summary: DFO should be stripped of any responsibility
for fisheries science. In regard to salmon farms and
sea lice, DFO has misled the public and their elected
representatives in at least three fundamental ways:
(a) by pretending that the burden of proof is on the
side that says sea lice transfer from farm to wild
rather than on the side that says they don’t,
(b) by doing junk science, and
(c) by not supporting other scientists like Alexandra
Morton and John Volpe who are doing the scientific work
that DFO ought to have done. (Emphasis mine – RM)
1. How did you get involved in this?
I’m a scientist, but my hobby is travelling the coast.
I’ve been all over the Broughton Archipelago, for
example. In 2001 when DFO’s Don Noakes said DFO didn’t
have the vessels to sample pink salmon in the Broughton
I had to laugh. Some years ago I explored most of the
Broughton in a 15’ boat.
The first sea lice epidemic in the Broughton (at least
the first one we are aware of) was a chance for DFO to
do a beautiful piece of science at very low cost. If
they had done it they would have been heroes. Sea lice
transfer from farm fish to juvenile salmonids had been
well known in Europe for over a decade, but was
difficult to study because wild Atlantic salmon aren’t
numerous, and wild, sea-run trout live their lives in
coastal waters.
The epidemic in the Broughton was a terrific scientific
opportunity because the salmon were pink salmon fry,
which are small and easy to catch, there were millions
of them, and they were migrating down inlets past the
farms. All DFO had to do was sample above and below the
farms, which is what Alexandra Morton subsequently did.
It’s unheard of for scientists to pass up a chance to
do a beautiful piece of science at very low
cost—especially when it’s the type of science that
their mandate requires. When this happens, it almost
always means that the institution they work for is
rotten at the top.
The DFO guys did everything they could to avoid doing
the obvious research: they delayed three weeks, they
showed up with the wrong equipment; they sampled in the
wrong places. Children might have done a better job.
Don Noakes led this sham investigation, but Dick
Beamish contributed to it. The only hero was the
pathologist who refused to sign off on Beamish’s sea
lice counts because “These fish were gathered in an
unscientific manner.” (Emphasis mine – RM)
If DFO leadership had any scientific integrity Don
Noakes (then director of PBS), Dick Beamish (former
director of PBS) and Laura Richards (Regional Director
of Science) would have been fired, and Wendy
Watson-Wright (ADM for Science) would have offered her
resignation to the Minister. In fact, nothing happened.
Another thing that got my attention was DFO’s attempts
to halt and then discredit the research of John Volpe
when Volpe was a graduate student at University of
Victoria. For example: Volpe had been promised Atlantic
salmon from PBS, and at the last minute Don Noakes,
then the director of PBS, refused to give Volpe the
salmon. Volpe had to begin his research from scratch at
another location. In science one never interferes with
the research of someone else’s graduate student,
especially in such a way.
In these two affairs DFO scientific leadership has
shamed the many honest scientists who work at DFO, it
has shamed Canada, and it has shamed science. Noakes is
gone, but Beamish, Richards, and Watson-Wright remain.
They should be dismissed and replaced by people with no
connection to DFO and impeccable reputations for
Since you can’t have Orcas without salmon, Alexandra
Morton’s reaction to all this was to stop studying
Orcas and begin studying sea lice. My reaction was to
read the science on sea lice and to work on theories of
parasite transfer between wild fish and farm fish. (On
a personal note, I happen to be a tenured professor,
and BC taxpayers paid for my education through
government scholarships. I am not an environmentalist,
and I have never received funding from any
environmental organization.)
2. What else do you have against DFO?
For years DFO scientific leadership has allowed the
salmon farming industry to fool the public, and has
misled the public itself, by chanting that there is no
proof of disease transfer from farm fish to wild fish.
DFO had a duty to point out that, since elementary
biology tells us to expect transfer, the burden of
proof is on those who say it won’t happen, not the
other way around. DFO also had a duty to either perform
the obvious experiments to study transfer (I’ve written
about these elsewhere) or at least admit that these
experiments had not been done.
With regard to its communications to the public
regarding salmon farming, DFO science leadership is
like the guy who stops at a bar on the way home and
loses his house in a poker game. When he gets home his
wife asks him why he’s late and he says that he stopped
at the bar. What he says is partly true, but it is not
the important part of the truth.
DFO science leadership deserves public ridicule. They
have had every chance to do the right thing, and they
have consistently not done so. When politicians attempt
to use government scientists to deceive the public, the
scientists are supposed to protest or resign. (Emphasis
added – RM) The education and all the professional
activity of government scientists is paid for by the
public, which asks only that they work on things they
think are important, and tell the truth.
3. What about sea lice?
First lets look at theory
It’s a mathematical certainty that putting farm fish in
the water will cause wild fish to decline through
infections—we know this without ever putting a fish in
the water—the only interesting questions are which
infections and how much decline and when it will
happen. The chain of causation goes like this:
Putting more fish into the ocean means more parasites
per fish (because you’ve increased the spatial density
of fish in the ocean) and more predation on wild fish
(wild fish with more infection are weaker, and thus
slower) and lower levels of wild fish. This would be
true even if you put every farm fish in its own cage
and separated them by miles. When you put thousands of
farm fish in one cage, trouble from infection is very
likely, though you still don’t know when it will
Now lets look at experience
OK, so we know before ever putting a fish in the water
that we are going to have disease problems, and
transfer to wild fish is very likely, but without
experience we don’t know exactly what form the disease
will take or when it will hit. (Atlantic salmon had 217
known diseases at last count.) That’s where experience
enters: from experience in Norway, Scotland and Western
Ireland DFO knew that that sea lice is a huge problem.
(They also knew that IHN is a big one, BKD is a big
one, furunculosis is a big one.)
My point is that anyone who had been reading the
scientific literature knew fifteen years ago that sea
lice would be a problem for farm fish and that transfer
was almost certainly harming wild fish. In other words
DFO knew that sea lice would be a problem in BC even
before salmon farming cranked up here. They knew that
transfer from farm to wild would happen.
Example: sea lice at the Burdwoods salmon farm in July
Paid spokespeople for the salmon farmers say that
nobody visited that farm to investigate, which is not
true. My wife and I visited that farm two days before
the Greenpeace protest. The manager gave us a tour and
we chatted with him and his assistant for over an hour.
He confirmed that his fish have lice. He said that
there were 660,000 fish on his farm and, in a sample of
twenty fish, some fish had lice and one fish had five
lice with eggs.
4. So what?
OK, lets do the math for some very conservative
(a) one oviparous (i.e. egg-carrying) louse for every
four fish
(b) 500,000 fish per farm
(c) 1000 eggs/louse/month
(d) 25 farms in the Broughton
The number of sea lice larvae going into the water per
month is therefore (0.25)(500,000)(1000)(25) = 3.1
billion larvae/month.
Assume that only ten percent of those larvae survive to
the copepodid stage at which they can infect fish. You
still have 300 million copepodids going into the water
every month, and most of them are going into the water
right on the migration routes of juvenile wild salmon.
It is unscientific to propose that the juvenile wild
salmon migrating past farms are going to escape
infestation unless you have very strong evidence for
such a surprising result. Remember, the lice on the
farm fish are the immediate descendants of lice
transferred from the immediate ancestors of the
juvenile wild salmon. The sea lice in question are
specialized to salmonids, but they don’t care which
species of salmon they infect.
We only know about pink salmon in the Broughton because
pinks are easy to study (they emerge in the millions
and they are easy to catch) but it is unscientific to
suppose that coho and chinook are not being affected
unless you have evidence for such a surprising result.
Being relatively large compared to pink fry, chinook
and coho juvenile will likely not die as a direct
result of lice infestation, but they will be weakened
and more vulnerable to predators. That is elementary
biology. When juvenile chinook and coho salmon are
infested, lice breed on them and put even more eggs
into the water, so later-migrating juveniles have even
more lice to contend with.
5. What about escapes?
This is John Volpe’s specialty, but I will give you my
views. Yearly escapes of Atlantic salmon from BC salmon
farms constitute a de facto bioinvasion as well as an
ongoing sequence of introductions. Volpe et al. (2000)
found juvenile Atlantic salmon of two year classes in
BC's Tsitika river, showing that escaped Atlantics are
capable of spawning under natural conditions in at
least some Pacific streams. A consequence of their
discovery is that that the probability P of
colonization by Atlantic salmon in any given year is
nonzero. By an elementary calculation the probability
of colonization over n years is given by 1-(1-P)n which
converges to 1 in the limit of large n. As very few
streams in BC are carefully checked for Atlantic
spawners, this probability calculation is retrospective
as well as prospective. In other words, since farmed
Atlantic salmon have been escaping in BC for over 16
years, the probability that they have already colonized
is 1-(1-P)16. For example, if P is 1%, the chance that
Atlantics have already colonized in BC is 15%, and if P
is 2%, the chance that they have already colonized is
27%. (Emphasis mine – RM)
Bioinvasion by Atlantics, even in small numbers, is
unlikely to benefit Pacific salmon. Spawned-out
Atlantic salmon, known as kelts, may over winter in
rivers, creating further potential for pathogen
transmission to emerging Pacific fry with naive immune
systems. In a worst-case scenario Atlantic salmon may
become carriers of an infection to which they are
immune but to which Pacific salmon are not immune. This
type of thing has been known to happen with introduced
species of birds, for example.
6. Notes on people and their qualifications
Qualifications aren’t important for researchers like
Alexandra Morton because research has to stand up to
review by other scientists in order to be published.
(Emphasis mine – RM) However, who you work for is
important: University scientists are promoted depending
on the esteem in which they are held by their fellow
scientists, and little else. Industry scientists are
promoted based on their contribution to the profits of
that industry. How government scientists are promoted
depends on the integrity of their leadership.
Since DFO has on many occasions punished scientists for
publishing opinions contrary to those of the minister,
the leadership of DFO can fairly be described as
lacking scientific integrity.
Let’s look at some of the players.
Patrick Moore
Pat Moore is a paid public relations person for the
salmon farming industry. Pat is paid to emphasize the
part of the story that benefits his client. If Pat
worked for tobacco companies, he would no doubt go
around saying that there is a lower incidence of
Parkinson’s disease in smokers, while failing to add
that smoking promotes many kinds of cancers and greatly
lowers life expectancy.
Alexandra Morton
Dislikes working on sea lice, and would stop in a
moment if she could. If DFO science were not corrupted
by politics, she would still be studying whales full
time. Instead she is doing DFO science’s job for it.
She has no PhD and no institutional affiliation, so her
science has to be even better than usual to get
accepted. It has been accepted; there is nothing left
for her to prove. I’ve read her manuscripts in draft,
and I think they are excellent by any standard.
(Emphasis mine – RM)
John Volpe
He’s a scientific hero. DFO tried to sabotage and
discredit his research, and he refused to be
intimidated. I’ve read his papers and I think they are
excellent. (Emphasis added – RM)
What about administrators? Although qualifications aren
’t important for researchers (because their work is
reviewed by other scientists) qualifications are
important for those who administer science because (a)
the public has trouble judging science, and (b) science
administrators make important funding and personnel
decisions which are seldom reviewed. The most important
qualification for a science administrator is an
excellent research record, as manifested by either
fundamental discoveries or many peer-review
publications. Of course a science administrator must
have other talents, but without a good research record
he or she will not enjoy the respect needed to attract
good people to his organization, nor will he have the
courage to stand up to politicians who try to capture
his organization to support a political agenda. The
lack of scientific qualifications of top DFO science
personnel explains the worthlessness of DFO’s work on
salmon farming and the capture of DFO science by the
salmon farming industry. (Emphasis mine – RM)
Wendy Watson-Wright
DFO’s Assistant Deputy Minister for Science, in other
words, chief scientist of DFO. Her qualifications: a
Bachelor’s in Phys. Ed., a Masters in Exercise
Physiology, and a PhD in Physiology. Watson-Wright
should be replaced by someone with an excellent
research record in fisheries science who has had no
previous connection with DFO.
Laura Richards
DFO’s regional director of Science. Having a PhD and
co-authoring a few papers does not qualify you to
manage science. Richards should be replaced by someone
with an excellent research record who has never worked
for DFO.
Donald J. Noakes
Why was a guy with a degree in computer science (not
biology) and only six first-author publications
appointed director of what was once the most highly
regard fisheries research institute in the world? This
is highly unusual in science.
The most reasonable explanation is that Dick Beamish,
the director of PBS before Noakes, didn’t want to be in
the position of having to feed the public a lot of
baloney about salmon farming, so, around 1992 he
stepped down and let Noakes take his place. Noakes was
Beamish’s friend; they cultivated rhododendrons and
collected beanie babies together.
Noakes had gone straight into DFO from graduate school
in engineering, so he was never part of an organization
that valued scientific integrity. What he understood
was sales engineering, in which you use the science you
know to sell your product. He was a sales engineer for
salmon farming.
Dick Beamish
Many publications. Order of Canada for research on acid
rain done in his youth. Beamish has worked very hard at
not being involved with aquaculture because he knows
that if he is forced to say the kinds of things that
the politicians want him to say, his scientific
reputation will go straight into the toilet. The
important thing is this: He’s the one scientist at DFO
that the politicians could not have ignored or
discredited if he had read them the elementary science
on sea-cage salmon farming. Noakes was his protégé, but
Beamish failed to restrain Noakes or protest Noakes’
actions. He cooperated with Noakes on the sham
investigation of the sea lice epidemic in the
Broughton. For the last fifteen years, at least,
Beamish has taken the easy road by going along with the
politicians. They rewarded him with the resources to
continue his research on coho and climate. (He made a
Faustian bargain and now the devil has come for his
soul in the form of politicians who want him to lie for
them.) It’s probably impossible to fire someone with
the Order of Canada, so Beamish should be forcibly
The scientists at DFO now “studying” the Broughton sea
lice (Dick Beamish and Brent Hargreaves) are smart
guys. They know that the sea lice on pink salmon fry in
the Broughton almost certainly come from salmon farms.
But they also know (see my remark above) that absolute
proof is astonishingly difficult to get in science.
This gives them lots of room to wiggle and protect the
industry by doing inconclusive studies. Dragging around
in the center of the inlets with a big trawl, for
example, as Dick Beamish does. Brent Hargreaves notes
that Alexandra Morton did not account for variations in
salinity, and sea lice epidemics have not occurred on
Muchalat Inlet. They ought to know that just because
you don’t get an epidemic every time doesn’t mean
epidemics are unlikely. For example, if you dress in
black from head to toe and walk down the middle of the
highway at night you may survive several nights, but
that does not mean your activity is prudent.
It’s not possible to do good science when one is
worried about protecting an industry. When I spoke
recently with DFO’s Brent Hargreaves about his research
on sea lice he said “You can’t shut down a multimillion
dollar industry just because somebody waves a placard.”
The fact that the industry, and its wealth would be a
consideration shows that he isn’t really doing science.
When you do science, you can’t think about who will be
harmed by your research and you can’t think about the
money; you have to just think about the science.
(Emphasis mine – RM)
The irony is that DFO’s denial of the inevitability of
disease has hurt the salmon farming industry itself.
Tremendous numbers of farm fish have been lost to
disease simply because farms were sited on the
principal migration routes of wild salmon.
7. Why salmon farming?
South American people are poor. We buy their fish cheap
and sell them to rich North Americans for a fat profit.
The problem is North Americans aren’t familiar with
South American fish and they don’t like eating little
fish. So we grind up those little fish and feed them to
farm salmon and then sell the farm salmon to North
Americans. The protein conversion ratios are terrible,
but one can still make a profit. The irony is that when
you farm big fish by feeding them little fish, you
concentrate the toxins. The smallest fish are really
the safest ones to eat. Therefore, by farming salmon we
starve South Americans and poison North Americans. Does
this make sense for a province with valuable wild
salmon that are increasing in value every year?
8. What should be done?
Strip DFO of any responsibility for science. Fund
fisheries science through NSERC or some other
independent body.
Communities and First Nations should have veto power
over aquaculture. When different communities try
different things, they learn from each others successes
and mistakes. In science this is known as the
robustness of distributed adaptive systems. It’s the
opposite of having decisions about salmon farming
centralized in Victoria and Ottawa.
Research open-ecosystem aquaculture. These are systems
in which predators are not excluded, so that disease
control is quick and inexpensive.
Put to rest the myth that fresh fish is better than
frozen. Fish properly frozen at sea is better than
fresh fish more than twelve hours old. The best chefs
are finding this out, but myths die hard. BC’s wild
fish are a tremendously valuable economic resource, and
they are becoming more valuable every year. It is not
an accident that prices for wild salmon have risen.
9. How did we get into such a horrible place?
DFO was created to bring scientists under the control
of politicians. Prior to the creation of DFO, funding
for fisheries science was funded through the Fisheries
Research Board, an independent body of eminent
scientists. (Emphasis added)
10. Why haven’t more scientists spoken out?
DFO is enormously powerful. You can’t take a fish out
of the ocean without a permit from DFO. If scientists
spent their time correcting nonsense statements by
politicians, they would never have time to get any work
done. The best Canadian fisheries scientists gave up on
DFO in the 1980’s I think. (Note from RM -Premier, this
goes back to the Kemano Completion Plan discussed
above) They are just waiting for it to self-destruct.
Most biologists work for one government or another.
They all have mortgages.
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