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Neil Frazer
School of Ocean and Earth Science and Technology
University of Hawaii at Manoa
Honolulu, HI 96822
neil@hawaii.edu
October 14, 2004
Mr. Rafe Mair
CKBD - 600AM
1401 West 8th Avenue
Vancouver, BC V6H 1C9
Sea lice and science notes
Summary: 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 those
who say that sea lice transfer from farm to wild rather than
on those who say they do not, (b) by doing junk science, and
(c) by not supporting scientists like Alexandra Morton and
John Volpe who are doing the obvious (and relatively inexpensive)
scientific work that DFO ought to have done at least a decade
ago. Accordingly, the scientific management of DFO may fairly
be regarded as unqualified and/or ethically compromised, and
key personnel should be replaced immediately with qualified
scientists who have no previous connection to DFO. Longer
term, fisheries science in Canada should be funded through
Canada's National Science and Engineering Research Council
(NSERC) or similar peer-review agency, and DFO should be relieved
of any responsibility for fisheries science.
- How did you get involved in this?
My hobby is traveling the coasts of BC and southeast Alaska.
Some years ago I explored most of the Broughton Archipelago
in a 15' boat. In 2001, when DFO's Don Noakes said that
DFO didn't have the vessels to sample pink salmon fry in
the Broughton, I knew something was wrong at DFO.
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 was generally accepted in
Europe (by scientists not affiliated with the salmon farming
industry), but it is difficult to study there because wild
Atlantic salmon aren't numerous, and wild, sea-run trout
spend 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 only pretending to be a scientific institution.
In that first Broughton sea lice epidemic DFO leaders 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. High school
students would 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
not gathered in scientific manner."
If DFO leadership had 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.
My attention was also drawn to DFO by its attempts to halt
and then to 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 Pacific Biological
Station (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. It is simply not done.
In those two affairs DFO scientific leadership has shamed
the many honest men and women 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 with people with no prior connection to DFO
and impeccable reputations for research.
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.
- What else do you have against DFO?
For years DFO scientific leadership has allowed the salmon
farming industry to mislead the public, and even 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 transfer doesn't happen, not on those who say it does.
DFO also had a duty to either perform the obvious experiments
to study transfer (see below) or at least to state publicly
that these obvious experiments had not been done.
In its communications to the public regarding salmon farming,
DFO science leadership is like a guy who stops at a bar
on the way home and loses the family home 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 true, but
it's the least 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 use government scientists
to deceive the public, the scientists are supposed to protest
or resign. The education and all the professional activity
of government scientists are paid for by the public, which
asks only that they work on things they think are important
and be as truthful as they can.
- 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 will it happen. The chain of causation
goes like this:
Putting more fish into the ocean results in more parasites
per fish (because the spatial density of fish has been increased,
making it easier for parasites to reproduce) which makes
wild fish easier for predators to catch (wild fish with
more infection are weaker, and thus slower) which causes
wild fish to decline.
The above holds even if you put each farm fish in its own
little cage and put the cages far apart.
Now lets look at experience
OK, so we know before ever putting a fish in the water that
disease problems are certain, and transfer to wild fish
is certain, but without experience we don't know how severe
the disease will be, how soon it will hit, or what form
it will take. (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.
My point is that anyone who had been reading the scientific
literature knew fifteen years ago that sea lice are a problem
for farm fish. DFO knew that sea lice would almost certainly
be a problem in BC. They knew that there is no biological
reason for sea lice not to transfer from wild fish to farm
fish and vice-versa.
- Example: sea lice at the Burdwoods
salmon farm, July 2004
Paid spokespeople for the salmon farmers say that nobody
visited that farm to investigate, which is untrue. 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 well over an hour. He confirmed that his fish
have lice. He said that there were 660,000 fish on his farm
and that, in a recent sample of twenty fish, most fish had
lice and one fish had five lice with eggs.
So what?
OK, lets do the math for some very conservative assumptions:
(a) one ovigerous (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. Then
300 million copepodids go into the water every month, and
most of them go into the water right on the migration routes
of juvenile wild salmon. It is unscientific to argue
that juvenile wild salmon migrating past farms will escape
infection 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 salmonid they infect. Moreover,
juvenile pink salmon are densely aggregated and relatively
slow moving, so once they are infected, it is very likely
that lice will reproduce rapidly on them. All this is elementary
biology.
- What science should DFO have done?
When basic theory and wide experience agree, the proper
scientific response is to design experiments to study the
phenomenon and seek funding to carry them out. One obvious
experiment is to measure lice levels on juvenile wild salmon
in areas with salmon farms and in similar areas without
salmon farms (as Rolston and Proctor have done for the David
Suzuki Foundation). A second obvious experiment is to sample
juvenile wild salmon before and after they migrate past
salmon farms, as Alexandra Morton has done. A third obvious
experiment is to put uninfected juvenile fish in small cages
throughout an area containing salmon farms and measure the
infection rates of these "sentinel fish." A fourth
obvious (laboratory) experiment is to introduce an infection
to a large tank of fish, with some of the fish crowded together
in a cage within the tank. All of these experiments could
have been carried out with less than one percent of the
money DFO has spent to promote salmon aquaculture. DFO has
good scientists at its lower levels, so it is impossible
that these experiments were not considered. That DFO neither
carried out these experiments (apart from shamming the second
experiment) nor made public the need for them, shows that
its management is either scientifically unqualified or ethically
compromised or both.
- Anything else about disease?
An essential part of nature's system of disease control
for Pacific salmon is that at the end of their life they
return to fresh water (which kills their parasites) and
then die. Over the winter, parasites and infections decline
in coastal waters for lack of hosts. In effect, nature fallows
the coast for six months of the year. Nature's fallow is
not total, but it is enough to do the job. Salmon farming
does away with this essential fallow.
- 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 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%.
Bioinvasion by Atlantics, even in small numbers, is unlikely
to benefit Pacific salmon. Spawned-out Atlantic salmon,
known as kelts, may overwinter 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.
- What about qualifications?
Salmon farming industry representatives and DFO personnel
have attempted to discredit the work of Alexandra Morton
because she does not have a PhD, so it is important to clarify
the importance of credentials in science.
For researchers such as Alexandra Morton credentials are
irrelevant because research is anonymously reviewed by other
scientists prior to publication (peer review). However,
the institution that a scientist works for is significant:
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.
On a number of occasions DFO has punished scientists for
publishing opinions contrary to those of the Minister, a
sure sign that DFO is not run on scientific principles.
Let's look at some key figures and their qualifications.
Patrick Moore
Pat Moore is a 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 doubtless 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. I feel sorry for Pat that he has
had to take this kind of work, but at least he is doing
the job he is paid to do, which is to mislead the public.
Government scientists (see below) are not paid to mislead
the public.
Alexandra Morton
She dislikes working on sea lice, and would stop in a moment
if she could. If DFO science were doing its job, 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 first rate to be accepted
by peer-review publications. 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.
As UBC's Daniel Pauly put it: "Alexandra has done the
necessary science. The task now is to help the public understand
it."
John Volpe
He's a scientific hero. DFO tried to prevent, and then to
discredit, his PhD research, but he refused to be intimidated.
I've read his papers and I think they are excellent.
What about administrators? Although qualifications aren't
important for researchers (because their work is peer reviewed)
qualifications are very important for those who administer
science because the public has trouble judging science,
and because science administrators make asset allocation
and personnel decisions that are not peer reviewed.
Qualifications for leadership in science
The most important qualification for a science administrator
is an excellent research record, as demonstrated 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. Let's see how DFO's scientific leadership meets
this criterion.
Wendy Watson-Wright
DFO's Assistant Deputy Minister for Science, in other words,
chief scientist of DFO. Her credentials: a Bachelor's in
Physical Education, a Masters in Exercise Physiology, and
a PhD in Physiology. These are good qualifications for a
junior professor of Physical Education, but not for the
chief scientist of a federal agency with an annual budget
over 1.5 billion dollars. Watson-Wright should be replaced
with someone with many frequently cited peer-review publications
in fisheries science, someone who has never worked for DFO.
Laura Richards
DFO's Director of Science, Pacific Region. Having a PhD
and co-authoring a few papers does not qualify you to manage
science. Richards should be replaced with someone with an
excellent research record who has never worked for DFO.
Don Noakes
It staggers belief that a man with no degree in biology
and only six first-author publications was appointed director
of DFO's Pacific Biological Station, once the most highly
regard fisheries research institute in the world.
One possible explanation is that Dick Beamish, the director
of PBS before Noakes, didn't want to have to feed the public
a lot of baloney about salmon farming, so, around 1992 he
stepped down and let Noakes take his place. (Public statements
leave little room for doubt that Noakes was Beamish's protege;
together they cultivated rhododendrons and collected beanie
babies.)
Noakes joined DFO after 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.
The paper published in Aquaculture by Noakes, Beamish
and Kent is a good example of sales engineering. There are
many true statements in that paper (recall my example above,
about the man who stopped at the bar on the way home) but
the numerical data presented were not analyzed quantitatively,
and when I carried out such an analysis by standard methods
I found that the data do not support the main conclusion
of the paper; in fact they are more consistent with the
opposite conclusion.
Dick Beamish
DFO's most prominent fisheries scientist. Many publications.
Order of Canada for research on acid rain done early in
his career. Director of PBS from about 1980 until about
1992 when he stepped down as Director and was replaced by
Noakes. As noted above, Noakes was Beamish's protégé,
and it is unlikely that Noakes could have been appointed
Director without Beamish's support. Moreover Beamish failed
to restrain Noakes or to protest Noakes' unscientific actions.
Though he left his name off the report-nobody at DFO was
foolish enough to sign that affront to science-Beamish cooperated
fully with Noakes on the sham investigation of the first
sea lice epidemic in the Broughton.
To a scientist the important thing is this: Beamish is
the one scientist at DFO that the politicians could not
have ignored or discredited if he had explained to them
the elementary science on disease transfer. Why he apparently
failed to do so is a mystery. However, it is not unknown
in science for a senior person who has accumulated many
honors, is admired (or feared) by coworkers, and is held
in awe by the public, to fall into the habit of thinking
that the world is as he would like it to be. Beamish has
stated that he knows little about salmon aquaculture, and
I think this is deliberate: it seems clear that Richards
and Watson-Wright depend on Beamish for their thoughts on
sea lice, and it is always much easier, even for scientists,
to tell those who sign your paychecks what they want to
hear rather than what they need to know. It is even easier
to tell them what they want to hear when you don't know
much about the subject yourself. Firing someone with the
Order of Canada would be a national embarrassment, so Beamish
should be forcibly retired as soon as possible.
Recent science at DFO
The scientists at DFO now "studying" the Broughton
sea lice (Dick Beamish and Brent Hargreaves) are intelligent
men. If they have read the scientific literature, and thought
about the elementary biology, they know that the epidemics
of sea lice on pink salmon fry in the Broughton are almost
certainly initiated by salmon farms. However, they also
know (see my remark above) that in science, absolute proof
is never possible. This gives them lots of room to wiggle
and protect the industry by doing inconclusive studies.
Dragging around the inlets with a big trawl, for example,
as Dick Beamish does, may be a good way to do coho surveys,
but it's a poor way to study pink salmon fry, which are
best sampled near shore in water a few meters deep.
DFO's Brent Hargreaves argues that Alexandra Morton did
not account for variations in salinity, and that sea lice
epidemics have not occurred on Muchalat Inlet. Hargreaves
knows that salinity is a second order effect compared to
the presence of hosts. He also knows that the inevitability
of disease transfer from farm to wild doesn't mean that
it will happen at every farm, or that every time it happens
you will be there to observe it.
It is not possible to do good science when one is worried
about protecting an industry. When I spoke with 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 are considerations shows that his science is constrained.
In order to do good 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.
The irony is that DFO's denial of the inevitability of disease
has grievously injured the aquaculture industry. Many millions
of farm fish have been lost to disease simply because farms
were sited on the migration routes of wild salmon.
- Why salmon farming?
This is an economic question not a scientific one, but I
think an economist would probably answer it as follows.
South American people are poor. We can buy their fish cheap
and sell them to rich North Americans for a fat profit.
The problem is that North Americans aren't familiar with
South American fish, and they don't like eating bony, oily
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 scientific dimension to the problem is that when we
farm big fish by feeding them little fish, we concentrate
the toxins. The smallest fish are really the safest ones
to eat. It seems to me that if we taught North Americans
to cook little fish, they would be healthier for it, and
the reduced pressure on South American fisheries would make
fish more affordable for South Americans. However, such
questions are not my concern. My concern is that the public
is being misled by government scientists regarding the effects
of salmon farming on wild salmon. If the public had been
presented with a fair scientific picture, and wanted salmon
farming anyway, I would not be concerned as a scientist.
- What should be done?
1. Relieve DFO of any responsibility for fisheries science.
Fund fisheries science through Canada's National Science
and Engineering Research Council (NSERC) or some other independent
body.
2. As (1) may take some time, Watson-Wright, Richards,
and Beamish should be immediately replaced with scientists
having no prior connection to DFO. Replacements should
be chosen by a panel of scientists with no prior connection
to DFO. If qualified replacements cannot be found, their
positions should be abolished.
3. Give Regional Districts and First Nations veto power
over aquaculture. When different communities try different
things, they learn from each other's successes and mistakes.
In science this is known as the robustness of distributed
adaptive systems. It's the opposite of having decisions
about aquaculture centralized in Victoria and Ottawa.
4. Research open-ecosystem aquaculture systems. These
are systems in which predators are not excluded, thus disease
control is quick and inexpensive.
5. Put to rest the myth that fresh fish is better than
frozen. Salmon frozen at sea by modern methods are superior
to fresh salmon more than 1-2 days old. Halibut frozen at
sea are superior to halibut more than a week old. Chefs
are finding this out, but myths die slowly. BC's wild fish
are a tremendously valuable economic resource available
for sale every day of the year.
- How did we get into such a horrible
situation?
Prior to the creation of DFO, funding for fisheries science
was through the Fisheries Research Board, an independent
body of respected scientists. Under this system scientists
were free to do research that might embarrass governments.
DFO was created to prevent that from happening. Scientists
knew that government control of fisheries science would
lead to the kind of mess we are in now, but it was hard
to make the public understand at the time.
- Why haven't more scientists spoken
out?
1. DFO is enormously powerful. You can't take a fish out
of the ocean without a permit from DFO.
2. Most biologists work for one government or another. They
all have mortgages.
3. After the demise of the northern cod (with loss of 50,000
jobs) and the Kemano fiasco the best Canadian fisheries
scientists gave up on DFO and are now quietly waiting for
it to self-destruct.
- Who the heck is Neil Frazer?
Full disclosure: Neil Frazer was born in Comox, BC. He has
a degree in engineering physics from the University of British
Columbia, and a PhD in geophysics from Princeton University.
He is Professor of Geophysics in the School of Ocean and
Earth Science and Technology, University of Hawaii at Manoa.
He is the author or co-author of over 50 publications in
peer-review scientific journals, and his research has been
supported by the National Science Foundation, the Office
of Naval Research, and the American Chemical Society. He
has an intimate knowledge of the coasts of BC and Alaska
from his expeditions there in small, open boats, and is
the author of the book, Boat-Camping Haida Gwaii: A Small
Vessel Guide to the Queen Charlotte Islands. His current
research interests include the population dynamics of parasite
interchange between farm fish and wild fish, the bioacoustics
of humpback whales, and Bayesian methods for the inversion
of geophysical data. He is not financially supported by
any environmental organization.
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