1037 Madore Avenue, Coquitlam, British Columbia, Canada V3K 3B7
phone 604.936.9474 fax 604.936.5150 e-mail wwss@telus.net

October 22, 2004

(Bud) C. C. Graham
Assistant Deputy Minister, Resource Development and Sustainability
Ministry of Agriculture, Food and Fisheries
PO Box 9120, Stn. Prov. Govt.
Victoria, BC V8W 9M2

Dear Bud:

Re: The myth of over-spawning, and other misconceptions and mistruths

I read with interest your response to comments I made on the Rafe Mair show about the myth of over-spawning.

As you'll recall, I made those comments following the July 19 meeting you and your Minister attended with the Haig-Brown Fly Fishers Association in Victoria. Interestingly, you adopt precisely the argument you reject-i.e., you "believe" your explanation is valid even though you admit not having the data to support your belief. And even though you have read the William's et al. report, and attended several scientific workshops on sea lice and salmon farms, you still appear to cling to unsound notions in both your note and in your denial of environmental impacts from open net-cage salmon farming.

I did indeed, as you noted, review the William's et al. report, and agree with its conclusion-that large (not over) escapements and lower productivity likely contributed to dramatic and sad declines of the area's wild salmon.

But contributing is not the same thing as causing. Let me summarize:

For years, fisheries managers and many fishermen held that over-spawning was a bad thing that should be avoided at all costs. Predictably, the "costs" included too little precaution and too much killing of salmon-as demonstrated in the 2004 Fraser River sockeye disaster. After all, why allow too many fish to escape from harvesters, when these fish would otherwise be wasted (never mind the nutrients they bring), just die along the way anyway, or harm their brethren through over-spawning impacts?

The press release heralding the Pacific Fisheries Resource Conservation Council (PFRCC) report-the report I referred to in my interview and in the Victoria meeting-concludes that: "an
assessment of available data for 21 sockeye salmon stocks and two pink salmon stocks [provides] evidence of declining rates of production at higher escapement levels, [but] there is no evidence to support anything like a 'collapse' or 'near-collapse' occurring." Furthermore, the statement says this "is significant as it demonstrates that very productive stocks will not suffer when risk averse management and other precautionary measures are undertaken to protect weak stocks."

Thus, the best scientific evidence indicates we cannot pin the 2002 collapse of Broughton pinks-and if this doesn't qualify as a collapse, then I hate to see what does-on over-escapement. Sorry, make that should not. Obviously, some people try; hence, my choice of the word, debunked.

The constant bunking and debunking surrounding government's myopic salmon farming agenda only fuels the frustration that the anglers attempted to convey to you and your Minister.

But before I go there, allow me to expose another myth so frequently wielded by self-interest groups (government included) to discredit people who care about wild salmon. And that myth is that conservation groups which speak out on these issues are anti-aquaculture. That assertion is especially galling to those of us who help organize and finance scientific workshops designed to honestly assess and deal with the risks posed by open net-cage aquaculture, and those of us who sincerely attempt to introduce potentially sustainable alternatives. Sadly, these workshops and efforts are largely ignored, trivialized, or rebuked. Please, then, let me restate: salmon conservationists are not anti-aquaculture, but they are pro wild fish, and you should cut them a little slack if they feel a tad under-whelmed by how their concerns are received, and by how governments continue to deny, lie, obfuscate, and thus rob from the future.

At the meeting we all attended, you and your Minister spent nearly 90 minutes extolling the economic benefits of salmon farming, and the 'environmental safeguards' you have put in place. The minister frequently referred to 'acting progressively' upon the recommendations of the very dated (especially on lice research) Salmon Aquaculture Review, once even mentioning this report's 'prominent position' on his office shelf. After an hour and a half, I suggested that the anglers in the room were hoping to hear an objective assessment of the risks associated with open net-cage aquaculture, and an honest appraisal of your government's progress in making farming sustainable, especially with respect to sea lice.

And herein lies the problem.

Despite the overwhelming weight of evidence suggesting a link between farms and impacts on wild fish, and despite the fact that there is no peer-reviewed science within government contradicting that weight of evidence, government continues to flout the precautionary principle (to which Canada is a signatory), continues to ignore and/or trivialize the hard lessons learned in Europe and elsewhere ("The situation is different in Canada."), continues to withhold data (and often money) that might shed desperately-needed light on the risks of farming, and continues to wield uncertainty as a tool to maintain status quo policies and practices and to advance government and industry goals-as unexamined, narrow-focused, and unwise as those might be. You did so in the meeting by saying, "We can line up our Ph.D.s and you can line up yours and they will say different things." (This ignores the weight of evidence, and is akin to "tobacco science".) Your ministry did so in a press release claiming that BC has the best salmon farming regulations in the world (even though we have no meaningful biological management guidelines for lice-as required for European farms-and for which your ministry was criticized at the Alert Bay sea lice meeting). You even use uncertainty in the last line of your letter, in addition to the misdirection on the myth of over-spawning.

This is all, of course, expected. Adaptive management guru Buzz Holling gives an excellent overview of the intentional misuse of uncertainty by vested interests in Panarchy, along with a sobering description of the sadly predictable pattern of resource management pathology. But such explanations, as enlightening as they may be, don't make any of this more palatable or acceptable. Nor do they change the fact that citizens in democratic societies (perhaps naively) expect elected officials (and their staff) to possess integrity and to act in the public's best interests.

You clearly took exception to the fact that Watershed Watch presumes to promote honest and open dialogue that is in the public's interest. You were extremely defensive and hardly open at the meeting-an observation made independently to me by several of the people who attended the meeting.

You also handed out a critique of Watershed Watch's recent paper on sea lice and salmon. Watershed Watch's mission, for your edification, is to elevate the dialogue surrounding the threats facing wild salmon. To fulfill that mandate, Watershed Watch contributes to scientific workshops on salmon, and hires independent scientists to produce reports examining such threats. While it is your right to critique the critiquers, Watershed Watch made an honest attempt to explain a subject that clearly troubles a large number of British Columbians. Government cannot claim the same, but does not hesitate to attack those who do. Instead, you have "published" a shoddy "white paper" on sea lice and failed to respond to a Coastal Alliance for Aquaculture Reform critique of that embarrassing effort (and perhaps even failed to inform your Minister of that critique, as he claimed not to have seen it). Instead, you hand out a nitpicking response to Watershed Watch's professionally-referenced research, research meant to answer the many questions we repeatedly hear about the sustainability of the current methods of farming favored by your government. Our attempts to answer those questions, while admittedly not perfect (after all, much of the data are not shared), have been well received by a wide audience of concerned citizens tired of a diet of government propaganda and pandering.

As well, the "review" you handed out has no attribution as to who authored it, or where it came from, for that matter. There is nothing which would help the reader assess its validity, its authority, its research, or where to find the "facts" that it suggests are misrepresented. Its intent is crystal clear, however: muddle, obfuscate, attack, discredit, deny. Collectively, these observations raise substantial ethical concerns. It is also ironic, to say the least, that you accuse Watershed Watch of spreading propaganda on the economic merits of farming, when government itself is the main source of propaganda on the actual economic returns, the safety of the current and favored method of farming, and on the care government provides to the wild fish that those present at the meeting value.

Finally, please do not trouble yourself, or Watershed Watch, by replying with counterpoints. You can debate little things and continue to obfuscate, overwhelm, and misdirect until the cows come home-or until wild salmon no longer do. That is, you can if you wish to continue plying your current and unprofitable path. What we need instead is meaningful and honest dialogue and leadership that considers the long-term best interests of all British Columbians. Unfortunately, in your recent correspondence with the PFRCC, you once again show a disturbing lack of support for both.

If you change your approach and wish to go there, please let me know.

Sincerely,

Craig Orr
Executive Director