Thank you for the opportunity to appear before you today, Mr. Chair and distinguished members of the parliamentary committee.
I am Dr. Kristi Miller-Saunders. I've been a research scientist for Fisheries and Oceans Canada for 23 years. For the last seven years I have headed the molecular genetics section in the Pacific region.
My technical expertise is in the area of molecular genetics and genomics, and my research centres on the adaptive capacity of aquatic species. My early research in the area of population genetics has contributed to the delineation of management and conservation units for many aquatic species and the development of a genetic stock identification program for salmon that is now highly applied for fisheries management in Canada and the U.S. Much of my research on adaptive genetic variation has centred on genes important for disease resistance.
For the past decade, my program has shifted focus to the development of new technological approaches to assess the health and condition of aquatic species that can not only identify the presence of key stressors undermining performance but also predict variations in survival. This technology could prove very useful for future assessments on impacts of habitat destruction on fishes. I have carried out this line of research on salmon and shellfish, but I'm probably most known for my research on salmon.
The molecular physiological research performed on salmon by my lab has been particularly focused on the critical and stressful transition periods when salmon smolts migrate from freshwater natal rearing areas to the ocean to feed and grow, and when they return as adults to the rivers to spawn. This research has shown that fish that are physiologically compromised by stressful conditions in freshwater rearing areas, whether that be from anthropomorphic activities, disease, high water temperatures, low oxygen, or other factors, suffer high levels of mortality during downstream and early marine migration.
The same is also true with returning adults. Physiological compromise at this critical period can lead to an inability to deal adequately with additional stressors as fish adapt to a new salinity environment and a shifting habitat. As such, it has become abundantly clear that for migratory species, we cannot simply focus our policies on preserving adequate conditions in one environment. We need to protect these species across the habitats and ecosystems upon which they depend if we are to optimize their sustainability and that of our fisheries.
During this research, my team was repeatedly resolved signatures in migratory salmon that were highly suggestive of the development of disease states associated with pathogen infection. I published the first critical study on this in one of the top-ranked science journals, Science, in 2011, which came out shortly after the evidentiary hearings for the Cohen commission of inquiry had begun.
I was a witness in two of the evidentiary hearings during the Cohen commission of inquiry—the disease hearings and the ISAv hearings—and it was really after this experience that my focus shifted almost entirely to understanding the role that infectious disease might play in declining salmon productivity. The Cohen recommendations were a strong motivation of my research direction, and I worked closely with Dr. Brian Riddell of the Pacific Salmon Foundation and with the chief scientific officer of Genome British Columbia to develop a strategic salmon health initiative, a $9-million project that is the most comprehensive assessment of pathogens and diseases in wild, hatchery, and farmed salmon ever undertaken.
Recently this research team has diagnosed a disease on a B.C. salmon farm that had eluded previous diagnostic detection and is among the third most economically important emerging diseases to the Norwegian aquaculture industry. We have also demonstrated more directly than before that pathogen infection is associated with migratory losses and that infection can considerably enhance the risk of predation by avian and piscine predators.
It is with this background that I speak to you today. I want to use the remainder of my time to offer some comments on issues of relevance to the review of changes to the Fisheries Act and its regulations.
There are many salmon stocks that are at record lows and that no longer are abundant enough to support fisheries. I am concerned, from the 2012 modifications of section 35 of the Fisheries Act, that these stocks may no longer be provided enough protection to rebound and become viable in the future. Moreover, these changes appear to be in direct contradiction to the wild salmon policy, which recognizes that for long-term sustainability of wild salmon resources, we must manage to conserve genetic diversity of our wild stocks, including those that may not be numerous enough to contribute substantively to fisheries.
Without these measures in place, these stocks will never get a chance to rebuild, and the range of stocks available to support fisheries will likely also continue to decline. As such, these changes do not support sustainability of our wild fisheries resources. My lab provides the tools that enable the implementation of the wild salmon policy by providing in-season genetic stock identification to managers so that they can specifically target fisheries on strong, healthy stocks while limiting impacts on stocks in need of conservation. I fear that if we are only protecting weaker stocks from fishing activities and not from other anthropomorphic activities, we may be pushing these stocks toward extinction, and as such lose a considerable amount of the genetic variation that will be so crucially important if these species are to survive the changes in climate that are already upon us and are expected to worsen in the coming years.
In the early 1990s, our west coast coho salmon stocks were severely depressed, and there were no fisheries on coho for a number of years. Even today, fisheries are extremely limited. Hence, under the amended legislation, I am concerned that in future, coho salmon may not receive the same level of protection as other more commercially viable species in southern B.C. How can we ever expect to maintain a healthy, sustainable fisheries if we do not in fact maintain healthy, sustainable ecosystems in which our fish thrive, and if protections are only afforded to species and stocks that are currently abundant enough to support fisheries?
DFO has been moving towards a more holistic management concept than the single-species management approach of the past, which was called the ecosystem-based approach to sustainable management of aquatic resources. This amendment is also at odds with this direction by selectively favouring some species over others. Under ecosystem-based management, scientists and managers are concerned with the cumulative impacts of multiple stressors on aquatic resources within an ecosystem.
I'm also concerned with the provision that harmful impacts that are deemed important under the revised Fisheries Act require harm to directly lead to the death of fish. Certainly my own research and that of my colleagues' has shown that fish that are stressed in one environment may become physiologically compromised, but they may not immediately die within the habitat in which the initial stress occurred. Rather, this compromised state may manifest as an inability to adapt and thrive as these fish move to new habitats. In this case, the death of fish and the impact of the stressor is unobservable.
I now briefly shift the focus of my comments on aquaculture. While I don't see a lot of provisions within the Fisheries Act that directly address aquaculture, I did notice that aquaculture certainly came up in questions that this committee has put to other witnesses.
In British Columbia there is considerable public debate on the risks that salmon aquaculture poses to our wild salmon. Given pressures from ENGOs, fishers, first nations, the scientific community, and the public, and the declining productivity of large numbers of our wild salmon stocks, it's imperative that the regulations put in place to assure minimal impacts of aquaculture on wild stocks are strongly evidence-based, and that the research to understand these risks be transparent, objective, and independent of influence from industry. It is also important that as regulators, we are not afraid to ask questions and conduct research that may unearth findings that are not immediately convenient to industry and may require us to rework policies to ensure minimal risk.
When I started down this path of research in 2012, I was told by an upper manager, who's no longer with the department, that it was irresponsible to ask research questions that could potentially result in negative economic ramifications on an industry if we did not already know the answer. At the time, my lab was developing very powerful technology that could simultaneously quantitate 47 different pathogens—viruses, bacteria, and fungal parasites—in 96 fish at once. We had populated this platform with assays to virtually all the infectious agents that were known or suspected to be pathogenic in salmon worldwide, including many that were associated with emerging diseases in other parts of the world but that had never been assessed in Canada. The manager was concerned that by employing this technology, we would make our salmon in B.C. look dirty, and impact their economic value in the market, and that if we uncovered agents that were not known to be endemic, ENGOs and the public would immediately point to the aquaculture industry as the culprit. As such, the attitude was don't look closely, especially for things that we didn't know already were there. It took almost two years to get approval to go ahead with this technology, which we are now employing on over 26,000 wild, enhanced, and farmed salmon in B.C.
I should say at the outset that I'm neither an industry advocate nor an anti-industry advocate. I feel very strongly that scientific research must not have an agenda and must remain independent from influence, especially if our research findings are to be accepted by the public and used to inform policy. I believe this independence is also crucial for public acceptance of the industry.
To use an analogy, we know that most drug trials are funded by pharmaceutical companies, and it's well evidenced that scientists who work with these companies rarely publish research that is either inconclusive or does not show positive benefits of the drugs under study. As a result, doctors and the consuming public are often unaware of the circumstances under which a drug may not be effective. The CBC reported on this finding just last week.
Since 2015 there have been great inroads undertaken by the department to move to a more science evidence-based approach to policy development. I wholeheartedly applaud these efforts, but it can be difficult when the department continues to carry a dual role as a regulator and an advocate. At a working level, I remain concerned that there is continued reluctance by scientists, veterinarians, most of whom have strong ties to the industry, and managers to ask questions and undertake research that might not turn out favourably for the industry. The level of DFO consultation with industry remains very high. While this can be a good thing, in my view when we are addressing risk assessments, regulators and researchers need to have objective independence from industry.
At present, the department relies heavily on information that the industry provides to determine, for example, what pathogens and diseases to focus risk assessments on. There are not, to date, any provisions to enable scientists to conduct risk assessments to sample fish on farms unless the industry agrees to provide them. With those agreements, the industry generally retains some level of control over how the information is analyzed and interpreted. The exception is the regulatory audit program, whereby the aquaculture management division collects samples of normal daily mortalities from farms that are randomly selected for sampling. When the industry was regulated by the Province of B.C., they had a right of refusal to provide these samples, but that changed when the federal government took the lead. My research program is the first to be allowed access to these audit samples for research purposes, and I'm extremely—
