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16 scientists condemn ‘scientific failings’ of ‘flawed’ DFO report

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Editor’s note: The following article is joint letter to the Honourable Joyce Murray, Minister of Fisheries, Oceans and the Canadian Coast Guard

Academic scientists’ critique of DFO Science Response Report 2022/045

Dear Minister,

We are a group of 16 professors and research scientists who, collectively, have extensive research expertise in fisheries, epidemiology, and the environmental consequences of aquaculture. We write to express our professional dismay at serious scientific failings in a recently published DFO Science Response Report (#2022/045) about sea lice on salmon farms and wild salmon in BC. We are deeply concerned with the report’s flaws and its main, unsupported conclusion: that the presence of parasitic sea lice on wild juvenile salmon is not significantly associated with sea lice from nearby salmon farms.

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In fact, a simple analysis of the report’s own results indicates an overall significant association between infestation pressure attributable to Atlantic Salmon farms and the probability of L. salmonis infestations on wild juvenile chum and pink salmon (details below).

We, the undersigned, have cumulatively published over 1500 peer-reviewed scientific papers, serve or have served on over 30 editorial boards of scientific journals, include five Fellows of the Royal Society of Canada, and have many decades of experience in science advice processes across levels of government. We note this so that it will not be taken lightly when we say that this report falls far short of the standards of credible independent peer review and publishable science.

In addition to technical flaws, we have serious concerns about the processes that generated this report. The report was written by employees of DFO Aquaculture Management and Aquaculture Science and was externally reviewed by one industry-associated professor. This does not constitute independent peer review. Furthermore, the report appears to rely on selective reporting of non-significant statistical results (see below). Finally, there are over 30 peer-reviewed scientific papers from BC that link sea lice on wild juvenile salmon with salmon farms, and many more papers internationally. Despite some of these being cited in the report, none were integrated into the report’s conclusions.

Yet, the report will be — and has been — taken to imply that sea lice from salmon farms are not a problem for wild salmon. This is not a credible conclusion. The Science Response Report in no way overturns the accumulated scientific evidence that salmon farms are one of the primary drivers of sea louse infestations on nearby wild juvenile salmon.

The research topic that this report seeks to address is fundamental to the precautionary management of salmon farming in BC, and has long deserved a peer-reviewed analysis by DFO that is much more rigorous than the one carried out for this report. Given the report’s major flaws, its findings are not suitable to feed into the upcoming CSAS “risk assessment of sea lice in BC” or policy decisions concerning BC salmon farms.

The key flaws of the Science Response Report are:

  1. the reporting of methods and results appears to be selective, according to ATIP records (Appendix B), such that not all analyses were reported and statistically significant results were omitted;
  2. the contributors to the report are almost all Aquaculture-focused DFO staff with the mandate to “support aquaculture development,” and no external, industry-unaffiliated scientists were involved, such that the report’s approval via a “National Peer Review Process” clearly violated any reasonable standards of independent peer review;
  3. the report downplays a large body of peer-reviewed research — both BC-focussed and international — that has repeatedly demonstrated the relationship between salmon farms and sea lice on wild juvenile salmon;
  4. the report lacks a power analysis to place in context the real possibility that negative results in each region resulted from weak analysis, even if effects of salmon farms truly exist;
  5. the analyses cannot be validated, because the underlying data were not provided.
  6. the claims rely on an unvalidated infestation model that is inconsistent with the state of scientific knowledge on the topic; and
  7. the statistical analyses were inappropriate (in terms of data manipulation, analysis type, and underlying assumptions), and analysis of the results in the report produces the opposite conclusions.

We have included further details regarding these seven issues in the attached “Appendix A.”

In conclusion, this report fails to meet widely accepted scientific standards on numerous fronts, and therefore falls well short of the quality of science advice that you need to make informed decisions on the future of salmon aquaculture in Canada. Wild salmon deserve better.

We hope that this letter is received as it is intended: to be constructive, and to help improve the quality of science advice that reaches you, Minister, and other decision makers at DFO. Ultimately, promoting a system of evidence-based science advice that attains the highest standards of impartiality and transparency, underscored by a rigorous and independent peer review process, will build Canadians’ trust in The Department and decisions surrounding controversial files, such as salmon aquaculture. The scientific community is ready to contribute.

Signed,

  • Prof. (Adjunct) Andrew Bateman, University of Toronto
    & Salmon Health Manager, Pacific Salmon Foundation
  • Prof. Chris Darimont, University of Victoria
  • Prof. (Emeritus) Lawrence Dill, Simon Fraser University, FRSC
  • Prof. Andrea Frommel, University of British Columbia
  • Prof. (Retired) Neil Frazer, University of Hawaii
  • Prof. (Incoming) Sean Godwin, University of California, Davis
  • Prof. Scott Hinch, University of British Columbia, FRSC
  • Prof. Martin Krkosek, University of Toronto
  • Prof. Mark Lewis, University of Victoria, FRSC
  • Prof. Jonathan Moore, Simon Fraser University
  • Dr. Gideon Mordecai, University of British Columbia
  • Prof. Sarah Otto, University of British Columbia, FRSC
  • Dr. Stephanie Peacock, Analyst, Pacific Salmon Foundation
  • Dr. Michael Price, Simon Fraser University
  • Prof. John Reynolds, Simon Fraser University, FRSC
  • Prof. (Emeritus) Rick Routledge, Simon Fraser University

Click here to see the letter with attachments.

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