The following letter which was sent to the Minister of Fisheries, Honorable Keith Ashfield, was published in the Liverpool Advance over three issues, July 3, 10, and 17th. The Mersey Biodiversity Facility is one of only two facilities holding endangered populations of wild Atlantic salmon. Any error in operation or a disease outbreak in the alternate facility, Coldbrook, could doom restoration effors if there is no alternate facility.
Honorable Keith Ashfield
Minister of Fisheries and Oceans
House of Commons
Room 107, Confederation Building
Dear Minister Ashfield:
We are writing you today regarding the recent decision to close the Mersey Biodiversity Facility, located on the Mersey River near Milton, Queens County, Nova Scotia. Certainly, we do realize that budget cuts are at times necessary, however we fail to understand the logic behind this facility closure.
The importance of maintaining this facility to support the future recovery of endangered Atlantic salmon and Atlantic whitefish is of utmost concern to the members of our Association, and Nova Scotians in general. The fact that the only remaining native Atlantic whitefish population in the world exists in the Petite River watershed, should be of sufficient significance to warrant population recovery support. It is our understanding that the Mersey facility closure decision was principally determined by bureaucrats in Ottawa, without the valuable input of biologists from the DFO Science Division in Halifax, input which would have been vital to allow Ottawa to understand the negative ramifications of this decision.
A representative of our Association attended the DFO Species at Risk Salmon Recovery Planning Assessment Conference held in Dartmouth from May 22 to May 25th, 2012. At that time we were officially informed of the DFO decision to close Mersey, an action which is expected to severely hinder the recovery potential of endangered Atlantic salmon in existing Southern Upland salmon rivers. In reality, this closure decision will likely mean that your future efforts to recover local Atlantic salmon will become virtually impossible. The very capable and dedicated employees at the Mersey Facility continue to perform their duties at a professionally high level of integrity, in spite of this process, and should be complimented in this regard.
In 1997, a previous Minister of Fisheries, the Hon. David Anderson, responded to our Petition to the Auditor General, Denis Desautels, pertaining to concerns which our Association had raised in opposition to the DFO Divesture Initiative. At that time, Fisheries and Oceans was closing hatcheries, and divesting others. With the Medway River salmon angling season having been closed in 1996, a closure which still remains in effect today, and the Lahave River recreational fishery later being closed in 2010, we find no pleasure in pointing out that Minister Anderson missed the mark in 1997. His response stated in part that “ salmon conservation will be ensured by use of management measures such as changes in fishing seasons and catch limits, catch and release fishing, etc., as required “, and also stated that hatchery facilities were not required. This was little more than a bureaucratic smoke screen to justify hatchery closures. We view the recent Mersey decision as an extension of that previous ill-conceived bureaucratic agenda. Please refer to that earlier exchange of documentation, which can easily be found through a simple Google search for “Queens County Fish and Game Association Auditor General “. It is painfully obvious that a lack of DFO action since 1997 has contributed to the current level of decline of salmon populations in the Southern Uplands of Nova Scotia.
In 2001, after the dust had settled on our numerous Access to Information requests following the DFO Divesture effort, your Department published a document titled - An Operational Policy Framework for Recreational Fisheries in Canada. Principle number 2 which was included in that Policy on page 5 states in part ….”It also involves promoting a shared conservation ethic in conjunction with all stakeholders to provide for sustainable harvesting opportunities, and where required, protect, restore, and enhance fisheries resources and fish habitat. Securing vibrant and robust fisheries resources is the cornerstone for sustaining recreational fisheries and increasing the growth of this sport and its associated economic activity.” Nova Scotians take pride in keeping their word, and expect Fisheries and Oceans to do the same. We are at a loss to understand, with salmon angling seasons being closed in the Southern Uplands, how DFO will meet its Policy of ensuring salmon abundance and conservation, let alone securing future recreational salmon angling opportunities, should the Mersey Facility be closed.
Over the last 35 years, our Association has accessed almost 1.5 million dollars to help modernize, and triple the production capacity of the Mersey Facility. Mersey has a deep and shallow water intake ability, to allow water temperature mixing depending upon the air and water temperatures, to maximize proper salmon rearing conditions. Mersey was the first hatchery to produce a quality one year smolt, and was years ahead of its time compared to other hatchery practices, by capturing river specific salmon brood stock, segregating their progeny in the facility, and releasing them back to their location in the river of origin at various life stages, to help maintain genetic variability and river specific uniqueness. This would include rearing and releasing mature adults under important Live Gene Banking programs. The Medway River has benefited from numerous previous hatchery stock support programs, and still exhibits excellent salmon genetic variability today. The present egg incubation equipment and oxygen injection system at Mersey ensures that it is a modern world class facility, and a future closure of Mersey would certainly be viewed as a major slap in the face to dedicated volunteer efforts.
The Mersey facility operates as a salmon support unit, in conjunction with the small DFO facility at Coldbrook, N. S. During the warm summer, brood stock is maintained in the cool water at Coldbrook, helping to maintain their fitness until fall spawning occurs. Some fish are raised in Coldbrook`s limited number of rearing ponds. The cold well water at Coldbrook, and its very limited quantity, creates a situation which can cause egg mortality, and additionally, fry do not hatch or feed very well in the cold water. Mersey operates as the major egg and production facility for existing Inner Bay of Fundy salmon Recovery programs. To think that Coldbrook can solely meet the production needs of the Inner Bay of Fundy, and the Southern Uplands salmon recovery, is just not realistic.
Of course, DFO can spend significant capital dollars to upgrade the Coldbrook facility, continuously heat existing water used in the facility, and attempt to purchase additional land, but the stumbling block will be a lack of water quantity. Attempting to mitigate disease recycling in endangered Atlantic Salmon, when existing water must be re-circulated through the pools, would not sufficiently follow proper due diligence, or meet the requirements of the DFO Precautionary Approach Policy. Mersey presently meets that requirement, and does not need to re-circulate water, or require expensive upgrades. Using the DFO Mactacquac facility in New Brunswick for Nova Scotia salmon production, presents many other concerns, and would be expected to create undue levels of risk and stress on our local endangered salmon stocks. The temperature difference and other water quality concerns relative to our Nova Scotia waters, pertaining to salmon rearing and cross border transport and release are so significant, that we do not even feel Mactacquac to be an option even remotely worthy of further comment.
Unfortunately, some DFO biologists presently hold the position that hatchery reared fish are sub-standard to wild fish, and hatcheries are not needed except for a last resort LGB ( Live Gene Bank) program to help prevent salmon extinction. While we can appreciate this position, we have yet to see a scientific, peer reviewed report conclusively substantiating that position, under situations where hatchery programs are properly being managed. The successful introduction of Medway salmon above Morgan Falls on the Lahave River in the late 1960`s and early 1970`s, and the introduction of later progeny of those salmon to the Sackville River, are two good success stories of effective introduction and re-colonization of Atlantic salmon under Mersey Hatchery programs. We do agree that salmon domestication can occur, and fitness may be compromised, under an improper hatchery rearing program. It is standard practice for DFO, and supported by DFO biologists, to utilize LGB hatchery programs to prevent extinction of genetically distinct salmon populations. These issues must be kept in perspective, as one DFO policy will not fit all situations. We only need to look at existing British Columbia DFO hatchery support programs, to understand that Nova Scotia salmon programs would be discriminately compromised under a possible future Mersey Facility closure.
The dangers facing our Atlantic salmon include marine mortality during that portion of their life cycle. We can assume that seals and other predators have an impact, but there are likely many other factors that contribute to the problem of declining salmon populations in the Southern Uplands, as well as in the Inner Bay of Fundy. We would suggest that Fisheries and Oceans soon initiate meaningful research to determine the actual causes of marine salmon mortality. We would be pleased to learn the findings of any future efforts by DFO in this regard, and the proposed action to be taken.
At the recent DFO Salmon Zone Management Advisory Committee meeting held in Bridgewater on June 12, 2012, which DFO promotes as being important to the DFO salmon management process, the consensus from stakeholders required that continued operation of Mersey was critical to salmon support in the Southern Uplands. It is very likely that the Atlantic Whitefish Recovery Committee also holds a similar position.
It is our understanding that Nova Scotia Power will continue to be co-operative and supportive should Fisheries and Oceans make the decision to continue to operate the Mersey Facility, as leases have successfully been renewed with NSP in the past. In the event that Mersey is closed, DFO will need to clarify the significant expenses involved to dismantle and remediate the existing Mersey site, and the expensive capital upgrades and additional annual operating expenses required at the Coldbrook Facility, versus the annual operating costs for Mersey. A complete cost benefit analysis, which clarifies all of these potential future actions, may prove very embarrassing to some DFO bureaucrats.
From the above, it is our opinion that you have previously received inaccurate bureaucratic advice in this matter, or a lack of good advice, when the decision to close the Mersey facility was determined. We are clearly unable to understand how this closure decision will allow DFO to meet its mandate to ensure the conservation of our Atlantic salmon populations, or provide for future angling seasons.
It would be appreciated if you would now re-visit the previous Mersey closure decision, consider the points which we have raised, and advise us of your final determination. The future health and recovery ability of our Atlantic salmon, will clearly hinge on your decision to continue operating the Mersey Facility.
Thank you for your anticipated support in this regard.
Queens County Fish and Game Association
P. O. Box 1598
Liverpool, N. S.
cc Hon. Gerald Keddy MP
cc Premier Darrell Dexter
cc Vicki Conrad MLA, Queens
cc Mayor John Leefe, Region of Queens
cc Nova Scotia Salmon Association
cc Atlantic Salmon Federation
cc Nova Scotia Federation of Anglers and Hunters
cc Rob Bennett, Nova Scotia Power