Salmon Wars: The Dark Underbelly of Our Favourite Fish

A new book pulls back the covers on the true costs of salmon farming, the lax systems that regulate it, and what we can do about it

Life diversifies in order to survive and humans do the opposite—we simplify in order to make things easier for ourselves and by imposing simplification in a world that has taken millions of years to so wondrously diversify, is a violent act on life itself.” (Carl Safina, Ecologist, from 2019 documentary Artifishal: The Fight to Save Wild Salmon)

The day the mooring chains securing Cooke Aquaculture’s Cypress Island salmon farm in Puget Sound to its underwater anchors broke loose, everything that could go wrong basically did. The unfolding disaster of the farm’s literal implosion, witnessed by several people at the time, is laid out in riveting detail by Douglas Frantz and his partner Catherine Collins in their seventh non-fiction collaboration, Salmon Wars: The Dark Underbelly of Our Favourite Fish.

In the nearly 370-page book, the authors meticulously trace the evolution of the salmon farming industry back several decades to the present, from the small, often family-owned pens where fish were destined for local markets to the industrial-scale feed lots of today. They show how the steady consolidation of the industry has landed control in the hands of a few multi-nationals, with each of them vying to become the major player. The authors refer to the trend in consolidation as “big fish eating little fish,” which they argue in the book, has led to a “dystopian vision.”

It’s a vision all the world can see, when, in August 2017, Cooke’s massive salmon feedlot, tenuously secured off the coast of Washington State, collapsed into the Sound.

As the story unfolds, we learn that the cages of the New Brunswick-based company’s Cypress Site 2 operation were so heavily clogged with mussels, kelp, and seaweed—what’s referred to in the industry as biofouling—that they essentially became “solid walls of marine life,” that acted like “massive sails” and were pushed by the tides and currents. As a result, in a slow-motion nightmare, the walkways twisted and became submerged, the net cages were torn open, and tens of thousands of Atlantic salmon were released into Pacific salmon territory.

“The risks of clogged nets,” the authors write, “were well known among salmon farmers and state officials in Puget Sound. Cooke’s lease with the state required the company to maintain its farms in clean and safe condition, with regular inspections and net cleanings. Later reports would show that the accumulation had occurred over many weeks.”

The story illustrates the myriad dangers posed by industrial open-net pen salmon feedlots: water pollution, the threats to native fish, and the lack of transparency and accountability on the part of the industry. Cooke blamed the collapse on the high tides and currents leading up to the solar eclipse that took place two days after the start of the collapse. But Frantz and Collins explain that eyewitness accounts of the system’s failure, as well as tide and current data, indicated there was nothing unusual about either that day. As for the escaped fish, Cooke refused to acknowledge the scope of the breach, claiming at first that only 4,000 and then later that “several thousand” had gotten free of the cages. Tribal fishers from Lummi and Samish First Nations said they alone had caught 55,000 Atlantic salmon in an effort to stop them from entering the rivers and streams of their tribal lands. But Cooke downplayed the number, calling it a “business loss,” and that the seals and other fishers could “enjoy them.”

As Frantz and Collins lay out, the matter would fall into the hands of three Washington State departments and a panel of experts who would investigate not only why the site collapsed and if there was negligence involved, but how many salmon escaped, and most importantly, what it would mean for salmon farming in Washington State.

As it turns out, the investigation found that there was ample warning the structures were unstable as there were reports filed by workers a month before describing buckling as a result of unchecked biofouling. Machinery that would normally clean up the cages was broken. Cooke had the opportunity to “harvest” the fish at that point, but “got greedy” and wanted to wait until they reached market size a few months later. In its report, the state agencies accused Cooke of negligence and found that between 243,000 and 263,000 Atlantic salmon had escaped into Puget Sound—60-70 times more than the company first reported. The anchor and mooring lines failed because they were “heavily corroded” and unable to withstand the strain from the fouled nets.

The investigation led to Cooke being fined $332,000, the cancellation of its lease for all three of its Cypress Island farms, and the end of any plans it might have had for further expansion. Cooke appealed both, but eventually lost.

A few months later, a Bill was passed that banned non-native fish farms, including Atlantic salmon, from Washington State waters by 2025.

Screen shot of Cooke Aquaculture’s collapsed salmon farm in Puget Sound. (Taken from 2019 documentary Artifishal: The Fight to Save Wild Salmon)

Below the Water Line

Frantz and Collins say the idea for Salmon Wars came in January 2020, after attending a community meeting in Mahone Bay, Nova Scotia—not far from their home in Lunenburg—organized by the Twin Bays Coalition. The group formed in response to the provincial Department of Fisheries and Aquaculture (DFA) granting Cermaq an option to lease in a number of areas in the province including two locations in the Chedabucto Bay region near Guysborough, St. Mary’s Bay near Digby Neck, Green Bay to Mahone Bay, and St. Margaret’s Bay.¹ The firm is part of Cermaq Global, formerly a Norwegian state-controlled salmon producer purchased by Mitsubishi Corporation in 2014 for $1.4 billion, with operations in Norway, Chile, and British Columbia, where after years of controversy as well as conflict with First Nations groups, the company was shutting down some of its operations. The company planned to locate more than 20 open net-pen farm sites along the coastline of the Nova Scotia.

“We came away from that meeting having heard a fair amount about the risks and environmental dangers and then we did what we’ve done for all of our other books – we investigated,” says Frantz.

While conducting research for this book, Frantz and Collins came upon a photo on the internet taken by scuba divers beneath a salmon farm near Spectacle Island on Nova Scotia’s south shore. Frantz called it an “aha moment.” The divers had gone down and stuck a yard stick into the sludge beneath the farm and it sunk down 32 inches before hitting the ocean bottom into what Frantz calls a “toxic brew of excrement and excess feed and chemical residue.” The image said “a lot about what’s happening here,” recounts Frantz.²

Yardstick standing upright in waste layer, up to 32-inch mark, Port Mouton Bay. Courtesy Kathy and Dave Brush. 

 Industry ‘wants to control the narrative’

One of the key problems with the size and therefore influence of the industry is that it’s “outstripped the ability of governments to regulate its practices,” the authors write, “from polluting oceans and producing contaminated products, to contributing to illegal fishing and to food shortages in lower-income countries.”

While the authors spend most of the book laying out the problems associated with the industrial-scale farming of fish, they also spend time exploring how and why these practices continue to be permitted, or ignored. It’s a topic of special interest for me, having spent a good deal of my career writing about regulatory capture and industry’s growing influence over academic and government research—arguably the two sources of research that should only be conducted in the public interest but often are not.  

The authors provide examples of how the industry exerts influence on government, academia, and the public—a “playbook” that appears to be replicated in many fields and industries today. One of the issues Frantz and Collins tackle is how legitimate scientific questions that would normally be explored by government or academia, are either not being asked or when they are, the answers are being suppressed.

They tell the story of Dr. Kristi Miller-Saunders, head of molecular genetics at the federal Pacific Biological Station in Nanaimo, British Columbia. Miller-Saunders had been studying the “crashing numbers” of wild pacific salmon for years and starting in 2006, her team found genetic markers for immune system decay and diseases typically associated with farmed salmon in the wild fish. In January, 2011 she published a paper in the journal Science describing genomic evidence that a leukemia-type virus was causing Fraser River sockeye to die in large numbers. Frantz and Collins write:

The anomalies appeared to explain, at least in part, why large numbers of wild salmon were dying. To determine whether the infectious diseases had spread from farmed salmon to wild salmon, Miller-Saunders needed to test farmed salmon. But no farm would provide salmon to test, and the DFO refused to require the farms to cooperate with the request from its own laboratory. Important scientific questions were left unanswered because of the industry’s role in financing government and academic research into aquaculture.

Miller-Saunders found evidence of “salmon leukemia” in dying wild salmon, a disease that critics of the industry said had been detected in Chinook salmon farms sited on the sockeye salmon route as early as the 1990s. Her findings were extremely significant in light of the 2009 collapse of the Fraser River sockeye, when only one million salmon returned to the river to spawn when more than ten million were expected. Legitimate concerns were being raised at the time over how farmed Atlantic salmon were affecting their wild Pacific counterparts in the entire corridor from the Strait of Georgia to the Queen Charlotte Strait, including the Broughton Archipelago.

Miller-Saunders’ findings raised an important line of inquiry: how did the wild fish contract the virus? Despite it being a groundbreaking study, the government scientist was not allowed to speak to the media about her findings. But when the shock and public outcry over the sockeye salmon collapse and its suspected links to the growing clusters of fish farms resulted in the Cohen Commission—a 21-month-long judicial inquiry to investigate the cause—Miller-Saunders was called to testify.  

Douglas Frantz and Catherine Collins. Frantz served as the Istanbul bureau chief for The New York Times, and the managing editor of the Los Angeles Times. He also served as the chief investigator for the Senate Foreign Relations Committee and as the State Department’s Assistant Secretary of State for Public Affairs. He was also the deputy secretary-general at the Organization for Economic Cooperation and Development in Paris. Frantz is the author of eleven non-fiction books, 7 co-authored with his partner Catherine Collins—formerly a foreign correspondent and reporter for the Chicago Tribune, the Los Angeles Times and The New York Times. Collins left her career as a reporter to specialize in the field of international financial fraud. Their latest book is published by Henry Holt and Company, 2022 (368 pages). Photo courtesy the authors.

During her testimony before Justice Cohen, Miller-Saunders revealed that the directives that kept her off-limits to the press were not from within the DFO itself but, she discovered, from the Privy Council Office, which served the then Prime Minister Stephen Harper. Frantz and Collins point to documents revealed during the commission that showed that top bureaucrats “killed the DFO press release” about Miller-Saunders’ study stating it “was not very good” because it was “focused on salmon dying.”

Frantz and Collins also tell the story about how the Canadian government tried to suppress evidence of another virus, infectious salmon anemia (ISA). In 2011, Alexandra Morton and Rick Routledge had evidence that ISA was present in juvenile wild salmon – the first known instance of ISA in the Pacific northwest. Morton is an independent marine biologist and outspoken critic of fish farms and Routledge is a professor of statistics and actuarial science at Simon Fraser University. In their book, Frantz and Collins note that the “stakes were high” because ISA posed a serious threat to wild salmon stocks and the jobs that depend on them, and regulations in the US prohibited the importation of salmon exposed to ISA. The source of the virus had to be identified and shut down. But when the Canadian Food Inspection Agency (CFIA) retested the original samples acquired by Morton and Routledge, it found no evidence of ISA.

“Alarmed by the new information from Morton-Routledge and by competing claims from the CFIA, Judge Cohen took the unusual step of reopening his inquiry for three days of additional testimony,” write Collins and Frantz. Cohen called Dr. Kim Klotins to testify. The senior manager from the CFIA provided Cohen with a “surprisingly candid assessment of how the government saw the stakes involved in the discovery of ISA.”

“Let’s say we do find ISA in B.C and markets are closed, then there will be no trade.”

Frantz and Collins write: “What she meant but didn’t explicitly say was that the CFIA therefore couldn’t afford to find ISA in British Columbia. Her admission demonstrated the triumph of economics and politics over protecting the environment in the federal government.”

By providing one example after the next, the authors show how the industry has exerted its influence and control over the salmon farm narrative. It finances both government and academic research into aquaculture. Independent scientists and researchers who “get in the way” of the industry’s commercial interests often suffer enormous consequences, with their work often discredited and their reputations left in tatters. Essentially, a “long-running legal and psychological battle” has been waged against environmental activists and scientists like Alexandra Morton, Kurt Beardslee, and Don Staniford, for instance. The approach has become a kind of “pattern” and are “part of [industry’s] playbook,” they write.

Frantz and Collins also report on how pro-salmon farm interests fund fake websites “to drive traffic to captive sites” that tout the benefits of farmed salmon. For instance, one now defunct site located on the Internet archive—pcbsalmon.com—assured visitors they should not worry about PCBs in farmed salmon (which incidentally is a result of their diets being high in fish meal and fish oil) because it was already “widespread” in the air, water, food, and environment. Industry-funding of research was also not always disclosed, making it difficult for the public to know what was real and actually based in science, and what was PR spin. The industry’s expensive lobbying efforts are often used to influence policies and regulations to ensure they are lax with little enforcement power.

The authors also mention that in researching their book they reached out to all the main industry players but none responded.

“They want to control the narrative.”

An underwater photo taken in an aquaculture cage with high densities of fish. Courtesy Atlantic Salmon Federation (ASF)

An industry of “freeloaders”

One section of the book that really resonated for me—having spent ten years working in the field of full-cost accounting—is where Frantz and Collins explain how industrial-scale feedlots are really only viable because they externalize the costs of production. These costs would include all the human, social, and ecological costs associated with the industry such as illness, environmental degradation, pollution, and biodiversity loss, to name a few. Essentially, these costs are off-loaded onto the shoulders of taxpayers or future generations.

Frantz and Collins point to a 2019 economic analysis of salmon farming by London-based Just Economics titled, “Dead Loss: the high cost of poor salmon farming practices,” which looked at the industry in Canada, Chile Norway, and Scotland—where 96% of global salmon production is concentrated. Just Economics found that between 2013 and 2019, the industry had produced negative externalities worth roughly USD$47 billion. On closer inspection, the numbers are not only startling, they raise serious questions about how heavily the industry is subsidized by taxpayers. Indeed, the numbers reveal a “false economy” and an industry of what the authors refer to as “freeloaders.”

According to Just Economics, salmon aquaculture is worth close to US$20 billion a year, with about 50% of production controlled by ten multinational companies. But when the long list of “unaccounted” for costs are taken into consideration— fish “mortality events,” escaped fish, lice control, disease spread, medications, pesticides, pollution including uneaten feed and faeces, and the losses to local communities who depend on wild salmon populations—the hidden costs exceed the value of production by more than double.

“Despite those losses, the industry remains highly profitable,” write Frantz and Collins.

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The authors make a point of acknowledging on a number of occasions in the book that the lure of jobs and increased tax revenue often eclipse the environmental concerns, and that employment benefits for rural communities are often overstated by the industry.

To illustrate the point, let’s take a look at how the industry has evolved here in Nova Scotia. According to provincial data, over the last 27 years, production and sales in finfish aquaculture (salmon, trout, halibut, bass, etc.) have skyrocketed from just 1.5 million kg in 1995 to 8.9 million kg in 2021. Over the same time period, sales increased nearly 12-fold to more than $71 million in 2021.

But despite the promise of jobs, technological “innovations” have resulted in jobs being shed not gained. In the finfish industry—where there’s been a 10-fold increase in production since the mid-1990s—the number of jobs has actually declined. In 1995, 311 people were employed in the industry, 100 of those full-time. By 2021, only 254 people were employed, 181 of them full time.

If job creation was commensurate with finfish production, there should have been more than 3,000 people drawing paychecks by 2021.

Workers at a Cooke Seafood site at Rattling Beach checking netting. Screenshot from Cooke Seafood video. 

Over the years, as production processes intensified rapidly in Atlantic Canada, coupled with shoddy regulatory oversight, egregious examples of reckless behaviour on the part of the industry became widely known. This knowledge led to the the Nova Scotia Auditor General’s report, then in 2013, a moratorium on new fish farms, and in 2015, new regulations for the industry. 

Frantz and Collins walk us through these fairly recent developments, and introduce us to the company behind it all, Kelly Cove Salmon, and it’s owner Glenn Cooke, the New Brunswick native who started the company back in 1985 and has been buying up competitors ever since. Kelly Cove Salmon is a subsidiary of Cooke Aquaculture, the company that dominates the scene in North America and is the sixth largest salmon producer in the world. Recall, it was a Cooke Aquaculture site that collapsed into Puget Sound in the summer of 2017, releasing tens of thousands of fish. The year before, Cooke bought that farm and five others in Puget Sound from Icicle Seafoods.  

From salmonbusiness.com

In Salmon Wars the authors set the stage for Nova Scotia’s regulatory overhaul. In early 2012, a year before the provincial government declared a moritorium on salmon farming, Federal charges were filed against Cooke Aquaculture, alleging illegal use of cypermethrin, a pesticide banned for marine use, to fight a stubborn case of sea lice—a move that ended up killing hundreds of lobsters in the Bay of Fundy. The company eventually pleaded guilty to two new counts of using cypermethrin at fifteen of its salmon farms and was ordered to pay $500,000. According to Collins and Frantz, while it was one of the largest fines ever levied in Canada in an environmental case, it was only a fraction of the $19 million in potential penalties the company faced. Also, as part of the plea bargain, the criminal charges against Glenn Cooke and his colleagues were also withdrawn.

“The only person who ended up with a criminal conviction was Clyde Eldridge, the sixty-five-year-old owner of the feed and pet store in Calais who had sold the cypermethrin to the Cooke employee. He was fined five thousand dollars and placed on probation for a year after pleading guilty to lying to American investigators about the sales,” the authors write.

According to Frantz and Collins, the investigators found evidence that cypermethrin use by salmon farms in the bay “had been widespread for years,” and that the “local aquaculture industry association had even distributed a manual with instructions on how to avoid detection when using the pesticide.”

“The pamphlet described how to apply pesticides containing cypermethrin ‘discreetly, so it would be unnoticed by regulatory officials, other fishermen and environmentalists.’”

The authors also describe the 2012 news of an outbreak of Infectious Salmon Anemia (ISA) at Cooke’s operation near Shelburne, Nova Scotia. It would be the first time the deadly virus was detected in the province, and since it spreads through the excretions from infected fish or via contaminated water, it can spread quickly. According to Frantz and Collins, an outbreak can “wipe out an entire cage, and then a farm, and even spread to nearby facilities.”

They write:

“ISA-infected salmon suffer hemorrhages, bloated abdomens, bulging eyes, and, ultimately, death. The U.S. Department of Agriculture warns that the disease can also develop without the infected fish showing any external signs. They keep eating and then suddenly die. By the time the virus is detected, it is usually too late.”

In the case of Cooke in Shelburne, the Canadian Food Inspection Agency ordered the company to slaughter nearly a million fish—something it eventually received $13 million for in government compensation. The authors note that in 2012, the federal government also paid $4 million in compensation to two Norwegian companies, Cermaq and Grieg, to cover losses due to exposure to another virus, infectious hematopoietic necrosis, in British Columbia. The payments, which amount to a bailout to the industry, raise serious questions about accountability. If companies are reimbursed for losses that are a result of their own negligence and poor practices, they have no incentive to change. Put another way, they create the conditions that result in diseased fish, and rather than pay a price for that, they are rewarded.

Frantz and Collins report that the Atlantic Salmon Federation found that between 1996 and 2012, the federal government paid more than $100 million in compensation to salmon farms in Canada’s three eastern provinces (Nova Scotia, New Brunswick, and Prince Edward Island) for destroying diseased fish.

In response to the public outcry over Cooke’s multiple transgressions, the province created an independent panel to make recommendations for new, more rigorous, regulations before the moratorium on new fish farms could be lifted. The review was led by the late Meinhard Doelle and William Lahey who at the time were two law professors at Dalhousie University with expertise in environmental law and policy, as well as in regulation in the natural resources sector. They travelled the province and held hearings in twenty-one coastal communities over a period of eighteen months.³

But, as Frantz and Collins describe, despite the call for a “fundamental overhaul” of the way aquaculture was regulated, the government was “not willing to give up any power,” making “rather plain its primary allegiance.”

In other words, “the industry was happy.”

Sea lice on wild salmon smolts, British Columbia. Screen shot of video by Nuuchahnulth Salmon Alliance.

When Cermaq arrived on the east coast in early 2020, public hearings had become a mandatory part of the “scoping phase” of the revamped regulatory framework. So the company embarked on a “Hello Nova Scotia” road show, and one of them took place in Mahone Bay, where Frantz and Collins experienced a crash course in the murky world of salmon farming. Everywhere Cermaq went in the province, it faced “a drumbeat of public criticism,” write the authors.

“Speaker after speaker denounced the company and its plans.”

 If Cermaq had gone ahead with its proposal to develop between 15 and 20 open-pen Atlantic salmon farm sites, four hatcheries and two processing plants with a minimum annual production of 20,000 metric tonnes of fish, it would have put the province’s new regulatory system to the test. Instead, the company announced that it would not be proceeding, and let all of the Lease Options awarded by the province expire.

Cermaq “open house” held in Chester, Nova Scotia. Photo: Linda Pannozzo

It's worth noting that as Frantz and Collins launch their book in Nova Scotia, the province is in the midst of a 5-year review of its 2015 aquaculture regulations, in keeping with one of the recommendations made by Doelle-Lahey. According to the provincial Department of Fisheries and Aquaculture, the review process currently underway “included interviews with key stakeholder groups as well as an opportunity for Nova Scotians to have input through a public consultation survey,” which closed on September 6th.

“The review process is led by the Nova Scotia Aquaculture Regulatory Advisory Committee, which will consider findings from the review process, including the public consultation survey, and make recommendations to the minister of Fisheries and Aquaculture,” says Bruce Nunn, the department’s spokesperson.

A list of currently licenced aquaculture sites in the province, applications open for public comment, and aquaculture decisions (by year) can be found here.

Cooke Aquaculture, adjacent to Coffin Island, Liverpool Bay. In 2012, reports of ISA infections at this site lit a spark and led to the forming of a coalition of more than 50 organizations including groups from the environmental, tourism, and commercial fishing sectors, calling on the governing NDP under Premier Darrell Dexter to declare a provincial moratorium on salmon feedlots.  Photo: Linda Pannozzo

Where do we go from here?

The book is replete with stories characterizing the aquaculture industry in Canada and abroad as being as slippery as the fish they farm: stories about mortality events, pesticide use, antibiotic use, and disease outbreaks; stories about data being withheld and lack of transparency; stories about how farmed salmon are affecting wild salmon populations, or affecting the lobster fishery. There are important questions being raised about whether there are enough wild fish left to feed the farmed ones, and whether choosing to feed farmed fish over human populations is even ethically justifiable.

Given the sketchy track record of the open-pen systems, it’s not surprising that the authors call for “embracing” the alternative: “the disruptive new technology that is moving salmon farms onto land.”

For one, recirculating aquaculture systems (RAS) would remove one of the main threats facing wild salmon stocks—which are already listed as endangered in Atlantic Canada. There can be genetic effects when farmed salmon escape into wild populations, and diseases and deadly sea lice can spread from infected farms to wild fish, especially when those farms are located on migration routes. Of course, fish farms aren’t the only threats facing wild salmon: overfishing, climate change, habitat destruction, migration barriers, and pollution are also important factors.

Frantz and Collins also tell the heartening stories of how people are working to restore the Miramichi River in New Brunswick and the Penobscot River in Maine for wild salmon. While they are far short of reaching historic levels, they still qualify as success stories.

But given that salmon is “America’s favourite fish,” the authors argue that land-based systems appear to be one way of decreasing the industry’s environmental impact, reducing the need for chemicals and antibiotics, while still meeting the public’s growing demand.

“RAS [recirculating aquaculture systems] fish never touch the ocean, and neither does their waste, which solves a range of environmental and health problems. In RAS tanks, salmon are not exposed to seaborne diseases or parasites, making antibiotics and pesticides unnecessary. The fish have no avenue for escape, eliminating threats to wild salmon. Waste is treated and turned into fertilizer, hauled to landfills, or burned for biofuel. Open-net farms are located in fragile, often remote coastal waters, but RAS plants can be anyplace with enough water to fill the tanks and enough energy to keep them running. Building plants close to major markets reduces transportation costs and the carbon footprint of eating salmon.”

Frantz and Collins acknowledge there are drawbacks and hurdles to RAS systems. For one, producing enough fish to offset the higher costs of construction and operations on land and still make a profit is a challenge. RAS plants also have big feet. Because “all the systems that are free for a farm located in the open ocean need to be re-created in a land-based system: circulation, temperature, oxygen levels, waste collection, sunlight,” the carbon footprint of these systems is large. There is also concern about the impact of the effluent, particularly when released into the marine environment. Also, the crucial need to address alternatives to fish meal and fish oil in the food remains.

Large wild Atlantic salmon photographed in the St. Mary’s River in Nova Scotia in Nov. 2019. Photo courtesy ASF/Nick Hawkins and Tom Cheney.

At one point in the book, the authors describe their visit to Sustainable Fish Farming Ltd., a land-based salmon farm located on the eastern shore of the Bay of Fundy.  Frantz and Collins write:

“The air inside smells like the ocean, but the background noise is not the waves on the shore. Instead, visitors hear pumps sending sanitized, oxygenated water into the tanks. The best vantage point is up a metal ladder to a walkway. From above, one can see about four thousand salmon swimming counterclockwise against the manufactured current in one of the tanks. Occasionally a renegade goes in the opposite direction.”

For me, this image is also a “dystopian” one. I mean, are the land-locked systems actually any kinder to the fish? It’s a thorny subject—one the authors do address briefly. Sure, the fish might be less likely to get diseases and parasites, but I can’t help but wonder what kind of a existence it is for an Atlantic salmon to spend its life swimming against an artificial current in a tank when it has potentially thousands of kilometres of migration routes imprinted on its DNA.

I would have liked to see more exploration of this subject, even if just a philosophical one. Is there any way to raise these fish in more humane ways? What does our treatment of animals tell us about our relationship with nature?

The authors write:

“When it comes to salmon farming, however, some conservationists and animal rights advocates argue that all the methods are cruel, whether the fish are in cages floating in the ocean or swimming in circles in tanks on land. Wolfram Heise, a conservationist in Chile, put it succinctly when he said, “There is no right way of doing the wrong thing.” People for the Ethical Treatment of Animals calls land-based salmon farming inhumane, comparing the density in a RAS tank to twenty-seven fish crammed in a bathtub. In response to these ethical concerns, growing salmon and other seafood directly from cells and plants that mimic the taste and texture is rising in popularity along- side veggie burgers and fake bacon. A San Francisco start-up called Wildtype is working to transform the seafood industry by cultivating salmon from cells. The company has produced what it describes as “sushi-grade” salmon with the same amount of omega-3 fatty acids as wild salmon.”

Despite the drawbacks to RAS—which the authors openly acknowledge—they argue that the technology “offers more hope for a better way of farming salmon as the technology improves.”

But given that it took about four decades to go from the small family-owned salmon farms in the fjords of Norway to the industrial-dystopian scale feedlots of today, what will stop the land-based systems from embarking on the same trajectory? The potential positive impact on wild salmon stocks aside, the repositioning of salmon farms from the oceans to the land will come with its own set of hidden (unaccounted for) costs, unless there are restraints, indeed limits, put on the industry to keep it from doing what the open-net systems did: grow too big, industrialize, be profit-driven, forget about the integrity of the fish, forget about natural limits.

The authors write:

“Land-based salmon farming accounts for only a fraction of the global supply, and its fish cost more than open-net salmon. But the business has taken on an identity and appears poised to grow rapidly as its ocean-based competitors face public opposition and as governments impose greater restrictions on where and how they can raise their fish.”  

From my perspective, that the industry is “poised to grow rapidly” is not necessarily a good thing.

In their book, Frantz and Collins introduce us to Dean Bavington, a professor at Memorial University. They meet up with him in a hotel lobby in St. John’s. In 2017, Bavington and Reade Davis, along with two graduate students, published a paper in Marine Policy titled, “Industrial aquaculture and the politics of resignation.” The paper describes how governments are “in a contradictory position” as both regulators and promoters of aquaculture and how taxpayer subsidies continue despite the risks to wild stocks. The study authors write:

“While neoliberalism is often framed as a withdrawal of the state, many scholars have noted that what is occurring is not so much a withdrawal, as a repositioning. Although many social services and regulatory functions once provided by government agencies have indeed been eroded, there has been a simultaneous channeling of new resources into other arenas, in an effort to create conditions in which private corporations can operate more profitably. This, however, often places the state in a contradictory position, simultaneously serving as regulator, investor, and development advocate for the private sector. This can become especially problematic in moments of ecological crisis when decisive and unbiased responses are needed.”   

Bavington also wrote the book Managed Annihilation: An Unnatural History of the Newfoundland Cod Collapse,” which in part looked at how industrial capitalism affected the way we “manage” commercial fish species.⁴

When Frantz and Collins met with Bavington, he had this to say about aquaculture:

“Their idea of protecting the environment through sustainable production actually destroys fishing places and peoples, breeding grounds and habitats that have established unique ways of living with the ocean and its creatures. It is a death-producing industry, and it is causing serious harm.”

Bavington argues that whether it’s cod or farmed salmon, there are a range of forces, many of them economic, that create a pressure to raise more fish. This makes me wonder about the RAS technology.

I put this question to Frantz and Collins: How are we going to stop the land-based systems from becoming profit-driven, dystopian fish factories too?

In an email exchange, the authors say that the “existence” of the new technology is “not enough” and that systems need to be put in place to ensure compliance with ethical and environmental standards. They write:

“[RAS] must be done right. And to do that, we believe that the RAS industry needs an independent certification program to monitor performance of these land-based facilities – including tracking fish welfare and ensuring that any discharges of water and waste do not damage the environment…The key to keeping these land-based companies on track is that the certification program must be truly independent, unlike the current industry-financed certification programs that are little more than a rubber stamp. 

For Frantz and Collins, whether the fish are raised in an open-net pen or land-based system, the sourcing of fish feed is the “most pressing sustainability problem.” They say, “fully a quarter of the fish harvested from the world’s oceans winds up in feed for aquaculture and pets. Huge trawlers pillage the fisheries off the coast of West Africa and Peru, robbing subsistence fishers of their livelihood and increasing food insecurity.”

While not explicitly stating it, the book makes the case that something has gone terribly wrong with our relationship to nature, and that something very meaningful has been lost. The authors dedicated the book to Collins’ father, Paul Collins, “a dedicated fly fisherman.” In a television interview, Collins tells the story of how her father, who “loved fly fishing the way some people love playing golf,” stopped fly fishing because he was concerned about the species’ decline.

“I grew up eating wild Atlantic salmon because he’d come home from fishing trips with all these fish. Our kids have never known that pleasure,” she says.

I ask the authors, “If the book could achieve one thing, what would it be?” Collins says that while neither she or Frantz are fishers, biologists, or environmentalists, they “want to make responsible, sustainable choices in life for lots of things, including what we put on our dinner plates.” She says that ultimately, they hope the book “will educate readers about this industry” so they’ll “push for change.”

“Obviously, 30, 40, 50 years into this dirty business, we cannot count on the government or regulators to do that for us.”

[If you’re in Nova Scotia, you might also want to attend a Salmon Wars book launch. The series can be found here.]

1. I covered the Cermaq story for The Halifax Examiner. Here are those links:

 Mitsubishi’s Fish: Japanese-owned Cermaq Canada Eyes Nova Scotia for Mega Fish Farm Expansion, Putting the Province’s new Regulatory System to the Test

“Rally” to Oppose Cermaq’s Proposed Industrial-scale Fish Farms Draws Large Crowds

Cermaq’s PR Fiasco (Part 1): Nova Scotians Raise Concerns, Cermaq’s Response? “Shit Happens”

Cermaq’s PR Fiasco (Part 2): Interview with Alexandra Morton

Fish Farm Limbo

Facing “Overwhelming Opposition,” Aquaculture Giant Kills Plan to Open Fish Farms in Nova Scotia

2. Quotes in this section taken from C-SPAN interview, August 2, 2022.

3. I interviewed Doelle in early 2020 to find out what he thought about the Cermaq proposal and if the new regulations were up to the task. At the time he was on leave from Dalhousie University and was Chair in Marine Environmental Protection at the World Maritime University in Malmö, Sweden. He thought it was still possible for the government to make good decisions on a case-by-case basis. Full transparency was key, he said, “about what happens at operating sites in combination with a commitment to only permit sites to operate that are able to meet the standards.” Hiding behind business confidentiality had to end and the strict conditions imposed at the start of any operation should be enforced. “Ultimately, much depends on how the province’s new regulatory system is implemented,” he said.

In their final report, Doelle and Lahey called for nothing short of a “fundamental overhaul” of the regulation of aquaculture and argued that the changes should aim for an industry that’s “low impact” while also being “high value.” They wrote: “By this, we mean aquaculture that combines two fundamental attributes: it has a low level of adverse environmental and social impact, which decreases over time; and from the use of coastal resources it produces a positive economic and social value, which is high and increases over time.” While they were urged by a number of participants in the consultation process to recommend a permanent moratorium on marine-based fin-fish facilities, particularly salmon farms, they weren’t prepared to go so far. They argued that if the regulation of aquaculture was overhauled as they recommend, it would be able to address “the serious and legitimate concerns raised,” and significantly reduce the risks and impacts. They noted, however, that even with the most stringent regulations, fin-fish operations are not appropriate in all coastal waters in NS and one of their “core” recommendations was the creation of a classification system that would rate coastal areas of the province as green, yellow, or red based on their relative suitability for finfish aquaculture. They also recommended that the regulation of aquaculture should be “strongly separated” from the “role of industry promotion,” a conflict of interest that was found to have compromised regulatory rigor in BC, resulting in a successful law suit, and a jurisdictional shift in that province of licensing to the feds. They also highlighted the importance of transparency: “As nearly as possible,” they wrote, “the objective should be to make application of the entire regulatory framework an open book.” But as I’ve noted in my previous pieces on this subject, the new regulations were a significant departure from the Doelle-Lahey recommendations. When the DFA released the new regulations in 2015, the Halifax-based Ecology Action Centre published described the omissions in the regulations as “a failure of government,” and called for a continued moratorium on new fin-fish farms. One of those glaring omissions was the classification system. The EAC argued at the time that the new regulations effectively only provide for “green zones,” providing “no certainty to communities or the aquaculture industry and did not take into consideration that much of the province is not suitable to open net pen fin fish” farming. Another, key, omission involved transparency. The updated regulations seemed to increase, rather than limit Ministerial discretion. According to the EAC—who put out a comprehensive analysis of the new regulations—limiting ministerial discretion was a foundational element of the Doelle-Lahey work because it would increase transparency and build public trust in the system. But instead, the new framework provides “avenues for Ministerial discretion in the absence of public consultation and science-based decision-making,” says the organization. The organization was also denied intervenor status at the province’s first Aquaculture Review Board hearing in May, 2021, to rule on a lease expansion proposal from Kelly Cove Salmon (a subsidiary of Cooke Aquaculture) at Rattling Beach in the Annapolis Basin, a site the group says has been operating outside of legal boundaries since 2014.

4. Bavington was also a reviewer for my 2013 book that explored the relationship between the grey seals and the cod. His work also featured prominently in my book.