Watershed Watch Salmon Society Responds to DFO September 28, 2017 update on Implementation of the Cohen Inquiry Recommendations

What is the Cohen Inquiry?

The Commission of Inquiry into the Decline of Sockeye Salmon in the Fraser River was headed by Justice Bruce Cohen, took over two years to complete and in 2012 culminated in an 1100 page final report and 75 recommendations. The entire inquiry cost taxpayers over $37 million.

The recommendations are pragmatic and wide-ranging; covering habitat protection, salmon farming, hatchery management, fisheries management, government accountability and more.

Despite the enormous cost of the Inquiry, the previous federal government did very little to implement the recommendations. The current government committed to implementing the Cohen recommendations in both their election platform, and in Prime Minister Trudeau’s mandate letter to the Minister of Fisheries and Oceans (http://pm.gc.ca/eng/minister-fisheries-oceans-and-canadian-coast-guard-mandate-letter).

Was DFO’s 2017 implementation update useful?

While this progress report, like the one in 2016, is an important demonstration of transparency, many details in the report are disingenuous and disappointing. The pace of implementing the recommendations has slowed since the last update in 2016.

The 2017 update reports on 64 out of 75 recommendations that have been “acted upon.“ While this is a good start, the recommendations were intended to be fully completed, not just “acted upon.” Many of the recommendations have deadlines attached to them, which have long since lapsed. In many cases, where DFO report they have “acted on” recommendations, they have fallen far short of actually completing them.

Self-reporting by DFO isn’t enough. We need an independent review of their progress, as detailed in recommendation #75. The Cohen Inquiry was essentially an investigation into DFO’s management of salmon, and it is therefore inappropriate to rely solely on the subject of the investigation for a progress update.

Implementing Cohen’s recommendations has never been more important. This year’s sockeye return to the Fraser River was one of the lowest on record.

Examples of major shortcomings in DFO’s implementation of the recommendations

There are numerous examples of Cohen recommendations that have not been completed.

Recommendation 75 – Independent audit of recommendations

“An independent body such as the office of the Commissioner of the Environment and Sustainable Development should report to the Standing Committee on Fisheries and Oceans and to the public as follows:

  • By March 31, 2014, and every two years thereafter during implementation of the Wild Salmon Policy, on progress in implementing the policy in relation to Fraser River sockeye salmon.
  • By September 30, 2015, on the extent to which and the manner in which this Commission’s recommendations have been implemented.”

This is incomplete. Essentially, the integrity of DFO operations around salmon management were investigated by the Cohen Commission; hence, an update from the agency under investigation is only worth so much. To date, no independent assessment has been completed of the implementation of all the recommendations.

Recommendation 4 – Wild Salmon Policy

“The Department of Fisheries and Oceans should immediately create a new position in the Pacific Region at the associate regional director general level with responsibility for

  • developing and implementing the Wild Salmon Policy implementation plan recommended under Recommendation 5; and
  • supervising the expenditure of funds provided under Recommendation 6 for implementation of the policy.”

This is incomplete. No new associate regional director general has been appointed. DFO’s logic for saying this recommendation has been “acted on” ignores the recommendations’ main intent; that a single high-level official be given primary responsibility and accountability for implementing the policy.

Recommendation 6 – Wild Salmon Policy

“The Government of Canada should establish dedicated Wild Salmon Policy funding sufficient to carry out the Department of Fisheries and Oceans’ implementation plan and to cover ongoing operational costs.”

This is incomplete. No dedicated funding has been allocated to Wild Salmon Policy implementation and DFO’s logic that “funding in DFO is attached to programs that implement policies, rather than policies that guide programs” is a meaningless dodge. While federal funding for salmon science and habitat restoration has increased, 2016 and 2017 saw the lowest levels of salmon monitoring since the second world war. A recent study by Simon Fraser University researchers found that that status of 50% of all wild salmon populations on BC’s north and central coasts cannot be assessed due to the current lack of monitoring (http://at.sfu.ca/aSFqMp).

Recommendation 18 – Salmon farming

“If at any time between now and September 30, 2020, the Minister of Fisheries and Oceans determines that net-pen salmon farms in the Discovery Islands (fish health sub-zone 3-2) pose more than a minimal risk of serious harm to the health of migrating Fraser River sockeye salmon, he or she should promptly order that those salmon farms cease operations.”

This is incomplete. Salmon farms in the Discovery Islands have not been removed despite new scientific evidence identifying new disease risks from salmon farms. A scientific article, “Risk and Precaution: Salmon Farming,” was published in the journal Marine Policy in December 2016. It concludes that salmon farms in the region of concern present greater than minimal risk of serious harm and that the farms in the Discovery Islands should be removed.

Another scientific paper, “Heart and skeletal muscle inflammation (HSMI) disease diagnosed on a British Columbia salmon farm through a longitudinal farm study” was published in February 2017 and identifies a previously unidentified disease. A precautionary management approach would be to remove the farms along the Discovery Islands; however, DFO continues to delay any meaningful action to protect wild fish.

Recommendation 3 – Salmon farming

“The government of Canada should remove from the Department of Fisheries and Oceans mandate the promotion of salmon farming as an industry and farmed salmon as a product.”

This is incomplete. DFO continues to promote the salmon farming industry and the product through its communications and social media and through its inaction on protecting wild fish from industry risks. The Minister of Fisheries has been quoted as not agreeing with Justice Cohen’s assessment, that DFO has a conflict of interest.


DFO’s second annual update announcement on its progress on Cohen Inquiry implementation was even more disappointing than the first in 2016. This year’s update lacks meaningful substance and details of its supposed action on implementation. It also attempts to replace the true intentions of fully implementing Justice Cohen’s recommendations with simply “acting” on the recommendations (meaningfully or not). Canadians deserve a truly independent assessment of the recommendations.