Friday, 9 November 2018

Pure Salmon - 8F Asset Management - 260,000MT - ON LAND

Yes, that said 260,000MT, making it almost triple the size of BC's entire industry. And all on land around the world. They are now putting together a 20,000MT plant project for the USA and a 10,000MT plant for Japan, called Soul of Japan. They have already built a plant in Poland with AquaMaof, who will supply all the on-land farms they build.

And it is about saving the oceans from fish farms. Stephane Farouze chairman and founder of 8F Asset Management says this:  “We believe that RAS technology will be the leading driving force for growing salmon in a resource-strained world, where producing sustainable food without further damaging our oceans is paramount.” (See quoted text below).

Thank goodness. The industry is paying attention to my post on the 255 different on-land fish farms around the world that I have found, and taking decisive action. See:

I don't usually simply just quote an entire article, as it has copyright and I am a writer to whom that is important, but I make no income from this process, and do so so rarely, I hope FISHupdate will understand.

Here is the link, if you wish to read the article on line:

The link with the Stephane Farouze quote above is from another fish farm industry news org:

In BC fish farms are still trying to say there is no problem with sea lice, when around the world, the rest of the industry has been making the move to land, for as much as a decade now.

Here is Pure Salmon:

Global roll-out of land based salmon

PLANS to establish land based salmon farms across the world have been launched by Pure Salmon, an enterprise set up by finance company 8F Asset Management, using RAS (recirculating aquaculture systems) technology pioneered by Israeli specialist AquaMaof.

Pure Salmon said its goal was to produce 260,000 tonnes of salmon a year in facilities that are free of chemicals, pesticides, antibiotics, mercury, microplastics and pollutants.

AquaMaof already has a successful track record in building RAS facilities around the world, said Pure Salmon, which built its first RAS plant in Poland.

Fifty per cent owned by 8F’s private equity fund and 50 per cent by AquaMaof, the Polish site is now producing adult-size fish of 5-6kg.

In addition to acting as a proof-of-concept, the facility is also a research and development and training location for Pure Salmon staff globally.

The Poland facility will produce 580 tonnes of Atlantic salmon per annum, said Pure Salmon. A second facility has been recently announced in Japan.

This, costing €141.9 million, will be the largest RAS salmon farm built in Asia, and one of the largest globally.

The 137,000 square metre farm will produce up to 10,000 tonnes of Atlantic salmon annually and will be fully operational from 2021, said Pure Salmon.

The company has plans to roll out large scale facilities of 10,000 or 20,000 tonne production per annum in the US, Europe, China and around the world.

All Pure Salmon land based sites will be fully integrated with on-site hatcheries, grow-out systems and processing facilities.

Stephane Farouze, chairman and founder of 8F, said: ‘We’re delighted to be launching what is the most exciting global development in land based Atlantic salmon farming.

‘We believe that RAS technology will be the leading driving force for growing salmon in a resource strained world, where producing sustainable food without further damaging our oceans is paramount.’

AquaMaof is also currently building an advanced RAS hatchery and nursery facility for Grieg Seafood in Marystown, Newfoundland.

This plant will produce seven million smolt ranging up to 1,500 grams. Grieg NL will stock 11 sea-cage sites for the subsequent grow-out and expect a harvest of 33,000 tonnes of Atlantic salmon by 2023.

Friday, 2 November 2018

Most Popular Posts - October, 2018

Here are the most popular posts by readers in October.

1. Precautionary Principle has Defined Approach:

2. Toxic Sea Lice Chemicals - Norway is a Disaster Zone. This was far and away the most popular post of the month:

3. DFO, Salmon and Killer Whales - Also a very popular post, ten thousand page views so far, and the first of two on this subject:

4. Let's Take Global Look at the SRKW Problem - the second post on this subject, a wide ranging post:

5. 254 On-Land Fish Farm Systems - the perennial favourite on this site:

6. Sustainable Wild Salmon Future? Well, No:

Thursday, 1 November 2018

The Silent Spring Syndrome - Clayoquot Lice, DFO, Cermaq Transparent as Mud

See the study on Clayoquot Sound lice:

Now see my post on the effects of lice treatment chemicals on wild animals in Norway, at concentrations far below their used levels: This is what I call the Silent Spring Syndrome, i.e., government/industry/chemical manufacturers saying that the chemicals are not harmful, while science ultimately shows that they need to be stopped because at concentrations far below use level are killing wild animals, for example, crustaceans.

Just how bad are current lice levels, and are they killing wild salmonids?

Well: "Clayoquot Sound used to support healthy populations of sockeye, chinook, coho, chum and pink salmon. Monitoring of wild juvenile fish during the spring 2018 out-migration, conducted by the salmon farming company Cermaq whose farms were responsible for the outbreak, captured a single pink salmon and no sockeye. A few juvenile Chinook were captured but released without examination.

Forty percent of the coho and chum that were examined in their study were infested with sea lice, with one chum reported as having 43 sea lice on it. One to three sea lice can kill a juvenile salmon. Sixty percent of the infested chum carried more than two lice. Independent monitoring found 96 percent of wild juveniles carried lice, with an average of 8.04 per fish. Lice counts ranged as high as 50 per fish."

And the well known SLICE used to kill lice has prompted resistance in lice:  "By 2017, Fisheries and Oceans Canada (DFO) unquestionably knew that resistance to SLICE™ had developed in west coast Vancouver Island farms, even as they denied it."

And the resistant lice may have been spread by processing Clayoquot farmed salmon in the Brown's Bay processor, thus spreading resistant lice to inside waters such as Johnstone Strait where the Broughton fish farms are located.

And, as I have noted before, sea lice reproduce into wildly high numbers in the presence of farmed fish held in netpens. "A single farm harbouring lice at an average of 3 females per fish is capable of shedding billions of larval lice that can travel 30 km on marine currents. 3"

Do go to the report and note the studies that have proven what is being said.

Around the world it is commonly acknowledged in the industry that lice are the worst cost, to control and in terms of fish loss. Do remember Helge Aarskog, CEO, Marine Harvest, asking for help to control this worst problem, and do remember that putting fish farms on land solves the problem of lice damage, and also the cost of treatment and fish deaths.

 Since this photo was published in 2014, lice problems have only gotten worse, around the world.

Now, the report turns to the issue of transparency. Industry likes to say it is completely transparent about everything, but on page 6 of this document, both DFO and Cermaq, have been non-transparent. in other words, don't believe it when they say they are transparent. The issue is lice counts, actions taken, slippery definitions of treatments, non-reporting of treatments, several months going by without treatment when the laws require action in 15 days, lice counts not being taken during treatments, then the use of hydrogen peroxide (yes, the chemical that has been causing the problems in the Norway post above), and lice levels rose above the 3 per fish level several times over the summer.

This wasn't an isolated case as five farms were treated: Plover Point, Bawden, Bare Bluff, Fortune Channel and Bedwell. Look at Clayoquot Sound on a map as it is closed at one end, as an inlet, thus it doesn't flush well, and there are 22 farms.

At Bawden the lice level rose to the exceptionally high number of 54.7 lice, yes, 54.7 lice per fish, and yes, the limit is 3. So the farms had 26M lice, and yes, downstream represent those billions of lice released.

And here is the point on resistance to SLICE and other chemicals: "Of greater concern is the pattern of peaking and troughing of lice numbers that is seen on this farm and all others in Clayoquot Sound in 2018. Sea lice numbers do not spontaneously reduce: absent some form of treatment, lice numbers just continue to go up. The pattern of peaking and troughing is strongly suggestive of repeated, ineffective treatments.

This kind of repeated, ineffective treatment actually promotes the development of drug resistant lice: lice that survive treatment and reproduce pass on the resistance."

This is exactly the pattern that Carson noted in the 1950s with regard to DDT, dieldrin, toxaphene and a couple of dozen other chlorinated hydrocarbons, as well as phosphorous based ones. This lead to the eventual banning of DDT, PCBs and so on, chemicals that are still with us today, in our livers, in our water tables, in our orcas.

Now we need DFO et al to ban these chemicals and put the farms on land.

But wait, there is more: more farms with high lice levels: Millar, Ross Pass, Dixon, Plover Point, Saranac, Bare Bluff and all the farms between the last two. And this during the out-migration of wild fry, something the industry is supposed to not have happen. (Page 8)

Page 9 has a map of the wild salmon streams on BC's coast. Just look at all of them.

On August 15, 2018 Eric Jensen, Regional Production Manager, Ceremaq confirmed that lice had resistance, and that resistance to SLICE has spread to all areas of west coast Van isle. And furthermore that Paramove 50 (hydrogen peroxide) was now becoming ineffective as well. Not only that, but that Paramove was actually killing 15% of farmed salmon exposed.

And what about DFO you ask? Ah, well their farm audit information has not been published since November 2017. Yes, this is a lack of transparency.

And it gets worse. You see, DFO covered up the trail of SLICE and resistance, a 2014 email on the issue, later being described - after redaction - as being in error. And DFO's Simon Jones initiated a project into resistance, in collaboration with Marine Harvest. While some text notes resistance, a paper has yet to be published. And DFO scientists said SLICE was ineffective in 2016, because of high water temperature. Not so, the manufacturer says it is equally effective at all temperatures.

It appears that the BC committee, Minister's Advisory Council on Finfish Aquaculture was convened, and was misled by testimony of various experts including Gary Marty of BCMAL. It filed its report in 2018 saying there is no evidence that lice are resistant to SLICE. Yet, in 2017, emails from DFO clearly show that resistance to SLICE is a well known phenomenon. Hmm.

Oh and I should add, something that I will use in a post on the new Wild Salmon Secretariat, Jeremy Dunn, ED of the farmers association was on the Minister's committee. In other words, the committer of the crime was part of the judge and jury in the case against itself. If they don't settle this, there is no way the Secretariat is getting fish farms out of the water.

The paper says this: "The evidence points plainly to one of two things: an attempt to mislead the Minister’s Advisory Council and concerned members of the public; or an inexcusable failure to communicate critical information about drug resistance to senior officials within the DFO."

Why would DFO mislead the committee/public, you ask? Well, the report, page 15, says: "The question why the Department might seek to mislead the public or the Council on this issue is not hard to fathom: uncontrolled sea lice and the cocktail of drugs and chemicals that have been used to combat them pose risks to wild salmon and marine ecosystems that many of us find unacceptable. The advent of drug-resistant sea lice takes B.C. into an entirely new regime of lice management, in which chemicals toxic to aquatic life will be dumped into the ocean multiple times in the course of each farm grow-out cycle, with unknown implications for wild salmon ecosystems."

This is the Silent Spring Syndrome - industry/government/manufacturers claiming the opposite of what society comes to know and take action to eliminate chemicals that kill farmed animals, such as DDT has been. Many humans were killed by the insecticides/herbicides/fungicides, so make sure not to come in contact with them.

Here are some of those scientific papers we need: "In one study, exposure to salmon farms increased sea lice infection on migrating wild salmon for 80 km, killing 9-95% of young wild pink salmon on migration routes in the Broughton Archipelago26. The youngest stages of wild salmon in the Broughton Archipelago were killed by just 1-3 lice per fish27. Heavily infected juvenile Fraser River sockeye salmon were 20% less successful at consuming food than lightly infected fish. 28"

And the industry is supposed to sample wild salmon fry during the spring migration. If you look at the data it masks the levels of lice due to the way it is presented. P17

Tellingly, an independent sampler, Cedar Coast Field Station also sampled the Clayoquot fry and found 96% had lice. Also, levels ranged from 0 to to over 50. Hmm.

And the Salmosam Vet, the third drug authorized is a phosphorous based drug, It's chemical name is: azamethiphos. See:

It is a phosphorous based insecticide, in other words, exactly the kind of chemical Carson pointed out had lots of science behind its toxicity, and resistance building when used as an insecticide way back in the 1950s. Just look at her book for the studies. We need to relearn what we have forgotten.

And the killer is that the Health Canada website says Salmosan Vet shouldn't be used near lobsters, failing to note that there are no lobsters in BC, yet says nothing about the crustaceans that are here.

As an alternative, the industry has tried to zap lice in Europe with warm water, the so called, Thermolicer, or Hydrolicer. Even with warm water, lice develop a resistance. Some lice die, but the ones that survive produce lice that also won't die, in other words resistance to the lice process itself. And in 2016, Marine Harvest killed 175,000 of its fish in Scotland using the process. Look at my BAD NEWS BITES posts for several articles on the losses. Each has a link.

Here is one, item 319 in this post:

And here is a report on a series of lice treatments in Scotland, all of which, were less than successful, i.e., resistance, leading to use of another chemical that also was less than successful: "Furnace Quarry was inspected on 28th February 2017. The FHI recorded,”...Treatments: Slice in April and June 2016, Alphamax June 2016, Salmosan 2 x August 2016 and end September/beginning October 2016, Hydrogen peroxide in October 2016, Hydrolicer x 2 beginning and end of November 2016. Levels coming down post treatment but resettlement [of lice on the fish]was reported to have been quick."

Now, to end, the solution to the lice problem is, wait for it: put fish farms on land where there are none. And the money saved from not using chemicals and from not losing fish due to being killed helps make more profit, too.


Okay, one more final thing, DFO said this to Global News, Oct 31, 2018: "However, there were documented failures of SLICE treatment at Klemtu in 2013 and Esperanza Inlet in 2017 and now Clayoquot Sound in 2018,” the DFO said in a statement to Global News." 


And one more: Marine Harvest uses Hydrolicer to get rid of SLICE resistant lice, Campbell River:

And yet another, on the global sea lice problem

Friday, 26 October 2018

Sustainable Wild Salmon Future? Well, No

Walter Schoenfelder has done an op-ed in the Times Colonist, Oct 26, 2018. Fish farms have done such a good job of creating false communication's spin, er, scratch the false, as all communications is spin, that he, a lodge owner in Quatsino Sound, can spit it out just as well as Marine Harvest et al can.

Walter says: 'I believe we need both wild and farmed salmon.'

A: After I lifted myself off the floor from a fishing guide singing the fish farm tune, I'd say, if you want to eat farmed fish, eat a vegetarian, not a carnivore that kills protein to make protein and thus is a net loss. And, no one is saying, close the farms, only that, it is time to put them on land and solve their environmental degradation like sewage.

And, on-land is now common, the spin is out of date by a decade. My list of on-land farms is now at 250: Walter and in-ocean fish farm companies don't seem to know the world has moved on. Take a look at Atlantic Sapphire (No. 176), Nordic Aquafarms and Whole Ocean, the new, mega farms being built in the USA. They will come in at almost triple the size of the entire BC industry, and if it isn't on land, it may just go belly up, throwing workers out of jobs.

Walter: The issue should be 'More survival for wild fish, and more healthy food for the world.' And, 'a modern industry is creating more wild-salmon stocks.'

A: The science shows that fish farms kill more than 50% of wild fish around the world where they operate, and this includes in BC:

And there is even more fish death. The Sea Around Us, in exhaustive research, determined that of the top 20 ocean forage fish, 19 are either collapsing, poorly managed or both, because they are caught to feed to farmed salmon: I calculate that the BC industry kills 5.76B of these wild fish to bring in one crop:

And healthy food for the world? The answer is no because farmed fish is far too expensive for most people on the planet. And there is that Hites article on the cancer-causing chemicals in farmed salmon, and Prof. Miller showed how fish farms, governments and related websites colluded to destroy the article's credibility, even though the science was true. This post has that link and a long list of links on the chemicals in farmed fish: So, no, not healthy food.

Walter: 'fish farms provide surrounding areas with nutrients from the farmed fish's waste... Far from creating some kind of dead zone, fish farms help create a healthy marine environment.'

A: You should work for Marine Harvest et al. You can create spin better than they can. Fish farm sewage is, in my opinion, the worst problem of fish farms. I spent several weeks figuring out that the conservative estimate of fish farm sewage in BC is $10.4B that we taxpayers pay for. We don't want to pay. The other end of conservative is triple this amount, at $31.2B. I was shocked to calculate these figures. This post has useful links:

In fact, global aquaculture, ocean trawling and human sewage have killed the vast Bengal Bay, and have scientists already worried about a global crisis in our oceans. Fish farms cause vast areas of ocean eutrophication and should not be allowed. Read about Bengal Bay:

And Grieg Seafood just had an algal bloom problem in BC, in 2018, causing a quarter of a million dead salmon: Hmm.

Walter: fish farms 'can't afford to have fish that aren't healthy, and that healthy fish pose no disease danger to wild salmon.'

 A: Go back up and read that article finding more than 50% of wild salmonids die when there are fish farms around.

And, Dr. Fred Kibenge, a world expert on fish diseases, says that one third to one half of all fish farm products are lost to disease, globally, so a huge amount:

Here is a short list of fish farm disease losses:

And in 2018, the CFIA notes a dozen ISA diagnoses at farms in Atlantic Canada:, and the year is not yet over. Oh and there are several dozen diseases.

I could go on but won't, other than to say that in BC Marine Harvest has been hampered with furunculosis many times, IHN for Cermaq and Grieg Seafood, and Cermaq just bought 2.2 million litres of lice chemicals, for release in Clayoquot Sound, a UN Biosphere designated water no less, and still had to close some farms because of lice being out of control.

The point is that fish farming is hugely risky; that is why, small producers, even in BC, go belly up and the big multi-nationals buy them up for peanuts because they have the resources to survive bankruptcies at individual sites.

Walter: These are hard times for wild salmon. 'Changing ocean conditions, commercial fishing and the destruction of habitat are part of' the picture.

A: Huh, we share some agreement. I'd say the big four problems for wild salmon are: freshwater habitat restoration, DFO, fish farms and climate change. We can do something for the first three. Here is why we don't trust DFO:

So, it is time to move on to have the BC Wild Salmon Secretariat get into putting money into freshwater habitat restoration by giving money to the Pacific Salmon Foundation that leverages such money 4 to 7 times:

Walter: The biggest benefit for wild salmon is that 'the fish produced take the pressure off remaining wild stocks.'

A: I have answered this above pointing out that farmed fish kill wild salmonids and kill huge numbers of wild forage fish to feed them. I am saddened that fish farm communications spin has been adopted by an angler who should know better, and look into the facts.

Walter: fish farms help us with out salmon netpens, and 'all the salmon we serve guests is farmed Atlantic.'

A: I have fallen off my chair, but am happy they are doing something with a social conscience. Too bad it doesn't include moving to on land farms and solving virtually all the problems. They could still help you out rather than spew their externalities on public ocean.

It sounds odd hearing fish farm spin, some dating from 50 years ago in Norway, come from a lodge owner's mouth, but Marine Harvest has been helping him. See:

I note from this article algal bloom problems in Quatsino. When I motored by the fish farms, I was concerned with just such an issue in a long, narrow, poorly flushing inlet.

Now that I have gotten off the floor: this post gives you more than fifty references for the problems with fish farms:

The point is: don't believe the spin, do some research and find the real answers. In a nutshell it will tell you: put fish farms on land, and raise vegetarians. 

Friday, 19 October 2018

Tasmanian Fish Farms Just as Bad as the Rest of the World's Fish Farms

Just in from Environment Tasmania that stands up for the environment in one of the most southerly countries in the world, their take on the many problems with fish farms in Tasmania.

They will sound familiar: major non-compliance, fire crackers/bean bags harassing seals, farmed fish rated red, or don't buy, flawed accreditation schemes. Note their website at the bottom. Read on: 


What an extraordinary week where multiple spotlights have been shone in to the Tasmanian Salmon Industry.

The release of an ASC audit (industry funded audit process) of Petuna seafood’s leases in Macquarie Harbour which found major non compliance and Petuna withdrawing from the certification process altogether.

Then we have the revelation that Tassal staff fire loud crackers and lead pellet loaded “bean bags” at seals.  Just this year up to July 1, 1,250 beanbags and 8,856 crackers had been used. Not only are the seals very vulnerable to damage but we have yet another example of fish farms polluting waters.

Next we had the highly respected sustainable fish eating guide produced by the Australian Marine Conservation Society recommend a just say no to Tasmanian Salmon. A red rating based on a rigorous review of all the available data.

Lastly, an international audit of the accreditation body for much of the world’s salmon industry including Tasmanian producers found the accreditation flawed in many cases. The review found Australian Salmon farms frequently breach Australian Stewardship Council standards but still have the right to badge their products with the ASC stamp of approval.

We are working very hard to protect our marine environment and we will bring about change. 

Philip Cocker


Monday, 15 October 2018

Precautionary Principle has a Defined Approach

Here is a thorough look at the precautionary principle, as applied to getting fish farms out of the water on the grounds they are detrimental to wild salmon. The reason for using the principle is that it doesn't matter how much science is done, fish farms will always say that the science done doesn't prove anything and that more science is required.

Doing science is thus a trap, because a decade will go by and still fish farms, and DFO, will say there is not enough science. Hence the reason for using the precautionary principle to save wild salmon. one example is that fish farms don't agree that lice cause problems even though there have been 30 such studies in BC, and 800 world wide, and that lice cause the greatest loss of farmed fish around the world. And Helge Aarskog, CEO of Marine Harvest says lice are their biggest problem, even though Marine Harvest in BC doesn't agree.

For links to the lice studies, see this post of mine:

There is a good coverage of the issue of precautionary principle in the Agriculture Minister's Advisory Council's Appendix 2 in the report:

Written by Tony Allard - who is a lawyer

He says: "There are constitutional, legislative, policy and international obligations that require the Minister to apply the precautionary principle.The precautionary principle does more than forbid decision makers from using scientific uncertainty as an excuse for regulatory inaction. It requires decision makers to err on the side of caution by anticipating harm and taking protective measures when there is environmental risk, even if there is scientific uncertainty."
The federal government has a constitutional obligation to protect fisheries and oceans. Section 91(12) of the Constitution Act, 1867 gives the federal government jurisdiction over the “Sea Coast and Inland Fisheries”.


"The history of the Oceans Act is important to understanding its legislative intent. By the early 1990s, the cod fishery on Canada’s Atlantic coast had collapsed. The Oceans Act was passed in 1996 to ensure that such a catastrophe never occurred again in Canada. The Oceans Act ext ended Canada’s jurisdiction over marine waters and required an ecosystem approach to the management of the marine environment based on the precautionary principle.

"Sections 29 and 30 of the Oceans Act expressly require the Minister to apply the precautionary principle.

"Moreover, in the Prime Minister’s Mandate Letter to the Minister, the Prime Minister expressly requires the Minister to “[u]se scientific evidence and the precautionary principle, and take into account climate change, when making decisions affecting fish stocks and ecosystem management”.

"In The Uncertain Future of the Fraser River Sockeye(the “Cohen Commission”), Mr. Justice Cohen came to similar conclusion. Mr. Justice Cohen observed that the Federal Court in Environmental Defence Canada v . Canada (Fisheries and Oceans), 2009 FC 878 said that Canada had ratified the United Nations Convention on the Conservation of Biological Diversity (the Convention) and, since the precautionary principle was a main component of that convention, Canada had committed to apply the precautionary principle.

"Canada has also committed to the precautionary principle in several pieces of federal legislation,including the Oceans Act, the Canadian Environmental Protection Act, 1999, SC 1999, c 33, and the Canadian Environmental Assessment Act, 2012, SC 2012, c 19, s 52."

Allard goes on to cite several cases and policy documents that show DFO is to use the precautionary principle.  For example Justice Rennie in Morton, 2016 spells out what is required:

"...although there is a healthy debate between respected scientists on the issue, the evidence, suggests that the disease agent (PRV) may be harmful to the protection and conservation of fish, and therefore a “lack of full scientific certainty should not be used a reason for postponing measures to prevent environmental degradation”: Spraytechat para 31"


"Mr. Justice Rennie’s interpretation al so sits squarely with the classic statement of the precautionary principle by the Supreme Court of Canada in the Spray Tech decision, but it shifts the emphasis away from scientific uncertainty, where the discussion is often focused, and places it back on anticipation and prevention of environmental harm:

In order to achieve sustainable development, policies must be based on the precautionary principle. Environmental measures must anticipate, prevent and attack the causes of environmental degradation. Where there are threats of serious or irreversible damage, lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation."

Allard points out that: "Canada’s Policy for the Conservation of Wild Salmon expressly requires the precautionary principle to be applied with respect to the conservation of wild salmon"

This means it applies to the Wild Salmon Policy.


"The precautionary approach, defined in the Oceans Act as “erring on the side of caution,is a key principle to be applied in the management of ocean activities. Under the Strategy, the Government of Canada is reaffirming its commitment to promoting the wide application of the precautionary  approach to the conservation, management and exploitation of marine resources in order to protect these resources and preserve the marine environment. 142

And, science is needed as a place to start, but not a place to say no: "Before the precautionary approach can be applied, scientific data relevant to the risk must be evaluated through a sound, credible, transparent and inclusive mechanism leading to a conclusion that expresses the possibility of occurrence of harm and the magnitude of that harm (including the extent of possible damage, persistency, reversibility and delayed effect).143"

 And the framework that government must use includes the following: "The application of precaution is distinctive within science-based risk management and is characterized by three basic tenets: the need for a decision, a risk of serious or irreversible harm and a lack of full scientific certainty.145"

Now, fish farms will always say that they have millions invested and the government can't just dump them on land, where is the science? I have pointed out several times that the sewage cost to BC is at minimum, $10.4B and this is vastly higher than the revenue, as measured by BC Stats of $469M. It would pay us well to give them $1m each to set up on land, as that total would be $85 million, given that roughly 85 farms are operating at any time.

"Since the Framework provides a series principles a decision-maker must follow to protect the environment, it is not surprising that the Framework makes it expressly clear that any impact on the assessment of trade occurs only after the decision- maker has determined the level of protection is consistent with society’s values. Accordingly, the Framework’s last principle makes it clear that the impact on trade is to be considered only after the decision to apply precautionary measures has been made"

 The precautionary approach, is summarized this way, rather than the oppposite of fish farms saying the country will never attract investment, that you have to show us 100% proof that w e cause damage, and jobs will be lost, etc.:

"First, a level of protection is chosen so that it is aligned with society’s values. Second, optionsfor protective measures that meet that level of protection are identified. Third, and only after the first two steps, the impacts on trade are assessed and protective measures that may have a lesser effect on trade may only be chosen if they maintain an equal level of protection.151 The decision-maker cannot decrease the level of protection to increase trade. Rather, once society’s chosen level of protection has been determined, the decision-maker can only choose between protective measures that maintain that level of protection. If multiple options for precautionary measures are available that provide the same level of protection, only then can the decision- maker choose the least trade-restrictive option."

 For example, DFO should refuse to let PRV infected smolts be put in the ocean, acting on the precautionary principle, not ironclad science, because fish farms say there is no ironclad science.

In closing, Allard puts it this way: "The precautionary principle does more than forbid decision makers from using scientific uncertainty as an excuse for regulatory inaction. It requires decision makers to err on the side of caution by anticipating harm and taking protective measures when there is environmental risk even if there is scientific uncertainty."

And that the minister must do what is reasonable, not what he thinks is reasonable, but what the situation requires as the most reasonable outcome, such as putting fish farms on land. You may know that my list of on-land fish farm systems now sits at 251 such RAS systems:

Friday, 12 October 2018

ISA in Canada

Here are the ISA cases reported in Canada by the CFIA for so far in 2018. As you can see it is a pretty full list.

There are two questions:

1. Do we trust the CFIA? I am not sure, as they were the agency that conspired with DFO to find a disease testing system that would produce a negative response for disease in BC. Here is a link to that post, and brilliant work by Alex Morton: I asked the Attorney General to investigate this case of fraud. Her staff said she could not, so I asked who do I contact to start an investigation? I will let you know what the AG has to say.

Are we supposed to trust the CFIA when its lab was criticized in the Cohen Commission process and that they colluded with DFO?

2. What is to be made of the cases where the CFIA says that a particular strain is not known to cause ISA disease? Well, the issues are that each strain can become infectious and then wipe out farmed fish, taking wild fish with them. And, the CFIA is not identifying where the strain is from. Typically it is from Europe, meaning eggs imported with disease. But they don't go into this.

Note the obvious: there are many cases of ISA that could become full blown epidemics in the list below.

Locations infected with Infectious Salmon Anaemia
Date confirmed Location Animal type infected Scientific Name
September 11 Newfoundland Atlantic salmon Salmo salar
August 30 Table Note * New Brunswick Atlantic salmon Salmo salar
August 28 New Brunswick Atlantic salmon Salmo salar
August 24 Table Note * Newfoundland Atlantic salmon Salmo salar
July 27 Newfoundland Atlantic salmon Salmo salar
July 24 New Brunswick Atlantic salmon Salmo salar
June 20 Table Note * New Brunswick Atlantic salmon Salmo salar
June 20 Table Note * New Brunswick Atlantic salmon Salmo salar
May 3 New Brunswick Atlantic salmon Salmo salar
May 2 Table Note * Newfoundland Atlantic salmon Salmo salar
March 26 Nova Scotia Atlantic salmon Salmo salar
March 13 Nova Scotia Atlantic salmon Salmo salar
March 9 Table Note * Nova Scotia Atlantic salmon Salmo salar
February 13 Newfoundland Atlantic salmon Salmo salar
Table Notes
Table Note *
This virus strain is not known to cause disease.