Wednesday, 14 August 2019

DFO Likes Lice More Than Wild Salmon - Watershed Watch

See: https://www.watershed-watch.org/media-releases/wild-salmon-threat-increases-with-new-fish-farm-feds-fail-again/?utm_campaign=shareaholic&utm_medium=facebook&utm_source=socialnetwork&fbclid=IwAR1J9s-n4nDVC_vPSvjgdHoFijDw2GbqT6uqfnEFb62Lb_dbAfKZWScTKGo.

And read the letter to DFO: https://www.watershed-watch.org/wordpress/wp-content/uploads/2019/08/Lutes-Creek-Comments1.pdf. It is 8 pages long.

Read the text from Watershed Watch et al. I seldom repeat what is said completely, but here is the whole text as there is so much of interest: 

Wild Salmon Threat Increases with New Fish Farm, Feds Fail Again 

VANCOUVER, Aug 4, 2019:

Conservation groups called proposed action by the Department of Fisheries and Oceans “irresponsible” in a letter released today, concerning the federal government’s intention to grant a new salmon farm licence on the West Coast of Vancouver Island.  The application by Grieg Seafood Ltd. is for a site called Lutes Creek in Esperanza Inlet, near Zeballos, where the company already operates three farms.  Internal government emails reveal that the company can’t control sea lice in the region and that the Department of Fisheries and Oceans purported management measures are completely unenforceable.  As a result, lice numbers soared to levels known to be lethal to young wild salmon.  Local wild salmon stocks are critically low, which means any additional sea louse impact threatens them with extinction.

The conservation groups note that awarding a company experiencing massive sea louse outbreaks a new licence is completely inconsistent with the Minister of Fisheries’ “Enhanced Sustainability in Aquaculture Initiative” which promises sweeping revision to the way his Department manages farmed salmon practices. Those changes are not expected until next year, at the earliest.

The letter cites correspondence between government veterinarians that reveals that Grieg’s husbandry contributed to the development of drug resistance in the lice.  A government veterinarian forbade further use of the drug SLICE™ and demanded a new treatment plan, but the company did not respond quickly enough to protect the 2017 out-migrating wild salmon.  Grieg was nevertheless allowed to restock its Esperanza Inlet farms in 2018 and lice numbers soared again to an average of 53 per fish.  When government field staff tried to press charges, they found the regulations were “unenforceable.”

“The Department has essentially thrown up its hands and left it to salmon farming companies to make what they can of sea louse control,” says the letter, written by Living Oceans Executive Director Karen Wristen on behalf of several conservation organizations. Emails obtained through Access to Information requests reveal that senior Aquaculture Management had earlier refused to act on advice from Conservation and Protection staff to tighten sea louse management conditions so that they would be enforceable.

KEY FACTS:
  • In nearby Clayoquot Sound in 2018, when on-farm lice levels reached heights similar to those in Esperanza, the numbers of lice per juvenile wild salmon reached lethal levels. With 40-96% of the juveniles being infected, extinction of local populations of wild salmon is highly likely. There is no published, independent monitoring of wild juvenile salmon in Esperanza Inlet.
  • The most recent published stream count for Esperanza salmon-bearing streams found no pink salmon; and critically low Chinook numbers (ranging from 93 to 253). Only hatchery-enhanced chum salmon were present in anything close to historic run sizes. WCVI Chinook salmon are considered a “stock of concern” by DFO.
  • When on-farm lice levels reach 3 per fish during the spring outmigration, farms are required to have, and to implement, a lice reduction plan. There is no enforceable requirement for the plan to work; and no timeline within which lice levels must be reduced. No farm has ever been charged for failure to control lice during the outmigration of juvenile wild salmon.
QUOTES:

“The science is clear: open net fish farms produce and export enormous quantities of sea lice larvae that attack juvenile wild salmon, causing their deaths and endangering their populations. It would be incredibly irresponsible to add more farms in an area where sea lice levels on the existing farms cannot be controlled.” –Dr. Lawrence Dill, Simon Fraser University

“It is unfathomable that the department would consider issuing a new salmon farm licence under a management regime that it admits has failed. The Minister’s Enhanced Sustainability in Aquaculture Initiative is being tasked right now with making concrete recommendations to improve management for the protection of wild salmon and charged with reporting out by December, 2019. Surely this site, dormant for ten years already, can await the results.” –Karen Wristen, Living Oceans Society

“The federal rules that govern salmon farms are broken. Fines are non-existent and aquaculture licences aren’t revoked if parasites get out of control on salmon farms. Imagine if that were the case with drivers speeding over the legal limit on our highways?” –Stan Proboszcz, Watershed Watch Salmon Society

Monday, 22 July 2019

DFO’s Public Consultation on the Framework for Aquaculture Risk Management (FARM), Updated Aug 10, 2019

Contact: AquacultureConsultations.XMAR@dfo-mpo.gc.ca.



A typical morning’s chinook catch in the 1960s, Mouse Beach, Nahmint River, Alberni Inlet. Where are they now DFO? Where are the Fraser chinook, and all the rest, DFO?

Four Responses – DC Reid

Summary: Fish farms promise jobs and revenue, but do not deliver either. Their environmental damage far surpasses the value of their contribution to GDP. Fish farms kill wild forage fish, salmonids, chinook stocks and thus killer whales. British Columbians want in-ocean fish farms banned and put on-land. British Columbians want targeted support for freshwater habitat restoration, epigenetic hatchery work and netpens of sterilized, fin-clipped chinook fry put in the Salish Sea every year, until wild stocks are healthy.

First Response

Crisis

DFO has been managing BC Salmon and Southern Resident Killer Whales (SRKW) into extinction for 50 years. Now, in a crisis of its own making, DFO continues doing more of the same – cutting the sport fishery, with 90% of businesses down – and expecting a different outcome.
The solution is to do something different: put more fish in the sea – 12 netpens of 2 million sterilized, fin-clipped chinook each every year, epigenetic hatchery production and focus on freshwater habitat restoration. (1) And put fish farms on land.

By failing to act, DFO is killing killer whales. And fish farms kill killer whales because they kill wild chinook fry by lice and chinook adults by jaundice anemia. (2, 3, 4, 5) Fish farm lice kill BC salmon, and salmonids all around the world, some 800 lice articles. (5)

Circumstance

Wild salmon mean as much to British Columbians as French does to Quebec. (6, 7)

There is no social licence for fish farms in BC and the vast majority wants them banned. (8) 

If Ottawa wants another fish farm, Justin, put it in the Rideau Canal in Ottawa. You won’t like it anymore than anyone else. 

DFO has ignored warnings. Step by step, I led DFO through more than 20 cases of legal, scientific and other problems three years ago, and gave DFO more than thirty references. (7) DFO did not take action and, thus, things have only gotten worse.

Now we are in crisis, with only 501 wild chinook in Clayoquot Sound where 20 fish farms have as many as 50 lice per fish, killing fry. And PRV kills adult chinook with jaundice anemia (2). Your own DFO scientist, Kristi Miller, told you this.

Fish Farms are banned or not allowed in all Pacific Coast jurisdictions except BC: California, Oregon, Washington and Alaska. BC also wants them banned.

Background

DFO backs fish farms because they promise jobs and revenue. But fish Farms do not lead to jobs and revenue. Their BC jobs are only 20% of the 9,000 sport jobs, and their jobs have declined 5.3% over the past 20 years to 1,800. Sport fishing employment is 500% higher than fish farms. (9)

Fish farms do not lead to revenue. Their contribution to GDP has fallen since 2010, - 2.8%, and their revenue is $582.9M, some 400% more than their contribution to BC real GDP; hence, fish farms take huge amounts of revenue out of BC, home to Norway and their shareholders. (9)

And the low number of jobs will drop dramatically when the automation in Norway is introduced to BC. In fact, in Atlantic Canada, jobs have dropped 32% in the past decade. Furthermore, Norway produces 10 times more salmon than Canada with only twice as many people, because of the automation already introduced there. (10)

DFO won’t reveal Norwegian testing of BC PRV. (11). It redacted a 2019 Norwegian email, and BC wants the full text revealed.

FARM


If DFO had introduced the FARM plan in BC in the ‘80s when fish farms were new, there would have been lots of time to get it right. But now, 40 years later, FARM is being considered in a time of crisis. There is no more time. If DFO comes back to do its ‘five year check’ on its plan, there may be no more salmon. DFO needs to wake up.

Precautionary Principle: (16) DFO says it will use the PP, but it has been unwilling to do so, using alleged scientific uncertainty, to keep fish farms in the water. It has appealed PRV court cases rather than take fish farms out of the water. (17, 18) The PP says that scientific uncertainty is not a reason to not use the PP, and economic loss is not to be considered before the PP is used.

Laws: DFO has a long history of refusing to use laws, to update laws and so on. Here is a list of 20 cases. (19) BC Does not believe DFO will act in accordance with the law. And there is a long history of failure to enforce the laws, so it doesn’t matter what the laws are if they are not enforced. (20) In fact, a scathing review of DFO’s use/misuse of fisheries law has just been released. (21)

Evidence and Science: DFO likes to say it uses evidence and science to make fish farm decisions. There is, however, that pesky PRV case where it did the opposite in court, then lost, then appealed, then appealed and quit. (18) Here is a list of 20 cases where DFO has not used E&S. (22, 23, 24). DFO only uses E&S when it suits the narrative it prefers, whether true or not.

Fraud: In fact, there is one fraudulent case where DFO and the CFIA colluded to find a lab that would return a negative result to diseases in BC fish farms. (25) This case should be investigated, but the AG would not sue DFO when I asked her to.

Forage Fish: Fish farms don’t save fish, they kill fish. Fish farms kill protein to grow protein, resulting in a net global loss of protein, and diverting global fish from Third World mouths, to fatten up fish for First World mouths. 5.76 Billion forage fish are killed to bring in one crop of fish in BC. (26)

Global Forage Fish: Fish farms don’t save fish, they kill fish. The Sea Around Us project has determined that 19 of the top 20 forage fish species are either badly managed, collapsing or both. (27) Norway is singled out for having destroyed global Jack Mackerel stocks to feed farmed fish, rather than humans. (28)

Fish Farms Kill Salmonids: Fish farms don’t take pressure off or save salmon stocks. They kill salmonids everywhere they operate in the world, including in BC and Atlantic Canada. Up to 50% of salmon are killed. (29, 30, 31, 32). 

Sewage: Sewage is the worst environmental and economic issue. Ocean eutrophication is the equivalent of climate change in the atmosphere. The conservative cost of sewage to BC is $10.4B (33). The other end of conservative is $31.2B. Dilution is not the solution. (34)


Antibiotics: fish farm bacteria become resistant to ones we need for humans, and there is a staggering list of scientific research on the problems (35)

Lice chemicals: Lice are a crisis in Clayoquot Sound, a UNESCO Biosphere with 20 fish farms in a non-flushing sound. Lice become resistant to every chemical used to kill them, while the chemical negatively affects the environment. (36)

Diseased Dead Fish Payments: Canadian taxpayers paid more than $177M to billion-dollar, foreign corporations for their dead fish. (37) The CFIA cancelled the program because of taxpayer complaint.
Taxpayer Payments: more than $107M so far, plus the dead fish payment equals $284M. (37, 38). This is a conservative estimate of taxpayer money given to fish farms.We don’t want our money given to multi-national, multi-billion-dollar fish farm companies.

Licence Costs: in BC total licence cost is $650,000. In Norway, the same licence costs $32- to $40- million each. That would be $4.16- to $5.2- B.  – or the company can come out of the water for a zero-dollar licence. BC is losing billions of dollars. (39)

Wild Salmon Restoration: DFO has put aside $142M along with a BC component. However, the fund requires innovation, technology and partnerships, rather than for citizens in gumboots, the most important kind of freshwater habitat restoration. (40) And why is restoration relegated to a later subclause?

Wild Salmon Restoration, BC: the Wild Salmon Advisory Council’s plan is far better than DFO’s. (41)

BAD NEWS BITES: from global fish farm/seafood industry press, I have found 5,000 problems in the past three years. (42)

Escapes: 97% of Van Isle rivers swum have adult Atlantics and progeny. (43) The research on this subject leads to an annual escape rate of 153,000 Atlantic salmon in BC. (43, 44, 45, 46, 47, 48, 49). DFO actively inhibited this research, pulling out 2 days before Volpe was to start.

Catastrophic Collapse of Wild Pink Salmon to Fish Farm Lice: in 2002, from 3.6 million pinks in Broughton Archipelago to 147,000 returned, or 96% killed. (50)

The Bottom Line: Fish farms are a huge environmental and economic loss to the host country. They should not be left in the ocean. And we taxpayers don’t want anymore of our money spent on them. It is over $284M so far (36, 37) There are so few jobs and they will decline with automation and there is so little net revenue that stays in Canada and the environmental cost is so extraordinarily high, there is no point DFO continuing to back this losing industry. Put them on land and move on. Spend our money on wild salmon. Note that on-land fish farm facilities represent a far higher investment in Canada, than twine nets in the ocean.

Second Response – DFO FARM Documents
Framework for Aquaculture Risk Management

Quote: Global demand for fish and seafood as a high-protein food source has increased significantly in the last decades. This demand is projected to increase as the world’s population continues to grow. With pressures on global fish stocks, aquaculture is recognized as having a valuable contribution to food security while reducing pressure on wild fish stocks. Ensuring the environmental sustainability of Canada’s aquatic resources requires a robust regulatory structure and a suite of policies to guide decision-making.
Answer:
1. The fish farm industry has trashed 19 of the top 20 global forage fish stocks for fish feed the Sea Around Us has determined. The 20th is Antarctica Krill, which is not even a fish. Norway is singled out as destroying the global Jack Mackerel stocks. (27) Fish farms are a net negative to global protein.
2. Fish farms kill third world fish to feed first world fish, a net protein loss.
3. Fish farms kill wild fish stocks everywhere they operate in the world. They do not reduce pressure on wild fish.
4. Canada’s oceans need fish farms put on land raising a vegetarian fish, not a too little too late in-ocean plan of ‘robust sweet’ measures, when wild salmon are in a DFO induced crisis.

Quote: In Canada, the management of aquaculture is a shared jurisdiction between the federal, provincial, and territorial governments. Each jurisdiction has specific regulatory requirements, mitigation measures and risk tolerances, as outlined in specific legislation and regulations. Federally, in addition to Fisheries and Oceans Canada (DFO), departments and agencies such as Environment and Climate Change Canada, Health Canada, Transport Canada, and the Canadian Food Inspection Agency also have regulatory responsibilities and make decisions on aquaculture.
Answer: DFO and the CFIA fraudulently colluded to find a lab that would return a no-disease finding for fish farm diseases in BC. These agencies should be prosecuted for fraud. (25)
Quote: Four key pieces of federal legislation apply to fisheries, including aquaculture: the Fisheries Act, the Coastal Fisheries Protection Act, the Oceans Act and the Species at Risk Act. Consequently, DFO’s mandate requires the consideration of the biodiversity within the ecosystem, and the habitat and productivity of fish species.
Answer: A recent review of DFO and federal fish farm law returned a scathing response to federal legislation and use of legislation, including the precautionary principle. (21) There are dozens of problems. (19)
Quote: Ensuring the sustainable management of fisheries resources is supported through a well-defined risk management framework, one with a clear understanding of unacceptable harm, embraces the precautionary approach where uncertainty and risk of serious impacts exists, and clearly communicates underlying policies, management objectives and decisions. The purpose of this document is to describe DFO’s aquaculture-specific risk management framework, the Framework for Aquaculture Risk Management (FARM).
Answer:
1. Frameworks impress only the people who draw them up. They have nothing to do with fish farms and wild salmon as they exist. I used to draw up such frameworks when I worked in Finance, BC. They look good on paper, but never get used in the real world.
2. DFO’s misuse of the precautionary principle has been well documented. (21, 51) When DFO has and is actively misusing the precautionary principle why should you be trusted to change your ways?
Quote: Objectives for sustainable aquaculture: The Department’s goal is to protect wild fish and their habitats using tools like avoidance, mitigation, monitoring, compliance and remediation approaches to reduce possible impacts to the environment. In this context, we seek to create the conditions for a sustainable aquaculture industry across Canada that also protects aquatic ecosystems and wild fish populations.

The threshold for unacceptable harm to fish or fish habitat is any aquaculture activity that is anticipated to cause population-level detrimental effects to fish populations.

Answer: 

1. We are in the stage where aquaculture is a major problem with wild salmon. Fish farms need to be on land. I have a list of almost 300 on-land fish farm systems around the world. (52) The reality is that in-ocean is a technological dinosaur, and has been so for a decade, and, there is a deluge of press on the new global, on-land movement. (53)

2. The vast majority of BC residents want fish farms out of the water. (8)

3. The statistics show that the balance of negative environmental and economic facts greatly outweigh the benefits of stagnant and declining jobs, sewage, and revenue that gets taken out of BC after Norwegian fish farms use our ocean as a free, open sewer. (33)

4. The term ‘population-level’ is just the kind of phrase that DFO is hiding behind now when appealing PRV testing. And it actively hides evidence, redacting the current Norwegian PRV testing email. (11)

Quote: Aquaculture Risk Management: Risk considers how likely an event is to occur (likelihood) and the severity of the potential environmental impact (consequence) should that event occur. For fisheries, the management of this risk is primarily through using decision rules focused on complying with pre-specified reference points for a fishery. In the aquaculture context, there are opportunities to manage risks at every decision-making stage. Adaptive management is informed by the results from compliance and audit monitoring, research, and science advice. This creates the ability to apply additional mitigation measures prior to the activity to address any risk of environmental or ecosystem impacts.

The level of acceptable risk is related to the status of the fish and habitat found in the local area where aquaculture is proposed or operating.

Answer:
 
1. This sounds good, almost like a game, on paper. But the reality is that DFO managed east coast cod into collapse. It has also managed west coast chinook, and other salmon stocks, as well as killer whales, into collapse, just short of extinction. A new approach must prevail, put fish farms on land and adequately do freshwater habitat restoration.

2. The legal analysis by Lee (21) and the industry wide criticism from Milewski (51) of the science side form a stinging indictment of DFO practices with respect to in-ocean fish farms. The people of BC (8), the people of Canada want fish farms on-land (54) and commercial fishermen all over North America want fish farms out of the water. (55) Everywhere that in-ocean fish farms soil the world’s oceans, the public who has to live with them, wants them out of the water. That includes far-flung Tasmania. (56) And the Indigenous people of BC want fish farms out of the water. (57)

Quote: Considerations include local environmental conditions, status of local populations, the scale and intensity of the activity, and predicted effects on habitats, particularly those that have specific functions for fish populations (i.e., nursery grounds, spawning grounds, forage grounds, etc). This level of harm avoidance is similar to fishery harvest control rules and avoiding the lower stock reference point in managing fish stocks, which if exceeded may result in population impacts (A Harvest Strategy Consistent with the Precautionary Approach [PDF - 104 KB])

Answer: Despite these good words, the reality is that DFO managed east coast cod into collapse. And DFO has managed chinook, and wild salmon, along with killer whales into crisis in BC. A different approach is needed or wild salmon and killer whales will become extinct. On DFO’s watch a dozen stocks of Fraser chinook have fallen to critical. Thompson steelhead stocks, once the envy of the world, are on the brink of extinction. Killer whales are down to 75 or lower. As above, the solution is: 12 net pens of 2 million sterilized, fin-clipped chinook, epigenetic hatchery work and freshwater habitat restoration.

Quote: Sustainable Fisheries Framework: Conservation and Sustainable Use Policies: We’ve adopted policies that use precautionary approaches and support the adoption of ecosystem approaches into fisheries management decisions. They help us to:
  • keep our fish stocks healthy
  • protect biodiversity and fisheries habitats
  • make sure our fisheries remain productive
Answer: These statements are false. Fish stocks are being managed into extinction. They are not healthy. (DFO’s two Integrated Fisheries Management Plans, as well as the annual Fraser sockeye stats show this). Fisheries habitat was being destroyed, not maintained. Fisheries are not productive. The commercial sector in BC crashed in the ‘90s and still has not come back to where it had been. Now, in 2019, DFO, cancelled sport fisheries, rather than putting more salmon in the sea, the only solution for killer whales, which may be dead long before freshwater habitat is improved enough to support them. (58)
The money put to habitat restoration has serious limitations on it. Innovation is required, technology is required, and partnerships are required. The most important aspect: sport fishers, students and others putting on gumboots and getting into streams is not where the greatest amount of money is going. (59)
Third Response
2019 Criticism of Laws, DFO and Fish Farms
The most recent scathing report of DFO handling of fish farms is: Laws: Farming the Sea, a False Solution to a Real Problem: Critical Reflections on Canada’s Aquaculture Regulations. Authored by Angela Lee and Pierre Cloutier de Repentigny, 2019, University of Ottawa. (21)
Quote P38: “…the regulatory land scape in Canada is, to say the least, complex, fragmented, and deficient in many respects, 25 as stated in government-commissioned reports 26 and as exemplified by the two case studies [PRV and genetically modified salmon] explored below.” P38

Quote P42 : “in her Spring 2018 report on salmon farming, the Commissioner of the Environment and Sustainable Development found the AAR deficient in both their design and implementation. 68 Specifically, the Commissioner found that DFO did not assess whether the AAR were adequate to minimize harm to wild fish, that DFO was not validating the information in the industry self-reports, and that the AAR were not sufficiently enforced to minimize harm to wild fish. 69 Further, the fragmented approach to regulation that is apparent in the case of aquaculture has been identified as a general roadblock for attaining sustainability. 70”

Quote P44:PRV: III. CASE STUDY: BC SALMON AND PISCINE REOVIRUS [PRV]
DFO has not been a role model in ensuring the sustainability of the aqua culture industry, focusing primarily on economic development rather than environmental protection, despite the demonstrable risks associated with aquaculture. 72” “It took litigation and the federal Commission of Inquiry into the Decline of Sockeye Salmon in the Fraser River (the Cohen Commission) to ensure that the federal government took responsibility over the impact of aquaculture on wild Pacific salmon. 73”

Quote P44: DFO would not act on PRV, so Alex Morton took them to court: “At the centre of the dispute was the concept of risk: the level of risk acceptable according to the FGR, and the risk posed by transferring fish infected with PRV. Justice Rennie (now of the Federal Court of Appeal), analyzed both points from a precautionary perspective. This fact alone merits attention, as the precautionary principle has thus far had a limited impact in Canadian case law, and the principle is not mentioned in the Fisheries Act or its regulations. 78”

Quote, P45:Regarding the risk of disease harmful to fish, the evidence was, on one hand, that PRV is likely the cause of HSMI, and on the other hand, that the causal relation between the two had yet to be proven with scientific certainty. 79 The lack of scientific certainty did not deter Justice Rennie; he found it was enough that PRV may cause HSMI and thus may harm fish. 80 In other words, there was a risk, and ignoring the risk would not be exercising the appropriate degree of precaution. Justice Rennie then turned his attention to the interpretation of paragraph 56(b) of the FGR. He found the regime to be one of risk management embodying the precautionary principle. 81”

Quote P46: DFO lost the case: “DFO and Marine Harvest initially attempted to appeal the decision. 86 Before the appeal could be heard, it was discontinued, prompted by the detection of an outbreak of HSMI disease among farmed salmon. 87 A study of the outbreak conducted in part by DFOs biologists demonstrated a link between PRV and HSMI, and a statistical correlation between PRV and the severity of some HSMI symptoms. 88”

Quote P46: “Furthermore, subsequent research on PRV infection in wild and farmed salmon in BC revealed that 95 per cent of farmed Atlantic salmon are infected, and that 3745 per cent of wild Pacific salmon close to aquaculture operations are infectedan infection rate that drops to five per cent for wild Pacific salmon the farthest from aquaculture operations. 89”
Quote P46-47:Despite the considerable risk posed by PRV transmitted through farmed salmon, the requirements of section 56 of the FGR, and the fact that DFO has recognized, to some extent, the link between PRV and HSMI, DFO refuses to test salmon for PRV before issuing a transfer licence. 91”

Quote P47: Prior to this the Cohen Commission accepted that there was a disease risk for Fraser sockeye. The paper goes on to say: “DFOs cavalier and potentially illegal attitude towards the risks inherent in aquaculture has not changed.”

Quote P52: The paper concludes: “In the case of PRV risk management, there is a clear disconnect between what DFO presents to the publicthat is, policy and decision-making based on a precautionary approach 125 and its actual management of diseases and risks related to aquaculture operations. DFOs actions suggest that it continues to demand scientific certainty or quasi-certainty of the threat posed by PRV and its extremely high occurrence within farmed Atlantic salmon populations before it will take measures to protect wild Pacific salmon populations.” In other words, DFO does not use the precautionary principle. 

Quote P 54: about pesticides: “but no precautionary measures have been put in place to mitigate these known risks to the environment. In fact, the AAR are very permissive regarding the use of pesticides (as long as they have been approved by Health Canada), leaving the industry to monitor itself and report to DFO on its pesticide discharge and certain events, like fish mortality. 137 In addition to the inherent limitations of such regulatory models, 138 enforcement of environmental standards, even in the face of serious incidents, 139 appears to be non-existent. 140

Quote P 54:Like the issue of disease transmission, the management of aquaculture pollutants by DFO is plagued by the same political use of science favouring economic development above other considerations.” Comment, this is, again, against the precautionary principle that economic issues are not to be considered.

Quote P 59: The current regulations do not provide sufficient safeguards to create a sustainable framework for aquaculture. Furthermore, scientific knowledge is currently used in decision-making and risk management as a shield, hiding political or value choices favouring the industrial development of aquaculture and techno-scientific solutions to environmental and food security issues, without sufficient transparency.”

Quote P60: “For example, in terms of disease risk management, the well-established precautionary principle can serve as an effective guideline to avoid the current situation regarding PRV. 162” And: “Instead of downgrading paragraph 56(b) of the FGR, as suggested by DFOs Notice of Intent, the regulation on fish transfer should specifically require proof that a disease or disease agent is not harmful to the protection and conservation of fish and marine ecosystems before a licence can be issued.” And: “Furthermore, the absence of conclusive scientific evidence demonstrating the harmful effect of a particular disease or disease agent should not be taken as proof that a transfer is safe.”
 
P60: the study goes on to say that: Atlantic stocks/smolts should be destroyed if carrying PRV.

P61: the law should be changed.

P63: And there should be a tribunal, and the whole system needs a rethink anyway, because: “We must consider that solutions to ecological concerns likely do not lie within the current productionist mind frame that created the environmental crisis we seek to resolve in the first place. 173”
P63: Farming the sea is a false solution to a real problem, in that it fails to address the fundamental issues underlying marine resource management and food production”

Fourth Response 

Criticism of Science, Social Licence, Jobs, Etc. 2019

In a scathing report, the best science article on fish farm issues that I have ever read, the Milewski et al paper, is a global view of all problems with respect to fish farms. (51) Go read the post, as it deals in more depth than the few issues quoted here.

Global Issues with Fish Farms

The paper starts by pointing out the array of problems: "The shift from small-to industrial-scale salmon farming has brought with it all the issues characteristic of industrial food-production systems. These include: waste-product pollution (feces, feed) [29], use of chemical and veterinary products (antibiotics, pesticides) [30], environmental quality issues (nutrient and organic loading) [31], off-farm pathogen transmission [32] and farm escapes [33], human health concerns [34], devolution of state-led control to corporate/market-driven governance [26,35–37], and increased control by large-scale processor and retailers (value chain) on seafood systems [38–40]. As a result, the development trajectory of farmed salmon production globally, and in Canada, has been uneven and marked by periods of reduced production due to a range of issues including disease (e.g. infectious salmon anemia, piscine reovirus) and parasite (sea lice) outbreaks, increased global competition, price fluctuations, availability of suitable farm sites, and moratoria [25,26,41]."

DFO is Remiss on Issues

"Environmental sustainability indicators identified in the scientific literature for finfish aquaculture operations, such as salmon farms, include the quantity of resources used (e.g. water, energy, space, feed and amount of raw marine ingredients), waste discharges (nitrogen, phosphorus, particulate organic matter, greenhouse gasses, metals), chemicals use (e.g. antibiotics, pesticides, hormones), disease incidence, escaped fish, genetic interactions, and biodiversity impacts [42–46]. To date with two exceptions (antibiotics and drugs), DFO does not publicly report on any of the aforementioned environmental indicators nor does it report on the environmental SI identified in Table 1."

DFO on Industry Reporting Rather than DFO Investigating

Just how bad can it be when fish farms need to report something? This bad: "Compliance with these new regulations means aquaculture operators are now required to report the quantity and frequency of drugs and pesticides use. In 2016 and 2017, marine finfish operators used 16.8 mt and 14.4 mt of antibiotics and 617 mt and 439 mt of pesticides (hydrogen peroxide) respectively [51]."

Doesn't this make you want to eat farmed salmon? Of course, they are not doing much to measure the effects on the natural environment, such as effects on lobsters etc. nor the cost of the sewage, which is far more than the deep piles directly under a fish farm. The rest floats away on ocean currents and contributes to eutrophication on a vast scale.

And what did the scientists find? This: "Monitoring sub-lethal, cumulative, and far-field (beyond the farm lease) effects of sequential exposure to antibiotics and pesticides on non-target species is not required."

The BC sewage is conservatively estimated at $10.4B (33), far in excess of economic return.

Jobs

The conclusion on jobs is stunning: "DFO identified employment in aquaculture as a social SI, but has not developed an employment target. One possible reason may be that the potential for expanding direct employment in aquaculture is continually being undermined by technological improvements that enhance economic efficiencies but reduce the amount of labour needed for production. Between 2007 and 2016, overall Canadian aquaculture production increased 18% but direct employment in the sector dropped 32% [24]. Nowhere is the impact from improved technological efficiencies more evident than in Norway which grows almost ten times (1.33 million tonnes in 2014) more farmed salmon than Canada (134,000 mt) but does so with slightly more than twice the direct labour force (6,300 people) than that of Canada (3,205 people) [23,24]. In addition since the mid-2000s, increased and significant reliance on the Canadian government's Temporary Foreign Worker Program by aquaculture" So no jobs for locals who are down on their luck.

In other words, there are few jobs in fish farming, and they will decline dramatically, leaving fish farms polluting the ocean, and taking all the revenue home to Norway, while jobs plummet to zero.
And DFO can’t get a handle on jobs and revenue because it can’t get: "access to farm-level financial and production data as many farms regard such data as confidential [53]." And the industry funded studies come in at 400% higher than, in BC, the BC Stats report figures.” (60)

The above stats suggest that if Canada's output is about 10% of Norway, that 10% of Norway's job numbers is all it will take to farm in Canada, or about 630 jobs. Even if you believe the 3,205 number of Canadian jobs, what would be left would be less than 20% of the current job numbers (630/3205 = 19.6%). Why does DFO want in-ocean fish farms?

Jobs in Port Mouton, NS

A fish farm was put in in 1995. And those promises about jobs were false: "Although farmed salmon production in Nova Scotia has increased 1000% from 1995 (1120 mt) to 2017 (11546 mt), the number of people employed in finfish aquaculture is the same (100) in 2017 as in 1995 and full-time employment has dropped 86% from 211 in 1995 to 46 in 2017 [72]." Look to the bottom, under the references for a link to a zero-job, offshore fish farm from Norway, Appendix 3.

Science on Environmental Effects

And: "Despite the federal government's long-standing interest in increasing knowledge for regulatory purposes about the impacts of aquaculture operations on wild fish (and shellfish) populations, water quality, and important marine habitat such as eelgrass [82,83], these studies [done by Friends of Mouton Bay] represented the first studies of their kind in Canada." This means that DFO had done zero studies.

Social Indicators and DFO

The various certification schemes, ASCs, and so on, have environmental, social, governance and culture measures, some 2830 indicators in all of the eight schemes looked at. It turns out that the prov/fed/DFO don't have anywhere near the indicators that the certification schemes have, and the ones they do have are, wait for it, not revealed to the public.

The social SIs have become far more important, there being 1427 in the private schemes. And the report says: "A weakness in both the DFO and certification schemes is the absence (DFO) and the near-absence (certification schemes) of indicators associated with community-level decision-making." 

Social licence is absent in in-ocean fish farms.

As for the indicators, DFO at zero, with the private certifications at 1427 - on the social side indicators. On the environment side DFO is remiss compared with these systems, and the local govt/social side, it is also 1400 to zero.

And you have to remember that DFO/feds want more aquaculture, more 'Blue Revolution' that Norway has had the rest of us rolling our eyeballs about because it is just a good slogan, when their entire emphasis is on making money. You know: neoliberalism, and those profit margins that range from 20- to 80-%. (51)

DFO and the Global Blue Revolution

Milewski et al noted that Bene had reviewed more than 200 papers that examined the contribution of fisheries and aquaculture to improving food security, nutrition and poverty in developing and emergent countries.

"Their analysis revealed no evidence to support the claim that a higher consumption of fish results in higher nutritional status, that an increased supply of farmed or wild fish had a direct effect on the micronutrient status of households and/or consumers and concluded that the protein contribution of fish to nutritional status was overstated [99]. The share of protein intake derived from plants far exceeds animal protein in general, and fish-protein in particular [102]."

You wouldn't know it from fish farms, but in fact: "World agricultural food production has now outpaced population growth by a significant margin [103,104]. The world now produces more than enough food, including animal protein, to satisfy the dietary needs of the entire global population [105]."

Despite this: "oversupply of food, more than 800 million people suffer from hunger, food insecurity and malnutrition." And not one of them will ever have enough money to buy even one farmed Atlantic salmon, raised by Mowi Harvest, Cermaq, or Grieg Seafood, from Norway, in their 'blue' revolution, and that trashed the ocean forage fish stocks that those 800 million third world humans should be eating.

Footnotes

1.     A new plan to save chinook and SRKWs: http://fishfarmnews.blogspot.com/2018/05/dfo-salmon-and-killer-whales.html.

2.     In Clayoquot Sound there were only 501 chinook in six streams in 2012. There are 20 fish farms. Lice kill fry, and PRV kills adult chinook with jaundice anemia: https://www.psf.ca/news-media/prv-virus-may-cause-disease-chinook-salmon. And: 501 wild chinook: http://commonsensecanadian.ca/author/dc/page/2/.

3.     Lice out of control in Clayoquot, DFO doing nothing: https://fishfarmnews.blogspot.com/2019/05/cermaq-lice-peroxide-slice-paramove-50.html.

4.     Lice out of Control in Clayoquot, and 30 BC studies, 90 studies by Mowi, 800 world wide studies: https://fishfarmnews.blogspot.com/2018/05/lice-outbreak-in-clayoquot-sound.html.



7.     Hasta La Vista liberals, Salmon Mean As Much to BC as French Does to Quebec: https://fishfarmnews.blogspot.com/2016/11/hasta-la-vista-liberals-salmon-as.html.

8.     Poll: 75% of BC citizens want fish farms banned. There is zero social licence for fish farms in BC: https://fishfarmnews.blogspot.com/2019/06/vast-majority-against-in-ocean-fish.html.

9.     BC Stats Report, the 2012 one and the 2016 one, released in 2019: https://fishfarmnews.blogspot.com/2019/03/mar-21-2019-bc-stats-report-2016.html.


11.  DFO won’t release the Norwegian test of BC PRV, 2019: https://act.newmode.net/action/unredactforsalmon?sp_ref=501813569.392.197751.f.0.2.

12.  Consultation on the Framework for Aquaculture Risk Management: http://dfo-mpo.gc.ca/aquaculture/consultations/farm-cgra/farm-consult-cgra-eng.html#contact.

13.  Framework for Aquaculture Risk Management: http://dfo-mpo.gc.ca/aquaculture/consultations/farm-cgra/farm-cgra-eng.html.

14.  Study on the State of Salmon Aquaculture Technology: http://dfo-mpo.gc.ca/campaign-campagne/aquaculture/study-eng.html. Introduces the committee.

15.  Government of Canada Announces new Way Forward on Aquaculture Management and the Protection of Wild Salmon: https://www.canada.ca/en/fisheries-oceans/news/2018/12/government-of-canada-announces-new-way-forward-on-aquaculture-management-and-the-protection-of-wild-salmon.html.


17.  PRV Case: https://fishfarmnews.blogspot.com/2017/01/dfo-taken-to-court-for-not-protecting.html. This post also has a link to a Norwegian study that proves PRV causes HSMI.

18.  Here is an Alex Morton video summary of the case, appeal and so on, that DFO lost on PRV: https://www.facebook.com/alexandra.morton.1671/videos/2398538087041405/.

19.  Laws: 20 links to legal problems with fish farms: https://fishfarmnews.blogspot.com/2017/04/the-strictest-laws-in-world-wrong.html.

20.  Randy Nelson: Poachers, Polluters and Politics, lack of enforcement:  https://onfishingdcreid.blogspot.com/2014/10/poachers-polluters-and-politics-by.html.

21.  Laws: Farming the Sea, a False Solution to a Real Problem: Critical Reflections on Canada’s Aquaculture Regulations, 2019, Angela Lee and Pierre Cloutier de Repentigny, U of Ottawa: https://commentary.canlii.org/w/canlii/2019CanLIIDocs16?zoupio-debug&fbclid=IwAR3mLofsVEVVr89sd-E5zSmtqVZjOwISMosaAjegS5iLPFUDtKqn2Q5UPDQ#!fragment/zoupio-_Tocpdf_bk_3/(hash:(chunk:(anchorText:zoupio-_Tocpdf_bk_3),notesQuery:'',scrollChunk:!n,searchQuery:'',searchSortBy:RELEVANCE,tab:'')).







28.  The Sea Around Us graph of Jack Mackerel collapse: http://fishfarmnews.blogspot.com/2016/08/jack-mackerel-fish-farms-buffalo.html.

29.  Fish farms kill wild salmonids: Norway, 2019 paper: https://fishfarmnews.blogspot.com/2019/04/fish-farms-kill-wild-salmonids-says.html.

30.  Fish farms kill will salmonids in Ireland, Scotland and Norway: https://www.thetimes.co.uk/article/fish-farm-lice-are-killing-wild-salmon-9s096zf3v.

31.  Fish farms kill wild salmon in BC, 2006 study: https://www.cbc.ca/news/technology/fish-farms-kill-wild-salmon-study-finds-1.590335.

32.  Fish farms kill wild salmon in Atlantic Canada, Pacific Canada, Ireland and Scotland: http://fishfarmnews.blogspot.com/2013/01/fish-farms-kill-more-than-50-of-wild.html. The original post.

33.  Sewage cost in BC: https://fishfarmnews.blogspot.com/2017/02/fish-farm-sewage-huge-cost-to-bc.html. Lots of links in this one.

34.  Dilution is not the solution, Ken Ashley Op-Ed, Times Colonist: https://www.timescolonist.com/opinion/op-ed/comment-science-flushes-away-sewage-dilution-theories-1.2283079.

35.  Antibiotic resistance, a staggering list of nearly 60 research papers: https://fishfarmnews.blogspot.com/2017/11/antibiotics-in-fish-farms-cause.html.

36.  Lice chemicals, a large Norwegian project. Even hydrogen peroxide, the simplest chemical, has bad environmental problems: https://fishfarmnews.blogspot.com/2018/09/toxic-sea-lice-chemicals-norway-is.html.

37.  $107M taxpayer money for fish farms. We don’t want to pay: https://fishfarmnews.blogspot.com/2018/06/taxpayer-support-for-fish-farms-too.html.

38.  And $177M we paid for their diseased, dead fish: https://fishfarmnews.blogspot.com/2016/01/taxpayers-pay-for-diseased-dead-fish.html. The CFIA finally cancelled the program because we complained so much.

39.  Lost licence revenue in BC versus $32- $40-million/licence in Norway: https://fishfarmnews.blogspot.com/2018/08/increase-license-fees-to-32-to-40.html.

40.  Salmon Innovation, Technology, Partnerships, Restoration Fund: http://fishfarmnews.blogspot.com/2019/04/salmon-restoration-and-innovation-fund.html.








48.  Volpe – DFO did its best to inhibit his work on escapes and Atlantic spawning success; and the 153,000 escape/crop calculation; and a link to a dozen papers on escapes in BC. Read this first: https://fishfarmnews.blogspot.com/2018/03/dfo-fibs-on-farmed-salmon-escapes-bc.html.


50.  Catastrophic collapse of Broughton Archipelago pink salmon: http://www.dominionpaper.ca/articles/3273.




-closed.html.

54.  Aquaculture the Inside Stories, Atlantic Canada: https://www.facebook.com/groups/nlaquaculture/permalink/2406848442872334/.

55.  Fishers Against Fish Farms: https://www.facebook.com/groups/375630722826057/.

56.  Tasmanians against fish farms: https://www.facebook.com/groups/2052031015025722/.



59.  Habitat restoration program, problems with it: http://fishfarmnews.blogspot.com/2019/04/salmon-restoration-and-innovation-fund.html.

60.  This is the MNP 2017 study for the BC Salmon Farmers Association, which also references Gardner Pinfold. Note the inflated figures when compared with the BC Stats report: http://bcsalmonfarmers.ca/wp-content/uploads/2015/01/BCSFA_Econ_ImpactStudy-SEP2017.pdf.

***

Appendices:  

1. Descending Sockeye Stats in the Fraser: