Salmon Farm Diseases - Norway, Updated Nov 10, 2016

In the Fish Health Report: 2015, released in 2016, the Norwegian Veterinary Institute's report may be found here: http://wwweng.vetinst.no/eng/content/view/full/13909.html.

It comes as a PDF of 75 pages, from a pro-industry research group, so it errs on the side of fish farms. Having said this, here is a summary of the summary:

1. Lice are the worst problem, with drug resistance, and deaths due to treatments, and handling of fish leading to mortalities. Medicine use is high.

Quote: "...there are many example of high mortality caused by treatment for this parasite. Fish that were already weak before treatment are particularly at risk. Alternative treatments for salmon lice that are not based on drugs are being developed, but many of these involve handling the fish, which can also lead to stress and mortality. Every year, salmon lice and their treatment cost the Norwegian aquaculture industry a great deal."

2. Pancreatic Disease (PD) is the worst viral disease. There are two epidemics occurring. SAV 2 and SAV 3 predominate. 137 new sites with disease found.

3. Infectious Salmon Anemia (ISA, often called the worst disease) was found at 15 sites. In addition to salmon found with disease, rainbow trout have also been infected.

4. Heart and Skeletal Muscle Inflammation (HSMI) which kills salmon is common. 135 sites had HSMI, fewer than 2014 - whoopy ding.

5. Piscine Rheovirus (PRV) has now been linked to HSMI, being found in fish that have HSMI in 2010. The 'dark spots' the virus leaves cost the industry.

Quote: "the cost of dark spots in fish fillets was estimated to be NOK 500 million."

6. Cardiomyopathy syndrome (CMS), is a serious disease of the heart that affects farmed fish usually after they are put to sea. In 2015, CMS was diagnosed at 105 sites.

7. Infectious Pancreatic Necrosis (IPN) that kills salmon was identified at 30 sites.

8. Amoebic Gill Disease (AGD - a disease in crisis outbreak in Scotland.) seems to be okay (by Norwegian veterinary standards).

9. Bacterial ulcers continue to cause significant problems in Norway.

10. Furunculosis - in clearner fish, lumpsuckers, has significantly increased. You will recall that Grieg Seafood, 'craft' Skuna Bay salmon in BC had deaths from Furunculosis in 2016 in BC.

                                                    ***********

Now, the overall tone of this is problem, what problem? This is what you get from farmed fish and we will treat the fish that need treating. This completely disregards that the wild fish die, and the public who has to live with fish farms comes to overwhelmingly reject them, just as has happened in BC. And, of course, in Norway.


10 different diseases, with no talk of taking farms out of the water. Little wonder that all the wild fish die in their presence.

Also, in several places the report says the stats are low, for one or another reason. Here, for example: "Where non-notifiable diseases are concerned, the Veterinary Institute’s data alone may not provide a complete picture of the national situation. Many private companies also analyses samples and maintain their own databases. We cannot be certain about the extent of such “hidden” figures, but we can say that this year, we have been sent data from a total of 593 salmonid farms, as against 757 last year and 704 in 2013."

In other words 22.8% lower data, for the data that is kept.

Marine Harvest Diseases, Wild Herring Eaten, HSMI, PRV - BC 2016, Updated Sept 22, 2016

 All disease issues in farmed salmon are solved, for wild salmon, and farmed ones, if farms are put on land in closed containment systems with recirculated water, and filtration of waste. On land systems have no diseases save the ones the stocked smolts may have, and sensibly raising such fish, eliminates such diseases.

These images are taken from the five minute Gopro video that Alex Morton took at the Midsummer, Marine Harvest farm in the Broughton Archipelago, in August 2016. This was a randomly chosen farm in a randomly chosen pen. Because the odds of this showing disease and the other issues, a reasonable person would conclude that many pens on many farms also show disease.

See the video here: https://www.facebook.com/alexandra.morton.1671/posts/1872308546331031?notif_t=close_friend_activity&notif_id=1473526423741130.  It has been viewed 750,000 times as of Sept 10,2016. This is huge interest in the well being of BC wild salmon.

The one below shows an emaciated, farmed Atlantic Salmon exhibiting the visual symptoms of HSMI/PRV. Would you eat this fish? Do you want this obviously diseased fish in BC water? I don't think so.

Meanwhile, Marine Harvest, Cermaq and Grieg Seafood cling to a semantic twist, and claim there is no PRV in BC (because a viral isolate has yet to be grown), that PRV does not cause HSMI (again for the same semantic twist) and that if HSMI were here it is caught from wild salmon, not PRV imported from Norway. Any reasonable person who looks at this two-inch-thick salmon, concludes it is an obviously sick fish. 

The second image shows a farmed fish eating wild herring inside the net. This is against the law. Do you want this to happen in BC? I don't think so. Note that the herring spawn has been eliminated in Kingcome Inlet for decades and there are 30 farms in this Musgamagw FN territory. Hmm.

The third image shows the pen's Atlantic farmed salmon exhibiting a common behaviour of farmed salmon with HSMI - they line up at the net, and sit there as they are too sick to move. HSMI stands for heart and skeletal muscle inflammation. It is easy to see why.

 

The fourth image shows wild herring outside the net eating fish farm feed that flows through the net, something that includes astaxanthin colouring, and the various PCBs, fire retardants and POPs found in fish farm feed. Do you want wild fish eating these chemicals? I think not.

Please go sign Fin Donnelly's Petition e-463 to get fish farms out of the water and set up on land. If they don't want to, they can go back to Norway and set up on land there, as Norway is also fed up with their environmental damage and is offering zero-cost licences for so doing, a $9- to $12-million subsidy, based on the saltwater auction price for a licence.

Sign at: https://petitions.parl.gc.ca/en/Petition/Details?Petition=e-463.

People who have to live with in-ocean fish farms come to overwhelmingly reject them and this is from countries around the world, as far away as Tasmania, and close by as Alaska, Atlantic Canada, Scotland and etc..........

KEY DOCUMENT: Fish Farm Diseases in BC, Updated Sept 6, 2016

This key document will list all the diseases in BC farmed fish that come my way. It will, like the 155 on-land fish farm document of mine, be a one-stop post for all I find on this issue.

A mid-coast BC fish farm fish displaying the symptoms of HSMI. Do you want this in our water, an infected farm releasing 56 billion viral particles per hour? I think not.

The on-land fish farm post remains the most viewed of all my nearing 300 posts on this blog. Here is the most recent iteration of the list: http://fishfarmnews.blogspot.ca/2016/05/152-different-on-land-fish-farm-systems.html.

You will note that the AKVA group has had an 'explosion' of on land sales in Q2, 2016: http://fishfarmnews.blogspot.ca/2016/08/akva-on-land-fish-farm-sales-exploding.html.

Like the two tipping point articles I wrote on the on-land issue in Norway and BC, I think the disease post will come to serve that function well. Disease is a constant in fish farms, around the world, from animals too close to one another and thus spreading disease, some 56 billion viral particles per hour. The Kibenge Powerpoint presentation notes that fish farm disease losses come to be one third to one half of all fish farm fish.

I should have started a disease post long ago, as it, like the bad news bites posts, will become equally as long, and equally damning on the global fish farm industry, that needs to raise a vegetarian fish and do it on land. The Bad News Bites post is here - you might be shocked:  http://fishfarmnews.blogspot.ca/2016/07/news-bites-farmed-salmonseafood.html.

You will recall that BC fish farms have had kudoa - MH has had great losses - furunculosis for Grieg Seafood's 'craft' Skuna Bay fish, and Cermaq having an algal bloom in Clayoquot. Then there are the past infections of IHN and IPN. And, you will recall during the Cohen Commission the several different labs that showed ISA in BC, including Are Nyland in Norway, the OIE lab for the eastern hemisphere.

And you will recall from the Cohen Commission, Dr. Kristi Miller's work on the 'viral-signature' wherein she listed the phenotypical disease problems in salmon and what they suggested were the diseases that caused them. This is a novel way of getting at the disease from the problems it causes, rather than the identification of the genetic material of a virus.

Here is the list of diseases, and the issue is that BC is the first place fish farms have come with a huge wild salmon population:

7. Images of diseased fish at  Marine Harvest, Mowi Brood Group, and McConnell Brood Group, Sept 21: https://www.facebook.com/alexandramorton.wildsalmon/photos/a.676225769212649.1073741845.201971229971441/676225785879314/?type=3&theater.

6. HSMI, Furunculosis, Disease, wild herring video, Aug 26, 2016: One GoPro, one stick, one pond on one fish farm, selected randomly. You will come away thinking the odds of such a thing are so small, on a random pick, that all fish farms are this bad:  https://www.facebook.com/alexandra.morton.1671/posts/1864901490405070.

5. The HSMI collection fish, 2013 - 2014, not only had HSMI, but the site had an algal bloom, perhaps caused by fish farm sewage, then there was a lice infection, then Slice treatment. See the Powerpoint presentation, page 6: https://www.psf.ca/blog/discovery-hsmi-bc-salmon-farm.

4. Furunculosis in BC, Grieg Seafood, Skuna Bay:  http://www.livingoceans.org/fr/media/releases/virulent-fish-disease-strikes-nootka-sound-fish-farms?language=fr.

3. PRV in BC, a cause of HSMI: http://www.theglobeandmail.com/news/british-columbia/disease-found-in-salmon-on-one-fish-farm-in-bc-but-more-research-needed-study/article30109962/.

2. HSMI in BC, Miller, PSF: https://www.psf.ca/blog/discovery-hsmi-bc-salmon-farm.

1. ISA in BC, the 'worst' fish farm disease - Jan 6, Virology Journal: http://alexandramorton.typepad.com/alexandra_morton/2016/06/cfia-testing-for-isav-in-british-columbia-acceptable.html.

Kristi Miller, DFO Scientists Allowed to Speak Under Trudeau Government

During the Cohen Commission on collapse of the Fraser River sockeye run, the Harper, Conservative Government muzzled government scientists, including Kristi Miller at the biological station in Nanaimo, BC.

She was told her paper on her viral signature work - phenotype work, rather than genotype, meaning what the fish looked like, its symptoms and which disease that that represented - could not be spoken about. Many scientists quit, and she considered it.

On the stand, if you read the third section, on disease, she is quoted as saying she found HSMI and ISA in Clayoquot Sound chinook farms. And the Sound, a Unesco Biosphere no less, wild salmon are pretty much extinct since 22 fish farms are in operation in a non-flushing sound. There are only 501 chinook in six streams. The Kennedy Lake sockeye run, once the second largest on Vancouver Island, was fished down and has never recovered during the period that fish farms have been in Clayoquot.

Little wonder.

The Trudeau government has opened the door and Miller, along with other scientists are now allowed to speak independently of the government. Here is an article that notes her response to the new freedom that she and others find themselves in: http://www.cbc.ca/news/canada/british-columbia/krist-miller-scientist-dfo-muzzled-1.3308549.

That means her new genomic work on wild and farmed salmon that Miller is the lead scientist in will allow her to speak, in a process that is stacked against wild Pacific salmon by having fish farm representatives on the committee to parse news releases, and DFO, which continues in a conflict of interest with fish farms. They won't have the last word. Thank you Justin Trudeau.

Thank you for putting an aboriginal in as the new Minister of Fisheries and Oceans Canada.Now, let's follow the Cohen recommendation that DFO be stripped of its role of supporting fish farms and simply get on with protecting wild Pacific salmon.

Key Document: CFIA Testing of Wild Pacific Salmon - Alexandra Morton

I will shortly put up a post on why we should be concerned about the CFIA recently analyzing more than 7000 Pacific salmon and finding no ISA or IPN. We would like to be happy, but there are unanswered questions from the Cohen Commission, that need a public reply.

However, the Alexandra Morton post on the specific scientific tests used by the CFIA does such a good, detailed, thorough job, you should read it. The link is: http://alexandramorton.typepad.com/alexandra_morton/2014/11/dear-cfia-what-test-did-you-use.html.

I will shortly go through the Cohen Commission fish farm disease testimony, which is evidentiary and thus, cannot be walked away from by DFO, the CFIA or others. The gist of the discussion among the experts on salmon/farmed salmon diseases, Doctors Miller, Kibenge and Nylund, cast doubt on the ability of the CFIA/DFO Moncton lab to find ISA. Each of these labs found ISA in BC.

And Miller's Viral Signature work looks at the phenotype of disease rather than PCR testing and culture of viruses. Some of the so affected Fraser sockeye died of pre-spawn mortality on their way up the river. As much as 90% of some run subcomponents died.

Also, several labs have found ISA in BC, so there is a need for an independent, reliable lab with no financial or other ties to fish farms, to do this testing. One main recommendation of the Cohen Commission was that DFO be stripped of its conflicting role of supporting fish farms, and to concentrate on wild salmon recovery. The CFIA also admitted it did not want to find disease. This is on the record. Just go read volume three.

The CFIA's post on the testing is here:. Read: http://news.gc.ca/web/article-en.do?nid=902639. They are going to look at farmed salmon next. It is impressive until you start peeling back the layers.

Norway Polluted with Farmed Salmon - 2014

On the eve of DFO and the federal government enacting an aquaculture activities act here in BC which would allow the Norwegian fish farms m to dump anything in our pristine ocean, the country where the fish farms are from, Norway, 2014 has been a year of great environmental degradation. If the same companies operate here, they will pollute BC the same way. Read on.

Here is an article from earlier this year in Norway on the fish farm issues of Marine Harvest, Cermaq (now Mitsubishi), Grieg Seafood, et al:

A heralded disaster "Billions (NOK) rolls into salmon farming. Politicians clap excitedly.

It covers up a profound environmental crisis, writes John O. Egeland. Published 4 April 2014.

The aquaculture industry trembles with success. Last year Norway exported salmon worth 40 billion (NOK). The average price of fresh salmon increased by an incredible 44 percent. The owners are counting
the money and the government will have more of the same.

It will be more farms and more fish allowed in each cage. Behind the national parade, the industry is facing the worst. Where the list of issues is long and painful: Escapes and genetic pollution, diseases and parasites,
discharge of sewage and pollutants, large land use in the fjords, feed resources that are not sustainable and a
steadily increasing concentration of ownership.

If industry and government clean up, it's only a matter of time before this toxic cocktail has a devastating effect. Both on sea life, fjords, salmon rivers and the Norwegian economy. Fisheries Minister Elisabeth Aspaker (H) "rejoices with the seafood adventure," wrote the  papers that export figures for 2013 were
presented.
.
Yet lice has made more progress than exports. According  to the industry's own figures, it costs salmon farmers around two million (NOK) for every pound they produce. Today salmon are treated at least three times a year for lice, which is triple since 2007. What is worse, the delousing agents are becoming less effective and many of them pollute, often for long periods.

It is noted that there is resistance in seven out of ten products used against lice. Marketing Director for the feed company EWOS has  stated that "we are about to run out of remedies against lice."

The following diseases in farmed salmon are numerous and complex. Such bacterial and viral diseases can in many cases lead to the infection of wild fish. A study conducted by the Institute of Marine Research shows that escapees can carry viral diseases SAV and PRV to the spawning grounds in rivers. It is also shown that
diseases from aquaculture can be transferred between different populations and species.

The research has come a long way in these areas, which in itself poses a danger. The development still has a clear tendency:        

Farming operations seem  to be creating more aggressive and more harmful disease organisms than those normally found in nature. The diseases are therefore no internal problem for the industry, but a threat to the ecosytems entire biodiversity. Escapes help to spread diseases and lice, and to the genetic destruction of wild salmon.

In its latest report on the risks of farming, says IMR that the real numbers of escapees is several times higher than  those farmers report. Moreover a large part of the escaped fish are the very young fish (fry). Probably the number of escapes is higher than the estimate of 1.5 million fish. Surveys in various rivers show that cross breeding with salmon farming varies from slightly more than two percent  to nearly fifty  percent.

An increasing problem is the pollution and land use in the fjords. [Note that BC's coastline is almost all long fjords] The pollution has many sources: Sewage from fish, chemicals and toxins from debugging, waste feed and impregnation (copper). Just the sewage volume of feces is the same as from several million people. This naturally affects the environment,  particularly in fjords where the replacement of water is poor.

Increasingly, come  reports from local fishermen report that good fishing spots are destroyed, or that the fish they do catch have lousy quality. Many places [in Norway] now have growing local opposition to the salmon farms. Conservative mayor Laila Davidsen in Alta stated that  the disadvantages are so great that the municipality does not want new farming operations.

The lack of sustainability in the industry has not been solved, even though there are less fish used in the fish feed. The aquaculture industry uses twice as much fish as it produces, and therefore contributes to reducing world food production. As is the concentration of ownership concentrates. The political ambitions of several governments for local ownership and control have not been fulfilled.

The ten largest aquaculture operators own about 70 percent of the approximately one thousand salmon  licenses. [In BC the three big Norwegian companies own mor than 90% of the industry]  The list of threats is long, but the most dangerous are still the owners, authorities and politicians capitulation to each other. No one will stop the party and take action about tomorrow.

The  Salmon adventure has been an after party that is out of control."

http://m.db.no/2014/04/04/kultur/meninger/hovedkommentar/kommentar/innenriksp
olitikk/32649871/?www=1

ISA - New Infections - Norway, Chile

There are two current infections of ISA halfway around the world from one another this week.

1. May 6, 2014 ISA in Norway: http://www.thefishsite.com/fishnews/23111/suspicion-of-isa-on-nordland-fish-farm. 

2. April 29, 2014 ISA in Chile: http://www.thefishsite.com/fishnews/23072/weekly-overview-chilean-salmon-producer-criticised-over-failure-to-harvest-infected-cages.

Chile's use of antibiotics for secondary infections hit the 2008 ISA outbreak level of use in 2013. I suspect we are now looking at another collapse of the Chilean industry. In the last one, a quarter of a billion dead fish had to be disposed of. 13,000 to 26,000 workers lost their jobs.

Go back and look at my ISA table, Friday, October 21, 2011: 2011: http://fishfarmnews.blogspot.ca/2011/10/isa-infections-world-wide-sine-1984.html.

I missed reporting for one year, so the table would be even longer, but, as is, the table tells the story: fish farms propagate ISA, and other diseases, thereby making virulent strains available for the wild fish that Canadians, Norwegians and so on want safe from fish farm infections.

Key Document - Land-Based Closed-Containment Fish Farm Science 2013, Updated Nov 3, 2013

International Summit on Farming Fish in Land-Based Closed-Containment Systems.

140 participants from 14 countries met in West Virginia in September, 2013 to share expertise on growing fish on land with recirculating aquaculture systems (RAS) for the sake of the sustainable fish production and food security. 

This is the Tides Canada weblink for the 50 plus presentations:  http://tidescanada.org/salmon/aquaculture-innovation-workshops-and-reports/.

This is a major collection of current science on closed containment from around the world and I suggest you go take a look at some of the presentations. This is a wonderful collection of papers, and is a credit to both Tides Canada for assembling all this work in one place on the web, and to the Save Our Salmon group for being involved.

This is the SOS link: http://hosted.verticalresponse.com/636112/842c3263a6/281374055/0f24f2d8f3/.

It is clear that fish farms will have no choice but to move to closed containment RAS systems that eliminate the problems caused by in-ocean net-pens, such as spilling raw sewage into pristine oceans, diseases, parasites, chemicals, escaped fish, genetic issues with wild fish, passing disease and parasites to wild salmon and killing them. The latter is a big issue in the Pacific Ocean as 10 species of wild salmonids, and other species, are threatened, from California to Korea. 

The NGO Save Our Salmon sent Chief Bill Cranmer, SOS President Eric Hobson and Dr. Andrew Wright who presented on the ‘Namgis Closed Containment Project in order to help catalyze a shift to this more sustainable technology. The farm is located on land beside the Nimpkish River, Vancouver Island, BC. and aims to grow Atlantic salmon to market size and reap the benefit as a brand distinct from the open net-pen product that now sells for considerably less as most consumers in the western world now avoid buying it for the environmental damage it causes.

Three issues that the fish farm giants suggest why they don't want to use RAS on land are: cost of electricity used, carbon footprint and capitalization. Presentations show that heat pumps reduce the power of electricity used by a factor of ten for on-land systems. They also show that when the raw sewage spillage is taken into account that net-pen in-ocean operations have a carbon footprint ten times that of on-land systems. As for capitalization, the Standing Committee on Closed Containment, of the federal Canadian government, recommends programs for making capital available. 

But until the government legislates fish farms out of the ocean, they will not move. This is an issue like airbags in cars. Car manufacturers said it couldn't be done for competitive cost pressure reasons. The government legislated airbags into cars and now every car in the world has airbags. As soon as BC removes site licences, the farms will be out of the water in 60 days.

As fish farms are a net negative to the BC economy, if they move back to Norway, BC still comes out far ahead in Gross Provincial Product and revenue from the sport, commercial and processing sectors in BC. In an upcoming post, I will detail the numbers. Some are staggering, for example, my first estimate of the cost of raw sewage spilling into our pristine ocean, a cost that the citizens of BC bear, exceeds $11 Billion, with the industry revenue size of only $469 Million, and the very small GPP contribution of only $61.9 Million, and only 1700 jobs (this is a BC Stats econometric, multiplier number, and I accept it as accurate. But I have collected the actual job numbers in this very small industry and it was only 840, after Marine Harvest let 60 staff go just before Christmas in 2011. Marine Harvest in particular has a Kudoa, myoliquifaction problem, and lost $12 Million of its stock in 2012. In 2013, MH Norway notes only 400 Canadian employees in their published numbers).

IPN - Fish Farms Cause Disease, Oct. 31, 2013

Fish farms have long been shown to be vectors for disease, but a recent PHD shows how stress causes reduced immune response and allows viruses to mutate, killing most of the farm. 65 Billion viruses per hour spill into surrounding waters and kill wild stocks.

Note: IPN means infectious pancreatic necrosis, a fatal disease.

See:  http://www.sciencedaily.com/releases/2013/01/130102083557.htm.

Gadan discovered that stress lead to increased production of the stress hormone cortisol. This affects the immune system of the fish and weaker immunity makes them more susceptible to infections. The fact that stress can trigger an outbreak of IPN is corroborated by the experiences of many in the field.

"For the first time, she was able to prove that when infected salmon fry were exposed to stress, otherwise benign variants of the IPN virus changed into pathogenic viruses. In other words, stress lowers resistance, increases the "production" of IPN virus in the fish's internal organs and can lead to benign viruses changing into pernicious variants of the virus."

Farmed fish are always under stress in net-pens because of crowding. That is why one third to one half of all aquaculture products are lost to disease. Fish farms like to say that wild fish give them diseases as they are not affected by those diseases. This is wrong because wild fish are not under the stress that penned Atlantics are. This is the issue of saying that nature has a problem, when the only problem apparent is the stress caused by farmed fish in cages. They need to be on-land in recirculating closed systems.

Fish farms shed 65 Billion viral particles per hour into the surrounding water. In a conservatively estimated 2 knot tide, this means those particles being spread to 12 nautical miles in a six hour tide. Then, when the tide turns the other way, the continued leaching of viruses from the fish farms is carried another 12 nautical miles in the other direction. This means that in half a day viruses can be found in 24 nautical miles of ocean, infecting wild fish as they are carried along.

It is easy to understand that in a closed Sound - most fish farms are in bodies of water with one closed end - say Clayoquot Sound, why there are only 501 wild chinook left in six streams, and why fish farms are the likely final cause of extirpation of the Kennedy Lake sockeye run, once the most important commercial harvest on Vancouver Island, BC.

The fish farm explanation is a communications strategy that may convince those with little experience in fish farm issues. The much more believable conclusion, however, is that wild fish do not spread, say IHN, because there are no wild salmon left anymore in Clayoquot Sound. The fish farms have killed them all.

Do recall that Miller's science showed 25% of farmed chinook in Clayoquot Sound had ISA and HSMI in her Cohen Commission testimony. DFO is doing nothing about this problem other than passively watching wild BC salmon die.

Critique: Mary Ellen Walling Letter to Victoria Times - Kibenge

This post contains three items: DC Reid article in the Times Colonist Newspaper, Mary Ellen Walling letter to the Times Colonist Newspaper, and my critique of Mary Ellen Walling's letter.

This is the DC Reid article:

Wild BC Salmon Lose Disease Doctor

A very important negative event occurred recently with the World Animal Health Organization (OIE) pulling Dr. Fred Kibenge’s status as the only disease reference lab in the western hemisphere for testing fish diseases, particularly, ISA from farmed Atlantic salmon.

I asked the OIE several times for the origin of the complaint but received no response. While news releases have pointed to complaints from other countries, the other factor is that the Canadian Food Inspection Agency (CFIA), discredited in the Cohen Commission testimony in December 2011, has made representations to the OIE to pull Kibenge’s status. In testimony they were cornered into admitting their interests are the export possibilities of the largely Norwegian-owned farms over natural wild salmon, a clear conflict of interest. Dr. Kim Klottins said the CFIA didn’t want to find ISA in BC. The video is not pretty.

You will have recently read in the TC that they tested several thousand wild salmon – not farmed fish, the source of the Atlantic Ocean diseases, ISA and HSMI – and announced they found no ISA in BC. That should be a good thing because the two diseases could well lead to the demise of all eleven Pacific salmonid species from California all the way to Korea. But it is not a good thing.

Drs. Miller (DFO, Nanaimo), Kibenge (PEI) and Nylund (the only other OIE lab in the world, in Norway), have found ISA in BC wild salmon. During Cohen they discredited the DFO, CFIA and the BC testing systems. The CFIA and DFO use the Moncton lab under Dr. Gagne, and the experts found its procedures don’t find ISA and its equipment is poor; this means a negative response for the worst fish farm disease means nothing. These doctors have found literally tens of thousands of cases of ISA in BC, dating all the way back to 1988.

For instance, Miller’s work showed 25% of Clayoquot Sound farmed Chinook had ISA and HSMI. This means 125,000 to 250,000 fish per farm. There are 22 farms in the Sound and wild Chinook numbers are at extinction levels – only 501 fish in six rivers. The Kennedy Lake sockeye run, once the largest on Van Isle, is no more.

The CFIA is a member on the OIE council which has members from many nations. Kibenge was the lab that found Atlantic ISA, (Nylund showed it was taken from Norway), in Chile. In 2008, ISA wiped out quarter of a billion farmed salmon, a loss of $2 Billion, with 13,000 losing jobs. The CFIA with its $740 million budget apparently wants to control the narrative with respect to farmed salmon diseases in Canada, and so Kibenge lost his status as the place where wild BC salmon have been sent most frequently for testing by concerned BC residents.

I read a scientific study not long ago that says fish farms cause a loss of 50% of the wild salmon/trout where they are introduced, and this includes BC. There are, for instance, only 6,000 wild Chinook spawners on the entire west coast of Vancouver Island. You will recall the Georgia St. coho fishery tanked in the 1980s. Then there are the Owikeno sockeye in the 1990s, etc. Fewer wild salmon translates into fewer jobs in BC Stats data, for example, commercial employment is down 50%. The largest sector, sport fishing, could likely employ more people, too. 

This is the Walling letter:

Re: “Loss of wild-salmon disease doctor will have major impact,” July 16.

(1)In the column, the actions of the World Animal Health Organization in pulling the infectious-salmon-anemia reference status at Dr. Fred Kibenge’s lab are presented as a negative. In fact, the organization’s decision should be viewed as a positive one. The organization conducted an audit with an international panel of scientific experts and found a series of weaknesses affecting the quality of diagnoses performed at the lab — which led to the unanimous decision by the general assembly of the organization to delist the lab.

(2). This news should reassure the public, as it shows that labs carrying international designations are held to high standards.

(3)It is correct that several thousand wild salmon were tested and no ISA was found. Thousands of Atlantic salmon have also been tested for ISA and those tests were also negative.

(4) ISA is a concern for B.C. salmon farmers — it has the potential to have an impact on our industry. That’s why our fish are tested and why we support ongoing wild- and farmed-fish monitoring programs.

(5). All the world’s oceans are connected, so it makes sense that viruses that have been found in other areas might eventually be found in B.C. That’s why ongoing monitoring of both wild and farm-raised fish is important so if a virus that causes disease, as not all do, does appear, it is found quickly and can be dealt with
.
Mary Ellen Walling
Executive Director, B.C. Salmon Farmers Association
Campbell River

Here is my Critique:

(1). The only evidence of complaint is the CFIA letter to the OIE. The CFIA told me only one other country complained.  And, of course, the CFIA, DFO and BC testing systems were shown to be deficient. 

(2). The Kibenge lab is the one that determined the Chile ISA infection and Nylund showed the ISA came from Norway. The subject only became public after Aqua Gen who transported eggs to Chile sued Nylund for bad science. They lost.

The big Norwegian companies have taken ISA to virtually every country they have gone to set up shop. The usual scenario is refusing to accept that ISA has been taken, with, once it is found, saying, well we just have to live with this. The problem in BC is the world's greatest salmon resource, the entire Pacific Ocean  is under threat of extinction, something that has never happened before.

Tragically, ISA is now in NS, NB and NL, as well as in BC - Miller, Kibenge and Nylund have found hundreds of thousands of cases of ISA in BC

(3). The DFO, CFIA and BC testing systems were all discredited by Miller, Kibenge and Nylund during the Cohen Commission.

(4). All the testing systems have been discredited. The BC public are right to be concerned with all wild salmon being killed by farmed diseases. Salmon farms can be eliminated from the ocean in two months by pulling their leases.

Also, the public is pretty appalled when I tell them that fish farms get reimbursed with taxpayer dollars - up to $30 per fish - by the CF|IA

(5). This is a classic fantasy generated by fish farms. Marine Harvest, Cermaq Minstream and Grieg Seafood, all Norwegian origin firms, are well aware that ISA, HSMI and other diseases are carried by imports of eggs and fry, both horizontal and vertical transmission of disease - not carried by the ocean tens of thousands of miles. That's just silly. 

Fish farms sure complain when environmentalists come anywhere close to their sites under quarantine, even though they are hemmorrheging 65 Billion viral particles per hour into wild BC salmon waters. 

Go read the Spinwatch.org article on how they neutralized a Science 2004 study that showed cancer causing chemicals and other persistent organic pollutants were in Scottish, and other country, farmed fish. It reads like a Hollywood thriller conspiracy blockbuster - link in several articles on this site. You will not believe any claim by a fish farm company ever again.

See Spinwatch link:: http://www.spinwatch.org/index.php/issues/health/item/141-spinning-farmed-salmon-part-3-of-3

Morton and Ecojustice take Keith Ashfield, Marine Harvest to Court Over PRV Transferred To the Pacific Ocean, May 8, 2013

I don't normally just give readers a piece to go and look at, but the Alexandra Morton taking DFO, Keith Ashfield, and Marine Harvest to court over transferring PRV - piscine rheovirus - from freshwater smolts to the BC Pacific Ocean, is very serious.

My readers are from all over the world and PRV has been identified as the number 2 fish disease killer of farmed and wild salmon. In some ways it is worse than ISA. You can read these posts:

This is on the lawyer's site, Ecojustice: http://www.huffstrategy.com/MediaManager/release/Ecojustice/8-5-13/Morton-Ecojustice-launch-lawsuit-over-transfer-of-diseased-salmon/2782.html

This is Ecojustices note of PRV facts:  http://www.ecojustice.ca/files/prv-hsmi-summary-of-facts-may-2013/.

This is Alexandra Morton's May 8, 2013 post on the court action she is taking:  http://alexandramorton.typepad.com/alexandra_morton/2013/05/on-may-7-i-launched-a-lawsuit-against-the-minister-of-fisheries-and-marine-harvest-in-the-federal-court-of-canada-for-th.html

Oh, and six months after the $26 Million Cohen Commission on Fraser River sockeye and still no response from DFO..

Move Fish Farms Out of Clayoquot Sound To Save Wild Salmon - Updated, May 19, 2017

Cermaq Mainstream fish farm, during the IHN infection earlier in 2012, blamed the outbreak on wild salmon passing its farmed salmon. This is highly unlikely for many reasons. It is far more likely that the IHN and other fish farm diseases have been killing wild salmon to the point of extinction.

First, a sound is closed at one end, and thus fish farm diseases do not flush out as they would in open channels. They will stay there for as long as each infected fish farm continues hemorrhaging 60 billion viruses per hour and for three weeks thereafter.In the last big outbreak of IHN, circa, 2002, 36 farms along BC's coastline were wiped out.


Second, there are 22 fish farms in Clayoquot Sound, and that at 500,000 to 1,000,000 exotic Atlantic Salmon, this implies as many as 22 million farmed salmon. Here is a ho-hum map of Clayoquot Sound, showing the 22 fish farms: http://mappery.com/map-of/BC-Salmon-Farms-Map. 


Third, the numbers of wild chinook and sockeye are so low as to be non-existent in the Sound. Non-existent fish cannot pass diseases. Because DFO authorized a new Plover Point fish farm in Clayoquot Sound – a UN Biosphere Reserve no less – I plumbed the Clayoquot Sound Chinook salmon and found their numbers are alarmingly low.

See these DFO links for Clayoquot Sound and West Coast Van Isle wild salmonids:

http://www-ops2.pac.dfo-mpo.gc.ca/xnet/content/salmon/sc%20stad/bulletins.htm#WCVI_Chum. And the second set of tables: http://www-ops2.pac.dfo-mpo.gc.ca/xnet/content/salmon/sc%20stad/WCVI_escapement/2012-5.pdf

I have summarized the figures as: 2012 counted fish, average number of wild chinook over the past 5 years and  average number of wild chinook over the last 12 years: Bedwell – 93 (5/12 – 60/110); Moyeha – none (120/130); Tranquil – 11 (220/760; Megin – 35 (20/50); Cypre – 362 (no 5/12 figures). No figure for the plummeting Kennedy Lake sockeye. No fish farms should be in these waters as the wild fish numbers are just too low. 

As the Moyeha is 0 and the Tranquil is 11 returned chinook, it is pretty obvious that fish farms, particularly farmed chinook, should not be in Clayoquot Sound. And, while fish farms like to say the source of IHN is wild fish, these numbers are so low - extinction levels - it is far more likely that fish farms are the source of the infection, and they are in fact destroying wild chinook, and sockeye.

DFO has the responsibility to protect wild fish and should have had all Clayoquot Sound fish farms moved to land years ago.

Fourth, the Creative farms - they raise chinook salmon - were shown during the Cohen Commission evidentiary hearings, by Dr. Kristi Miller, to have 25% of all fish with ISA - the worst of all diseases for wild salmon - and HSMI, also lethal, an exotic disease originating in Norway. HSMI cannot be in BC unless it was brought here from Norway and those fish passed it to the Creative farms and one or the other passed it to wild chinook.This means 125,000 infected fish per farm.

BAP Awards Not Awards - Updated July 5, 2012

July 5, 2012. One day after Marine Harvest took credit, as below, for BAP certification in BC, CTV has reported on fish farm diseases: Marine Harvest alone spent $12 million last year to clear out infected fish [Kudoa] and provide refunds for tainted products, and there are estimates that Kudoa affects 20 to 50 per cent of all salmon farmed in the province.


Read this:http://bc.ctvnews.ca/parasite-ridden-salmon-sold-in-b-c-stores-1.864202.


So, what is it that BAP awards mean? Not much.


Now, read my July 4 post on the BAPs

Read this:  http://www.canada.com/Marine+Harvest+gets+certification/6880995/story.html.

Marine Harvest et al have been trumpeting the past couple of weeks around the globe in news reports about receiving the really worthwhile BAP awards. The problem is that the BAPs are not awards at all.

The industry got together and made the organization then they all put money into it. And they now get the BAP certification from themselves. Don't be fooled. Nothing has changed. Fish farms only want to be in the ocean to use it as a free, open sewer.They should be on land.

You may recall it is only a couple of weeks since 7 fish farms in BC and Washington tested positive for viral diseases. And remember that at the recent Cohen Commission in December, 2011 testimony showed that 25% of Clayoquot farmed chinook tested positive for HSMI and ISA. (This is a huge problem for wild fish, and my bet is that the Clayoquot Sound chinook and Kennedy Lake sockeye are in trouble because of billions of viruses in the non-flushing Sound).

In truth, Marine Harvest Canada is in trouble. It lost money in Q1, of 2012, -.6%, its only major operation around the world to post a loss. And they let go 60 employees at Christmas time. And are reducing orders for smolts.

And, by the way, the CEO of Marine Harvest, Alf Helge, in Norway has just complained about fish farms refusal to bring forth sea lice data. See: http://viewer.zmags.com/publication/84be8a79#/84be8a79/16.

You see, 40% of farms don't report lice and the government doesn't follow up. Meanwhile, here in BC Canada, Marine Harvest has just pulled out of a joint study with environmental groups studying, wait for it, ... that sea lice do not cause problems with wild fish or transfer diseases. Same fish farm company, completely different response.

What Marine Harvest did get out of the five year agreement with the Suzuki Foundation and so on in BC is not being criticized in the press. I would say that lucky outcome has ended.

Oh, and you will remember that Marine Harvest plead guilty in December of 2011 of having wild salmon and herring in its nets in BC - having for almost two years previous, protested its innocence. And in Ireland, Scotland and Norway, in the past year nearly 500,000 farmed salmon escaped from fish farms. Hmm.

The BAPs don't mean much.

KEY DOCUMENT: CFIA Testing of ISA in BC, Updated Mar 3, 2012

This document contains the Canadian Food Inspection Agency's new plan to test for ISA, IHN, and IPN, but not Marine Anemia in BC: http://www.inspection.gc.ca/animals/aquatic-animals/diseases/reportable/isa/eng/1327197013896/1327197115891.

Since before the Cohen Commission testimony in December, the CFIA, that has a conflict of interest over testing wild Pacific salmon because they deal only in foreign trade issues of farmed salmon, has repeatedly dug in its heels and continued to say the same thing about ISA in BC that they have said all along. That is that they changed the Moncton lab's assessment of a faint positive ISA test in one of 49, sockeye fry samples - samples the lab admitted were too degraded for testing - into a negative result for ISA. The CFIA ignores the hundreds of positive tests by the world expert labs, including, Kibenge, Miller and Nylund.

And here is an article, one of many, regarding a Cooke Aquaculture infection of ISA right now in Nova Scotia: http://www.globaltoronto.com/canada/suspected+outbreak+of+salmon+virus+at+nova+scotia+fish+farming+operation/6442583545/story.html. The CFIA, rather lately, has now admitted that Cooke has ISA, Mar 10:
http://www.inspection.gc.ca/about-the-cfia/newsroom/news-releases/infectious-salmon-anaemia/eng/1331155048243/1331155084131.

Its backing up the farm for being good enough to slaughter the fish - that we as taxpayers pay for - means everything is A OK and business as usual. This will not work in BC with our five species of salmon, and those of a dozen countries.

Then the post brought in more Kibenge tests of Morton procured salmon - in March, 2012. Five of 21 farmed Atlantic salmon sold in a small BC chain store have tested positive for ISA and one more chum carcass in the Vedder River has tested positive:

http://www.inspection.gc.ca/about-the-cfia/newsroom/news-releases/infectious-salmon-anaemia/eng/1331155048243/1331155084131.

The CFIA does not admit these tests for BC. The situation is getting ridiculous, and strongly suggests that the 4726 fish tested by the provincial system as negative for ISA need to be retested by Kibenge, Miller or Nylund. But there is more. Using the 'chain of custody argument the CFIA said the samples were too degraded to reach a positive result and has turned all of Morton's March ISA positive fish into negatives, and will use the Moncton lab to 'confirm' the OIE world stature lab. The CFIA needs to be taken out of the ISA testing regime.

Here is my critique.

1. CFIA has a conflict of interest and should not lead this project. The Kim Klotins testimony and the Joe Beres email during the Cohen Commission hearings in December made it clear that the CFIA is only interested in suppressing ISA issues in farmed Atlantic salmon and that they view the issue as winning a PR war. What is required is independent officials and academics with no ties to fish farms.

The CFIA's stamping its feet and claiming ISA is not in BC - after Cohen - by continuing to say the Rivers Inlet sockeye fry exhibited no ISA (before Cohen) is not a truthful or complete and fair assessment of that testing. It changed its Moncton lab's finding of one faint positive and that the 49 samples of sockeye were to degraded to do accurate testing - to false readings.

Furthermore, it has refused to talk about the coho, chinook and chum positive ISA readings that were analyzed by the Kibenge and Nylund labs. Kibenge and Miller, in Canada, testified that they were intimidated by the CFIA.

2. The expression 'Industry led' testing needs clarification. If this includes the commercial fishing, the sport and the processing sector, conflict free academic, and environmental NGOs, aboriginals, officials from other countries, including the Pacific nations with Pacific salmonids, and the expert labs under Miller, Nylund and Kibenge, and freely allows individuals to collect samples for ISA testing, then have them tested, the input will contain those affected by this testing. And the process will have credibility.

But if the expression means fish farms only, it will have the conflict of interest that has always existed in fish farming and no credibility

3. Other partners include DFO, its Moncton, and the BC testing system. Minister Ashfield has on several occasions said there is no ISA in BC and that testing has been negative, even though the Fraser River samples for coho and chinook were also positive. DFO does not want to find ISA. Most importantly, DFO has a conflict of interest in promoting fish farms but also having responsibility for wild salmon. Richards opened the gates to ISA infected eggs on the ground that the fish farms might sue on restraint of trade, but she has no expertise in trade issues. Miller has found ISA all the way back to 1986.

The BC system was found to say it was using one PCR test for ISA, but was not using it. It also used a grad-student-developed probe/primer that was not peer reviewed. That means it could not find ISA, and the 4,726 fish so tested need to be tested by an expert lab. The 1100 recorded symptoms of ISA may likely be true and thus be ISA. And Marty has used Marine Harvest lice data to do a scientific study that was later shown to be wrong. This implies a conflict of interest, too.

The Moncton Lab was shown by the experts to not be able to find ISA, because their equipment was old and their procedures were not up to international standards. This is the lab the CFIA and DFO will rely on.

Furthermore, the CFIA has said previously that it won't allow testing paid for by individuals. This means that the citizens of BC will have to fund testing by Nylund in Norway.

4. The Exec Summary says the wild, anadromous species known to be infectable will be tested in the first two years. The table on P 42 lists coho, steelhead/rainbow, sea trout/brown trout. Sea trout is an Atlantic Ocean term not used in BC, and CFIA seems not to know this. And there are precious few sea-run browns, if any, as BC does not acknowledge that these exist, an unintended outcome of stockings as much as 80 years ago. But the list does not include chinook, chum, sockeye or pink salmon, nor does it include, Dolly Varden, herring, nor the bottom fish that may well be carriers.

Morton's tests with Kibenge and Nylund show sockeye, chum and chinook have ISA virus. See the Kibenge world spread of ISA document here: http://www.oie.int/eng/A_aquatic/Docs/Presentations/1.11Kibenge.pptAnd Miller has shown that 25% of Clayoquot chinook have ISA. Her samples show ISA in sockeye from 1986, two years after Atlantic eggs began flowing into BC for fish farms.

5. Farmed salmonids are also being targeted for surveillance activities. As the CFIA has a focus on suppressing disease findings because of its conflict of interest regarding foreign trade in farmed fish, there is no reason to accept its findings. Armslength testing by people and facilities that cannot be affected by the CFIA and reporting to the public are what is needed.

Certainly, when the farmed industry suggested to Miller that they would make their farmed Atlantics available for ISA testing, they then wanted management control of the project, wanted her to test for the parvovirus first, and access to farmed fish was taken off the table. She declined to be a part of this 'plan'. The CFIA was shown to accept, on a phone call basis with, fish farms when they said they did not have ISA. Unacceptable.

6. The reporting of any positive findings will be done by notification to the appropriate stakeholder and industry groups and to the World Organization for Animal Health (OIE). As noted above, if the system is oriented to not finding ISA, there will be no ISA reported. And what does the term 'appropriate stakeholder' mean.

7. ISAV and IPNV are not currently known to be present in British Columbia (BC). ISA is in BC and I will spend no more time on this counter-factual claim by the CFIA - except for one thing: the document goes on to say there is no ISAV in BC; this little switcheroo, is a semantic difference, meaning the disease is not present, even though the virus is here and brought from the Atlantic ocean for fish farms. Go read the OIE tables on what constitutes a disease presence: http://www.oie.int/fileadmin/Home/eng/Health_standards/aahm/2010/2.3.05_ISA%20.pdf. Real proof is a viral isolate, but in ISA's case, this can be hard to achieve, hence, the odd conditions in the OIE manual for proving ISAV.

8. Compartmentalization? What does this mean? That ISA can travel on the boots of humans, therefore, the route of infection cannot be traced to the Norwegian derivative fish farms in BC that also have farms in as many as 21 countries, and thus its own staff may have brought ISA in? Hard to say. But certainly, that is their stance after egg transfer company Aquagen was shown to have brought ISA to Chile - a $2 billion loss.

9. Chain of custody of fish samples must be maintained. The CFIA means that anyone who does any collection and testing of ISA, as happened in the fall of 2011, outside of itself, is not valid. Good thing Morton, Kibenge (Fred and wife Molly), SFU, Miller and Nylund established ISA is here before the CFIA could intimidate and dismiss their findings.

On the other hand, it is fair to note that samples have to be taken in a precise way, and the sampler needs to avoid taking the ISA to the next site and then 'finding' it there.

10. The scenario tree divides the population of interest into smaller groups,
within which each individual has the same probability of being detected as diseased given that the population is infected. It does this by describing both the structure of the population and all events that influence the probability that disease or the disease agent, if present, will be detected by that SSC. This sounds good but there are 9,562 different strains of the five species of salmon in BC. DFO has stats on only 57% of salmon demes. And DFO has announced it will lay off 200 science staff. Hence there is no 'structure of the population' in almost 43% of cases, some 4,112 strains of BC salmon.

11. The following is a list of lead organizations involved in ISA testing. It includes the province's system that has been shown, above, to be using an unverified probe/primer, and the BC Salmon Farmers Association for its data. It is good to note, however, that the fish farm group has fought release of this data every step of the way since the early '90s, and finally had no choice because Cohen made the release of the BC info public in December. When less detailed info was required by Cohen in August 2011, the fish farms fought its release, and when compelled by Cohen, immediately changed their tune and trumpeted how open and transparent they were (only to become entrenched once again by Dec 2011).

12. The stochastic decision tree has some nifty math, but no where in this plan is there testing of the water column for up to ten kms from each farm. There are two issues: the farms are not far enough away from one another to be independent; and, as many as 60 billion virus particles are released from one infected farm in an hour and carried by the tide. Looked at another way, this might explain why the Clayoquot Sound fish are diseased to the 25% level - more than 100,000 fish per farm - because it is a dead end, and thus does not flush. (As it is a UN Biosphere Reserve, there should not be fish farms here anyway).

13. Tests are to prove absence of disease. This stance is maintained by the CFIA throughout the report. Seems to me that we should be proving presence of disease.

14. Design prevalence factors are assumptions at a defined percentage. Here are three: trading partners requirements; biological plausibility; and, resources and political considerations. You may recall that biological implausibility of ISA was cited by more than one expert in Cohen testimony. So does that mean the percent is: 0%? And should political considerations and resources get an assumed percentage? Since DFO, the CFIA, the province of BC and the ministers all think ISA is not in BC, should the percentage be 100% that the design prevalence factors are good? Do percentages make sense for these factors?

15. Time period of analysis - whether short or long. The problem is that ISA carries on at a mortality of about 1.5% and then, at an undetermined point - and they are testing for ISAV rather than ISA - can rapidly exceed more than 50% mortality with 100% of fish having to be slaughtered and disposed of, just as is currently happening to Cooke Aquaculture in Atlantic Canada.

16. All five species of wild salmon will be tested. Good thing. But the note that they are being tested because they have 'trade significance' ignores that the sport industry at over $500 million in revenue, perhaps 60% of which is from anglers from other countries, is not considered trade. And the sport sector is the biggest and highest employer of the commercial, aboriginal, aquacutrue and processing sectors. 7,500 employees compared with only 820 for aquaculture - that means 915% larger than fish farms.

17. Among other places, wild salmon will be collected at processing plants. The problem here is that fish in packers are stored together in holds, so one fish can contaminate the thousands of other fish in the hold.

18. The current scientific evidence on the susceptibility of Pacific salmon species to ISAV is limited. There is a large amount of science/news on the susceptibility of Pacific salmon to ISA. Here are dozens of them: http://isearch.avg.com/search?cid={59265ce4-372b-4df6-925d-b95785f49726}&mid=c6f75560551047d19ab6d1526267478d-c18e2e88897e2d0377e4ddcc18a0f231c9c4f6db&ds=ins12&v=10.0.0.7&lang=en&pr=sa&d=2012-02-29%2012%3A11%3A48&sap=ku&q=ISA+in+Pacific+Salmon.

19. DFO hatcheries can be considered sentinels for disease. Contrary to this assertion, it has been the provincial hatcheries that have a long history of being worried about fish farm diseases. There is an extensive email history of being concerned about DFO introducing ISA - which ultimately did happen.

It should also be pointed out that in freshwater, cross contamination is very easy. If one fish has it, the whole river and its hatcheries do. On the other hand, infection of skin or gills can mean recent infection, while heart or other internal organs means long-term infection, and infection not prone to occur from passing through an infected river.

20. We will use QRT-PCR as a screening test and confirmation will be on viral isolate. The problem is that ISA is very hard to isolate, hence, all such cases will be 'negative' to the CFIA.

21. The l% design prevalence is assumed, and thus 75 fish per strain. Good luck. As DFO has no data on 4,112 strains of Pacific salmon, good luck trying to do a good job. Oh, and there are those pesky runs teetering on extinction. Do remember that the Kibenge report noted a 100% infection rate of all 64 Cultus Lake sockeye. Now only one or two returns, likely because DFO ignored the report in 2004.

22. 4900 fish (1750 adult and 3150 juveniles and spawners) will be collected per year for two years. So, let's see, that means one half of a fish per strain in BC. Hmm.

23. A five course series is required for collectors and inspectors. And this comes when DFO is letting go 200 science people? And the Harper government is looking to downsize by 5 - to 10% of the rest of DFO and government? Good luck getting funding.

24. Ideal collection conditions are inside a building, and staff can make their own structure. Given that BC has 25,000 km of coastline, and the Pacific is a big ocean and it rains on the wetcoast, conditions are not ideal. And ka-ching.

25. We will collect and process 175 fish per day. This computes to 25 fish per hour in a 7 hour day for one person. That means 2.4 minutes per fish, or 4.8 if there are two people. Good luck.

Oh, and just how are you going to collect those steelhead? Fish for them? Good luck. And isn't it against the law to kill wild steelhead? I know many steelhead fisheries that only have 100 wild fish as the entire run. The CFIA shouldn't be killing endangered runs, even though steelhead are the prime species that I would pick first.

26. We will test apparently healthy fish. What about the obviously diseased ones? Discard them?

27. Steelhead, unlike salmon, spawn more than once. This is not really true. My guess is it is max 35% and then triple spawners are more like 10%.

Footnotes 6 and 7 (p19 and 20) say testing for steelhead will be non lethal, but still 175 fish. I can see gill, mucous, anal fluid and stomach pump material. Infected livers and kidney would shed into anal fluid, but hearts? And 175 steelhead per run? Good luck catching those. The CFIA might have to angle for several months and tag sampled fish. This plan may seem good in Ottawa, but the CFIA will need an army of top notch anglers to catch even 10% of their target number in the swelling rivers of autumn.

On the other hand, if they pay me, I will catch steelhead for them. I'll work overtime, seven days per week. I am starting to like the CFIA.

28. Hatcheries only produce a small percentage of the total number of juveniles which enter the ocean in any given year. This may be true on the Fraser for, say, sockeye, (140 million wilds from the Chilko River alone in good years) but far more rivers the enhanced fish outnumber the natural ones. On the other hand, if they mean all hatcheries and all rivers, the overall numbers support what is being said.

29. Table 4. Sampling juveniles and spawners by sampling area per year. This table demonstrates the stunning lack of coverage in the CFIA program. The North and QCs will have 175 adult fish taken. The Skeena is five miles wide for dozens of miles it is so huge. On the other hand, in the QCs (Haida Gwaii) there are dozens of little streams that have salmon, but they may have only 100 yards of spawning gravel before they rise precipitously up the mountains. So each species in each stream is its own genetic fingerprint, but the CFIA program will only do, say, half of its Northern sampling, a total of 87 fish?

The next area is all of east Vancouver Island and the mainland from Rivers Inlet all the way to just north of Vancouver. A huge area with thousands of strains of salmon, will be sampled for only 175 fish? Ditto for the other areas.

30. A formal collection agreement with the CFIA is required for any collection of samples done on behalf of the CFIA. This seems reasonable, but what it does is forbid anyone else from taking samples and being part of the CFIA study. This means that the public will have to do their own work and send the samples outside of Canada for testing.

31. The industry role is defined for commercial fishermen only. This means environmental orgs, individual scientists, environmentalists, concerned public members, the sport industry and aboriginals cannot be part of the project.

32. It is proposed that CFIA, as Canada’s veterinary competent authority, will provide an oversight function to industry-led surveillance effort, which will include an annual visit to sites. As before, the CFIA has no credibility in this issue. The CFIA dealt with a case of ISA on the phone and took the fish farm saying it had no problem as truth. This is not the way to do surveillance. The role needs to be adversarial in the way that police deal with issues, and visits need to be unscheduled and more often than once per year. Do recall that Marine Harvest has just paid a fine, Jan 18, 2012 for possession of herring and wild salmon. News reports noted tons of wild fish being destroyed. This kind of thing will never be discovered without unscheduled visits of officers that can lay charges and are not working for a body that has a conflict of interest with farmed fish. The only reason the issue came up is that onlookers watched herring and salmon falling out of off-loading boats in Port Hardy.

33. Administrative animal health regulations and oversight by the competent authority will help maintain trading partner confidence for either specific commodity groups or the entire region. The CFIA keeps saying this, but this does not agree with what has just happened in the USA. It eliminated a 26% duty on Norwegian farmed fish originally issued for anti-dumping reasons. Norway has had ISA continually since 1984, so why would the USA accept ISA infected fish, if the CFIA contention were true?

In addition, the losers in this duty change will be Canada and Chile who are the main suppliers to the USA market. And Norway is right now going after the markets of Scotland's Atlantic production. BC fish farms are in bad shape, as MHarvest just laid off 60 employees because of difficult times. It is going to get much worse. And, Chile, has once again hit an oversupply position, and fish prices will drop. It may prove fortunate for BC if another ISA crisis hits Chile - 23 farms are now cited for ISA and one farm was just slaughtered for viral disease.

34. It is proposed that a proportion of [farm] sites be visited by the CFIA on an annual basis (between 10 and 20 sites visited annually). This is ridiculous. There are approximately 125 marine leases and 100 freshwater leases in BC that grow
anadromous salmonids. This means that it will take between 11.25 to 22.5 years for the CFIA to get to any individual fish farm! ISA will have wiped out BC salmon by that time.

35. There are 4 principal salmonid aquaculture companies in British Columbia: Grieg Seafood BC Ltd. (20 marine sites and 1 freshwater site), Marine Harvest (61 marine and 11 freshwater sites), Mainstream Canada (27 marine and 4 freshwater sites), and Creative Salmon Company (6 marine and 1 freshwater sites). Thanks for the info. So few fish farms can create so much environmental damage - 114 sites. Hard to believe.

36. Fisheries and Oceans Canada (DFO) oversees the National Aquatic Animal Health Laboratory System (NAAHLS) to support CFIA’s delivery of the regulatory mandate of the NAAHP. Tell us what the actual facilities are. The Moncton lab that can't find ISA?

37. Plan review and meetings with stakeholders, Federal and Provincial authorities to explain the surveillance plan, garner support and assistance, and clarify roles and responsibilities. As before, who are the stakeholders?

38. The dissemination of final positive test results... will be done via prompt e-mail notification to selected stakeholder and industry groups and to the OIE... Who are among the selected stakeholders? And, why can we not know about individual locations of disease? See: the identification of affected premises is not provided. The BC tables provide site specific data, and these are now public, thanks to Cohen.

39. Dissemination of info will be: to maintain and enhance welfare, productivity, and economic viability of aquatic animal industries in Canada. This means the purpose of the whole exercise is to maintain fish farms as they are, in the ocean. This is an outcome that is not viable in BC anymore. Everyone knows fish farms should be on-land, and the CFIA studies are superfluous to this knowledge and outcome.

40. Outbreaks of ISA have occurred in Atlantic salmon cultured in New Brunswick in the Bay of Fundy. However, the last detection of a pathogenic strain of ISAV in this area occurred in 2007. Here is my table, based on Kibenge and others, of ISA in the world: http://fishfarmnews.blogspot.com/2011/10/isa-infections-world-wide-sine-1984.html. The CFIA comment does not agree with the table. Oh, and the Cooke Aquaculture destruction of two farms in Atlantic Canada in Feb/Mar 2012 for ISA has not yet been added to this table.

41. ISA occurs in spring or early summer in water temperatures from 3°C to 15°C. This includes BC water as it is typically 6 - 11 degrees all around the year; however, if we believe the quote, ISA occurs as wild smolts out migrate, and early spawners return, as in sockeye and pinks.

42. ISA: Vertical transmission has not been demonstrated; egg surface-associated
transmission does occur. This runs counter to the study on Aquagen that showed vertical transmission to Chile from Norway.

43. 7.2. ISAV, IHNV, IPNV Case Definitions. This table does not recognize Kibenge's work on genotyping the ISA strains in Chile. There are 28. Looking for segment 6 or 8 only, could lead to negative results when they are in fact positive for ISA. However, the table also says non-pathogenic ISA can be determined by positive tests from two different assays.

44. The bottom of page 41 is reasonable indication of wild river/marine area infection provided you believe the lab, and the process is free of conflict. It is not, but the unswayed experts Miller, Kibenge and Nylund should be involved and free to report their findings. And, if they have been required to sign any agreements about testing only chain of custody fish, this should be public information - Nylund is probably not in this category as he works in Norway. And their 'informal' expert comments should be publicly reported without any meddling by the CFIA, DFO, BC and so on.

45. Appendices. There is some spectacularly interesting information in the Appendices. You may want to go here first and cruise around before committing to the drudgery of the report itself.

Whew, this was a lot of work.