Hi Brenda McCorquodale
I have just read your response to Elena Edwards note to you and have some comments.
But first, you have to realize there is no way forward for old tech, polluting Norwegian fish farms in BC other than on land in closed containers. By their own admission there are only 820 actual jobs in aquaculture. I estimate there are 100 million wild salmon in BC. It simply makes no sense to threaten them anymore.
1. Treating wild fish for pathogens.
The point is that we don't want anymore 'scientific' fixes. We want fish farms on land. I have a list of 51 different on-land closed systems comprising some 8055 actual, on land fish farms around the world. See:http://fishfarmnews.blogspot.ca/2012/01/key-document-34-mostly-on-land-closed.html. The only reason fish farms want to be in our pristine ocean is to use it as a free open sewer.
Not to mention that treating wild fish for pathogens isn't possible, for example, a million wild sockeye in the Fraser. How do you catch every one? And what mortality would there be in catching the few you do catch?
Not to mention that 7 farms/hatcheries have been found to have viral pathogens in the past month in BC and Washington.
2. The CFIA and their biosecurity protocols.
The December Cohen testimony pointed out the conflicts of interest of the CFIA, DFO and the BC testing system and that the Moncton lab was not able to find ISA.
We don't want the CFIA to do anything because they are not trustworthy. What is needed is an international panel reporting to the public of all the nations on the Pacific Ocean with salmon. Kibenge, Nylund and Miller should be on it.
I have critiqued the CFIA plan here: http://fishfarmnews.blogspot.ca/2012/02/key-document-cfia-testing-of-isa-in-bc.html.
3. Plover Point
You fail to note that all sites in Clayoquot Sound are in channels that don't flush as they have one closed end. They shouldn't be there and no one should have let fish farms in a UN Biosphere.
I think the science will show that the Kennedy lake sockeye and the Sound wild chinook have been wiped out by the non-flushing nature of the Sound. The water column will be filled with billions of viruses for a good ten miles from every fish farm as a sound does not flush.
4. Salmon Aquaculture is a major business.
No it is not. With only 820 actual jobs (and MH losing money) aquaculture is tiny - logging is large, with 87,000 jobs.
Aquaculture will never contribute in a meaningful way to the BC economy, but we lose all species of wild salmon. And in any event, fish farms, no matter what their employment is, need to be on land.
Sport fishing is far larger than aquaculture, at $1 billion and 15,000 jobs. It makes no sense to destroy a billion dollar industry to put money in Norwegian pockets.
5. Fallowing results in clean bottoms.
There are easily a dozen videos on youtube showing that this is not true. The bottom is full of sewage. In Norway, the problem is so bad that in some fjords they have had to dredge out several km of polluted bottom sediment.
6. POPs shouldn't be in the environment.
True. And fish farms on land would never put POPs into the water. The most recent paper, in 2012, says that the amount of PCBs in one meal of farmed salmon will take 50 to 75 years to clear your body. Who wants to eat such fish?
And the new feeds have chicken feathers in them, ones laced with a dozen different pharmaceuticals including flouroquinolones. Some new feed uses chicken feces and animal feces. Then genetically modified plant oils, for example, soy and canola, are being used in feeds. Further, they are fishing the low end of the food chain, krill, in the last pristine ocean, the Antarctic.
You are not hearing what BC residents, including First Nations have been saying to DFO for years: all of us want fish farms on land. But if they are unwilling and you can't hear what we are saying, then they need to go back to Norway.
Here is Elena's Letter:
Thank you for your last thorough response.
You also note that;
Almost one year later since our last correspondence there have been a great deal of additional concerns raised regarding the practice of salmon farming in B.C. waters.
Given your role in Senior Aquaculture Management for DFO, you will be aware of the Cohen Commission proceedings on the topic of Aquaculture as well as the Cohen Commission reopening for three days examining the positive ISAv findings in wild and farmed salmon. I trust you are very familiar with the proceeding of those days and the significant concerns that arose through the evidence and testimony presented.
You will also be aware that Justice Cohen's final report has been postponed until Sept 30th. As I understand from your response, it will be business as usual for the aquaculture industry in spite of the alarming evidence of European viral strains being present in both farmed and wild salmon, of which DFO has failed to acknowledge aside from Dr. Kristi Miller's testimony during the Cohen Commission.
Now I see on the DFO website that regulations are being proposed to treat wild fish populations to control pathogens.
"Under some circumstances, under the Health of Animals Act, the Canadian Food Inspection Agency may need to treat wild fish populations to control fish pathogens that may have been introduced into Canadian waters."
This raises even more serious concerns as DFO and the salmon farming industry have been completely quiet about the presence of introduced pathogens that pass between farmed and wild salmon. For the government to take such drastic actions is not only indicative that there has been a serious breach in security regarding protecting wild fish from foreign pathogens, but that rather than address the source of these introduced pathogens the government is now seeking to treat a wild species with something that is completely unnatural to wild fish stocks with the effects of such treatment being unknown.
Can you please elaborate what this means and why DFO is considering treating wild salmon for an introduced pathogen and what these introduced pathogens are?
Regarding the comment that;
"DFO is consulting directly with First Nations with respect to their issues and concerns."
I question the extent to which First Nations are able to come forward with their concerns when they are not even made aware of what the concerns are. For example, to what extent has DFO informed First Nations along the Fraser River of the introduced pathogens that are a threat to Indigenous wild salmon? Are they being informed that the CFIA and DFO are considering treating their wild fish for these pathogens? Should they not have a say in the matter? Does DFO only consult with First Nations who have salmon farms in their territory? If such is the case then there is a case of grave negligence in recognizing that so long as open-net farms are in waters where migrating wild salmon swim by then it is a concern for all First Nations whose wild salmon might be infected.
You also note that;
"A number of measures are in place both with CFIA and DFO in order to ensure that any possible risks with respect to fish health are minimized. As a Condition of Licence, a Fish Health Management Plan is required for each facility, which includes the development of biosecurity protocols."
Is the presence of introduced pathogens not evidence that biosecurity protocols have failed?
While the 6th question of my previous email may seem of a more ethical nature than scientific, I would still appreciate a response as it falls to the core of allowing the salmon farming industry to have become a seemingly permanent fixture in the marine environment that wild salmon must survive in. I am re-posting that question in the hopes that someone might be able to offer a valid response, especially given the recent outbreaks of diseases in the salmon farms and highly contagious viruses being found in farmed and wild salmon;
6.) Given the knowledge that it IS possible for such a virus to spread beyond the veterinarians ability to monitor or control it, how is it acceptable for DFO/ the government, to allow such a risk to be placed in the oceans when wild salmon populations already have numerous factors threatening their survival into the future? How is this considered using the precautionary principle?
Regarding the Plover Point application;
When you note that;
- "The Plover Point application, to which you
have specifically referred, is considered to be a potential replacement site
which is currently being assessed to determine if it could improve upon the
environmental performance of an existing aquaculture licence. Plover Point is
being considered as a replacement for the Cormorant Island site. Once a new,
more appropriate location for a farm is approved, the Cormorant Island licence
will be rescinded."
What this implies is that the Cormorant Island site has had a negative environmental impact where it is located and now a Unesco Biosphere is being considered as an alternative site location. It goes without saying that the reasons for the transfer indicate that the Plover Point site will suffer the same environmental problems that are requiring the Cormorant Island licence to be rescinded. The logic in this site transfer completely fails in exercising the precautionary principle.
In the DFO report on contaminants which you participated in (http://www.dfo-mpo.gc.ca/Library/278588.pdf) it is noted;
"Salmon Aquaculture: is a major industry in the central coast as the majority of all BC salmon
farms operate in this region. Chemicals are used in many aspects of salmon aquaculture including
intentional use of pesticides to control sea lice, chemical additives in food, antifouling chemicals, as
well as inadvertent chemicals found in feed and building materials. Organic enrichment from fish
wastes and excess food can result in sediment contamination and changes in the ecological
community below salmon net pens.
Most chemical contamination impacts from salmon farms appear to be localized in nature and are
relatively short-lived. For instance, ecological communities below net pens often largely recover after
a 6-month fallowing period. However, it is uncertain how ecological communities are affected by
pesticides, antibiotics, and organic enrichment. In addition, cumulative impacts of multiple farms or
net pens is an important issue that must be resolved in order to determine the number of farms that
should be located in any given area. Persistent Organic Pollutants (POPs) found in some salmon feed
presents a source of harmful contaminants to the marine environment that should be eliminated. "
Given that every problem that has ever existed within salmon farming still remains along with additional problems, it can only be seen that there is no appropriate location for the Plover Point farm and that the only precautionary action at this point would be to fallow all farms and move this risky practice into closed containment.
Regarding your comment that;
- "The department is committed to developing
advisory processes and a management approach which encourages dialogue between
First Nations, industry, and stakeholders, and we look forward to
recommendations from all parties relating to siting requirements for
Does such dialogue only allow for those of who accept the placement of additional salmon farms in the marine environment or does it allow for the presence of those presenting the case that salmon farms should be sited away from wild salmon completely?
In the past year the threats to wild salmon have only increased and with bill C-38 being proposed to strip protection of fish habitat, millions of dollars being put toward aquaculture expansion, and another another bleak run of the Fraser River Sockeye salmon, the Cohen Commission is being made a complete mockery and waste of $26 million if such decisions are being made prior to Justice Cohen submitting his final recommendations.
I hope you are able to respond to these concerns as it is becoming increasingly challenging to get straight forward answers in a time when they are much needed.
Thank you for taking the time.