Kim Jong-Un, On-land Fish Farmer, North Korea!

Surprise, surprise! Even North Korea, one of the least technically advanced nations on earth (only 1000 computers connected to the internet) has on-land, closed-containment fish farms.

The big dude himself can be seen looking down to the fish in the tank. Lovingly? Can’t say, but it has to be said: even the most technology-challenged of countries put fish farms on land where they belong. Even dictators with no sense of humour are doing it.

Marine Harvest, Cermaq, Grieg Seafood, it’s time to get out of the water and quit using the world’s pristine oceans as free, open sewers.

See: http://www.dailymail.co.uk/news/article-2885133/So-kill-time-North-Korea-internet-goes-Kim-Jong-visits-fish-farm-country-s-web-access-cut-off.html. 


See my link for 70 fish farm systems, now 71, on land, comprising more than 8,000 on land fish farms around the world. There is no need anymore for the excessive environmental damage caused by in-ocean fish farms: http://fishfarmnews.blogspot.ca/2012/01/key-document-34-mostly-on-land-closed.html. 

NB - Wild Atlantic Salmon Decline - Miramichi

In New Brunswick, wild salmon declines have occurred in many of its rivers. In the Miramichi, here is some information from the Atlantic Salmon Federation:

Of course, any salmon river is a valuable asset to the region through which it flows. In 2011, a Gardner Pinfold report (Economic Value of Wild Atlantic Salmon) estimated the total annual economic value for wild Atlantic salmon at $255 million, supporting over 3,800 full-time equivalent jobs. One of their four case study rivers was the Miramichi (the other three were the Exploits, Margaree and Grand Cascapedia), where they pegged annual spending related to wild Atlantic salmon at $20 million, supporting 637 full-time equivalent jobs.

See more at:http://asf.ca/voices-of-the-valley-in-winter-14-asj.html#sthash.VTx6x59d.dpuf. 

By October 15, only 198 grilse had passed through the Northwest Cassilis trapnet compared to 230 on the same date last year. For salmon, the numbers were worse, 83 compared to 196 in 2013. Salmon and grilse numbers at the Millerton on the Southwest Miramichi had recovered by October and 743 salmon passed through the Southwest’s indicator trapnet (466 on same date in 2013) with 568 grilse (versus 371, same date ’13).  

The numbers become ever more startling with a quick glance back through earlier years. Average counts at the Northwest Cassilis trapnet between 2001 and 2010 were in the 400 range for salmon and 1100 for grilse. This is in stark contrast to the 83 salmon and 198 grilse counted by the same time period in 2014. While the salmon counts at the Millerton trapnet on the Southwest are somewhat closer to the averages for the same time period, the grilse numbers, while up from 2013, are very depressed. From 2001-2010, average grilse counts at Millerton ranged from 1,935 (2006-2010) to 2,663 (2001-2005).

The trapnet numbers are not complete counts of what is in the river, but rather are partial counts that provide an indication of fish that are entering the Northwest and Southwest systems respectively.   - See more at: http://asf.ca/voices-of-the-valley-in-winter-14-asj.html#sthash.VTx6x59d.dpuf

The average number of salmon returns to the Miramichi River has declined rapidly from 82,000 annually in the 19902 to 53,000 in the first decade of this century, to 23,000 a year since 2011. Preliminary numbers from DFO indicate even further declines in 2014.

A Gardner Pinfold report estimated the toal economic value for wild Atlantic salmon in 2010 at $255 million, with the recreational fishery alone worth nearly $130 million, supporting nearly 4,000 full time equivalent jobs.

See more at: http://www.thefishsite.com/fishnews/24809/government-to-set-up-wild-salmon-decline-committee#sthash.rmhiBeCk.dpuf

In BC, in an average year, there are 100,000,000 salmon that return. This shows that wild Pacific salmon in BC, are in far larger numbers than Atlantic salmon on the east coast, that resemble more, in their habits and numbers, our BC steelhead. BC salmon are far more important to the province of BC than salmon in other jurisdictions. 

Study: On Land Fish Farm Systems Make More Money

Here is another article that shows that on-land closed recirculating fish farms make more money and shield the environment from sewage, disease, lice and the other problems associated with the old-tech in-ocean methods employed, particularly by the Norwegian companies, Marine Harvest, Cermq and Grieg Seafood.

Abstract

Research into the use of recirculating aquaculture systems (RAS) addresses the question of how to achieve profitable production while consistently recycling water and nutrients with minimal fresh water demand and waste production. The RAS facilities require an adequate supply of fingerlings, and a facility for fingerling production in conjunction with each RAS can prevent disease transfer and ensure quality and continuous production. The time, space, and financial investment can be eliminated by hatching (purchased disease free ova) and rearing of fingerlings every 2-3 months. The present study evaluated (water quality assessment, feed utilization, production cycle duration) a simple low cost recirculating hatchery for salmonids as a safe and continuous source of fingerlings for further rearing in RAS. The tested recirculating hatchery enabled low cost efficient production on a small scale (at least 5 production cycles per year, > 63 000 fingerlings per each cycle), low fresh water demand (0.05 l.sec-1) with maintaining good rearing conditions, and environmental and zoohygiene safety. Such simple facilities can support the sustainability of inland aquaculture and strengthen the effort to deliver quality products with minimal operational and environmental costs.

See: http://omicsonline.org/open-access/a-simple-and-effective-recirculating-hatchery-for-salmonids-2155-9546-5-271.php?aid=31145.

See my link for 70 fish farm systems on land, comprising more than 8,000 on land fish farms around the world. There is no need anymore for the excessive environmental damage caused by in-ocean fish farms: http://fishfarmnews.blogspot.ca/2012/01/key-document-34-mostly-on-land-closed.html. 

Some more text from the study:

The positive results obtained in a simple recirculating system call into question the reported need to use additional technologies for hatcheries such as UV treatment, ozone application, microsieve filtration, oxygenation, and aeration. The RHS was fully functional without such treatments, thus is more efficient with respect to initial investment as well as operating costs. Nevertheless, potential use of additional technologies in enhance the RHS should be discussed. Added aeration and oxygenation may increase the capacity of RHS, but benefits such as increased production and increased biofiltration rate are cancelled out by increased operating costs. Oxygen level and biofiltration efficacy were found to be sufficient in the current study. -

 See more at: http://www.thefishsite.com/articles/2001/a-simple-and-effective-recirculating-hatchery-for-salmonids#sthash.sdp4Ved9.dpuf.

Key Document: Irish Public Against Norwegian Style Fish Farms

The Irish public, like the public all over the world where Norwegian style in-ocean fish farms set up shop, criticize fish farms for the same problems that everyone else does: sea lice, diseases, fish escapes, chemical pollution, released sewage, damage to wild salmon and, in their case, sea trout and so on.

The point is that in-ocean fish farms are old-tech dinosaurs that need to be on land, in closed containment with recirculating systems, sewage capture and energy production along with hydroponics.

The Galway Bay and Bantry Bay issues have been long standing flash points in Ireland for many years. Read the text, as it is in keeping with other citizen complaint in Ireland:

Letter to the Editor, Inshore Ireland, Dec 2014 – Jan 2015 Issue

Dear Editor,

Please allow me space in your magazine to reply to the outdated policies on salmon farming by Donal Maguire and Benen Dallaghan of B.I. M in your August/September issue.

Donal Maguire is wrong to blame the anti-salmon farm lobby for the low output of Irish salmon farm production. According to Marine Institute records and other documents which we acquired under freedom of information there is approximately 32,000 tonnes licenced capacity and approximately 10 to 15,000 tonnes unlicensed capacity salmon farms operating all along our west coast. The truth of the matter is that these salmon farms were only able to produce less than 10,000 tonnes last year and 10, to 15,000 tonnes in previous years due to outbreaks of diseases such as Amoebic Gill Disease (AGD), Pancreas Disease and infestations of sea lice.If there is approximately 47,000 tonnes of licenced and unlicensed capacity already in existence and salmon farmers cant even reach a 1/3 of this capacity why in Gods name do BIM insists that we need another 15,000 tonne salmon farm in our beautiful iconic Galway Bay and another 5,000 tonnes each for Inis Bofin and Gola Island?

Contrary to BIM,s assertion that the Irish coast is ideal for salmon farming our sea temperature’s are now rising to approximately 21 degrees and according to weather experts they may rise another 2 degrees over the next 10 years, these high sea temperatures are ideal only for AGD and sea lice to multiply and for high moralities in farmed salmon.

AGD is now prevalent in nearly all salmon farms along the west coast (including BIM,s flagship Clare Island) and is costings salmon farmers millions of euro to treat their fish with fresh water which some of them have to take illegally (no planning permission) from rivers and lakes, yet in the Environmental Impact Statement (EIS) compiled by BIM for the Galway Bay salmon farm there is no mention of AGD or where the operator is going to get water to treat anything up to 14.4 million farmed salmon (salmon farm capacity is 30,000 tonnes). This EIS  is now out of date and should be withdrawn.

BIM keep telling everyone that the Galway Bay salmon farm is a deep sea salmon farm. The dept of water at the Inverin Bank site is only 18 to 26 metres deep and the Inis Oirr site only 30 metres deep,this is hardly deep sea.

Benen Dallaghan says that ”The mass movement of water on these sites also serves to maintain the pristine nature of such offshore environments”. Mr Dallaghan cannot prove that statement to be fact as BIM themselves admit in the EIS (model limitations page 188) that there is no proper model to determine what will happen under a salmon farm until the salmon farm has been in place for a period of time.

The EIS is also out of date in relation to wave heights in Galway Bay as it states (page 165) and I quote ”It would be expected that significant wave heights would be below 1 metre for approximately 80% of time while significant wave heights in excess of 3 metres would occur during storm events only.” We now know that last winters storms produced waves of 9.7 metres and over in Galway Bay (MI data) which caused tens of millions of euro damage to property and infrastructure all around Galway Bay. If there had been a salmon farm in Galway Bay during these storms it would have been destroyed along with the salmon farm in Bantry Bay which had similar type cages to those proposed for Galway Bay. A previous salmon farm at the Inis Oirr site was destroyed by gales in the early 1990s after being in operation for a short time.

Donal Maguire says that ”One cannot have a tank reared organic salmon”. Why not? Surly a salmon reared in a closed containment on land system that didn’t need to be treated with pesticides to kill sea lice,didn’t need antibiotics to treat diseases and wouldn’t cause any harm to wild salmon or sea trout would be more organic than what is now being produced.

I believe the reason BIM do not want closed containment on land salmon farms is because the remit for these farms will go to some other Government Department other than BIM as they (BIM) are a SEA fisheries department and not a LAND fisheries department. BIM needs these sea cage salmon farms to justify their existence.

Minister Simon Coveney needs to bypass the outdated thinking of those in BIM and embrace the new technology that is out there in relation to RAS systems. Salmon farm systems that all stake holders would be happy with.

Yours sincerely,

Billy Smyth                                                                                                                            Chairman Galway Bay Against Salmon Cages,

Summary: Fish Farm Environmental Laws Damaged by DFO and Harper Government, Updated April 28, 2015

Gathered into one post here is all of what DFO and the Harper Government have done to weaken the laws in Canada and to allow fish farms to dump raw sewage, chemicals and other pollutants into public waters.

The major beneficiaries are the multi-national, multi-billion dollar Norwegian companies Marine Harvest, Cermaq and Grieg Seafood.

1.      Weakened the fish habitat regulations in the Fisheries Act. S-35 and S-36.

See: http://fishfarmnews.blogspot.ca/2014/11/key-document-strictest-laws-in-world.html.

2.      Weakened the Canadian Environmental Assessment Act - 2012.

See: https://www.ecojustice.ca/files/ceaa-backgrounder-1/at_download/file.

3.      Weakened the science apparatus by firing scientists, and refusing to let them talk about their science in public. 90% of DFO's own scientists are against what DFO is doing, weakening laws and reducing science budgets. This includes weakening laws, letting scientists go and the new and even weaker aquaculture regulations. See:  http://fishfarmnews.blogspot.ca/2014/12/canada-strictest-fish-farm-laws-no-best.html.

4.  Weakened the law by allowing fish farms to take over dumping their pollutants into the sea. These are the new, weaker, Aquaculture regs: http://www.dfo-mpo.gc.ca/aquaculture/management-gestion/aar-raa-proposition-eng.htm.

5.      Weakened NAFTA oversight into fish farm damage to wild salmon. Specifically: That Canada violated its own laws by allowing fish farms to harm wild salmon stocks through the spread of parasites. Canada, the federal government, refused to allow the investigation.

The petition to NAFTA's Commission for Environmental Cooperation, was filed in February 2012 by the Centre for Biological Diversity, the Pacific Coast Wild Salmon Society, the Kwikwasu'tinuxw Haxwa'mis First Nation and the Pacific Coast Federation of Fisherman's Associations. The groups had asked for a fact- finding inquiry into whether Canada was failing to enforce its Fisheries Act by protecting British Columbia's wild salmon.

"This NAFTA process is supposed to shine light on whether environmental laws are being enforced, but the process has become increasingly politicized and it's clear Canada does not want the facts revealed about the damage to wild salmon from industrial fish farms," said Jeff Miller with the Center for Biological Diversity. See: http://www.kcet.org/news/redefine/rewild/commentary/could-canadian-fish-farms-harm-californias-wild-salmon.html.        
6.      Weakened Canada Marine Act. See: http://www.envirolawsmatter.ca/d_j_vu_again.  Bill C-43 allows the federal government to exempt ‘port’ lands from the Canadian Environmental Assessment Act and the Species at Risk Act, and to delegate powers to any person, eliminating oversight.

7.      Weakened DFO Conservation and Protection enforcement. DFO enforcement budget and staff numbers in BC are vastly underfunded and understaffed with respect to the rest of Canada, and the salmon enhancement program budget is dumped into the across Canada C&P budget, thus it is only a bargaining chip, when budgets are rationalized annually.

During the Cohen Commission, for example, Conservation and Protection revealed that it was approved for 55 staff to deal with fish farms alone. It was told to take out all of northern BC saltwater and all freshwater hatcheries, and not to talk with the Province’s staff that had previously done the job prior to 2010.

The behind the scenes emails on this show a DFO as dysfunctional as everyone in BC thinks it is (do note most BC residents are on the side of BC DFO staff). Ultimately only 12 staff were received, only 21.8% of what was authorized, and one was sent to Port Hardy, making enforcement activities on fish farms completely ineffective in the view of C&P’s top staff.

One of its Funding and Operational Issues submissions (the shortfall total was $15.639 million plus $1.5 million for capital items) is hilarious if it were not so sad. There is only one boat for the whole province, and it is in disrepair. Here is the kicker: for rigid hull vessels, DFO did not authorize any fuel for the boats – a budget of only $200,000. Pretty much zero oversight for fish farm infractions.

Here is an example from the Cohen Commission document: “C&P was advised that fish farm compliance was nearly 100% and the need for enforcement would be low. After one of the first fish site visits… [the fish farm reported] one dead sea lion in their predator nets. C& P returned with an underwater camera and located 55 dead sea lions in the netting.”

8.      The Index for this Fish Farm News blog will take you to many posts on weakening fish farm laws in Canada. Note particularly the Nancy Greene Raine posts. See: http://fishfarmnews.blogspot.ca/2014/10/index-to-wwwfishfarmnewsblogspotcom.html. 

9. Here is an April 2015 update on the weakened Regs that DFO Minister, Gail Shea is going to bring in, totally disregarding that residents who have to live with fish farms overwhelmingly want them out of the water, or they can go back to Norway: https://www.facebook.com/photo.php?fbid=1663476680547553&set=np.1430232327071432.100001711032000&type=1

Key Document - Norwegian Fish Farms Choose Advertising Not Coming On-land to Solve Their Problems

In France, consumers have decided they don't want to buy Norwegian farmed salmon from in-ocean net pens because it pollutes the ocean and causes environmental damage. But the billion Dollar Norwegian firms, like Marine Harvest, Cermaq and Grieg Seafood, persist in not coming out of the water into closed containment to solve the problem.

Instead, they want to advertise their way out of the problem, rather than solving it. See: http://www.undercurrentnews.com/2014/12/15/image-not-price-the-issue-as-french-salmon-market-sinks/. 

Norwegian salmon's reputation has contributed to falling sales to French shoppers in 2014, with total sales down 12% in volume in Europanel and Norwegian Seafood Council data. This is a drop from 59,000 metric tons in 2013 to 51,600 mt in 2014. In 2012 sales reached 64,000 mt. The value of salmon sold in France has fallen too, despite a 5% increase in prices from over 1.01 billion Euros to 929.38 million or 8%.

The high price for farmed salmon from in-ocean net-pens? Prices have increased by 5% since 2013 from 17.17 Euros/kg to 18.01 Euros/kg. Fish farms like to claim they are needed to feed a hungry world. This is obviously not true, because no hungry person can afford these prices. Only those in first world countries can, and they are voting against farmed salmon because they understand the environmental damage caused by fish farms.

Marine Harvest, advertise your way out of this: consumers will not buy your products once they have been educated on your environmental damage. Cermaq and Grieg Seafood, come out of the ocean and solve your problems today. 

Norway – Closed Containment Study

My list of 70 on-land, closed, recirculating fish farms, comprising more than 8000 actual fish farms, is at this link:  http://fishfarmnews.blogspot.ca/2013/10/65-on-land-fish-farm-systems-oct-20-2013.html

Even Norway is getting on the bandwagon of getting them out of the water: http://www.thefishsite.com/fishnews/24701/nofima-to-host-centre-for-aquaculture-research

Norway, where the environmentally damaging in-ocean fish farming of Atlantic salmon began, is looking at closed-containment. It pretty much deletes diseases, lice, high mortality and escape issues and makes more money by delivering fish more quickly.

As not having to pay for the sewage damage that in-ocean closed fish farms is so large a part of the costs not borne by in-ocean farms like Marine Harvest, Cermaq, and Grieg Seafoods today it is difficult to see whether or if ever the companies actually will come out of the water. They persistently refuse to come out of the water, and the highest cost they avoid is the sewage they release.

The commonly accepted comparison of fish with human sewage is that 10 fish equal the sewage of one human being. In Norway, Scotland, and BC Canada, the sewage cost avoided is equal to all the sewage put out by the entire population of humans.

Nevertheless, Nofima is one of 17 institutions chosen to become host for Centres for Research based innovation. “A considerable part of salmon production in the future will be carried out in closed-containment systems on land or in semi-closed containment systems in the sea.” Since so much mortality comes at smolting at 80 grams, the first benefit has shown that holding them in on-land closed systems to 250 grams past the time of smolting, lowers losses.

Their research phase is funded for 8 years at the present, so it provides another decade of time for fish farm companies to refuse to come out of the water. However, “the overall goal of the CtrlAQUA Centre is to develop the technological and biological innovations that can lead to closed-containment systems becoming a reliable and financially viable technology.”

Canada: Strictest Fish Farm Laws? No. Best Science? No. Weakest Laws in the World? Probably

Go back and look at the index to this site and read the several posts on how the fish farm laws in Canada have been weakened in the past two years: https://www.blogger.com/blogger.g?blogID=1880129387856188740#editor/target=post;postID=890992371737194469;onPublishedMenu=posts;onClosedMenu=posts;postNum=8;src=postname.

And the new aquaculture regulations that the Harper government wants to bring in are aimed at making the already weakened environmental regulations regarding fish farms in Canada even weaker, by passing responsibility for environmental damage directly to fish farms: http://www.dfo-mpo.gc.ca/aquaculture/management-gestion/aar-raa-proposition-eng.htm. 

And, of course, 200 scientists were let go in the past year.

Now, a month later, federal scientists, are finally so concerned with budget cuts to science, particularly for the environment, they have taken the unprecedented step of surveying their members:  http://www.pipsc.ca/portal/page/portal/website/issues/science/vanishingscience.

Their documents may be accessed from the above link. It is titled Vanishing Science, and, the summary headline says it all:

Harper Government Cuts to Science Overwhelmingly Detrimental and Out of Sync with Public’s Priorities, Say Surveys

Here is what federal government scientists say: 9 out of ten scientists and almost 75% of Canadians say the Harper government is not acting in the best interests of science and the environment:

"According to newly released data from a survey conducted by Environics Research, over 9 out of 10 federal government scientists (91%) believe cuts to federal science budgets – most of which take effect over the next few years – will have a detrimental impact on the federal government’s ability to serve the public. (Over half – 51% – already believe the impact to be very detrimental.) Moreover, the cuts are strangely at odds with the science priorities of the overwhelming majority of Canadians. A recent poll of Canadians, also conducted by Environics, reveals that nearly three-quarters (73%) believe public health, safety and protection of the environment should be the government’s top science priorities – some of the very areas that have come in for the severest cuts."

Nine out of 10 - 90% - of scientists at the Department of Fisheries and Oceans Canada (aka DFO) believe recent omnibus legislation changes to the Fisheries Act (S.35 and 36) will hamper Canada's ability to protect fish and fish habitat.

So  90% of DFO's own scientists are against what DFO is doing, weakening laws and reducing science budgets. This includes the weakening laws, letting scientists go and the new and even weaker aquaculture regulations.

"Invitations to participate in the online survey of federal scientists, hosted by Environics Research, were sent to 15,398 PIPSC members – scientists, researchers and engineers – engaged in scientific work in over 40 federal departments and agencies. Of these, 4,069 (26%) responded between June 5 and 19, 2013. The survey is considered accurate + or – 1.6%, 19 times out of 20. A shorter public opinion survey was conducted by Environics of 1,003 Canadians between November 14 and 20, 2013. The results are considered accurate + or – 3.1%, 19 times out of 20."

The PDF to the one-pager of stats can be accessed from the survey link. Look for: 
factsheet.en.pdf. On their survey site.

This document lists the specific demands of the union of professional scientists and engineers. It include the right to speak about science and to not be silenced: http://www.marketwired.com/press-release/federal-government-scientists-seek-protect-scientific-integrity-through-collective-bargaining-1973561.htm

Fish Farm Feed and GMO Plant Products

Fish farm fish feed can now contain genetically modified materials that pass antibiotic resistance to bacteria in the gut of farmed fish. The reason for so doing is that most of the world’s stock of small fish for feed, that the fish farm industry has had a large role in fishing down, rather than them being used to feed people, are in short supply. For example, anchovies in Chile. Now, plant material with the genes are being used because it is now cheaper than the small fish the industry is culpable for eliminating.

 Read this about Norway: http://translate.google.co.uk/translate?hl=en&sl=no&u=http://www.bioteknologiradet.no/2014/11/stopper-dispensasjon-for-omdiskutert-fiskefor/&prev=search.

There are other issues: Norway had laws that were not in concert with the EU, it chose to allow fish farms to apply for an exemption to import GMO products with nineteen known genetic modifications, eight of which code for antibiotic resistance.

In a Google translation, the problem for humans who eat such farmed fish is:

“Antibiotic Resistant bacteria have become one of the greatest threats to global health. Only in the EU and EEA dies 25,000 people annually as a result of infections that we few years ago could treat. Antibiotic resistance is the bacterial defenses in the ancient arms race between bacteria and their enemies. Human use of antibiotics and germicides have made it an enormous advantage for bacteria having genes encoding antibiotic resistance.

If we fail to slow development, we and the generations after us have a far more slunkent medicine cabinets to defense, even against infections that today are perceived as banal. A recent report on antibiotic signed an interdisciplinary and independent experts were handed Health Minister Bent Høie in August this year, showing that the problem is growing in Norway.”

With Norway not following up on such products and providing an exemption for such feed, a consumer has no real assurance that a GMO antibiotic resistant product has not been used in Norwegian farmed salmon. It should also be noted that bacteria found in cold blooded fish, may not be active in warm blooded humans that eat the fish.

It is a twisted road in the past ten years regarding GMO use in farmed fish in Norway. Here is a part of that history:

“Yet the FSA since 2008 given dispensation to introduce eight varieties genetically modified feed with antibiotics. It all started in April 2004, when the EU introduced new rules for genetically modified organisms (GMOs). The so-called "GM-package" includes approval requirements for GMOs.

Norway had prior to 2005 no restrictions on imports of non-living, genetically modified feed, with or without antibiotic, and more genetically modified ground feed was probably used in feed or attempt. When the EU came with new accreditation requirements, altered Norway regulations to adapt the EU. Regulations for feed was changed in 2005 so that the FSA must approve each application for permission to import of genetically modified, not viable feed.”

Then, further on: “The Norwegian regulations have not yet been harmonized with EU regulations. Since 2008, feed producers sought FSA for exemption from the requirement for approval of the nineteen feed products. FSA has granted this exemption, due to the need to have genetically modified feed in reserve.”

“Thus feed manufacturers had to import genetically modified feed with genes coding for antibiotic resistance, but resistance among customers and the market has done that feed producers have not wanted to use the feed, and the genetically modified feedstuffs, according to manufacturers not been an ingredient in fish pellets since 2005.”

However, in 2014: “the FSA for the first time refusal to grant an exemption for fish feed producers. Because they have never availed itself of the exemption, says the FSA that it no longer "is no real need" for the goods. Now you must feed manufacturers seek approval pursuant to regulations on animal feed. Then it is far from certain that feed with genes coding for antibiotic resistance is allowed.”

And so on. A twisted story.