DFO RAS Study Has Big Flaws - Jonathan Wilkinson?

Hi Jonathan Wilkinson (<min@dfo-mpo.gc.ca>)

So you want to do a study of RAS systems, do you: https://www.undercurrentnews.com/2019/03/07/canada-salmon-aquaculture-study-kicks-off-to-take-close-look-at-ras/?utm_source=Undercurrent+News+Alerts&utm_campaign=78312ab316-Americas_briefing_Mar_07_2019&utm_medium=email&utm_term=0_feb55e2e23-78312ab316-92426209.

There are several problems:

1. Lack of 'evidence and science' based DFO decision making. I cite a dozen examples on this site in the past year. A current one is that after the Feb 5, 2019 decision by Strickland that DFO must test for PRV, you coalesced your 'rapid science response' people to say PRV is not a problem.

See the well respected Brian Riddell nix your RSR: http://fishfarmnews.blogspot.com/2018/11/fake-science-by-dfo-riddell-response.html. Note that Riddell, currently CEO of the Pacific Salmon Foundation, was formerly a scientist with DFO.

2. The recommendations you cite from the Popham finfish committee, are tainted. The committee had fish farm representatives on it. The committee that has come after it is the Wild Salmon Secretariat, for bringing back wild salmon. It has no fish farm representatives twisting the recommendations.

Here are the tainted recommendations that you cite:

• “A brief overview and economic analysis of existing and emerging technologies, including their state of commercialization; (Fish farms are dead set against on-land and will argue all day long that it doesn't make money, ignoring the huge value in protecting the ocean/salmon from using it as a free open sewer);

• “An analysis of the environmental impacts of these technologies; (Fish farms say there is no land for on-land, and use far more electricity than in ocean, overlooking the $10.4B in sewage damage they have caused in BC, PRV and so on, lice explosion in Clayoquot Sound in 2018, algal bloom for Grieg, etc).

• “An analysis of how sensor technologies and data could further address potential environmental impacts; (Sensors largely monitor the fish and do not assess environmental impacts).

• “An analysis of the social implications, including job creation and impacts on coastal/rural communities; (Fish farm stats are false. They claim 7,000 multiplier jobs, when the BC govt's own figure is 1800, making the fish farm stat 390% too high. I will shortly crunch the new BC Stats report, released in 2019).

• “A financial assessment of commercially available technologies, including an analysis of the main factors influencing their financial performance; (I have dozens of studies on how on-land makes money. See the 270 on land post below. It is led out by dozens of studies).

• “An analysis of trade-offs between environmental, economic and social impacts of the technologies reviewed; and, (The reality is that using the ocean as a free, open sewer far exceeds the revenue from the in-ocean sector, $777M is only 7.5% of the sewage damage: $10.4B. We can completely avoid the sewage cost and have increased revenue on land).

• “Recommendations to address potential obstacles to adoption of each of the technologies reviewed.” (Fish farms will argue all day long that on-land can't be done, even while the USA takes away almost 85% of its market by the big four on-land systems coming on line: Atlantic Sapphire, Whole Oceans, Nordic Aquafarms and Aquabanc, a total of 218,000mt).

Here is my list of 270 on-land fish farm systems, comprising almost 20,000 actual farms around the world: https://fishfarmnews.blogspot.com/2016/05/152-different-on-land-fish-farm-systems.html.

Here is my list of global news items on on-land, more than 70 items in the past three months:  http://fishfarmnews.blogspot.com/2018/11/links-to-on-land-closed-containment.html. Note Pure Salmon in the list, aiming at 260,000mt on land around the world. The BC industry is slightly less than 100,000mt, or only 38.5% of this one companies plans. The in-ocean industry in BC is toast.

Jonathan how about you see the light and choose on-land fish farms? You might consider the hundreds of thousands of votes you'll get in the 2019 election, and announce on-land right now. BC residents, like all citizens who must live with in-ocean fish farms around the world, hate in-ocean fish farms.

D

******

Here is another example of DFO not doing science/managing fish farms:
368. DFO Not Managing Fish Farms - https://www.thetelegram.com/opinion/letter-to-the-editor/letter-aquaculture-piling-more-pressure-on-salmon-stocks-296199/?utm_source=Watershed+Watch+Email+List&utm_campaign=e72633df9d-EMAIL_CAMPAIGN_2019_04_03_11_24&utm_medium=email&utm_term=0_405944b1b5-e72633df9d-166907249&mc_cid=e72633df9d&mc_eid=5777c92bcd. Quote: "
A spring 2018 report on Canadian aquaculture, in both B.C. and Atlantic Canada, by the Commissioner of the Environment and Sustainable Development stated, “We concluded that Fisheries and Oceans Canada did not adequately manage the risks associated with salmon aquaculture consistent with its mandate to protect wild fish. Although the Department had some measures to control the spread of infectious diseases and parasites to wild fish in British Columbia, it had not made sufficient progress in completing the risk assessments for key diseases that were required to understand the effects of salmon aquaculture on wild fish. It also had not defined how it would manage aquaculture in a precautionary manner in the face of scientific uncertainty. Moreover, the Department did not adequately enforce compliance with aquaculture regulations to protect wild fish.”" This is the link to the 2018 report: http://www.oag-bvg.gc.ca/internet/English/parl_cesd_201804_01_e_42992.html.