Key Document: Slaughter Payments to Fish Farms - Jan 16, 2014

This link takes you to the Telegram newspaper that reports $33 Million of taxpayer money given to fish farms in Atlantic Canada by the federal government for slaughtered diseased fish farm fish: http://www.thetelegram.com/News/Local/2014-01-11/article-3571724/N.L.%26rsquo%3Bs-destroyed-salmon-tab%3A-%2433M/1.

I now have some figures that I accept on slaughter fish payments of taxpayer dollars in BC and Grant Wartkentin and Cermaq Mainstream, Marine Harvest and Grieg Seafood may be happy to hear I will eat some crow here, as the BC figures are lower, much lower than my estimate.

The reason for having to make an estimate is that fish farms regularly refuse to let the public know how much taxpayer money they receive for diseased fish that foul our pristine oceans. And behind the scenes, they regularly have their lawyers keeping such numbers, and in the BC case, the disease records for testing of their farms, from the public, as happened during the Cohen Commission, and in this case, getting information from government.

And in this case, it was precisely that, a fish farm legal injunction that made my request wait 10 months before the millions of taxpayer dollars were put in a table and sent to me. My estimate of $35 million in BC is incorrect. The payments to Cermaq Mainstream's IHN diseased Clayoquot Sound farmed salmon are: $2.64 Million for 959,498 diseased salmon (paid in Nov 2012); and, $201,000 for infected equipment and supplies (paid in Jan 2013). The total is $2.8 Million, or $3 per fish, not $30 per fish.

What has not made the news is that the Grieg Seafood open net operation in Sechelt also received payment for slaughtered IHN diseased fish: $1.61 Million for 312,032 diseased salmon (Nov 2012); and, $152,000 for infected equipment and supplies (2013), or $5.60 per diseased salmon.

And here's the bottom line. In the past year or so, the Canadian Food Inspection Agency paid fish farms a total of $30.6 Million of taxpayer dollars for diseased slaughtered fish farm fish. That's pretty close to the $35 Million estimate and I don't think any taxpayer wants to pay a single dollar for these diseased fish, particularly when diseases become a thing of the past when the fish are raised on-land in closed containers with recirculating systems. The old-tech dinosaur operations need to move to land.

I will get back to you with more when I have had a chat with the Telegram. Stay tuned.

Mainstream – Slaughtered fish Money, Clayoquot Sound – Updated Dec 7, 2013

In response to Grant Wartkentin’s post about taxpayer-funded slaughter payments to Cermaq Mainsream for its Clayoquot Sound fish that had IHN, here are some quoted segments of his post: 

If Reid had done a 30 second Google search for "Cermaq financial statements," he would have found the actual amount of compensation we received in the public Cermaq quarterly financial reports, particularly for Q4 2012. 

The number you are looking for is on page 7 where it states:"Mainstream Canada received a compensation of NOK 15.4 million following the mandatory culling of the Millar site due to an IHN outbreak in July 2012."

That's roughly $2.8 million CAD, a far cry from Reid's imaginary number of $35 million. The market value of the fish which were culled, if they had grown to harvest, would have been at least 10 times that amount. 

Hopefully Reid will correct his mistakes, since his whole premise, and his numbers, are completely fabricated nonsense. 

In response: yes, it has been a long time since I have accepted anything a fish farm says without doing independent research. I lost belief in fish farms when they neutralized a Jan 9, 2004 Science article showing that farmed fish had high levels of PCB’s, cancer causing chemicals and persistent organic pollutants (1). The post on this read like a Hollywood movie script (2,3,4).  The same Albany university group has been publishing on the chemicals in farmed fish in the years following their Science 2004 article, and Norwegian scientists have also published on this in 2013 (5).

My investigations should result in the actual dollar figures paid for slaughtered farm fish all across Canada, but an estimate is the best that can be done now because fish farms are not transparent. I researched the Canadian Food Inspection Agency, and other sources to come up with what seems a reasonable approach – you can see it in the last post. So, until I have independent verification of the amount, my $35 Million estimate stands for now – I have noted Wartkentin’s claim of $2.8 Million. Should it or another figure prove to be the more likely than my current estimate, I will amend my figure.

Let me give you an example of non-transparency. A year ago, my research into fish feed showed that some companies were using chicken and other land animal faeces in fish feeds. I checked on Cermaq/Mainstream’s fish feed company EWOS and found that among other things, they were using, as they put it, feather meal. This means chicken feathers. So if you eat a farmed fish, you could be eating chicken feathers. These have been shown to contain multiple chemicals in them, for example, fluoroquinolines. I would not eat a farmed salmon.

I sent a note to EWOS asking them if they used chicken faeces and/or animal faeces in their fish feeds. I did not receive a response. I asked six times, and received no response. If I had been EWOS I would have wanted to be sure no one in the world thought I was using faeces in EWOS feed. So it is still not clear whether chicken faeces or other animal faeces are in EWOS feeds.

One other thing, Mainstream actually had IHN virus at three Clayoquot fish farms: Millar, Dixon and Bawden. Wartkentin does not mention this. And Grieg had IHN at Culloden in the Sechelt. In 2001 to 2003, 36 fish farms in BC had IHN, killing some 12,000,0000 farmed fish. Were these compensated for at today’s figure of $30 per fish this would mean $360 Million. Canadian taxpayers don’t want their tax money going to foreign multi-billion dollar corporations. In this case the company is owned, currently, 59.2% by the Norwegian government and the people of Norway.

The final thing I would add is that the tone of Wartkentin’s notes is not professional. If I were Mainstream/Cermaq I would not let him speak this way, or I would let him go.

1.       Science, Jan 9, 2004. This is the article that fish farms neutralized: http://www.albany.edu/ihe/salmonstudy/salmon_study.pdf. This Albany (Hites et al) group has gone on to author many reports on chemicals in farmed fish in the years since 2004, including chemicals that cause cancer.

2.       This is the spinwatch.org link to the article David Miller wrote on about the fish farms. It details a story that doesn’t seem real, one that would make a Holllywood script. After reading this, you will probably come to the same conclusion that I did:  I never believe anything a fish farm company says unless can independently verify the claim:  http://www.spinwatch.org/index.php/component/k2/item/139-spinning-farmed-salmon-part-1-of-3.

3.       This is part 2 of the Miller article: http://www.spinwatch.org/index.php/issues/spying/item/140-spinning-farmed-salmon-part-2-of-3

4.       This is part 3 of the Miller article: http://www.spinwatch.org/index.php/component/k2/item/141-spinning-farmed-salmon-part-3-of-3

5.    See the table Norwegian scientists referred to in October 2013, on chemicals in farmed salmon. The chemicals in farmed salmon are about a factor of 10 times all other commonly consumed meats. The table can be found here: http://alexandramorton.typepad.com/alexandra_morton/2013/11/dear-minister-of-health-farmed-salmon-toxins.html.

   

jj

Fish Farm Companies Make Taxpayer Money from Diseased Fish - Updated Nov 25, 2013

The article by me was first published by the Common Sense Canadian a week ago. It was responded to by Grant Wartkentin who works for Mainstream. His response is on their website. I stand by what I have said, and do not agree with his assessment of what the fish-site post says about Mainstream losing money when they had disease. As the supply of fish went down, prices rose in the US, but in BC fish farms, their sales to the USA will go down because their parent company, Cermaq Mainstream and the other Norwegian firms had a 26% tariff rescinded to the US market, and now the parent companies of BC fish farms will be out-competing their own corporations in BC.

Please note that Wartkentin did not object to my estimate that Mainstream received $35 Million of taxpayer dollars from the CFIA for their slaughtered, diseased fish. This leads me to suspect that they received even more than my $35 M estimate.

Fish Farms Get Rich on Our Money

You might think the multi-billion dollar fish farm industry was a licence to print money. You’d be almost right, but not for the reason you might think. Marine Harvest, Cermaq Mainstream and Grieg Seafood comprise 90% of BC’s farmed salmon industry and Marine Harvest operates in 22 countries. What you don’t know is that taxpayers, meaning you and me, pay big money to them when their fish get diseases and have to be slaughtered.

Once the Canadian Food Inspection Agency detects a reportable disease, it issues a slaughter order and the fish are destroyed. Then the CFIA sends a very large cheque to the fish farm. This taxpayer cheque compensates them for disposable items like infected nets, cost of transport and offloading, cost of sequestering diseased carcasses in perpetuity, and disinfecting all other items that came in contact with the fish, including the boat that transported them. In addition to all this, the commonly accepted extra payment for each fish is up to $30. This figure really comprises an average payment because of all the other costs mentioned.

You’d think they would have insurance for losses, but my conversations with a marine insurer tells me they have difficulty getting insurance because they lose so many ‘crops’ to – wait for it – disease. So why are we, the Canadian taxpayers, paying these foreign, multi-billion dollar corporations?

Fish farms like to say their fish get diseases from wild salmon because the latter don’t get sick, as if that’s a justification for cash. Not so. A recent PHD dissertation from Norway showed that the problem with farmed fish is that they are stressed (1) – the cages are overcrowded. This results in high output of the stress hormone cortisol and that weakens immune systems in farmed fish, thus they get disease. They actually change benign viruses into infectious killers.

How much product is lost to disease? One third to one half of all aquaculture products in the world are lost to disease every year, some $35 - $49 Billion (2). I started a Freedom of Information request to the CFIA and DFO to find out just how much we taxpayers in Canada pay to these billion dollar foreign corporations. I have been waiting 10 months now with no answer, so, let me give you a reasonable estimate.  

Overall, my expectation is that the cross-Canada disease total will come in at several hundred million taxpayer dollars over the past decade for BC, NS, NB and recently NL. Here in BC, Cermaq Mainstream’s Dixon Point and Millar Channel 2012 IHN slaughters would have paid them, in my estimate, about $35 Million of our cash. That’s so much money that it moved this boom/bust business into positive earnings before interest and taxes (i.e., EBIT), when it lost money the year before – and only made money this year because of having  disease.(3). They’ve had a decade of problems before (4).

See thefishsite.com, November 8, 2013:

Mainstream Canada reported an EBIT pre fair value and non-recurring items of NOK 43 million, an improvement from a loss of NOK 26 million the previous year, even though volumes sold declined from 5,600 tons to 4,400 tons. EBIT per kilo was 9.6 NOK. Good prices in the North American market and the IHN outbreak last year are the main factors behind the improved result. (5).

So Mainstream lost money when they didn’t have disease and made money when they did have disease – because you and I paid them. And they shipped far less fish, oh and a third farm, Bawden Point (8), posted a weak positive for IHN – but they were quickly harvested and sent to humans to eat. This should not be the case. Do complain, as I did, to Gail Shea, Minister of DFO, Min@dfo-mpo.gc.ca.

On another aquaculture front, you may be even more unhappy to know Shea announced $400 Million in gifts to the aquaculture sector in Canada last week(6).  That’s a lot of dead, diseased fish. I have asked her for $400 million be given to the commercial, sport and processing sectors in BC that provide 600% more in contribution to gross provincial product than fish farms. I’ll let you know.

And fish farms in BC have been losing money. Mainstream lost money in 2012(4). Marine Harvest has lost money in the last few years, too, largely due to Kudoa a fungal disease that cost them $12,000,000 in 2012 – and just prior, in 2011, things were so bad they laid off 60 employees – right before Christmas. Nice guys.

Kudoa results in myoliquifaction that makes farmed fish into mush. Would you buy salmon you had to put in a container with a spoon? Oh and then there is Grieg. They got IHN too, last year, in their Cullodon site in Sechelt. Fortunately we did not have to pay for that as well. Grieg is also the company that had to pay a fine of $100,000 for drowning 65 - 75 sea lions in their Skuna Bay nets in 2010 - they tarted up that site to sell to the unsuspecting in the USA as environmentally-sustainable, organic farmed salmon. Where is PETA when you need them?

Grieg has also been losing money (7):

“In Canada, the company cut losses, with a negative ebit [sic] before fair value adjustment of the biomass of NOK 2.71/kg, compared to a loss of NOK 8.22/kg in the same quarter of 2012.”

And the kicker? Cermaq is owned 59.2% by the government and thus the people of Norway. Why do we give another government our money for their killing our fish in our ocean rather than raising their fish on land in closed containers? This does not make sense.

Ask Shea for BC’s $400 million. We can spend it on habitat restoration, something DFO has been sadly remiss about in BC for decades. This year’s total DFO habitat projects for BC is a measly $900,000, only 2.6% of our own money Ottawa sent to diseased fish farms in BC.

dcreid@catchsalmonbc.com

 References:

11. Koestan Gadan PHd: http://www.sciencedaily.com/releases/2013/01/130102083557.htm.

22.   Kibenge document of fish farm diseases: http://www.oie.int/eng/A_aquatic/Docs/Presentations/1.11Kibenge.ppt.

33.  See: http://www.thefishsite.com/fishnews/21731/strong-salmon-market-drives-earnings-improvement-for-cermaq#sthash.x4EVcGXu.dpuf

44.    Cermaq’s other disease problems in Clayoquot Sound in the last decade: http://www.farmedanddangerous.org/solutions/industry-reform/about-the-industry/

55.    Mainstream did a write down of Dixon Bay for $4.5 Mil for biomass insurance purposes. Millar Channel is the other farm slaughtered.

66.    See The Fish Site - http://www.thefishsite.com/fishnews/21654/federal-400-million-fund-to-enhance-canadas-fishing-industry.

77.    Grieg: http://www.undercurrentnews.com/2013/11/01/grieg-plans-norway-growth-in-2014-as-weak-results-in-canada-continue/.

88.    Bawden Point: http://www.timescolonist.com/news/local/fish-farm-quarantined-after-virus-discovered-1.4434.

99.    And Cermaq/Mainstream lost money in Finnmark to disease, too: “The PD [pancreatic disease] outbreak in July had a negative EBIT impact of NOK 25 million for the Finnmark operation - See more at: 

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.

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 - Low Dose Hormones Lead to Worse Health Problems, April 14, 2012

Some low-dose chemical pollutants in farmed food, and these are in farmed salmon, have just been shown to have worse health problems for humans than the same chemicals in higher doses.

Dozens of hormone-disrupting chemicals include small amounts of BPA (bisphenol A), PCBs, dioxins and atrazine, a pesticide. Atrizine is used for on-land farm crops and thus the use of soybean, corn and other plant oils to replace fish meal oil, that contains PCBs, dioxins and so on, doesn't represent a clear healthy alternative to the forage fish that have been fished down for use for fish feed (and still is in Peru). The point is that wild Pacific salmon have lower levels of these chemicals than farmed salmon.

Read this: http://edrv.endojournals.org/content/early/2012/03/14/er.2011-1050.full.pdf+html.

Go back to this article on fishfarmnews to read the list of chemical pollutants in farmed salmon: http://fishfarmnews.blogspot.ca/2011/11/key-documents-levels-of-pcbs-pops-and.html.

The 2012 article reviews hundreds of scientific studies and is a brilliant synthesis of world wide science on the effects of hormone-mimicking chemicals found in our foods. Here is the abstract:

For decades, studies of endocrine-disrupting chemicals (EDCs) have challenged traditional concepts in toxicology, in particular the dogma of “the dose makes the poison,” because EDCs can have effects at low doses that are not predicted by effects at higher doses. Here, we review two major concepts in EDC studies: low dose and nonmonotonicity. Low-dose effects were defined by the National Toxicology Program as those that occur in the range of human exposures or effects observed at doses below those used for traditional toxicological studies. We review the mechanistic data for low-dose effectsanduse a weight-of-evidence approach to analyze five examples from the EDC literature. Additionally, we explore nonmonotonic dose-response curves, defined as a nonlinear relationship between dose and effect where the slope of the curve changes sign somewhere within the range of doses examined. Weprovide a detailed discussion of the mechanisms responsible for generating these phenomena, plus hundreds of examples from the cell culture, animal,andepidemiology literature.We illustrate that nonmonotonic responses and low-dose effects are remarkably common in studies of natural hormones and EDCs. Whether low doses of EDCs influence certain human disorders is no longer conjecture, because epidemiological studies show that environmental exposures to EDCs are associated with human diseases and disabilities. We conclude that when non-monotonic dose-response curves occur, the effects of low doses cannot be predicted by the effects observed at high doses. Thus, fundamental changes in chemical testing and safety determination are needed to protect human health. (Endocrine Reviews 33: 0000–0000, 2012.

This is scary and farmed salmon are scarier than wild Pacific salmon.

LICE In Norway/LICE in BC - April 13, 2012

In Norway, sea lice are out of control. Read these articles:

The New York Times (2011). Copy and paste this:http://www.nytimes.com/2011/03/22/business/energy-environment/22iht-rbog-fish-22.html?pagewanted=all

"In Norway, which is a leading producer of farmed salmon, the head of the Directorate for Nature Management recently called for salmon production to be halved to save wild salmon stocks. Such drastic action was needed to bring lice under control, he said"

The Caledonian Mercury (2010): http://caledonianmercury.com/2010/02/16/plague-of-super-lice-threatens-wild-salmon/0029326

"The Norwegian Institute for Nature Research has estimated that there are over 300 million lice infesting 350 million farmed salmon in cages along the coast of Norway. The industry is six or seven times larger than its environmentally sustainable limit, the institute suggested.

The Norwegian government’s Directorate for Nature Management is arguing that salmon farming in Norway must be reduced this year."

Copy and paste this link into Google for its very long list of articles on sea lice being out of control in Norway, : https://www.google.ca/#hl=en&sclient=psy-ab&q=Directorate+for+Nature+Management+norway+calls+for+reduced+salmon+farms&oq=Directorate+for+Nature+Management+norway+calls+for+reduced+salmon+farms&aq=f&aqi=&aql=&gs_nf=1&gs_l=hp.3...7945.13465.1.13616.31.31.0.0.0.0.233.2904.23j7j1.31.0.frgbld.&pbx=1&bav=on.2,or.r_gc.r_pw.r_cp.r_qf.,cf.osb&fp=b6eae99fd1f9e98c&biw=991&bih=531

This scientific paper, 2012, says that Norwegian sea lice are at such a high level that they limit growth of greater numbers of farmed salmon:http://rspb.royalsocietypublishing.org/content/early/2012/02/07/rspb.2012.0084.full.

The problem is so bad that Norway, where Marine Harvest, Cermaq/Mainstream and Grieg Seafood, the parent companies of those in BC, originate, that K44 million is being invested in research to find new chemicals because SLICE does not work on lice.

What is happening in BC, you ask? The Norwegian derivative fish farms are doing a five year study in the Broughton Archipelago to prove - wait for it - that sea lice are not a problem. The point is that fish farms deny a problem in every new legal jurisdiction they open in and will argue - often for more than a decade - what they have given up on in the rest of the world.

Do note that the BC fish farms claim 1.5 lice per farmed fish and that that's not so bad that it can harm anything. You will also note from above that the figure in Norway is 300/350 or .86 lice per farmed salmon. That means that BC fish farms have almost twice as many lice as Norway where the parents of BC fish farm companies acknowledge lice are out of control.

How many lice are there per smolt in BC? Price et al, 2011, found very high lice numbers: http://www.cbc.ca/news/technology/story/2011/02/09/science-sea-lice-sockeye-salmon.html

The study found an average of 4.83 sea lice per fish in 2007 and 1.61 sea lice per fish in 2008. Upstream from the farms, they found 1.10 and 0.95 sea lice in 2007 and 2008 respectively. In 2007, there were just 0.17 sea lice per fish off the north coast of BC, where there were no salmon farms.

More ISA in BC

Two of Alexandra Morton's recent posts on ISA are well done, concise documents on ISA in BC salmon. BC, DFO and the CFIA are doing nothing. At some point some very expensive lawsuits may be launched against all three. We are watching a potential tragedy unfold, with no one in charge doing anything other than saying it is not happening.

More ISA Virus Test Results, Ap 10, 2012: http://alexandramorton.typepad.com/alexandra_morton/2012/04/more-isa-virus-test-results.html

It notes, among other things:

There are four milestones in detection of ISA virus (salmon flu) in salmon:
1- visual sign in the organs
2- PCR positive result
3- sequencing the virus
4- finding the live virus and culturing it.

Culturing it can prove exceedingly difficult as Dr. Fred Kibenge noted when he was the lead OIE lab covering the ISA outbreak in Chile. It produced a $2 billion loss, but no cultured live virus.

Do look at Dr. Gary Marty's small table (of the BC test system), as in fairness, you need to know that ISA testing is not simple and conclusiveness needs to be statistically significant: http://alexandramorton.typepad.com/Exh%202078%20-%2022-JaundiceSyndromeNotISAV%20copy.pdf

Also published on Ap 10, 2012, Morton summarizes the Cohen testimony and other notes in a timeline in Backgrounder: ISA Virus Results/Testimony in BC: http://alexandramorton.typepad.com/alexandra_morton/2012/04/salmon-flu-infectious-salmon-anemia-virus-isav-infectious-salmon-anemia-isa-was-first-discovered-in-salmon-feedlots.html

I crunched through the papers on the Owikeno sockeye collapse, and while several other plausible scenarios could explain why the third largest commercial sockeye harvest in BC collapsed in the early 1990s, it has never come back, and is consistent with ISA/fish farm lice as an explanation. The smolts are small and are not dying in freshwater:

http://www.for.gov.bc.ca/hfd/library/ffip/McKinnell_SM2001NAmJFishManag.pdf.

Google: Consumers Don't Buy Farmed Salmon

For interest's sake, go Google: consumers don't buy farmed salmon.

This is the link that comes up: https://www.google.ca/#q=consumers+don%27t+buy+farmed+salmon&hl=en&prmd=imvns&ei=gcB3T_iPBuiKiALym5GnDg&start=50&sa=N&bav=on.2,or.r_gc.r_pw.r_cp.r_qf.,cf.osb&fp=bd3320c5af24bc29&biw=1012&bih=531.

I scrolled through the list of pages and stopped at page 52 - Google was offering still more; this means that consumers are well aware of the environmental and chemical issues with farmed salmon.

KEY DOCUMENT - Farmed Fish Prices Will Tank in 2012 - Updated April 30, 2012

The latest article on fish farm prices has finally seen the light and is predicting a huge drop in fish farm fish prices in 2012: http://www.thefishsite.com/fishnews/16734/2012-salmon-price-outlook-negative-as-production-up.

Go back to the post on share prices and scroll to the bottom, to find articles as recent as Mid-March, 2012 predicting a rise, when it is obvious that with Norway being released from a 26% countervailing duty for dumping fish on the US market, and mounting fish supply, and Chilean product back at 500,000 tons that Marine Harvest, Cermaq/Mainstream, Grieg Seafood and so on will have their share prices back in freefall in 2012: http://fishfarmnews.blogspot.ca/2011/10/key-links-fish-farm-share-prices-and.html.

And, now, in early April, here is the first article on falling Atlantic salmon sales, and price drops, in Norway: http://www.thefishsite.com/fishnews/16859/seafood-exports-declined-in-first-quarter

And now, in mid-April, an article on falling Atlantic salmon prices. Gee I must be psychic: http://www.thearcticsounder.com/article/1215fish_factor_salmon_markets_get_all_shook_up.

"the average price of $3.17/lb. was a drop of 19.3 percent to from $3.93/lb. in January, 2011."

And still in April, Marine Harvest's Q1 sales (EBITs) compared with Q1 2011 is K270 versus K963 or only 28% of last year. And the big Chilean numbers have yet to be harvested - (now estimated as high as 700,000 tonnes). See: http://www.fishnewseu.com/index.php?option=com_content&view=article&id=8034:marine-harvest-q1-preview&catid=46:world&Itemid=56

April 30 - And Russia's denying import of Norwegian farmed fish as it found salmonella and ecoli will further depress sale prices:  http://www.fsvps.ru/fsvps/press/2584.html?_language=en.

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.