Giving Narwhal Some Correct Information

The Narwhal has a long, well written post on the in-ocean/on-land fish farm industry in BC: https://thenarwhal.ca/bc-salmon-farming-transition/. However there are some errors here and there:

Here are some comments:

1. Atlantic salmon could compromise Pacifc Salmon genetics. False. Atlantics cannot interbreed with any strain of Pacific Salmon. In fact, no Pacific species can interbreed with another Pacific species. We wouldn't have five species if this could have nappened over 10,000 years of Pacific evolution.

On the other hand, the 'leakage' number is 153,000 per year, and John Volpe did river swims, showing the outrageous number of 97% of Van Isle Rivers with multiple Pacific salmonids have Atlantics, and multiple generations of Atlantics, meaning they have spawned in BC: http://fishfarmnews.blogspot.com/2021/06/escaped-atlantic-salmon-invade-bc.html.

2. The Precautionary Principle should be used. This is true, and the person to talk to on this one is Tony Allard, a lawyer who has written on the Principle in BC. The link to his take is in this post: https://fishfarmnews.blogspot.com/2020/11/dfo-is-biggest-threat-to-wild-bc-salmon.html.

3. There are not 75 on-land fish farms in process or completed. My list has 372 on-land fish farms around the world. On-land is common: http://fishfarmnews.blogspot.com/2016/05/152-different-on-land-fish-farm-systems.html.

4. Atlantic Sapphire in Florida is aimning at 220,000MT. False, they are aiming at 260,000MT which is triple the size of BC's in-ocean fish farms, in only one on land. If BC fish farms won't come out of the water, they will be put out of business by all the plants coming on sream in the States, including many in both Maine and California. The reality is that consumers will choose on-land for environmental reasons and BC loses 85% of its market which is the US. Look at my post on the avalanche of news on the on-land industry around the world. I'm up to about 1200, yes 1200, articles/papers from the fish farm/seafood indusry press, good news about on-land: http://fishfarmnews.blogspot.com/2021/05/good-news-post-now-more-than-thousand.html.

5. Contrary to what the fish farms industry and DFO says, employment is low in in-ocean fish farms. They say 7,000, while the BC government's own BC Stats Report on the 'fishing sectors', says only 1800, making the indstry claim 390% too high. In other words, they can't 'lead the recovery' as they are much too small.

The BC Stats Report is analyzed here: http://fishfarmnews.blogspot.com/2019/03/mar-21-2019-bc-stats-report-2016.html.

6. Terry Beech is working on a fish farm paper for government. My take on what they should do is:

1. Start a program to retrain the workers from in-ocean to on-land.

2. Charge $1M for an in-ocean licence, with on-land at zero. Then the in-ocean should be systematically raised to what these same companies pay in Norway, $32- to $40-million.

3. Give on-land farms $1Million to set up on-land.

4. Alternatively, give them use of Crown Land for free for, say, ten years.

7. Fish farms say there is no sewage, while Karen Wristen, of Living Oceans, says there is lots. I did the calculations to derive a conservative sewage cost to BC residents of in-ocean. The conservative end of the conservative numbers is a massive $10.4Billion: http://fishfarmnews.blogspot.com/2017/02/fish-farm-sewage-huge-cost-to-bc.html. Note that this post shows the amount of work I put in to calculate a number on a fish farm issue.
8. Terry Beech says the industry is a multibillion dollar industry. False. The revenue goes back to Norway, for distribution to shareholders, and fund global in-ocean.

Next time, Narwhal, you might do just a bit more homework to cover all the bases. Meaning, your writer might like to do a bit more. They can contact me if they want to. I cover all the bases. Or you can just have me do the article.

DFO Is Biggest Threat to Wild BC Salmon

I have long argued that DFO has been managing salmon into extinction for the past 50 years.

I am glad to hear that others feel the same way. Tony Allard, who did a good job on stating what the Precautionary Principle means (he is a lawyer), has now come to the same realization as I and others have about DFO.

See: https://ipolitics.ca/2020/10/30/the-biggest-threat-to-wild-pacific-salmon-is-fisheries-and-oceans-canada/?fbclid=IwAR0c9AKUWV6SHqFNzS94MJy_3OmduQBGHHNbTaL2ZcKNLKp6C3D8FQWm52M&mc_cid=ac81828f2c&mc_eid=5777c92bcd.

Here is a quote: "Today, DFO does whatever is necessary to support Atlantic salmon farming along B.C.’s coast — to the significant threat of wild Pacific salmon. Only Canada allows the farming of Atlantic salmon on the migration routes of wild Pacific salmon. And, just like 30 years ago, DFO continues to rig science so it can skirt its primary duty to protect B.C.’s iconic keystone species."

The policy paper I put together as part of a Green Party committee argues that the big problems for wild salmon are: prevention of habitat destruction and restoration of habitat; DFO; fish Farms; and climage change. If you want the paper, let me know.

And here is a long post on the problems with fish farms in BC: http://fishfarmnews.blogspot.com/2019/07/dfos-public-consultation-on-framework.html.

Here is Allard's post on the PP: https://fishfarmnews.blogspot.com/2018/10/precautionary-principle-has-defined.html.

Now, more from the current article in iPolitics: "In 2015, the Federal Court found DFO had not adhered to the precautionary principle — the law of our land — when regulating the foreign Piscine orthoreovirus [PRV], saying DFO’s “arguments with respect to the precautionary principle are inconsistent, contradictory and, in any event, fail in light of the evidence.” Four months later, DFO reinstated the same policy, adopting a risk threshold that prohibited only risks that could sterilize entire populations, species, or ecosystems." And PRV is present in 90% of farmed fish.

And, of course, you should know that DFO has gone back to court to argue against the PP, when they have already lost that argument twice.

And DFO said that Discovery Island fish farms posed no threat, but failed to test for sea lice one of the most killing parasites of migrating juvenile salmon. Note that in the early 1900s, 100,000,000 - yes, that's 100 million - sockeye returned to the Fraser. In 2020, the pitiful number is 285,000 sockeye or a quarter of one percent, that is .25%.

John Reynolds, aquatic ecologist at Simon Fraser University, and chair of the Committee on the Status of Endangered Wildlife in Canada (COSEWIC) said: “We have an overwhelming weight of evidence from research coming at this from all different directions. The current open-net-pen fish-farm model that we have is not compatible with protecting wild fish.”

If you have Tony Allard's email address, let me know. He is not hard to find on the net, but his email address is.

Precautionary Principle has a Defined Approach - Updated Oct 10, 2019

Here is a thorough look at the precautionary principle, as applied to getting fish farms out of the water on the grounds they are detrimental to wild salmon. The reason for using the principle is that it doesn't matter how much science is done, fish farms will always say that the science done doesn't prove anything and that more science is required.

Doing science is thus a trap, because a decade will go by and still fish farms, and DFO, will say there is not enough science. Hence the reason for using the precautionary principle to save wild salmon. one example is that fish farms don't agree that lice cause problems even though there have been 30 such studies in BC, and 800 world wide, and that lice cause the greatest loss of farmed fish around the world. And Helge Aarskog, CEO of Marine Harvest says lice are their biggest problem, even though Marine Harvest in BC doesn't agree.

For links to the lice studies, see this post of mine: https://fishfarmnews.blogspot.com/2018/05/lice-outbreak-in-clayoquot-sound.html.

There is a good coverage of the issue of precautionary principle in the Agriculture Minister's Advisory Council's Appendix 2 in the report: https://www2.gov.bc.ca/assets/gov/farming-natural-resources-and-industry/agriculture-and-seafood/fisheries-and-aquaculture/minister-or-agriculture-s-advisory-council-on-finfish-aquaculture/maacfa-2017-docs/minister_of_agricultures_advisory_council_on_finfish_aquaculture_final_report_and_appendices.pdf.

Written by Tony Allard - who is a lawyer


He says: "There are constitutional, legislative, policy and international obligations that require the Minister to apply the precautionary principle.The precautionary principle does more than forbid decision makers from using scientific uncertainty as an excuse for regulatory inaction. It requires decision makers to err on the side of caution by anticipating harm and taking protective measures when there is environmental risk, even if there is scientific uncertainty."
 
The federal government has a constitutional obligation to protect fisheries and oceans. Section 91(12) of the Constitution Act, 1867 gives the federal government jurisdiction over the “Sea Coast and Inland Fisheries”.

And:

"The history of the Oceans Act is important to understanding its legislative intent. By the early 1990s, the cod fishery on Canada’s Atlantic coast had collapsed. The Oceans Act was passed in 1996 to ensure that such a catastrophe never occurred again in Canada. The Oceans Act ext ended Canada’s jurisdiction over marine waters and required an ecosystem approach to the management of the marine environment based on the precautionary principle.

"Sections 29 and 30 of the Oceans Act expressly require the Minister to apply the precautionary principle.

"Moreover, in the Prime Minister’s Mandate Letter to the Minister, the Prime Minister expressly requires the Minister to “[u]se scientific evidence and the precautionary principle, and take into account climate change, when making decisions affecting fish stocks and ecosystem management”.

"In The Uncertain Future of the Fraser River Sockeye(the “Cohen Commission”), Mr. Justice Cohen came to similar conclusion. Mr. Justice Cohen observed that the Federal Court in Environmental Defence Canada v . Canada (Fisheries and Oceans), 2009 FC 878 said that Canada had ratified the United Nations Convention on the Conservation of Biological Diversity (the Convention) and, since the precautionary principle was a main component of that convention, Canada had committed to apply the precautionary principle.

"Canada has also committed to the precautionary principle in several pieces of federal legislation,including the Oceans Act, the Canadian Environmental Protection Act, 1999, SC 1999, c 33, and the Canadian Environmental Assessment Act, 2012, SC 2012, c 19, s 52."

Allard goes on to cite several cases and policy documents that show DFO is to use the precautionary principle.  For example Justice Rennie in Morton, 2016 spells out what is required:

"...although there is a healthy debate between respected scientists on the issue, the evidence, suggests that the disease agent (PRV) may be harmful to the protection and conservation of fish, and therefore a “lack of full scientific certainty should not be used a reason for postponing measures to prevent environmental degradation”: Spraytechat para 31"


And:

"Mr. Justice Rennie’s interpretation al so sits squarely with the classic statement of the precautionary principle by the Supreme Court of Canada in the Spray Tech decision, but it shifts the emphasis away from scientific uncertainty, where the discussion is often focused, and places it back on anticipation and prevention of environmental harm:

In order to achieve sustainable development, policies must be based on the precautionary principle. Environmental measures must anticipate, prevent and attack the causes of environmental degradation. Where there are threats of serious or irreversible damage, lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation."

Allard points out that: "Canada’s Policy for the Conservation of Wild Salmon expressly requires the precautionary principle to be applied with respect to the conservation of wild salmon"

This means it applies to the Wild Salmon Policy.

And: 

"The precautionary approach, defined in the Oceans Act as “erring on the side of caution,” is a key principle to be applied in the management of ocean activities. Under the Strategy, the Government of Canada is reaffirming its commitment to promoting the wide application of the precautionary  approach to the conservation, management and exploitation of marine resources in order to protect these resources and preserve the marine environment. 142

And, science is needed as a place to start, but not a place to say no: "Before the precautionary approach can be applied, scientific data relevant to the risk must be evaluated through a sound, credible, transparent and inclusive mechanism leading to a conclusion that expresses the possibility of occurrence of harm and the magnitude of that harm (including the extent of possible damage, persistency, reversibility and delayed effect).143"

 And the framework that government must use includes the following: "The application of precaution is distinctive within science-based risk management and is characterized by three basic tenets: the need for a decision, a risk of serious or irreversible harm and a lack of full scientific certainty.145"

Now, fish farms will always say that they have millions invested and the government can't just dump them on land, where is the science? I have pointed out several times that the sewage cost to BC is at minimum, $10.4B and this is vastly higher than the revenue, as measured by BC Stats of $469M. It would pay us well to give them $1m each to set up on land, as that total would be $85 million, given that roughly 85 farms are operating at any time.

"Since the Framework provides a series principles a decision-maker must follow to protect the environment, it is not surprising that the Framework makes it expressly clear that any impact on the assessment of trade occurs only after the decision- maker has determined the level of protection is consistent with society’s values. Accordingly, the Framework’s last principle makes it clear that the impact on trade is to be considered only after the decision to apply precautionary measures has been made"


 The precautionary approach, is summarized this way, rather than the oppposite of fish farms saying the country will never attract investment, that you have to show us 100% proof that w e cause damage, and jobs will be lost, etc.:

"First, a level of protection is chosen so that it is aligned with society’s values. Second, optionsfor protective measures that meet that level of protection are identified. Third, and only after the first two steps, the impacts on trade are assessed and protective measures that may have a lesser effect on trade may only be chosen if they maintain an equal level of protection.151 The decision-maker cannot decrease the level of protection to increase trade. Rather, once society’s chosen level of protection has been determined, the decision-maker can only choose between protective measures that maintain that level of protection. If multiple options for precautionary measures are available that provide the same level of protection, only then can the decision- maker choose the least trade-restrictive option."

 For example, DFO should refuse to let PRV infected smolts be put in the ocean, acting on the precautionary principle, not ironclad science, because fish farms say there is no ironclad science.

In closing, Allard puts it this way: "The precautionary principle does more than forbid decision makers from using scientific uncertainty as an excuse for regulatory inaction. It requires decision makers to err on the side of caution by anticipating harm and taking protective measures when there is environmental risk even if there is scientific uncertainty."

And that the minister must do what is reasonable, not what he thinks is reasonable, but what the situation requires as the most reasonable outcome, such as putting fish farms on land. You may know that my list of on-land fish farm systems now sits at 251 such RAS systems: https://fishfarmnews.blogspot.com/2016/05/152-different-on-land-fish-farm-systems.html.

*****

In 2019, read about DFO using economic considerations to not do anything about the extinction nearing Thompson steelhead, a tragedy of the commons, and failing to use the PP:  https://www.kamloopsthisweek.com/community/the-outdoor-narrative-ottawa-s-decision-on-steelhead-is-shortsighted-1.23971848?utm_source=Watershed+Watch+Email+List&utm_campaign=ca899b6bf5-EMAIL_CAMPAIGN_2019_10_10_12_24&utm_medium=email&utm_term=0_405944b1b5-ca899b6bf5-166907249&mc_cid=ca899b6bf5&mc_eid=5777c92bcd.