P.O. Box 71, Alert Bay, B.C. V0N 1A0 (250)974-5855 Fax (250)974-5855 *51
alby@north.island.net
SUBMISSION TO THE LEGGATT INQUIRY ON SALMON
AQUACULTURE
Alert Bay, BC
October 4, 2001
presented by:
Michael D. Berry (R.P.Bio.)
Abstract: The current state of public dissatisfaction with the salmon aquaculture industry
and the uncertainty experienced by that industry is a product of the lack of clear
government policies and government(s) inability to exercise their various mandates for
protection of the environment and wild fish stocks. The salmon farming industry cannot
be wholly blamed for current practices; it is, after all, a profiteering industry and will only
act in response to clearly articulated and enforced regulations. A variety of Federal and
Provincial agencies are (intentionally) avoiding enforcement of the various acts and
legislated regulations the public expects and the environment deserves. The salmon
farming industry may be able to thrive on the BC coast, but only if it is given clear
directions based on the public’s desires and sound environmental science.
SUBMISSION TO THE LEGGATT INQUIRY ON SALMON
AQUACULTURE
Alert Bay, BC
October 4, 2001
1.
The Precautionary Approach
Most scientists accept that in most cases where development has the potential for impact
on the natural environment, the Precautionary Approach should be applied. “In most
cases the information (that is available about potential impacts) is uncertain, unreliable
or inadequate and if this is the situation we say that we must err on the side of caution.
There are seven questions which we apply:
1.
2.
3.
4.
5.
6.
7.
Have the needs of future generations been considered?
Will changes that are not potentially reversible be avoided?
Have undesirable outcomes and measures that will avoid or correct them
been identified?
Can corrective measures be initiated without delay?
Will the corrective measures achieve their purpose promptly?
Has priority been given to conserving the productive capacity of the
resource?
Has there been an appropriate placement of the burden of proof?”
(Malcolm Windsor, North Atlantic Salmon Conservation Organization)
The salmon aquaculture industry is in a position of uncertainty with respect to many of
the potential impacts on the natural environment and, therefore, should only persist in an
atmosphere of caution using precautionary approach principles.
2.
Environmental Reviews and Results
There have been a number of reviews of the salmon aquaculture industry over the past 10
years. Probably the most notable was the EAO/SAR (Environmental Assessment
Office/Salmon Aquaculture Review). Many of us in this room attended the SAR sessions
and participated in the development of the 49 final recommendations that resulted. These
recommendations were, in part, accepted by governments and those of us who spent
many volunteer hours at the meetings were hopeful that action on the recommendations
and research stemming from those recommendations would be initiated. To date, many
of the recommendations have seen no action. Site carrying capacity reviews and
appropriate down-sizing of farms where necessary have not been completed; coastal zone
inventory, mapping, and zoning processes have not been supported; First Nations issues
have not been addressed; escape prevention measures have not significantly reduced the
number of escapes; the interactions/impacts between escaped farm fish and wild pacific
salmon have not been defined; public participation through local advisory bodies has not
taken place. There are many more examples of recommendations that have received no
action. Most of us who participated in the SAR process wonder if our time was not
wasted.
More recently the Pacific Fisheries Resource Conservation Council (PFRCC) chaired by
the Hon. John Fraser, ex DFO Minister, hosted a “think tank” of international scientists,
industry, public, and government personnel to discuss some of the more pressing issues
respecting salmon net cage operations and the potential impact on wild salmon stocks.
(SFU, March 2000). Five questions were put forward:
1. Do genetic interactions occur between wild and farmed salmon and, if so, how
are such interactions manifested in the gene pool of wild salmon?
2. Can farmed salmon invade the ecological niches of wild salmon?
3. What is the evidence that disease spreads from farmed to wild salmon (and
vice versa)?
4. What are the dangers associated with farming of transgenics?
5. What steps should be taken to reduce the risk of aquaculture to wild salmon?
The PFRCC “think tank” left us with more questions than answers – proof once again
that we are proceeding in a state of uncertain, unreliable or inadequate information and
that the Precautionary Principle must apply. In most cases of potential
interaction/impact the available science was unable to answer the basic questions: Has it
been examined? (No); Has it been demonstrated/documented? (No); What is the potential
for impact on native stocks? (Risk anticipated but magnitude unknown).
3.
Agency Responsibilities
Canada has been described as one of the most regulated countries in the world when it
comes to development and natural resource impacts. We have a number of federal and
provincial acts and statutes that are designed to reduce, prohibit, or mitigate impacts on
the natural environment. The Province has stated that: “The provincial salmon
aquaculture policy is geared towards bringing the industry in line with tough new
environmental regulations while encouraging the development of new made-in-BC
salmon farming technology.” The federal Fisheries Act speaks of “no net loss of habitat”
and can impose large penalties for “the Harmful Alteration or Destruction of fish
habitat”. There is, however, a huge variability in how and when those regulations are
enforced – it appears to be a matter of political will rather than equitable application of
those rules for all.
If, for example, you wish to construct a floating structure (e.g. a dock) you are likely to
be required to design it in a way that the ocean bottom is not shaded or, develop
replacement habitat to compensate for that shading. Failure to do so can result in a
Harmful Alteration of habitat charge that brings heavy penalties. One need only look at
the 76% of natural foreshore on Denman Island that has been privatized, cleared, and
netted over for clam culture with no evidence of compensatory habitat replacement or
mitigation to realize that the same rules do not apply to all.
It is evident that senior politicians and beurocrats choose to ignore many of the
requirements of the acts and regulations they are mandated to enforce, and that the public
expects. Field personnel have been instructed to “turn a blind eye” or not interfere when
it comes to aquaculture development. This is evidenced in a statement made by a senior
DFO beurocrat in charge of aquaculture development throughout Canada who states:
“The dawn of the new millennium will be looked upon as the time when mankind went
from fisheries to aquaculture”. (Yves Bastien, Commissioner for Aquaculture
Development). This sentiment is hardly in keeping with the new DFO Wild Salmon
Policy that implies protection of the wild salmon resource above all!
New federal regulations will likely require any activity that may impact fish habitat
(including simple stream restoration projects) to be subjected to screening under the
Canadian Environmental Assessment Act (CEAA review). One can only wonder if the
same requirements will apply to the salmon farming industry.
Mr. Commissioner, there is no point in reviewing the SAR recommendations or the
various federal and provincial statutes that are designed to protect our natural resource
heritage; you, most certainly, are aware of them and the lack of action or enforcement we
are witnessing. I am not saying there is no place for aquaculture on the BC coast; rather,
I am urging you to recommend a precautionary approach. The burden of proof lies with
the industry and those politicians who support it all costs to the environment and without
respect for Canadian law; we must be absolutely certain that the protection of our natural
resources comes first and foremost – development can only proceed if that protection is
not compromised.