Document 15294854

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The British Columbia Government is in the process of the de-staffing and cutting back on the programs and services it delivers

( http://vancouver.cbc.ca/template/servlet/View?filename=bc_sever020220 ) ( http://www.gov.bc.ca/prem/popt/corereview ), including basic environmental protection due to lack of capacity and funding programs. Simultaneously it has been courting industry and business development within this province.

The province ( http://www.bcbudget.gov.bc.ca

) calls it a “ structural fiscal imbalance

” and plans to:

 “

Reduce the regulatory burden

 “

Encourage a greater private-sector role in providing public infrastructure and services through public-private partnerships and alternative service delivery models”

 “

Foster growth in other sectors, including agriculture and aquaculture, as well as film and television production and new media

In fact, the province says that Ministry of Water, Land and Air Protection will have fewer staff and resources directed to:

Permitting of low- and medium-risk pollution sources (protection will be addressed through codes of practice and other authorization tools).

Directly protecting habitat and fish and wildlife species where risks are relatively low.

One of the main reasons the British Columbia government is in fiscal restraint, is due to the softwood lumber dispute, and the associated high punitive import penalties applied to BC wood products by the US which has all but shut-down the forest industry in BC. British Columbia gets much of its provincial budget through stumpage rates, employment in the forestry sector, and corporate forestry taxes. It is both ironic and sad that there is also a North American Free Trade agreement between the two countries.

The combination of reductions in crucial provincial government services combined with the development of certain key resource industries leaves a large and urgent gap in information and associated breach of provincial responsibility. Punitive import duties have had the unexpected (or possibly expected) result of lowering environmental standards, assessment and mitigation abilities in

British Columbia.

I am specifically referring to the impending development of the aquaculture industry here on the North Coast, without having any baseline with which to adequately assess site placement and long term impacts. Additionally, there are similar concerns surrounding the potential lifting of the oil and gas moratorium and associated development

( http://vancouver.cbc.ca/template/servlet/View?filename=bc_offshore020301 ). Both industries have the potential to impact fisheries resources on a regional and international scale. We are close to the Alaskan border, here. I am sure they too are concerned ( http://www.pewoceans.org/articles/2001/07/30/pr_18839.asp

)

( http://www.senate.gov/~murkowski/releases107/02-19-02-2.html

) (

( http://www.gov.state.ak.us/press/02021.html

http://www.state.ak.us/adfg/geninfo/special/AS/docs/graham_letter.pdf

)

)

( http://www.seacc.org/PressReleases/FishFarms.htm

).( http://seattletimes.nwsource.com/html/localnews/134398565_fishfarms01m.html

)

( http://www.seacc.org/PressReleases/FishFarms.htm

) ( http://www.state.ak.us/adfg/geninfo/special/AS/docs/AS_white2002.pdf

)

( http://www.state.ak.us/adfg/geninfo/special/AS/docs/AS_workshop.pdf

)

I am a watershed/fisheries biologist with many years experience in both here on the North Coast and in other parts of Canada. I have also worked the aquaculture industry and am keenly aware of both its potential and its risks. I am less familiar with the oil and gas industry however; a similar baseline also needs to be developed for the same reasons.

The potential lifting of the oil and gas moratorium has received far more media attention then the impending arrival of Atlantic net-cage aquaculture development here on the North Coast. In reality, aquaculture could arrive as early as this summer, and probably sometime with in the next year and a half

( http://vancouver.cbc.ca/template/servlet/View?r=762145432&filename=bc_fish020131 ).

This has not received adequate media coverage to date. It has been eclipsed by news on health and educational cut-backs. It is equally as important news, but more directly affects rural and coastal peoples. Industry is now advertising for entrance-level jobs for their sites on this coast for this spring/summer in the Band Office of their First Nation partner, and not the general media. I guess someone has been making back-room deals with the premier and the government. It’s happening way faster than I even thought it would.

Check out: http://www.fis.com/fis/worldnews/worldnews.asp?l=e&country=35&monthyear=2-2002&day=&id=944&ndb=1

Aquaculture Development in BC, Baseline Necessity and Associated Politics and Legal Issues Page 1

To give you some background on the recent developments within the pending arrival of the net-cage Atlantic salmon aquaculture industry here on the North Coast:

For the past 4-5 years, Marine Harvest Canada has been working with the community of Kitasoo/Klemtu on aquaculture development there. They’ve had net-pens there for at least 4 years, and installed a processing plant in

Kitasoo. About 90% of the employment in that village is related to aquaculture, now (contact Percy Starr or Larry

Greiba). Environmental concerns aside, the community has benefited from the development. Marine Harvest Canada is one of the most responsible players in the industry in BC, and made substantial efforts to include Kitasoo members and perform environmentally responsible. However, they too, have had problems with IHN virus as of late. They are now working with the Haisla in Kitamat to secure agreements (if they haven’t already), and are the ones finishing the

6.5 million $ Wolf Creek hatchery in Port Edward, next to Prince Rupert. They have 2+ million fish to go into the waters by this coming October.

Well, where does that leave us?

I think we should support all coastal communities in their attempts to provide employment for their people. However, I do not believe that this should come at the expense of irreparable long-term damage to the resource and environment. We need to riskmanage before industry arrives, at the barest minimum.

Wild salmon have been the mainstay of aboriginal peoples for thousands of years here on the coast and even inland. We do not have even the most rudimentary baseline with which to adequately access site placement (largely a provincial responsibility) or even perform the required coastal planning processes. Additionally, the area where the industry wishes to locate here on the

North Coast is also within the food fishing areas of the Kitkatla First Nation. The large commercial fishing sector here is also very interested in the development of Atlantic salmon aquaculture here, and could potentially be negatively affected.

I am personally committed and currently working towards the resolution of these issues. There is broad and considerable support towards the development of a baseline and related concerns towards the development of the aquaculture industry within the larger scientific community). I am definitely not alone in my concerns. Check:

( http://www.parl.gc.ca/37/1/parlbus/commbus/senate/com-E/fish-e/rep-e/repintjun01part1-e.htm#ISSUES%20RAISED )

( http://www.oag-bvg.gc.ca/domino/reports.nsf/html/ch9728e.html

)

( http://www.leggattinquiry.com/Report/InquiryReport.asp

)( http://www.grida.no/geo2000/english/0100.htm

)

( http://www.georgiastrait.org/Articles2002/newsfeb1.htm

) ( http://www.capecod.net/ccp ) ( http://www.mar.dfo-mpo.gc.ca/science/mesd/he/eim/ ).

There are 2 basic types of potential impacts from net-cage aquaculture: local and regional.

Local impacts include both benthic impacts and potential conflicts with local stocks ( i.e

. resident fish, crustaceans, bivalves, and echinoderms). Local issues can be dealt with by proper site assessments beforehand. The provincial government has some

“guidelines” (not enforceable rules) for site applicants that may or may not be sufficient. These can be dealt with through the public review process, if it is given any legitimate status of veto over applications (which remain yet to be seen).

Regional impacts, which may be the more critical impacts over the long term, include potential negative interactions between migrating stocks (esp. wild salmon and herring) and the net-pen fish. To date, we have absolutely no database on the North

Coast with which to assess these risks. I am very concerned about this.

The most obvious and potentially threatening regional impacts include the potential for impacts to the vulnerable early-life stages of wild salmon stocks ( i.e.

smolts) migrating through these sites on their way to the ocean ( http://www.mar.dfompo.gc.ca/science/rap/internet/Home.htm

) ( http://www.ecoserve.ie/projects/sealice/ )( http://www.oregonstate.edu/dept/salmon/ ).

Check-out: http://www.watershed-watch.org/

This has been the experience of Norway ( http://www.naturvern.no/english/salmon.html

), Scotland

( http://www.sepa.org.uk/guidance/fishfarmmanual/manual.asp

) ( http://www.wwf.org.uk/filelibrary/pdf/bitterharvest.pdf

)

( http://www.foe-scotland.org.uk/nation/fish_report_summary.html

), Ireland

( http://www.fis.com/fis/worldnews/worldnews.asp?monthyear=2-2002&day=20&id=1181&l=e&country=&special=&ndb=1 )

( http://www.marine.ie/library/publications.html-ssiThe ), Massachusetts ( http://www.state.ma.us/czm/aquatoc.htm

), and New

Brunswick ( http://www.asf.ca/ ). Alexandra Morton of Alert Bay (an independent whale researcher, (250) 949-1664, wildorca@island.net

) has noted similar negative effects on pink smolts in the Broughton Archipelago between Vancouver Island and the mainland in British Columbia, where Stolt Sea Farms has a large number of net-cage sites. Her results are currently being disputed by the Federal Department of Fisheries and Oceans (DFO). Conversely, DFO results from a later study are similarly under dispute as to timing and methodology ( http://www.georgiastrait.org/Newsletters/news0111-15.htm

).

Aquaculture Development in BC, Baseline Necessity and Associated Politics and Legal Issues Page 2

We currently have no database on “pristine” conditions to compare, and we will soon lose this opportunity here on the North

Coast. Industry has already completed its site assessments for most of the sites on the North Coast, and soon will be submitting applications to the provincial government (if they haven’t already). Once these site applications are open for public review and comment, these sites can be independently checked for potential benthic impacts.

We desperately need to provide a baseline on potential, regional interactions between net-cage aquaculture fish and migrating wild fish stocks in the next year or so (industry will arrive here between ½-11/2 years). There appears to be exceeding limited funding with which to perform this work. There are issues around duplication of government responsibilities in conjunction with current government fiscal restraints, which preclude a one stop shopping. Also nobody wants to be the first up to bat, because it may cost money out of their budget. It will be highly unlikely that any level of government will be able to release funds (even if it was committed) in time for the smolts migration this spring.

To state the obvious; the potential risks include:

Risk of disease and parasite transfer from netcage fish to wild fish, or from wild fish to netcage fish

( http://vancouver.cbc.ca/template/servlet/View?filename=bc_fish020215 )( http://www.state.ma.us/czm/wpfshlth.htm

),

Disease and parasite amplification due to poor husbandry practices in combination with poor siting

( http://www.registerguard.com/news/20020209/2b.wst.killsalmon.0209.html

),

Local nutrient loading (organic carbon, organic nitrogen, and soluble nitrogenous, compounds) from excess feed and faecal material, whose effects generally do not extend far past 300m in well suited sites with adequate currents and flushing and over softer substrates,

Potential negative interactions between local, freshwater resident salmon stocks (esp. steelhead, and possibly coho and chinook) where escaped aquacultured salmon have established self-perpetuating populations in adjacent watersheds

(John Volpe http://www.ualberta.ca/FOLIO/0102/1019/ http://www.tidepool.org/features/salmon.volpe.cfm

has done work on this issue on Vancouver Island on interactions between Atlantics and steelhead, and New Brunswick [Atlantic

Salmon Federation: http://www.asf.ca/ ] is currently battling the same issue between aquacultured and native stocks of

Atlantic salmon),

Death and entanglement of marine mammals and birds,

Loss of anchorages and traditional harvesting areas,

Visual impacts,

Impact on wild salmon prices and the commercial fishery,

Negative interactions between the use of chemicals to control sea lice on net-cage fish and adjacent crustacean stocks

(i.e. prawns, crabs, etc.), and

Potential antibiotic resistance and residues in sediments and benthic fauna due to excessive or inappropriate use of antibiotics and other chemicals.

I find it also interesting that on the DFO Pacific website ( http://www-comm.pac.dfompo.gc.ca/english/publications/factsheets/aquaculture/atlanticsalmon.htm

) DFO states that “

There have been attempts to stock

Atlantic salmon around the world and to date no anadromous or sea run populations have been established

”. It is also interesting that the BC Salmon Farmers Association web page

(http://www.salmonfarmers.org/network/Taking%20Care_atlantic.html) similarly states: “

There is no evidence, however, that escaped Atlantic salmon pose a threat to Pacific salmon, or that Atlantic salmon could establish themselves in local waters …”

Both of these web page sites (that supply “official” government and industry views on Atlantic net-cage aquaculture) directly conflict with John Volpes findings (see above).

It is difficult to believe that both web pages are never reviewed and updated with current information. John Volpes findings have been published through a peer-reviewed journal (Can. J. Fish. Aquat. Sci. 58:

197-207 (2001)) since January 04, 2001, and his findings have been known through the media for a year previous.

As well the DFO web page states that “

There is no scientific evidence to support that mature Atlantic salmon could disrupt the life history processes or cause disease transfer to wild Pacific salmon

”. This time DFO is contradicting its own findings, as well as the rest of the world’s experiences. One wonders if this web page is an archive from the pre-1990s. However, one sees references to 2001 on the page.

Certainly this web page does nothing to alleviate the publics’ perception of distrust, collusion and lack of scientific objectivity within the DFO due to the department being simultaneously tasked with the conflicting mandates of aquaculture development

( http://ocad-bcda.gc.ca/egreetings.html

) and fisheries protection ( http://www.dfo-mpo.gc.ca/habitat/Policy/english/index_e.htm

) within the same department.

The Fisheries Act (DFO is charged with administration of this act) prohibits “ harmful alteration, disruption or destruction of fish habitat (s. 35)

”. Fish habitat is defined in the Act as: “ spawning grounds and nursery, rearing, food supply and migration areas on which fish depend

”. Additionally, the Department is stated as being guided by “

a precautionary approach ( http://www.pco-

Aquaculture Development in BC, Baseline Necessity and Associated Politics and Legal Issues Page 3

bcp.gc.ca/raoics-srdc/default.asp?Language=E&Page=Precaution&Sub=Pamphlet ) ( http://www.dfait-maeci.gc.ca/tnanac/booklet-e.asp

) and risk analysis, recognizing the limitations of our understanding of oceans related sciences

”. It should encourage, or perhaps even oblige, decision-makers to consider the potential for harmful effects of activities on the environment before they approve those activities. How can we even think about “risk management” without an adequate baseline?

Within the provincial website on salmon aquaculture

( http://www.eao.gov.bc.ca/PROJECT/AQUACULT/SALMON/Report/final/vol1/V1chp10.htm

) there are comments on legal liabilities: “

If there were to be a major disease outbreak in wild stocks, it would likely be difficult to definitively say whether or not that the disease outbreak was caused by salmon aquaculture. The tools to accurately trace a disease in the open aquatic environment to its place of origin are limited although they will expand with the implementation of recommendations in this report regarding fish disease surveillance

”.

One could also add that if there is no prior baseline to determine “natural” levels of disease in wild stocks, industry could never be held responsible for any disease catastrophe in adjacent wild stocks, since the aquaculture industries assumed causal effects could not be conclusively proven. We desperately need time and funding to acquire such a baseline. I am currently seeking funding sources and partners.

I do not believe that the provincial government is on solid legal ground while granting new aquaculture tenures. The Supreme

Court of Canada has not yet ruled (or been forced to) on BC's jurisdiction over waters North of Vancouver Island. The discussion revolving around and the potential lifting of the oil and gas moratorium have highlighted this debate. Somebody should examine the option of legal action (i.e. a freeze or injunction) against the British Columbia government in the regards to its jurisdiction over near shore waters and in the granting of new net-cage aquaculture site tenures, in order to provide a breathing room in which to obtain the necessary baseline.

Check-out: http://www.admiraltylaw.com/offshorediscussion.htm#leglaarticles http://www.admiraltylaw.com/OffshoreOil/Caselaw/GeorgiaStraightReference.HTM

http://www.cec.org/pubs_info_resources/law_treat_agree/index.cfm?varlan=english http://dmoz.org/Society/Law/Legal_Information/Admiralty_and_Maritime_Law/ http://vls.law.vill.edu/compass/international/ http://www.greenpeace.org/~intlaw/othcon.html

http://www.oceanlaw.net/guide.htm

http://web.uvic.ca/masc/report.pdf

http://www.sfu.ca/cstudies/science/oilgas/2-BC%20Situation.pdf

http://www.state.ak.us/adfg/geninfo/pubs/afrb/vol2_n2/shelv2n2.pdf

http://www.unece.org/env/eia/ http://www.biodiv.org/

In 1984, The Supreme Court ruled on the

“Georgia Straight Reference ”; a case about the Province of British Columbia's claim to jurisdiction and property rights over the seabed between Vancouver Island and the mainland (particularly Queen Charlotte Strait,

Johnstone Strait, Georgia Strait, and Juan de Fuca Strait). The court found that because these areas were not part of the "Pacific

Ocean", as stated in the colonizing legislation, they were therefore inside the boundaries of the Province and therefore within the jurisdiction and being the property of the Province. The court did NOT rule on the provinces jurisdiction of the waters North of

Vancouver Island, which are still in question as to the province’s jurisdiction.

There are other legal issues also looming ahead. Obviously, with respect to development of industries potentially detrimental to highly migratory fish stocks, there are a number of international agreements that apply that Canada has entered into

( http://pubx.dfait-maeci.gc.ca/A_Branch/AES/Env_commitments.nsf/bysubjectmatter )

( http://cec.org/pubs_info_resources/law_treat_agree/index.cfm?varlan=english )

Aquaculture Development in BC, Baseline Necessity and Associated Politics and Legal Issues Page 4

These international agreements include:

Convention On Biological Diversity ( http://www.biodiv.org

)

RIO Declaration On Environment And Development ( http://sedac.ciesin.org/pidb/texts/rio.declaration.1992.html

)

Convention On Environmental Impact Assessment In A Transboundary Context ( http://www.unece.org/env/eia/ )

North American Agreement On Environmental Cooperation

FAO Code of Conduct for Responsible Fisheries ( http://www.fao.org/fi/agreem/codecond/ficonde.asp#9 )

Agreement For The Implementation Of The Provisions Of The United Nations Convention On The Law Of The Sea Of

10 December 1982 Relating To The Conservation And Management Of Straddling Fish Stocks And Highly Migratory

Fish Stocks (Draft)

Convention For The Conservation Of Anadromous Stocks In The North Pacific Ocean ( http://www.npafc.org

)

Pacific Salmon Treaty ( http://www.ncr.dfo.ca/pst-tsp/agree/toc_e.htm

)

Agreement Between Canada And The United States On Fisheries Enforcement

( http://www.cec.org/infobases/agreements/SourceFiles/F12-AGREEMENT.HTML

)

The RIO Declaration on Environment and Development (Rio de Janeiro, 3-14 June 1992), for example, has relevant sections

( http://www.unep.org/Documents/Default.asp?DocumentID=78&ArticleID=1163 ) that state:

Principle 2:

States have, in accordance with the Charter of the United Nations and the principles of international law, the sovereign right to exploit their own resources pursuant to their own environmental and developmental policies, and the responsibility to ensure that activities within their jurisdiction or control do not cause damage to the environment of other States or of areas beyond the limits of national jurisdiction

.”

Principle 10:

Environmental issues are best handled with the participation of all concerned citizens, at the relevant level. At the national level, each individual shall have appropriate access to information concerning the environment that is held by public authorities, including information on hazardous materials and activities in their communities, and the opportunity to participate in decisionmaking processes. States shall facilitate and encourage public awareness and participation by making information widely available. Effective access to judicial and administrative proceedings, including redress and remedy, shall be provided

.”

Principle 13:

“States shall develop national law regarding liability and compensation for the victims of pollution and other environmental damage. States shall also cooperate in an expeditious and more determined manner to develop further international law regarding liability and compensation for adverse effects of environmental damage caused by activities within their jurisdiction or control to areas beyond their jurisdiction”.

Principle 15:

“In order to protect the environment, the precautionary approach shall be widely applied by States according to their capabilities. Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation.”

Principle 19:

States shall provide prior and timely notification and relevant information to potentially affected States on activities that may have a significant adverse transboundary environmental effect and shall consult with those States at an early stage and in good faith

.”

Agenda 21 - Chapter 40 of the United Nations Division for Sustainable Development states:

40.2. While considerable data already exist, as the various sectoral chapters of Agenda 21 indicate, more and different types of data need to be collected, at the local, provincial, national and international levels, indicating the status and trends of the planet's ecosystem, natural resource, pollution and socio-economic variables. The gap in the availability, quality, coherence, standardization and accessibility of data between the developed and the developing world has been increasing, seriously impairing the capacities of countries to make informed decisions concerning environment and development .

Aquaculture Development in BC, Baseline Necessity and Associated Politics and Legal Issues Page 5

The United Nations Convention On The Environmental Impact Assessment In A Transboundary Context (there is also a Draft

North American Agreement on Transboundary Environmental Impact Assessment), Article 2, General Provisions states:

3. The Party of origin shall ensure that in accordance with the provisions of this Convention an environmental impact assessment is undertaken prior to a decision to authorize or undertake a proposed activity listed in Appendix I that is likely to cause a significant adverse transboundary impact.

4. The Party of origin shall, consistent with the provisions of this Convention, ensure that affected Parties are notified of a proposed activity listed in Appendix I that is likely to cause a significant adverse transboundary impact.

This is why I am contacting you.

Someone should examine the option of legal action (i.e. a freeze) against the British Columbia government in the regards to its jurisdiction over near shore waters and in the granting of new netcage aquaculture site tenures, in order to provide a breathing room in which to obtain the necessary baseline.

The long term risks associated with improper site placement are so huge with large potential for legal action. This scenario may yet happen, but only after your irreparable environmental damage has occurred due to poor site selection. I wish to avoid this scenario at all costs.

I'm concerned.

Warmest Regards,

Dave Rolston, BSc.

Also check:

Pacific Northwest Salmon Recovery Efforts and the Pacific Salmon Treaty: http://www.ncr.dfo.ca/communic/Reports/shaffe_e.htm#PRÉCIS

Gulf of Maine reports: http://gulfofmaine.org/council/aquaculture.shtml

Suzuki reports: http://www.davidsuzuki.org/Publications/Aquaculture_Reports/default.asp

SFU reports: http://www.sfu.ca/cstudies/science/salmon/wild_salmon.pdf

Pew reports: http://www.pewoceans.org/reports/137PEWAquacultureF.pdf

Gyrodactylus salaris page: http://alun.uio.no/gyrodactylus/

Alaska Fisheries: http://www.cf.adfg.state.ak.us/region1/finfish/salmon/salmhom1.htm

DFO acts: http://www.ncr.dfo.ca/communic/policy/dnload_e.htm

PBS Nanaimo: http://www-sci.pac.dfo-mpo.gc.ca/ioslib/pbslib-e.htm

Rivershed Society of BC: http://www.fraser2000.com/

Rainforest publications: http://www.ancientrainforest.org/reports/ff_report_disease.pdf

http://www.ancientrainforest.org/reports/nightmare_report.html

Sierra Legal Defense Fund: http://www.sierralegal.org/

UK fish diseases: http://www.stir.ac.uk/Departments/NaturalSciences/Aquaculture/fishing/fish/fish.htm

The Canadian Senates report: http://www.parl.gc.ca/37/1/parlbus/commbus/senate/com-E/fish-e/rep-e/repintjun01part1-e.htm#ISSUES%20RAISED

BC Governments site: http://www.bcfisheries.gov.bc.ca/com/aqua/SAPF_Implementation_update.html

North American Site: http://www.naaec.gc.ca/english/naaec/naaec.htm

UBC Fisheries Centre: http://www.fisheries.ubc.ca/

West Coast Environmental Law: http://www.wcel.org/

Coastal management: http://www.coastalmanagement.com/research.html

NOAA Fisheries: http://www.nmfs.noaa.gov/aquaculture.htm

DFO Fish Habitat Policy: http://www.dfo-mpo.gc.ca/habitat/pa_regulatory_e.htm

DFO Maritimes: http://www.mar.dfo-mpo.gc.ca/science/review/1996/Page/Page%20e.html

DFO Aquaculture: http://www-sci.pac.dfo-mpo.gc.ca/aqua/pages/aq/aq82.pdf

DFO/BC Salmonwatch: http://www-sci.pac.dfo-mpo.gc.ca/aqua/pages/atlsalm.htm

Aquaculture Development in BC, Baseline Necessity and Associated Politics and Legal Issues Page 6

Potential Legal Assistance& Political Support:

AIDA - Interamerican Association for Environmental Defense c/o Earthjustice Legal Defense Fund

180 Montgomery St., Suite 1725

San Francisco, CA 94104 USA

Fax 415-627-6749 aceder@aida2.org

http://www.aida2.org/english/index.php

Alaska Center for the Environment

807 G St. Suite 100

Anchorage, AK 99501

Ph: (907) 274-3665

Fax: (907) 274-8733 michell@pobox.alaska.net

http://www.akcenter.org/

Alaska Rainforest Campaign (ARC)

National Office

122 C St. NW suite 240

Washington, DC 20001

Ph:(202) 544-0475

Fax: (202) 544-5197

Michael Finkelstein , Campaign Manager (Ph: 202-550-5613) mfalaska@aol.com

Chris Soderstrom , Conservation Associate chris@akrain.org

Brian McNitt , Conservation Director

Washington, D.C. 20001

(202) 508-3860 (Phone); (202) 508-3843 (Fax) cso@sso.or

g http://www.sso.org/cso/

Commissioner of Environment and Sustainable Development

Office of the Auditor General of Canada and the Commissioner of the Environment and Sustainable

Development

Attention: Petitions

240 Sparks Street

Ottawa, Ontario

K1A 0G6

Telephone: (613) 995-3708

Fax: (613) 941-8286

Email: petitions@oag-bvg.gc.ca

http://www.oagbvg.gc.ca/domino/cesd_cedd.nsf/html/menu7_e.html

Defenders of Wildlife

National Headquarters

1101 14th Street, NW #1400

Washington, DC 20005

Phone: (202) 682-9400

E-Mail: info@defenders.org http://www.defenders.org/ bmcnitt@akrain.org

Alaska Rainforest Campaign Alaska Office

201 Lincoln Street, #1

Sitka, AK 99835

Ph: (907) 747-8292

Fax: (907) 747-8873

Michelle Wilson , Rainforest Grassroots Organizer michell@pobox.alaska.net

info@akrain.org

http://www.akrain.org/about_us.asp

Alaska Wilderness League

320 Fourth Street, NE

Washington, DC 20002

Ph: (202) 544-5205

Fax: (202) 544-5197

Cindy Shogan , Executive Director cindys@boo.net

http://www.alaskawild.org/

American Society of International Law

Wil Burns, Chair, ASIL Wildlife Interest Group c/o Journal of International Wildlife Law & Policy

1702 Arlington Blvd.

El Cerrito, CA 94530 USA

650.281.9126

801.838.4710 asilwildlife@pacbell.net

http://eelink.net/~asilwildlife/index.shtml

A Territory Resource (ATR)

603 Stewart Street, Suite 1007

Seattle, WA 98101-1229 tel. 206/624-4081 fax. 206/382-2640 website@atrfoundation.org

http://www.atrfoundation.org/

Coastal States Organization

Hall of the States, Suite 322

444 North Capitol Street, NW

Environet

Editorial Department

Chuck Bernstein, Director

(202) 887 - 8836 cbernstein@environet.org

David King, Director

(202) 887 - 8838 dking@environet.org http://environet.policy.net/

EnviroTrust

Tidepool

Ed Hunt, Editor in Chief editor@tidepool.org http://www.tidepool.org/

Environmental Defense

National Headquarters

257 Park Avenue South

New York, NY 10010

Telephone: (212) 505-2100

Fax: (212) 505-2375 webmaster@environmentaldefense.org http://www.environmentaldefense.org/home.cfm

Environmental News Network Inc.

2020 Milvia

Suite 411

Berkeley, CA 94704

Phone: (510) 644-3661

Fax: (208) 475-7986

Email: mgt@enn.com http://www.enn.com/

Friends of the Earth –

1025 Vermont Ave. NW –

Washington, DC

20005 , USA

Tel: 1-877-843-8687 or 202-783-7400 –

Fax: 202-783-0444 – email: foe@foe.org

Aquaculture Development in BC, Baseline Necessity and Associated Politics and Legal Issues Page 7

http://www.foe.org/

Giaschi & Margolis,

Barristers & Solicitors

401-815 Hornby St.

Vancouver, BC,

V6Z 2E6,

(tel.) 604 681-2866

(fax) 604 681-4260 giaschi@admiraltylaw.com

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Telephone: (212) 727-2700

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General Information: info@oceana.org

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OmCED

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Development omced@ecouncil.ac.cr http://www.omced.org/

Commission for Environmental Cooperation

393, rue St-Jacques Ouest

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H2Y 1N9 Canada

Tel: (514) 350-4300

Fax: (514) 350-4314 info@ccemtl.org

Mr. Wiecher Schrage, Secretary

Convention on Environmental Impact Assessment in a

Transboundary Context

Office: 407, Palais des Nations

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Phone: +41 22 917 2448

Fax: +41 22 917 0107 or 917 0634

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Citizen Submissions on Enforcement Matters http://www.cec.org/citizen/index.cfm?varlan=english

Raincoast Victoria Office:

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Rainforest Action Network

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Tel: 415-398-4404

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Email: rainforest@ran.org http://www.saveourenvironment.org/index.asp

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Phone 415-977-5500

Fax 415-977-5799 information@sierraclub.org environmental911@sierraclub.org http://www.sierraclub.org/contact.asp

Sierra Club of BC

576 Johnson St., Victoria, BC V8W 1M3

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phone: 250.386.5255 fax: 250.386.4453 e-mail: info@sierraclubbc.org sharon@sierraclubbc.org http://www.sierraclub.ca/bc/index.html

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Main Office

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T. "Buck" Suzuki Environmental Foundation

160-111 Victoria Drive,

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Phone: (604) 255-8819

Fax: (604) 255-3162

Email: bucksuzuki@ufawu.org

http://www.sfsfishfirst.org/tbs.htm

Transboundary Freshwater Dispute Database http://terra.geo.orst.edu/users/tfdd/

West Coast Environmental Law Research Foundation

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Email: info@wcel.org

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Western Canada Wilderness Committee

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Canada V6B 2K7

Toll Free: 1.800.661.WILD

Phone 604.683.8220

Fax 604.683.8229

Email info@wildernesscommittee.org

http://www.wildernesscommittee.org/

Conservation Action Network

World Wildlife Fund actionquestions@takeaction.worldwildlife.org

http://takeaction.worldwildlife.org/contact.asp

The Wilderness Society

Alaska Regional Office

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Nicole Evans , Deputy Regional Director nicole_whittington-evans@tws.org

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900 Seventeenth Street, NW

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Ph: (202) 429-2662

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UN Oceans and Law of the Seas http://www.un.org/Depts/los/index.htm

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Gyrodactylus salaris Malmberg. Aquaculture 98: 303-310.

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The impact of escaped farmed salmon on wild populations may have potentially negative genetic and ecological effects. There is widespread evidence that farmed salmon interact with wild salmon. The use of sterile fish in culture has been proposed as a means of eliminating genetic interaction and minimising the ecological effect of farmed salmon. In this study, the migration behaviour of groups of triploid salmon was investigated through the controlled release of microtagged triploid and diploid stocks on the western coast of

Ireland. Mixed-sex and all-female stocks of ranched grilse origin were triploidised using hydrostatic pressure. Smolts were ranched from the hatchery of origin and two groups of post-smolts were released from cages in a marine site. The return of adult salmon from these experimental release groups to coastal and freshwater capture sites was monitored as part of the Irish national coded wire tag recovery programme. The return of triploid salmon from each of the release groups, both to the coast and to fresh water, was significantly reduced compared to diploid salmon. The highest percentage return to fresh water (2.25%) was in the ranched mixed-sex diploid group. In contrast, no salmon from the cage release groups returned to the hatchery location on the Burrishoole river system and recoveries in other freshwater systems were low

(<0.01%). The return of a small number of hormonally deficient, sterile triploid female fish suggests that migration to fresh water is not inextricably linked with reproduction. The substantially reduced return of hormonally competent triploid males to the coast and to fresh water indicates that other factors may have an effect on their marine survival. The reduced return of triploid salmon to the coast and to fresh water, together with their inability to produce viable offspring, demonstrates the potential for triploidy as a means of eliminating genetic interactions between cultured and wild populations, and of reducing the ecological impact of escaped farmed fish.

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