Brief by the Atlantic Salmon Federation to. Standing Senate Committee on Fisheries and Oceans. On the Future of Aquaculture.

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1 Brief by the Atlantic Salmon Federation to Standing Senate Committee on Fisheries and Oceans On the Future of Aquaculture November, 2014 The Atlantic Salmon Federation (ASF) is pleased to present to the Senate Committee on the Future of Aquaculture to provide an overview of our interest in developing an environmentally- sustainable salmon aquaculture industry to protect wild Atlantic salmon and their environment and our role in researching the interactions between wild and farmed salmon, making the public and government aware of these threats, and, most importantly, researching and developing solutions to the problems. Atlantic Salmon Federation (ASF) ASF is an international non- profit organization, headquartered in St. Andrews NB, with regional offices in Quebec, New Brunswick, Nova Scotia, PEI and Newfoundland and Labrador. We also have offices in northeastern United States. We are dedicated to the conservation, protection and restoration of wild Atlantic salmon and the ecosystems on which their well- being and survival depend, a mission that the organization has carried out for 65 years. We work closely with our seven Regional Councils and 111 volunteer river organizations in eastern Canada and northeastern United States on a range of programs that involve research, restoring salmon habitat, controlling harvest, and advocacy and public awareness. Our network covers the freshwater range of wild Atlantic salmon in North America. Threats from Open Net Pen Aquaculture A major threat to wild Atlantic salmon and their environment is open- pen salmon farming and it is an issue to which we devote significant resources, time and energy. Escapes pose the biggest risk of all the industry impacts on wild Atlantic salmon. Large- scale escapes are frequent occurrences in open- pen fish farming and can happen through routine handling, large- scale episodic events such as storms, structural failure and predation. There is potential for escapees to enter rivers, and breed with wild salmon causing reduced genetic diversity and fitness in wild populations. In addition, wild salmon are then faced with a new competitor for freshwater resources. The prevalence of disease and parasites increases with the high density of fish in pens that is common to salmon aquaculture and spreads to wild fish, subsequently threatening the persistence of wild populations. Fish in open- pen salmon aquaculture can contract diseases from wild fish. However farmed fish in sea cage operations can magnify the infection within and between cage sites, in turn contributing to the spread, intensity and maintenance of these diseases in wild populations. Infectious Salmon Anaemia (ISA) is one of the prevalent diseases found in the east coast salmon aquaculture industry. There is no treatment, and outbreaks in the aquaculture industry of eastern Canada have been numerous. Since 1996, at least $135 million has been paid by governments to compensate industry for having to eradicate fish infected with ISA. 1

2 As few as 8 sea lice can kill an Atlantic salmon smolt going to sea. The dense crowding in salmon farms encourages a population explosion of sea lice, which must be treated with chemicals. Sea lice have become highly resistant to the treatment of choice, SLICE, which can be delivered in feed. Industry wishes to have the ability to use more toxic chemicals that require well- boats for bathing the farmed salmon. These have the potential to kill crustaceans such as lobster and krill, an important food for many fish, including salmon. The desperation of the aquaculture industry to control sea lice and the deadliness of the chemicals that they may use were obvious in an incident several years ago that resulted in charges being laid. In the spring of 2013, Cooke Aquaculture was found guilty of two charges by Environment Canada in connection with the deaths of hundreds of lobster in the Bay of Fundy from using an illegal pesticide to control sea lice. That the open net pen industry is seeking to operate outside the confines of the Fisheries Act and is lobbying hard for an Aquaculture Act is well- documented in the media and in the industry s positions to government. This would allow the industry to operate unencumbered by laws that are meant to protect wild fish and their habitat. The aquaculture activities regulations, which just went through public comment are a telling example of this. These regulations deal with facilitating the usage of pesticides for sea lice, drugs for disease and depositing excess feed and feces into the ocean. If adopted (despite the many opposing briefs that have been submitted by conservation, fisheries and environmental organizations and First Nations), Environment Canada (the department that was able to charge Cooke Aquaculture with the kill of lobster) will be excluded from the process and the Fisheries Act will no longer apply. ASF advocates for effective regulation and enforcement to deal with impacts on wild Atlantic salmon from open net pen fin fish farming to provincial and federal governments and to international governments at the North Atlantic Salmon Conservation Organization (NASCO) as representatives on the Canadian delegation and as an accredited NGO. We gave input to the aquaculture activities regulations and we hope that this Senate Committee reads carefully the many briefs that were submitted to make sure it gets a full understanding of the concerns. ASF registered our concern with the lack of third party oversight when the industry treats their farmed salmon for sea lice and disease. We provided a series of recommendations relative to the need for industry to alert authorities and the public when the industry has problems in controlling sea lice and disease and when they are treating, and the need for auditing of sites post treatment. We indicated there is need to identify critical marine habitat for wild salmon to avoid impacts on wild salmon from treatments, and a need for a public testing and an approval process for each chemical used, for third party monitoring, and for public publication of sea lice density data. We called for defined criteria to keep industry from operating near lobster pounds, fish and shellfish spawning areas, and in vulnerable wild salmon migration corridors as well as a clear process for removal of sites from areas prone to sea lice outbreaks. ASF also gave input to the expert Doelle- Lahey panel, the two Dalhousie University Law Professors appointed by the Nova Scotia government to carry out its aquaculture regulatory review, who have provided draft recommendations to the Nova Scotia Government. These too are well worth scrutiny by the Senate Committee. After more than a year of community meetings and hearings, the report recommended that protection of wild salmon populations should be listed in the legislative framework 2

3 as one of the criteria to be considered in leasing and licensing decisions, that the regulatory framework should be clear and explicit about the need for appropriate physical separation between marine- based aquaculture and salmon rivers and known salmon migration routes and deal more extensively with the prevention of escapes in a manner that is equally as effective as the Maine system. The report emphasized transparency and separation of the promotion and regulation of aquaculture in departmental mandates, and recommended a system of red, yellow and green zones, depending on the suitability of conditions for salmon farming, including consideration of environmental impacts. The view of the expert panel was that development of closed- containment systems could be a tremendous benefit to Nova Scotia s future in aquaculture, and that the province should establish itself as a leader in the development and deployment of closed- containment systems for salmon aquaculture. ASF believes that Canada should progress towards closed- containment operations to position itself as a leader on the world stage. Canada should recognize the importance of complete separation of fin- fish farming from the environment, and the need for support by government for entrepreneurs who wish to set up to meet the growing demand for fin fish that are grown in an environmentally- sustainable manner in closed- containment facilities. State of Wild Atlantic Salmon Populations North American Atlantic salmon populations have experienced a dramatic decline in the past few decades, from 1.8 million in 1973 to 470,000 in Between 2001 and 2011, in part through efforts of ASF and our affiliated organizations, salmon populations, with the exception of the southern Canadian range, began to recover. However, there has been another serious trend downward since 2012 for many rivers, especially in the southern range. The wild salmon populations of the Bay of Fundy have decreased in number from about 40,000 a year in the 1980s to fewer than 200 in recent years. The salmon populations of the inner Bay of Fundy were listed under the Species at Risk Act (SARA) ten years ago. The populations of the outer Bay of Fundy and the southern uplands region of Nova Scotia have been assessed as endangered by the Committee on the Status of Endangered Wildlife in Canada (COSEWIC) and are being considered for listing under SARA. The populations along the southern coast of Newfoundland have been assessed by COSEWIC as threatened and they too are being considered for listing. All of these areas have substantial open- pen salmon farming operations. In 2012, salmon production in Nova Scotia was 5,900 tonnes and 30,000 tonnes in New Brunswick, according to Statistics Canada. Finfish aquaculture in Newfoundland, primarily salmon production, was 17,000 tonnes. Escapees from these operations can and do outnumber the endangered and threatened wild salmon populations of rivers in their vicinity. In the 1980s, when salmon populations amounted to about 40,000 a year in the inner Bay of Fundy, there was a vibrant recreational fishery that provided substantial economic benefits to Nova Scotia and New Brunswick. These rivers are now closed to recreational salmon fishing. In southern Newfoundland, the economic benefits are being eroded, along with the salmon runs to such rivers as the Conne River. The returns to this river were less than half last year s and show a frightening decrease in long- term averages since This river is on the south coast in Newfoundland s salmon 3

4 farming area and the Conne s wild salmon run has the added stress of potential damage from genetic introgression and sea lice and disease outbreaks in the nearby salmon farming industry. Even today, despite loss of salmon fishing in Bay of Fundy rivers and along the southern coast, the recreational salmon fishery is worth $4.4 million to Nova Scotia s GDP, $40 million to New Brunswick s GDP, and $ 24.5 million to Newfoundland and Labrador s GDP, according to a report by Gardner Pinfold Economists. These benefits would, of course, increase as salmon populations are restored. The recreational salmon fishery benefits rural communities, where unemployment is high. Harnessing increased economic benefits that come from the salmon recreational fishery in the Bay of Fundy, coastal Nova Scotia and southern Newfoundland would require stopping the negative impacts of this industry on these already vulnerable salmon populations. Peer- reviewed Scientific Reports The report by COSEWIC noted that growth of the Canadian aquaculture industry has coincided with a severe decline in wild populations in the nearby rivers in the Bay of Fundy. COSEWIC also found that, In North America, farm- origin salmon have been reported in 87% of the rivers investigated within 300 km of aquaculture sites. Salmon farming, which began in the late 70s in the Bay of Fundy, was identified as a key threat to the salmon populations of the Magaguadavic River in the Outer Bay. The Magaguadavic River in southwest New Brunswick is one of very few locations in North America where scientists can detect farmed salmon escapees and monitor their impacts on wild Atlantic salmon. ASF has conducted research on this North American index river for interactions between wild and farmed salmon since The Magaguadavic is situated at the centre of New Brunswick s open net pen salmon farming industry, and also has several hatcheries that leak juvenile farmed salmon into the river. A fishway on this river enables identification of every salmon entering the river. ASF s biologists report that farmed escapees entering the river have outnumbered annual wild Atlantic salmonreturns in all but two years since In the 1980s, the annual run averaged 800 wild salmon. By 1992, the run was reduced to 293 and by 2014, despite an active restoration program, to eleven. Genetic characteristics of salmon from aquaculture cages have been altered in controlled programs to provide domesticated strains of fish. This results in adverse genetic consequences for wild Atlantic salmon that have been documented in numerous scientific reports. Specific to the Magaguadavic River, scientific studies have documented successful spawning of farmed salmon, interbreeding with wild stocks and fitness reduction in wild salmon as a result of the interbreeding (Bourret, O Reilly, Carr, Berg, and Bernatches). Numerous other scientific reports in Europe and North America have documented that interbreeding can have genetic effects that threaten the reproductive capability and recovery potential of wild populations because the offspring are less fit to survive in the wild. In 2008, Dalhousie University researchers, Jennifer Ford and Ransom Myers, confirmed that, globally, there is a much steeper decline in numbers of wild salmon living in rivers adjacent to the salmon farming industry, for some populations by as much as 50%. The Royal Society of Canada Expert Panel on Sustaining Canada s Marine Biodiversity responded to the challenges posed by aquaculture with the following: 4

5 There is reason to believe that the harm posed by pathogens might be greater than currently perceived. The lack of transparency in public reporting of diseases at aquaculture farms has hindered meaningful, constructive and respectful debate. And After a decade of study it is generally accepted that open- pen salmon farms can cause infections of the salmon louse and contribute to infection in native salmonids, and that these infections can increase juvenile salmonid mortality rates directly and probably indirectly through increased predation. The constant response of government and industry to our citing of numerous peer- reviewed research papers that have found salmon farming poses a risk to wild salmon populations is that they have research that says just the opposite. We have asked to see this peer- reviewed research. So far, we have seen nothing. We can only conclude that the driving force and lack of precaution in investment in open net pen salmon aquaculture is profit for the industry. The open net pen salmon aquaculture industry is implicated globally in widespread negative environmental impacts. The naysayers in the aquaculture industry say it would be too costly to move the industry to land. Whenever there is a large amount of money to be made, there will be manufactured arguments for maintaining the status quo and excuses for not moving forward with a new and better technology. Finding Solutions Best Practices The open net- pen salmon aquaculture Industry is held to higher standards in Maine. The only player there, Cooke Aquaculture, has publicly said in the media that they are expanding in Canada, rather than Maine, because the State better controls the industry s impacts. The United States has officially listed as endangered all wild Atlantic salmon populations in the Gulf of Maine. The salmon aquaculture industry came crashing down in Maine a few years ago because of fish disease, the pullout of companies using Norwegian strains of salmon following the endangered species listing for wild salmon, and a federal judge s ruling that several salmon operations violated the Clean Water Act. New practices that focus on escape prevention, reporting all salmon escapes, marking of all fish to trace escapees back to sites, and third party audits were developed in consultation with government agencies and conservation organizations. Their implementation has meant better control and tracking of escapes, and control of parasites and disease. Since then, the only escapees that have been detected at Maine s monitoring sites are presumed to be Canadian, based on Maine s genetic monitoring program. In Norway, there is a system of public reporting on sea lice loads and escapes that should be emulated here. In its implementation plan to carry out an agreement reached by Parties to NASCO to counter the threats by salmon aquaculture to wild Atlantic salmon, Canada failed to supply information to gauge progress towards the achievement of the international goals for effective sea lice management and progress towards the achievement of the international goals for ensuring 100% containment. 5

6 The salmon aquaculture industry in eastern Canada is essentially self- regulated. It is important to have effective monitoring and regulation by government that is strictly enforced, with sanctions such as fines and loss of licenses for companies that contravene these laws. For example our Magaguadavic River monitoring detected 91 farmed salmon escapees in 2013, most of them in the fall, indicating significant escapes had taken place in the tens of thousands. Yet there have been no reports by industry to government of any escapes, even though New Brunswick governance has required, since 2010, reporting of escapes of more than 100 salmon. Despite the fact that ASF reported 91 escapes at the fishway in 2013 and brought the conclusion that this large number is indicative of significant escape events to the attention of government, industry and the public, no action has been taken or sanctions imposed. Since industry does not mark its fish, the escapees cannot be identified back to the owner, allowing operators to hide from any responsibility. Nova Scotia s Auditor General expressed concern with the $25 million in assistance approved for Cooke Aquaculture in June He found that there was no security for a $16 million loan included in the aid package, and the net economic benefit to the province is negligible. The funds are not limited to use in Nova Scotia even though the company operates in other jurisdictions. Most of the assistance will be provided before projects are complete and related jobs are created. This identifies and is an example of the folly of government aligning itself too closely with the open- pen aquaculture industry on the promise of employment for its citizens, and to the detriment of other industries, such as tourism and recreational and commercial fishing. It is important to take into account such incentives from government and payouts for ISA compensation when comparing the costs associated with growing salmon in open pens, compared to closed containment. Closed containment systems need more support and funding from government to establish in Canada, at least as much incentive as the open net pen industry receives. Closed containment systems are at an economic disadvantage because much of their cost goes toward creating growing conditions that the ocean provides for free, including the chemical properties and temperature of ocean water, as well as ocean current and tidal action that provides waste dispersion services. In other words, the open- pen industry has the advantage because it is not required to pay for the environmental costs of using the ocean, a public resource, which leads to disease and parasite outbreaks, pollution of the ocean floor, displacement and killing of other sea creatures, and loss of livelihoods that depend on healthy wild populations and their environment. The industry is allowed to operate with minimal cost for leases and no property tax on cage sites. The Ultimate Solution Closed Containment ASF is conducting trial projects in land- based, freshwater closed containment facilities, located in Shepherdstown, West Virginia. Our partner is The Conservation Fund, an American non- profit that has spent 20 years developing closed- containment aquaculture systems to grow trout, perch, and now salmon at its Freshwater Institute there. It is refining water recirculation techniques that continuously 6

7 filter and recycle the water used to grow the fish. This means that it can achieve large- scale fish farming with a small amount of water and release little to no pollution. This opens the door to commercial fish production in areas with limited water resources, separate from wild fish and their environment. The Freshwater Institute and ASF have been involving the aquaculture industry in a series of very well- attended workshops to provide information on the advances in technology and to help industry transition to closed containment. The immediate appeal of closed- containment technologies is for fish farmers who want to market high- value fish raised in a sustainable manner. There is a growing demand for such a product among chefs and consumers, who are aware of the serious environmental impacts of operations that grow salmon in open net pens in the sea. The open- net pen salmon farming industry has said that the economics and energy costs associated with land- based farms are such that the closed- containment model won t work. Companies that are establishing in closed- containment ventures are convinced that it will work and will be, without a doubt, a commercially- viable business model. Recently, three closed- containment salmon farming operations (KUTTERA in BC, Atlantic Sapphire in Denmark, and The Conservation Fund s Freshwater Institute in West Virginia) achieved the top Best- Choice (Green) sustainability ranking by Monterey Bay Aquarium s Seafood Watch program and the Vancouver Aquarium s Ocean Wise program. These three farms are considered to be representative of current practices and, therefore, the third- party assessment and recommendation is applicable globally for additional farms as they develop, unless there is a demonstrable difference in production practices. These programs presently indicate that salmon grown in open net pen operations in the ocean should be avoided. No escapes, no need to use harsh chemicals to treat sea lice or antibiotics to treat disease, no need to compensate for ISA outbreaks, no displacement of other industries such as wild fisheries and tourism, no threat to economic benefits generated by other industries, and a better product all of this reinforces the viability of closed containment. The open- pen industry and government often portray ISA as a disease that occurs naturally and must be expected as part of the business of salmon farming. However, growing in disease- free closed containment facilities circumvents the expense of destruction and compensation, adding to the economic viability. The industry has exaggerated the amount of land, water and energy required in land- based freshwater closed containment facilities. It claims that 8,000 football fields would be required to put the salmon farming operation of New Brunswick and Nova Scotia on land. The research by Freshwater Institute has found that growing 30,000 tonnes of salmon would require only 75 to 150 football fields, including the end zones. When considering carbon footprint, it is important to take into the account the local effects of untreated pollution being discharged from open net pen farms directly into the ocean. Ocean- based open pens do not have discharge limits, effectively placing the burden on the marine environment and other resource users, rather than where it belongs with the farmer. Recommendations: 7

8 1. In areas where open net pen finfish aquaculture is now established, impose a moratorium on expansion or new leases until best practices and standards are implemented and regulations enforced (eg traceability and 3rd party audits which are similar to standards in Maine). 2. Impose a moratorium on any future expansion of open net pen finfish aquaculture to regions where this industry presently does not operate (eg. Chaleur Bay) and restrict future fin fish aquaculture expansion to these regions to land based closed- containment facilities. Best Practices and Regulated High Standards For the present open- net finfish operations, emulate the Nova Scotia government s action to stop issuing new licenses to provide time to develop a regulatory regime that is based on best practices currently undertaken in Maine and Norway and that includes a system of enforcement and repercussions for violations (fines and license suspension). Impose harmonized regulations among Newfoundland, New Brunswick and Nova Scotia on best practices and high standards that are currently undertaken in Maine and Norway: Maine Emulate Maine s containment management system, which became part of Maine s Clean Water Permitting in 2003, resulting in no significant escapes since then: Mandatory Prerequisite Program on site condition for license Implementation of a Hazard Analysis Critical Control Points (HACCP) that identify and provide solutions to causes of escape from hatchery to final harvesting Implementation of regular inspections, including diving Marking of all fish to trace origins from hatchery to net pen to market, allowing escapees to be traced back to owner System of record keeping: o o o o Logging and reporting of all escapes of any size Failure to report and log events later discovered by audit a serious violation All facilities subject to this without warning 3rd party audits paid for by tax on salmon revenues 8

9 Norway Reports on all escapes and sea lice loads accessible to the public Penalty is imposed if escapes not reported (companies have been fined) Improved industry- level technical standards Genetic identification leading to increased accountability from operators Designation of important salmon rivers that are off limits to cage sites (aquaculture free zones) Closed- containment Recognize the social and economic benefit of promoting Canada and its image of healthy oceans in association with closed- containment facilities. Give Canada the opportunity to take the lead in setting the highest standards towards a sustainable, environmentally- friendly farmed salmon product. Provide support by government for entrepreneurs who wish to set up to meet the growing market demand for fin- fish that are grown in closed- containment facilities. Investigate the true costs of open- pen operations, including the costs to the environment because of free access by the industry to oceans and rivers that are important to the social and cultural fabric of all citizens. Itemize and take into account the financial losses of plant closures and in inventory and employment because of disease, parasites and escapes, pollution of the ocean bottom, disease compensation costs, government grants, and losses of the economic benefits of other industries (tourism, recreational and commercial fishing) because of environmental pollution and harm to other species. Recognize that the production costs of open- pen salmon aquaculture and closed containment aquaculture are about equal and that capital costs are higher for closed containment ventures because this industry is controlling all impacts on wild species and their river and ocean environments. Develop a Plan and Timeline for Transition to Closed Containment Research and Science Study the list of significant publications that have already been carried out that identify the impacts of open net- pen aquaculture on wild species and their environment, acknowledge them and act to reverse these threats. Identify areas where further peer- reviewed research is needed and carry it out. 9

10 Set up index rivers comparable to the Magaguadavic River in NB for monitoring of escapes and interactions between wild and farmed salmon in other eastern provinces that have open net finfish operations. Base all siting decisions on science- based criteria, including the potential impacts to the environment and wild species, including Atlantic salmon. 10