FOPO Committee Report

In the previous section of this report, we recommended the development and implementation of legislation and regulations that would govern the development of aquaculture in Canada. The Committee, however, also heard evidence that was primarily focused on environmental issues concerning netcage salmon aquaculture. These specific issues deserve to be discussed in more detail. Salmon aquaculture is still strongly opposed by a number of groups on the West Coast for a variety of reasons. Nevertheless, the industry believes that most of this opposition is based on outdated information. While the industry concedes that it was not managed optimally in its earlier days, it says that recent advances in husbandry and technology have reduced its environmental effects to a minimum.

Major issues included:

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The risk of colonization of B.C. rivers by escaped Atlantic salmon;

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The genetic interaction of escaped domestic and wild salmon stocks, which is mostly a concern on the East Coast;

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The potential for salmon farmed fish to transmit disease to wild stocks, and the need for a National Aquatic Animal Health Program;

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The environmental effects of organic wastes from netcages;

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The environmental sustainability of the industry; and

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The use of drugs, pesticides and other chemicals by the industry, and other human health-related concerns.

Fish Escapes

One of the most important issues raised before the Committee was the problem of farmed fish escapes. Witnesses addressed a variety of related issues, including the colonization of wild salmon habitat, competition for food and habitat between escaped and wild salmon, predation, genetic interactions, and disease and parasite transfer from farm salmon to wild salmon. The emphasis on these concerns is different on the West and East Coasts. In British Columbia, the Atlantic salmon is a potentially invasive exotic species. Many witnesses were concerned that Atlantic salmon might succeed in colonizing West Coast streams and rivers and establishing feral populations, which could then compete with native salmon species. On the East Coast, where both the farmed and wild stocks belong to Atlantic salmon species, a major concern is that interbreeding with farm salmon may reduce the fitness for survival of wild salmon.

Colonization

The Atlantic Salmon Watch Program (ASWP)³⁵ reported that between 1991 and 2001, there were over 413,000 escaped Atlantic salmon in British Columbia.³⁶ This estimate may be conservative. Although producers are required to report every accident causing escapes, small escapes are often overlooked. In the 11 years for which the ASWP reported data on escapes, the proportion of escaped Atlantic salmon (relative to the proportion of other escaped farmed salmon) has grown in parallel with the growth of the farming of this species. In the past five years, two thirds of the escapes were Atlantic salmon. In the same period, the number of salmon from commercial catches has decreased steadily each year, for an estimated total of 209 million for 1991-2001.³⁷ Commercial salmon landings are considered to reflect the size of wild salmon stock. However, a recent report from DFO researchers attributes the sharp decline of Pacific salmon (most severe for coho and chinook salmon) to a combination of climate change, overfishing and freshwater habitat destruction. The researchers further affirm that despite speculative links, salmon farming poses a low risk to wild salmon stocks. Further, they concluded that hatchery programs for Pacific salmon currently pose a far greater genetic risk to Pacific salmon than do fish farms, by reducing genetic diversity and substituting wild salmon by hatchery fish.³⁸

Attempts were made to introduce Atlantic salmon on the Pacific coast for angling purposes on several occasions between 1905 and 1934.³⁹ These attempts failed for reasons not fully understood. Their failure has been presented as evidence that recently escaped Atlantic salmon will also fail to colonize. For example, the SAR also concluded in 1997 that colonization would not be a significant problem. The situation is different nowadays, however. Atlantic salmon are now found in fresh and salt water in British Columbia, and as far north as Alaska. More importantly, the species can proliferate, as shown by a recent report of juveniles and adults found in three rivers in British Columbia.⁴⁰ Evidence that Atlantic salmon are breeding in the wild in West Coast rivers was first found in 1998, when juvenile salmon were discovered in the Tsitika River in northeastern Vancouver Island. Since then, Atlantic salmon have been found to spawn in two additional rivers,⁴¹ and juvenile Atlantic salmon have also been found in four additional rivers. These observations contradict earlier DFO claims that Atlantic salmon could not survive in the wild and that, even if they did, they could not spawn successfully.⁴²

The Committee heard different views about the probability of colonization. Dr. John Volpe stated that colonization was “inevitable.” His preliminary data suggested that Atlantic salmon would undergo a rapid adaptation of fitness during colonization, with unpredictable and likely irreversible effects on native stocks.⁴³ A workshop on salmon farming, organized by Simon Fraser University, concluded that the possibility that Atlantic salmon would successfully invade the northeastern Pacific could no longer be characterized as remote. Workshop participants warned that natural selection could produce a population better adapted to compete:⁴⁴

But even if in the early going, these domesticated fish are barely able to sustain small populations in the face of aggressive competition from wild Pacific salmon, there can be no complacency. Atlantic salmon have the capacity to produce a large number of offspring. Only the fittest of these will survive and reproduce. This selection process may someday produce fish with substantially different competitive abilities than the original colonizers.

On the other hand, according to Dr. David Groves, the Atlantic salmon is not typically an invasive species.⁴⁵ This view is supported by the fact that, once extirpated, Atlantic salmon are difficult to re-establish in areas of their own native range. The original Salmo was a circumpolar species; but about 15 million years ago, the genus Oncorhynchus (the Pacific salmons) differentiated from Atlantic salmon. Despite being in the Pacific basin before the Pacific salmons, Atlantic salmon became extinct. Dr. Groves suggested that this was either because the Atlantic salmon was unable to adapt to a changing environment or because it was simply out-competed by the Pacific salmon.

Dr. Eric Taylor, of the University of British Columbia, stressed the lack of information on both sides of the debate and the lack of research by DFO to objectively assess the potential ecological and genetic effects of escaped Atlantic salmon.⁴⁶

Genetic Interactions

A major concern on the East Coast is the potential for genetic interaction between wild and domesticated salmon. North American populations of wild Atlantic salmon have been declining for 30 years for reasons not fully understood.⁴⁷ In fact, the returns of Atlantic salmon from the ocean to home rivers have been declining in both Europe and North America. In parallel, there has been an expansion of the aquaculture industry, and in particular of salmon farming. The potential threat posed by salmon farm escapees has to be included among the list of factors contributing to this decline. Farmed fish now vastly outnumber wild fish on the East Coast, and escapees now dominate annual runs in salmon rivers in areas where the salmon farms are located.⁴⁸ Atlantic salmon farming on the East Coast is concentrated in the Bay of Fundy, which accounts for 90% of the eastern Canada production. In its 1998 Stock Status Report, DFO reports that in 1994, escapees of Atlantic salmon were estimated at 20,000 to 40,000.⁴⁹ It would appear that more recent reports on salmon escapes on the East Coast are not available. The authors of the DFO report conclude that:

A more thorough assessment of the impact of aquaculture escapees on wild salmon stocks is urgently required in the context of the growing abundance of escapees within rivers and the depressed state of some of the wild stocks.

Wild Atlantic salmon are characterized by a large number of genetically distinct populations, each adapted to the specific conditions of the river systems from which they originate and to which they return to spawn. Over thousands of years, evolution has fine-tuned the genetics of each population to its natal river. By contrast, salmon raised on farms have been subjected to an intensive domestication program to selectively breed fish with genetic uniformity, low aggressiveness, resistance to disease, and enhanced rapid growth. However, this breeding has yielded salmon stocks less adapted to a wild environment. It is thus believed that genetic interaction between escaped farmed and wild salmon will reduce the fitness for survival of wild salmon through interbreeding. There is a pressing need for research on the extent and scale of local genetic adaptations in salmon. Such adaptations are likely to have been generated by complex combinations of genes, resulting from a lengthy evolution process. Research is also necessary on the long-term consequences of genetic interactions between farmed and wild fish.

A DFO workshop report reached conclusions similar to those drawn above:

The potential for negative impacts is clear. The likelihood that wild stocks are adapted to their local environments makes it highly unlikely that the impact of farmed escapees on wild stocks will be positive. Current understanding is insufficient, however, to specify the precise nature and degree of negative impacts, which can be expected.⁵⁰

The conclusions discussed above were not, however, shared by all of our witnesses. The Commissioner for Aquaculture Development suggested, based on a report that he had commissioned, that gene flow has a positive effect in natural populations, and that interbreeding with small numbers of escapees could have a positive effect on a wild population. In his report, Potential Genetic Interaction Between Wild and Farm Salmon of the Same Species, Dr. Ray G. Peterson nevertheless cautioned:⁵¹

Large intrusions of farm genes into wild gene pools are expected to cause severe declines in fitness in the short-term. Recovery is likely, but several generations would be required and the stock may not survive the initial flood.

Unfortunately, the current situation on North America’s Atlantic coast appears to correspond perilously to this scenario.

Despite the adoption of preventive measures by the industry, farm fish are still getting out in the wild in significant numbers. Moreover, a sustained growth of the industry may lead to greater escapes in absolute terms. The Committee believes that even with expansion, the industry should be able to reduce the total number of escapes by a combination of improved management, improved recovery efforts, and enforcement of penalties for negligent farm operators.

The Committee recommends:

RECOMMENDATION 11

That nationwide standards and regulations to minimize escapes from net pens should be adopted. These should include:

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Independent monitoring of all farm operations;

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Maintenance of containment system records,

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Tracking of inventory and losses,

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An identification system for all farmed fish;

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Immediate reporting of any escapes;

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Active recovery efforts; and

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Operating licences tied to compliance, with fines or loss of licence for escaped fish.

In addition, that DFO, in cooperation with its partners, intensify research into reducing the number of fish escaping from aquaculture facilities and promote the adoption of the results of such research.

Given the positive role played by the ASWP in providing data on the abundance and distribution of Atlantic salmon on the West Coast, and the lack of such information for the East Coast, the Committee also recommends:

RECOMMENDATION 12

That the number of annual surveys of rivers under the Atlantic salmon watch program be expanded on the West Coast and that a similar program be introduced on the East Coast.

Fish Health

Growing healthy fish is essential to the aquaculture industry. Achieving this goal entails providing high-quality nutritious food, keeping reasonable stocking densities, ensuring good water quality, limiting sources of stress, acquiring and developing healthy fish stocks, and practising good fish husbandry. Fish farmers have strong financial incentives to minimize the incidence of disease on farms, and the industry has made rapid improvements in the management of disease. Survival rates of over 90% for farmed salmon are common today, whereas farmers struggled to achieve 65% survival rates in 1988.⁵² Despite these successes, significant problems related to fish health can be observed. Many of the criticisms are directed not at the industry’s failure to do what is needed from a production standpoint, but rather at its disregard of the effects of farm fish production on fish health in the wild. Critics of the industry believe that salmon farming has had a negative effect on wild fish populations in regions where it has been practised, and that fish farms have been a major factor in the decline of wild salmon stocks in Norway, Scotland, Ireland, and on both the North American West and East coasts. One argument put forward by these critics is that stress caused by high stocking densities in netcages predisposes farmed fish to disease. The close physical proximity of fish facilitates the transmission of pathogens between individuals. According to the critics, when farmed fish escape or when wild fish swim close to the net pens, the risks to wild stocks are increased.

Disease reporting and surveillance, as well as the incidence of drug residues in the environment and fishes, were additional issues pertaining to fish health brought up by witnesses. The Canadian Aquaculture Industry Alliance advocated the need for a comprehensive and equitable National Animal Health Program specific to the aquatic environment. The program should include comprehensive surveillance, mandatory reporting, and compensation for farmers for ordered stock destruction. The program would give the industry the ability to respond rapidly and effectively in the event of an outbreak. According to the Canadian Aquaculture Industry Alliance’s proposal, such a program would cover elements such as implementation of appropriate legislation, expanding the knowledge base on aquatic animal diseases, response procedures for different diseases of concern, and program management. The industry and DFO are already working on the development of the National Aquatic Animal Health Program (NAAHP). The Committee believes that such a program should be developed and implemented as soon as possible.

Therefore, the Committee recommends:

RECOMMENDATION 13

That the Department of Fisheries and Oceans give a high priority to the development and implementation of a National Aquatic Animal Health Program to provide for:

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the early detection and mandatory reporting of diseases for farmed aquatic animals;

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regulations for the proper disposal of dead and diseased fish; and

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a system of compensation to farmers for ordered eradications to support effective disease management similar to that given to other livestock farmers.

Disease transfer to the wild has been a main fish health concern raised by witnesses. Disease may be transferred by several means: by escaped fish, by water-borne pathogens, through faeces, through hatchery and overseas introductions,⁵³ and via vectors such as sea lice. Thus, both the problem of escapes and the broad use of net pens potentially contribute to the transmission of parasites and diseases from farmed fish to fish in the wild. Nevertheless, there appears to be little direct and conclusive scientific evidence concerning such transmission of disease.⁵⁴ To some extent, this can be attributed to the difficulty of studying the incidence of disease in wild fish. The survival rate of wild fish is very low compared to farmed fish, and disease-related mortality is difficult to assess, as most diseased wild fish die quickly and are thus rarely observed. By contrast, disease is easier to observe in a mass culture system.⁵⁵

Like any health management program, fish health management should be based on both prevention and treatment. Reasons for the improved survival rates observed in recent years include more effective vaccines and vaccination techniques, strict disease screening of broodstock, and isolation of year classes.⁵⁶ Improved vaccines and advanced husbandry have drastically reduced the use of antibiotics in salmon farming, to a level that is far below that of any other agricultural industry in the world. ⁵⁷

The Committee recommends:

RECOMMENDATION 14

That the Department of Fisheries and Oceans promote lower stocking densities and continued preventive fish health practices such as effective vaccines and vaccination protocols to reduce the incidence of disease in net pens.

Most losses in salmon farming are due to diseases that are categorized as fungal, bacterial, viral, or parasitic. In fresh water, fungi and protozoan parasites are the greatest threat. Eggs are particularly susceptible to fungal infection, so treatment with fungicide is necessary. In seawater, the three major concerns are (1) pancreatic disease, (2) sea lice and (3) furunculosis. Other problems may include infectious pancreatic necrosis (IPN), vibriosis and, in rare cases, bacterial kidney disease (BKD). Bacteria cause some of the most problematic diseases for the salmon farming industry.⁵⁸ Bacterial diseases are usually treated or controlled by antibiotics, immunization, or a combination of these two methods.

The most common viral diseases for salmonids include the infectious haematopoietic necrosis, viral hemorrhagic septicaemia, infectious pancreatic necrosis, and the salmon papilloma. Recent introductions of viruses include the infectious salmon anaemia found in 1996 on farms in the Bay of Fundy, and the salmon swim bladder sarcoma virus in wild Atlantic salmon populations in 1998.

Infectious Salmon Anaemia

During the Committee’s hearings, infectious salmon anaemia (ISA) received the most attention. This disease was first observed in Norway, where an outbreak in 1984 lead to a widespread plague that affected 98 farms over the next six years. The virus also infected farms in Scotland. In Canada, ISA was first detected in New Brunswick in 1996. In December 1997, the provincial government ordered large numbers of fish killed, ultimately shutting down 25% of the industry in an effort to stop the spread of the disease. Between April 1998 and June 2000, 55 farms were infected with the ISA virus and 4.1 million fish were slaughtered.⁵⁹ No compensations were initially planned for the government-ordered extermination, resulting in several farmers delaying killing potentially infected fish. Industry losses were compensated by $10 million in assistance authorized by the New Brunswick Cabinet and a $34.2 million federal allocation through the Disaster Financial Assistance Arrangement Program.⁶⁰ Infectious salmon anaemia was subsequently discovered in wild salmon in New Brunswick in late October 1999. Some witnesses criticized DFO for its failure to immediately order the slaughter of infected fish, despite Norway’s experience.⁶¹ In retrospect, the ISA outbreak in New Brunswick would probably have been handled differently had a National Aquatic Animal Health Program been in effect at the time. In particular, an effective compensation system for farmers for ordered eradications could have resulted in a different outcome. Had a National Aquatic Animal Health Program been in place, as in Recommendation 15, the federal government would have been obliged to exercise its responsibility and the province of New Brunswick would not have been forced to act by default.

Sea Lice

Farmed salmon are susceptible to a number of external and internal parasites. The most significant of these is sea lice. Sea lice are small external parasitic crustaceans that infect salmonids and other fish species. Sea lice inflict damage both directly by feeding on the host’s body and indirectly by making the host more vulnerable to secondary infections. Sea lice cause substantial losses for the salmon farming industry by reducing growth rate and feed conversion efficiency, by reducing marketability, through the cost of treatments for sea lice and secondary infections, and by increased mortality. One witness estimated the total economic cost of sea lice to B.C. salmon farmers at over $340,000 annually per farm.⁶²

Of the threats posed to wild salmon by aquaculture, many observers believe that sea lice represent the greatest risk. According to witnesses, sea lice outbreaks in wild salmon and related species have been reported in other countries such as Norway, Scotland and Ireland, in areas where salmon farms are located.

In the summer of 2001, outmigrating juvenile pink salmon in the Broughton Archipelago were found to be carrying unusually heavy burdens of sea lice. This observation was unusual and generated considerable concern about the possible reasons for the infestation. Some witnesses, such as Watershed Watch attributed the outbreak to the large concentration of salmon farms in the area. Although the sea lice are natural occurring parasites, many observers believe that high densities of fish in the farms may act as “reservoirs” of lice, which can contribute to the infestation of wild juvenile fish, thereby affecting the commercial fishery.

In December 2001, DFO released the report of a study of sea lice incidence in the Queen Charlotte Strait. The DFO report minimized the effect of sea lice on the general health of juvenile wild salmon, finding that juvenile pink salmon as well as other species collected in two surveys appeared to be in very good condition.⁶³ The study did not specifically address a possible correlation between the incidence of sea lice infestation and the proximity of fish farms. The DFO study was widely criticized for both its timing and methodology.

In addition to the observation of heavy infestations of sea lice on juvenile pink salmon, there has also been an extraordinary decrease in the number of pink salmon returning to spawn in the Broughton Archipelago, from 3.6 million spawners in 2000 to an estimated 147,000 in 2002.⁶⁴ The collapse led to increasing “polarization” between environmental organizations and First Nations and the federal and provincial departments.

This situation prompted the Pacific Fisheries Resource Conservation Council (PFRCC) to undertake a public consultation to review the available information and gather information necessary to recommend appropriate actions. In November 2002, the PFRCC issued an advisory, urging “safe passage” for pink salmon and raising concern over the potential impact of salmon aquaculture and sea lice. The PFRCC offered, as options for action, preferably, fallowing of all salmon farms in the Broughton Archipelago, to be completed six weeks prior to the pink salmon entering the marine environment or implementation of rigorous sea lice control measures on salmon farms, geared to the protection of wild fish.

In February 2003, DFO announced a plan designed to protect pink salmon in the Broughton Archipelago. The plan shares elements with the PFRCC recommendations but proposes selective rather than area fallowing coupled with improved health management protocols. The approach is more similar to the second of the two PFRCC recommendations, but which was judged by the Council to represent the higher risk to the pink salmon stock.

Although establishing causality between the collapse of pink salmon and the prevalence of sea lice in the Broughton Archipelago is difficult to prove scientifically, the concurrence of the observations is persuasive. Appearing before the Committee, Gordon Ennis of the PFRCC summarized the issue in the following terms:

Based upon knowledge in Europe, other studies, the farmed salmon pick up the sea lice from the natural environments, perhaps even from adult pink salmon. Sea lice is a natural organism in the environment, but with the fish being so crowded on fish farms, we feel it acts like an incubator. The fish are under stress, their loading is high, so they have a greater propensity to have sea lice on them. And each sea louse can produced, each female that’s gravid, some reports say, 1.5 million eggs. So there is, indeed, a potential risk…

This is not absolute scientific proof, but it was compelling, especially combined with information garnered in Europe, where there had been fish farming for years. In Norway, Scotland, Ireland, sea lice on wild salmon have been reported, reported extensively. Certainly in Ireland it’s been very controversial. So the observations, combined with the knowledge of what has happened elsewhere, led the council to conclude that sea lice were the most likely cause for the collapse. It’s indirect evidence, but that was our conclusion.

A number of techniques are available to fish farmers for the control of sea lice. These include preventative measures such as fallowing, the use of single-year age classes, appropriate siting, and vaccines. When outbreaks occur there are generally two options: external application of pesticides in a “bath” treatment and drugs administered in the feed. Bath treatments are costly and can cause high levels of stress to the fish. After treatment, the pesticide is released into the marine environment and some of the pesticides used to treat sea lice can be highly toxic to marine invertebrates, particularly crustaceans.

In B.C., treatment with medicated feed is the preferred approach. B.C fish farmers currently have access to two products, both of which are available by veterinary prescription only: ivermectin and emamectin benzoate or SLICE. Neither product is currently approved in Canada for use in fish. Ivermectin is approved for use in other types of animal husbandry but can be prescribed for fish under the practice of extra-label use. SLICE is not yet licensed in Canada but can be prescribed through the Emergency Drug Release program of Health Canada. Emamectin is currently in the process of being licensed by the Veterinary Drugs Directorate at Health Canada. SLICE has now mostly replaced ivermectin for the treatment of sea lice.⁶⁵ Maximum residue limits have not been set for either of these products in farmed salmon going to market in Canada.

The Committee recommends:

RECOMMENDATION 15

That DFO and the industry promote the development and use of improved methods to control sea lice, including better husbandry techniques, fallowing farms, developing louse-resistant strains of salmon, and non-chemical treatment methods; and

That the recommended National Aquatic Animal Health Program explicitly includes a requirement for monitoring and reporting sea lice levels on farmed fish, as well as specifying maximum allowable sea lice burdens.

Biological Wastes

Much of the controversy surrounding the aquaculture industry is related to net pens. One of the major criticisms levelled against the salmon farming industry is that the wastes generated by salmon farms — including faeces, vaccines, fungicides, and therapeutants — pollute the surrounding waters and the sea floor underneath the netcages. Salmon farmers depend on clean water to produce a high-quality product. Although they have an incentive to ensure that the waters they use are clean, this requirement is not sufficient to ensure that they will not generate pollutants since the ocean is large. Nevertheless, since feed accounts for approximately 60% of production costs, fish farmers have a strong incentive to maximize the efficient conversion of feed into salmon and to minimize waste. The aquaculture industry has made a great deal of progress in improving feed formulation and feeding technology. For example, B.C. salmon farmers release about a third of the organic waste to the environment than they did 10 years ago despite a 300% increase in production.⁶⁶

In the late 1980s, coho and chinook had feed conversion ratios⁶⁷ (FCR) of about 2 to 1. The FCR for Atlantic salmon was about 25% better. Ratios for all farmed salmon species have since been improved by 20%. With an average farm feed budget of about $2.5 million, the superior FCR performance of Atlantic salmon is important for the profitability of the industry.⁶⁸

Feeding efficiency has also improved dramatically since the 1980s, when feeding relied on untrained staff using basic equipment. The technology now includes underwater video cameras, and feed detection devices such as Doppler radar and Aquasmart detectors. These advances, coupled with computerized, pneumatic feed machines, have made feeding more efficient and reduced wastage of uneaten food.⁶⁹

The feed industry has dramatically improved the quality of feed by tailoring it to the dietary requirements of the cultured species. More digestible feeds have reduced wastes (in the form of faeces) and thus the resulting effect on the sea bed (benthos). Increased digestibility is also largely responsible for improvements in FCRs.⁷⁰ Despite this success, there may still be room for improvement. It is possible that further advances in husbandry practices and the optimization of protein-energy ratios will enable FCRs to approach 1 to 1.⁷¹

Critics often compare farm wastes to municipal sewage. For example, the Friends of Clayoquot Sound (FoCS) estimated that, based on the 1998 production of 42,300 tonnes of salmon, B.C. farms generated raw sewage equivalent to a city of about half a million inhabitants. More recently, Dr. Volpe offered the comparison that the total suspended solids allocation from four salmon farms in Bremerton, WA, exceeds the total suspended solids from the city of Seattle (5.3 million lb/yr faeces vs. 4 million lb/yr total suspended solids). The salmon farm wastes are not treated, while the municipal sewage is filtered and sterilized at an ongoing cost of US$80 million/yr and an initial treatment facility cost of US$536 million.

Although there may be an element of truth in these comparisons, the two types of waste are not directly comparable. The discharge from salmon farms is primarily a nutrient loading issue, while concerns with municipal sewage are related more to human pathogens, heavy metals and toxic organic compounds associated with industry and urban development.

Fish farm wastes can have two main types of environmental effect: local accumulation of wastes, and release of nutrients in the marine environment. The accumulation of wastes immediately below the farms can smother the benthos and deplete water of its oxygen content.⁷² Anaerobic decomposition of the accumulated wastes releases methane, hydrogen sulphide, and ammonia. Ammonia is a nutrient, which can potentially contribute to toxic algal blooms. It was suggested that the appearance of toxic algal blooms in the Broughton Archipelago area of the B.C. coast coincided with the arrival of the salmon farming industry.⁷³ Conversely, fish farm wastes can be viewed as simply as nutrients,⁷⁴ which contribute to the sea floor organic enrichment, provided that they are adequately dispersed.

The areas most affected are generally limited to the sea floor directly beneath the farm structures. The extent of the area affected is influenced by a variety of factors, such as depth and site circulation dynamics; but in the majority of sites, the effects of organic wastes can be detected only within 50 metres of the farm perimeter.⁷⁵ As constituents of waste material present a low risk to the environment, the overall effect to the environment is assumed to be low. Once a fish farm has been removed, the site’s environment will recover. The Committee was informed that typical recovery periods range from 0 to 18 months, and up to 48 months in a worst case.⁷⁶

Conditions in the Bay of Fundy are unique. The Bay is relatively enclosed, and it has been estimated that a complete exchange of water takes 76 days.⁷⁷ It was emphasized that scientific knowledge to determine the amount of waste that the Bay of Fundy region can absorb is currently lacking.⁷⁸ While the strong currents of the Bay move the wastes around and away from farm sites, they do not flush them out of the Bay efficiently. Witnesses recommended imposing a moratorium on increasing salmon production in the Bay of Fundy until science has determined what level of fish production the Bay can support without causing problems such as eutrification, anoxic sediments, and loss of biodiversity.⁷⁹

Witnesses criticized DFO for its failure to address these issues adequately. In principle, DFO could regulate salmon farm wastes under sections 35 and 36 of the Fisheries Act, which prohibit the harmful alteration, disruption or destruction (HADD) of fish habitat and the deposition of deleterious substances into waters frequented by fish. Under the terms of a 1985 Memorandum of Understanding (MOU), responsibility for section 36 of the Act was delegated to Environment Canada, although DFO still retains ultimate authority for all sections of the Act.

The Auditor General, in his December 2000 Report to Parliament, criticized DFO for failing to ensure adequate monitoring of the effects of salmon farms on fish and their habitat, and for not enforcing compliance. He also criticized Environment Canada for monitoring the effects of salmon farming only on shellfish beds and not on salmon or their habitat.⁸⁰ Moreover, he noted that no fish farm operator had been prosecuted under the Fisheries Act for releasing a deleterious substance having an effect on fish or fish habitat. A prosecution launched by a private citizen, in March 1999, of a fish farm operator was stayed by the Department of Justice on the basis that licensing the site with knowledge of the effects would reduce the chances of a conviction.

While a number of other industries are regulated under section 36 of the Fisheries Act, aquaculture is not. One explanation for this may be the dual nature of fish farm wastes as either potential nutrients or deleterious substances. In principle, fish farm waste could be regulated under the Fisheries Act.

Another option presented to the Committee was to amend Part VII, Division 1, Nutrients, of the Canadian Environmental Protection Act (CEPA) in order to explicitly include the deposition of nitrates and phosphates into marine waters from aquaculture operations.⁸¹

The Committee recommends:

RECOMMENDATION 16

That DFO develop environmental performance regulations explicitly for the finfish aquaculture industry under either a new Aquaculture Act or, in the interim, either the Fisheries Act or the Canadian Environmental Protection Act to control the output of nutrients and other wastes into marine waters from aquaculture operations.

In most cases, the severe environmental effects of fish farms are limited largely to the immediate vicinity of the farms themselves. Some areas such as the Bay of Fundy or the Broughton Archipelago have high densities of fish farms; in such areas, there is the potential for fish farm wastes to have a cumulative effect that extends beyond the immediate vicinity of farms and that may exceed the assimilative capacity of the region. Regulations governing the deposition of wastes should also take into account the capacity of water bodies in which large concentrations of cage sites are located to assimilate fish farm wastes.

The Committee recommends:

RECOMMENDATION 17

That, for marine areas with high concentrations of fish farm operations, a precautionary approach be adopted with respect to farm density and overall production limits until such time as scientific research can determine the capacity of the system to assimilate wastes, nutrients and other chemical products deposited from farms. If it is determined that an area cannot maintain its biological integrity at a given production level, then either total production must be scaled down or more stringent discharge limits implemented for fish farms.

Under the federal Fisheries Act, the Department of Fisheries and Oceans and its agent, Environment Canada, have a statutory responsibility for the protection of fish and fish habitat. The federal-provincial/territorial memoranda of understanding on aquaculture are intended to delineate responsibilities of the respective levels of government. Generally, federal responsibilities include scientific research, fish health and inspection, and the protection of fish habitat. Provincial and territorial responsibilities include promotion development and regulation. Under the terms of the MOUs (at least with New Brunswick and British Columbia), both levels of government have responsibility to conduct periodic inspections of aquaculture facilities to determine compliance with respective acts, regulations and guidelines.

Nevertheless, the issue of waste regulation remains something of a grey area. British Columbia has developed its own aquaculture waste regulations, although this is an area of federal responsibility. If DFO develops federal aquaculture waste management regulations, there is potential for duplication and confusion.

The Committee recommends:

RECOMMENDATION 18

That, as far as possible, any federal, provincial and territorial regulations allowing deposition of wastes be harmonized; and

That where provinces and territories have developed their own environmental performance regulations, DFO determine whether such regulations meet federal performance standards and, if they do not, ensure that the more stringent federal standards apply.

Reduction of the Environmental Effects of Aquaculture

The environmental effects of aquaculture are more likely to be significant when fish farms are located on or close to rearing grounds, and along migratory routes. In order to minimize these effects, other countries such as Norway and the United States have specified minimum distances between siting areas and salmon streams.⁸² Given the important negative consequences of escapes in terms of colonization and genetic interactions, the Committee recommends:

RECOMMENDATION 19

That DFO conduct an exhaustive investigation into the effects of siting netcage fish farms on adult and juvenile salmon migratory routes, as well as on fish rearing grounds. In particular, safe and acceptable distances between the sites of farms and the prohibited siting areas should be determined, taking into consideration data from, and standards in place in, other countries; and

That the licensing authorities be urged, in the strongest possible terms, that the granting of additional salmon farm licences proceed with extreme caution until such a study has been completed.

Ideally, the goal for the fish farming industry should be to achieve “zero escapes.” Many of our witnesses believed that only total physical containment would allow this objective to be realized. Physical containment would also solve many fish health problems, and, together with adequate waste management, would address concerns about deposited organic waste, drug and feed residues. Containment measures based on physical barriers include land-based systems, as well as closed-bag and very secure net pen culture systems. Conversion of the industry to land-based, closed, contained systems would increase production costs for the industry, thus reducing its ability to compete in a very aggressive global market.

The Committee recommends:

RECOMMENDATION 20

That governments dedicate funds for research on the environmental effects of netcage systems, and the improvement of closed containment technology. These new systems should be phased in on a trial basis.

Sustainability

One of the arguments frequently offered in favour of aquaculture development is that it can replace the growing shortfall in production from traditional capture fisheries and relieve pressure on wild fish stocks. In its biennial reports, The State of World Fisheries and Aquaculture, the Food and Agriculture Organization of the United Nations consistently points out that, as traditional capture fisheries have already reached their maximum productivity, aquaculture will be expected to play a greater role in food security in the future. The same theme was repeated in the 1995 Federal Aquaculture Development Strategy and the B.C. Salmon Farmers Association used much the same argument when it appeared before the Committee:

By enhancing the production of fresh farmed salmon in B.C., we can alleviate fishing pressures on remaining wild stocks while creating well-paid, full-time jobs for displaced fisheries workers. At the same time, our industry’s expertise, knowledge, and resources can be brought to bear to reverse the declines of B.C.’s wild salmon populations.

Worldwide, the vast majority of aquaculture is of non-carnivorous species, mainly carp, tilapia and milkfish, as well as shellfish. Most of this aquaculture uses a low level of technology, is practised at low intensity and has a long history of sustainability.⁸³ A number of witnesses, however, questioned the sustainability of salmon farming, which (like the farming of other carnivorous fish species) consumes more protein than it produces. Salmon require feed with a high percentage of fishmeal and fish oil in order to replace/replicate their diet in the wild, and it is estimated that it takes approximately 3 kg of wild fish to produce 1 kg of farmed salmon.⁸⁴

In order to meet its requirements for fish feed, the Canadian aquaculture industry depends heavily on foreign imports of fish oil and fishmeal, which come mainly from South America. Every year a considerable amount of so-called “forage fish,” such as anchovies, sardines, herring, jack mackerel, capelin and menhaden, some of which may in fact be suitable for human consumption, are harvested for conversion to fishmeal and fish oil. These small pelagic fish also play an important role in the food chain as the main food source for larger predators, including cod, tuna, whales and seabirds. Harvesting forage fish reduces their availability for these top-level predators.

The Food and Agriculture Organization of the United Nations has estimated that about one third of the global catch of these forage fish species is turned into animal feeds, of which 31% is used in aquaculture production.⁸⁵ Industry experts expect that within a decade the global aquaculture industry could use two thirds of the world’s fishmeal production.⁸⁶

Thus, while the aquaculture industry often claims that it has a very small environmental footprint, largely limited to the area occupied by the farms themselves — B.C.’s aquaculture industry occupied only about 1,191 hectares of the province’s coastal waters in 2000 — some critics of the industry argue that, when the area of ocean harvested to provide the supplies of fishmeal and fish oil needed by the industry are taken into account, the industry’s real environmental footprint is vastly larger than the area occupied by the farms themselves. For example, according to Dr. John Volpe:⁸⁷

The marine area required to sustain a fish farm is 40,000 to 50,000 times the area of the fish farm itself. So if you have a one-hectare fish farm, an ocean surface area of 50,000 hectares is required to maintain that area. Using current production numbers, the B.C. industry consumes the biological productivity of approximately 7.8 million hectares of ocean. That’s equivalent to about 278 times the area of all terrestrial horticulture in B.C. So this idea that the [fish] farming industry has a small environmental footprint is false to say the least.

The typical formulation of fish feed is 45% fishmeal and 25% oils, with the remaining made up of minerals and binders. Some companies are now investigating plant-based feeds. Currently, substitutes such as grains, oilseeds, fish and meat trimmings, and processing wastes are less digestible than high-quality fishmeal, and their use can result in slower growth and increased levels of organic waste such as fecal matter. Replacing fish oil is particularly problematic. Vegetable oil substitutes may decrease fish growth rates, change fish flavours, and reduce the ratio of essential fatty acids in some species.⁸⁸ Research, however, has demonstrated that partial replacement of fish oils with rapeseed and linseed oils can be successful in the culture of Atlantic salmon without significantly influencing growth performance.⁸⁹ Moreover, genetic modification of crop species such as soybean to produce an oil fully suitable to the dietary requirements of farmed fish may allow total substitution of fish oil with plant-based oils in the future. The level of consumers acceptance of farmed fish fed with feed derived from a genetically-modified crop would have however to be taken into consideration.

Nevertheless, it appears that carnivorous fish will continue to require more fishmeal and fish oil than herbivorous or omnivorous species. Encouraging the farming and consumption of non-carnivorous fish that are lower on the food chain would require less marine protein and could help reduce the aquaculture industry’s dependence on forage fish. Furthermore, the reliance of the aquaculture industry on a single species, Atlantic salmon, makes the industry more vulnerable both to biological and economic risks. Diversifying the variety of species cultivated could also help reduce the industry’s susceptibility to the economic and biological risks associated with monoculture.

The Committee recommends:

RECOMMENDATION 21

That the federal government support the aquaculture industry in its efforts to diversify the species cultivated with a view to reducing the industry’s reliance on imported fishmeal and fish oil; and

That the federal government promote the research and development of feeds that use a greater proportion of plant-based proteins and oils.

Human Health

Issues related to human health fall into three categories of risk: the development of antibiotic resistance in human pathogens as a result of the use of antibiotics in aquaculture; the potential presence of harmful chemical residues in fish directed for human consumption; and the nutritional value of farmed fish as compared to the salmon caught in the wild.

Advances in fish health management practices, and particularly in vaccine technology, have contributed significantly to reductions in antibiotic usage.⁹⁰ There are a limited number of drugs, pest control products, and anaesthetics approved for use on fish farms in Canada. Of a total of eight, four are antibiotics. Antibiotics are used for therapeutic purposes only and not as growth promoters.⁹¹ In practice, nearly all of the antibiotics fed to farmed fish are prescribed by veterinarians,⁹² who are subject by licence to strict standards of practice and professional ethics. About 90% of the antibiotics used in aquaculture are administered as medicated feed. Despite the aquaculture industry’s success in minimizing its usage of antibiotics to a level below that in other forms of animal husbandry,⁹³ the industry was criticized by some of our witnesses for its heavy use of antibiotics. According to these critics, fish farm wastes often contain antibiotics as well as other drugs used in fish farming, and most of the antibiotics fed to fish end up in the environment since the fish absorb only 2-10% of the antibiotics they are fed. Witnesses argued that the release of antibiotics, which include some of those used to treat human infections, into the aquatic environment increases the risk of generating antibiotic resistance among potential pathogens. These views appear to be supported by a number of studies. For example, a literature review by the U.S. Center for Disease Control and Prevention indicates that certain antibiotic-resistance genes in Salmonella — bacteria that can cause severe food poisoning in people — might have emerged following antibiotic use in Asian aquaculture.⁹⁴ In addition, the Task Force on Antibiotic Resistance of the American Society of Microbiology recommended in a 1994 report⁹⁵ that systematic studies be undertaken to determine the link between current clinical problems due to antibiotic resistance and fish and animal farming practices. The report specifically identified aquaculture as a concern because of the use of antibiotics at subtherapeutic levels for prophylactic purposes and the potential for drugs to become widely disseminated in the open environment due to sustained release.⁹⁶ Moreover, the task force reported on studies that showed the emergence of antibiotic resistance in pathogens in wild fish populations in close proximity to farms after farmed fish had been treated with antibiotics.⁹⁷

Other sources of antibiotics in the marine environment, including municipal sewage and agricultural wastes can also contribute to the problem of growing antibiotic resistance in pathogens. In fact, the production of beef, pork and poultry is a major area of concern in terms of increase of antibiotic resistance in animal pathogens. In contrast, salmon farming is one of the least medicated forms of agriculture; and antibiotic usage in fish farms is small by comparison with terrestrial farming and continues to decline.⁹⁸ Nonetheless, antibiotic resistance due to the use of antibiotics in fish farming is a legitimate concern.

The Committee recommends:

RECOMMENDATION 22

That aquaculture operators be required to report drug and pesticide use for each farm site.

While the development of antibiotic resistance has broad global and social implications, other potential human health issues concern mainly individuals who consume aquaculture products. Some witnesses argued that consumers should be able to choose between wild and farmed salmon and that the industry should be prepared to support labeling of farmed fish that they believe to be nutritious and safe.

One of the food safety issues discussed was the presence of residues of antibiotic drugs in farmed salmon. Since its creation, the Canadian Food Inspection Agency (CFIA) has had the responsibility for inspecting farmed salmon for the presence of such residues. According to the Georgia Strait Alliance, significant levels of antibiotics residues have been found in 3-4% of the farmed fish that go to the market. In fact, between 1997 and 1999, 0.4-1.1% of the farmed salmon tested in British Columbia showed drug residues above the maximum recommended level. The corresponding numbers for New Brunswick were 5.5% in 1997 and 1.5% in 1998. ⁹⁹

Tests are not conducted for all drugs (including antibiotics) used on salmon farms. While CFIA monitors sulphonamide and tetracycline antibiotics, it does not analyze samples for the presence of another widely used antibiotic, florfenicol.¹⁰⁰ Moreover, by the time tests are completed, the fish have already been sent to market, bought and in most cases consumed, preventing the possibility of any recall of products that exceed recommended levels of antibiotic residues.

Another witness stated that federal inspections are clearly underfunded and that, as a result, only a tiny proportion of the farmed fish is actually inspected.¹⁰¹

The Committee recommends:

RECOMMENDATION 23

That the Canadian Food Inspection Agency increase the effectiveness of its monitoring program to ensure the safety of aquaculture products by expanding its testing of all drug and contaminant residues, and by providing the results in a timely manner. Moreover, actions such as public advisories and removal of products from the marketplace must be taken when maximum levels are exceeded.

Another issue that has received attention in both our study and the media is the possible presence of high levels of environmental toxins in farmed fish. One witness, Dr. Michael Easton, found high levels of dioxins and PCBs in farmed salmon in a preliminary study. According to Dr. Easton’s study, a single serving of farmed salmon contained three to six times the World Health Organization’s recommended daily intake limit for dioxins and PCBs.¹⁰² Dr. Easton’s study has been criticized on the grounds of its small statistical size of the sample tested (four farmed salmon, only one of which was an Atlantic salmon, and four wild salmon), the collection method, and the fact that the individual farmed Atlantic salmon used in the study had an unusually high content of fat for its size (dioxins and PCBs preferentially accumulate in fat).

The current Canadian guidelines for dioxins and PCBs contaminants in fish and fish products¹⁰³ and the recommended tolerable daily intake (TDI) values from Health Canada are reproduced in Table 6, where they are compared to the equivalent values from the Joint WHO/FAO Expert Committee on Food Additives (JECFA). Both Health Canada’s maximum allowable concentration of dioxin in fish and its TDI for this contaminant are four times higher than the internationally recommended values.

Table 6: Comparison of maximum allowable concentrations and tolerable daily intake of dioxins and PCBs

	Maximum allowable concentration in fish			Tolerable daily intake
	Health Canada	WHO/FAO104		Health Canada	WHO/FAO
Dioxins	20 ppt	5 ppt		10 pg/kg BW	2.3 pg/kg BW105
PCBs	2 ppm			1 µg/kg BW

The Committee recommends:

RECOMMENDATION 24

That Health Canada brings its PCB and dioxin guidelines into line with the recommended international standards.

Environmental toxins can be found virtually everywhere. Therefore, farmed salmon producers might argue that they have very little control over the level of contaminants found in their products. Nevertheless, one possible area for action is in monitoring the animals’ diet more closely. The European Commission’s Scientific Committee on Animal Nutrition has recently found that among many animal feed ingredients, fishmeal and fish oil were the most heavily contaminated with dioxins and PCBs.¹⁰⁶ The sale, import and manufacture of livestock feeds are regulated by the Canadian Food Inspection Agency (CFIA) under the authority of the Feeds Act and regulations. In view of recent international cases where concentrations of dioxins and furans were traced back to contaminated feed, the CFIA conducted a preliminary survey of dioxin and furan contamination in animal feedstuffs. Dioxins, furans, PCBs, mercury and DTT levels in fish feed, fishmeal and fish oil were all found to be below the levels set out in the Canadian Guidelines for Chemical Contaminants and Toxins in Fish and Fish Products.¹⁰⁷ These levels were similar to those found in comparable products in Europe and in the United States.

The Committee recommends:

RECOMMENDATION 25

That the Canadian Food Inspection Agency (CFIA) conduct a more extensive survey of the comparative levels of environmental toxins in farmed fish and fish feeds.

The final aspect related to human health issues associated with salmon farming pertains to the nutritional value of farmed salmon relative to wild salmon. In particular, farmed salmon tend to have a higher content of fat and a lower proportion of desirable essential fatty acids than normally are obtained from fish. The Committee feels, however, that while this issue is significant, it should be looked at in the context of overall trends in the nutritional quality of our foodstuffs.

Proposed Federal Support of Aquaculture

Research

Witnesses, both proponents and opponents, emphasized the need for research into such issues as the environmental sustainability of the industry, fish health, and food safety. The issue of research was also addressed in the context of developing new production technologies related to aquaculture. The need for an increased federally funded research effort pertaining to aquaculture was highlighted. Although this research effort is already significant, it is perceived as being intended to financially benefit the industry rather than to understand the various environmental effects of aquaculture on marine ecosystems. The reality is, however, slightly different. A rapid survey of federally funded research indicates $36.5 million in promised investments by the Government of Canada until 2004-2005, with almost two thirds already approved or committed. This amount does not include all of DFO’s in-house research or funds from programs such as the Environmental Science Strategic Research Fund. The two largest beneficiaries are DFO’s Aquaculture Collaborative Research and Development Program ($20 million), and the Network of Centres of Excellence for Aquaculture in Canada, AquaNet, funded by NSERC and SSHRC ($14.4 million). Most of the AquaNet projects are directed at bettering knowledge of the ecological effects of fish farming. For it’s part, the Aquaculture Partnership Program will receive $2.1 million. The Committee strongly supports these initiatives. It would like to see, however, an intensification of this research effort, the quick and efficient translation of research findings to all aquaculture stakeholders and, finally, targeting of research efforts to issues highlighted by our witnesses. The Committee believes that research should focus primarily on invasion biology, genetic interactions, and disease transmission. If, as a result of this research, an unacceptable risk to wild stocks is demonstrated, DFO and its partners should take immediate measures to ensure the full protection of wild stocks in accordance to the precautionary principle.

The Committee recommends:

RECOMMENDATION 26

That the Department of Fisheries and Oceans focus its ongoing aquaculture research programs on improving understanding in the following areas:

•

the effects of the netcage fish farming industry on wild fish stocks;

•

the potential environmental and ecological effects of an expanded fish farming industry;

•

fish health issues;

•

the socio-economic effects of fish farming; and

•

policy and governance issues related to aquaculture.

Financial Support

As illustrated in figures 1 and 2, production and sales in the aquaculture industry continue to grow, limiting the need for federal financial assistance. If assistance is given, it must be given only when the following three criteria are met: (1) the assistance is intended to diversify the economy of a specific region; (2) there is a market failure that, if left uncorrected, would not achieve some desired result in a reasonable time, and (3) the assistance should be temporary in nature and must be phased out over time.

The use of public funds may be valid in regions where the industry is in the early stages of development, and where employment opportunities may be limited. In this case, the value of each additional job created will have a greater positive effect in these communities relative to areas where aquaculture is well established. Additionally, the use of public monies may generate positive linkages with the rest of the regional economy, for instance by helping to create a more skilled and productive labour force for the region. Federal financial assistance can have greater positive effects if it is targeted at investments that — such as roads — also benefit other regional economic sectors and communities. Such infrastructure investments may help these areas to employ their resources more fully, allowing them to reap further benefits. The positive effects of the assistance will increase as the administrative costs are minimized.

In an area where aquaculture is in the early stages of development, lack of experience on the part of both aquaculture investors and banks may mean that potential aquaculture investors have difficulty in obtaining financial assistance from the private sector. This situation results in a market failure only if the expected benefits to the community are significant; if the expected benefits are minor, then there is no market failure, and federal government monies are better spent elsewhere, where they can generate greater positive effects. If the expected benefits are significant, however, federal financial assistance could provide necessary assurance to banks, thereby helping investors to arrange loans from banks. It may be that the private sector will eventually invest in the aquaculture sector in these areas, but for the time being does not, thereby delaying these economic benefits to these communities. Federal financial assistance will not crowd out investment from private sources in such cases; rather, it may speed up development in these regions.

When the industry is in the early stages of development, people — such as private lending agencies, managers, technicians, and other workers — will have limited experience with it and are therefore likely to be less productive than those in regions where an aquaculture industry is well established. At this stage, productivity increases and costs decrease over time as managers and technicians “learn by doing”, and the regional aquaculture sector should mature into an efficient competitor. This increase in competitive capacity reduces the need for financial assistance. Ideally, this assistance should be entirely phased out as these productivity increases are fully realized. As a general rule, any financial assistance must meet the following three criteria:

•

the assistance is intended to diversify the economy of a specific region;

•

there is a market failure that, if left uncorrected, would not recover within a reasonable time, and

•

the assistance should be temporary in nature.