FOPO Committee Report
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SUPPLEMENTARY OPINION BY
THE NEW DEMOCRATIC PARTY
As the Vice-Chair of the Standing Committee on Fisheries and Oceans, I was pleased to be a full participant in the process that led to the creation of this report.
I have no objections to the overall foundation, direction and structure of this report. There are however, several points that need clarification and some recommendations that need to be strengthened.
Community Involvement
In Recommendation 10, the report states:
…Integrate the industry with coastal communities, include local decision-making, and ensure that local communities benefit from aquaculture activities.
The federal government should work to develop and implement a process to gain the consent of coastal communities and First Nations regarding the location of all existing or proposed aquaculture operations. Communities that do not support an aquaculture site should not be forced to accept one (e.g. Northwest Cove in Nova Scotia). Some aboriginal communities reject fish farms in waters that lie within their traditional territories and this request should be honoured.
Communities that have expressed an interest in developing aquaculture projects should be assisted by the government to build the industry (e.g. Coast of Bays region in Newfoundland and Labrador). Local communities must be involved in meaningful consultation to avoid conflict and be allowed to participate in the decision making of a proposed site.
Siting Issues
In Recommendation 19, the report states:
That DFO conduct an exhaustive investigation into the effects of siting net-cage 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.
I suggest that DFO prohibit the development of fin fish aquaculture near or in major salmon bearing rivers, migration routes, feeding locations, productive lobster or shellfish beds, or other sensitive habitats. Setting site guidelines of a specified distance from a salmon stream or migration route is not, in several cases, adequately precautionary.
DFO should work with industry to phase out current aquaculture sites located in these areas — using the precautionary principle as the motivation for this policy. This siting policy would help prevent interaction and disease transmission between farmed and wild salmon. In a 1999 report, DFO recommended that the siting of cages within salmon rivers or near their mouths should be avoided because complete containment is not feasible, and even if achieved, would not eliminate the risks of ecological interaction or disease transmission between farmed and wild salmon.
Closed-Loop Systems
In Part III, the report states:
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.
Then, the report states in Recommendation 20:
That government dedicate funds for research on the environmental effects of net-cage systems, and the improvement of closed containment technology. These new systems should be phased in on a trial basis.
I strongly urge the government to work with industry to develop closed-loop aquaculture systems for fin fish aquaculture. The use of closed-loop fin fish aquaculture should be phased in as the only system permitted in Canada. Closed-loop containment, on land or at sea, isolates the fin fish farm from the marine environment by replacing net cages with impermeable structures. Water, waste, and other elements within the fish pen are contained and not released into the surrounding environment in a closed-loop system. Isolating the farmed fish in this manner may resolve many of the environmental concerns associated with aquaculture. While closed loop systems involve a higher capital investment, these costs can be offset by greater yields. Fewer fish escapes, more efficient use of food, and high fish survival rate are some of the economic benefits of closed loop systems. The government should work with industry to support the research and development of closed loop aquaculture systems.
Due to the diverse opinion and controversy of fin fish farms in British Columbia, we believe a moratorium on the further expansion of fin fish farms in this province should be continued until all major stakeholders can reach agreement on their issues and concerns.
Fish Meal and Fish Oil
In Recommendation 21, the report states:
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 fish meal and fish oil.
That the federal government promote the research and development of feeds that use a greater proportion of plant-based proteins and oils.
The federal government should set immediate reduction targets to eliminate the use of fish, that could be used for human food (such as herring, mackerel, sardines, and anchovy) as the primary feed for farmed salmon. Also, the federal government should prohibit the use of any feed derived from a genetically modified crop. The Federal New Democratic Party does not support the use of genetically modified, engineered or altered fish for aquaculture purposes or any other use.
Regulatory Responsibilities
Critics of aquaculture have debated whether DFO should maintain responsibility for aquaculture at the federal level. After much thought, I believe that DFO should remain the federal department responsible for aquaculture. That said however, DFO must ensure the protection of wild fish stocks and their habitat is its first priority and ensure that the aquaculture industry meets the provisions of the Fisheries Act, the Navigable Waters Acts and that the provisions of the Canadian Environmental Protection Act are applied to all existing and future aquaculture facilities.
Use of Pesticides
In Recommendation 15, the report states:
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;
The use of pesticides that have not been thoroughly tested for their effects on marine organisms should be prohibited. Furthermore, when products are approved for use under the Pesticide Control Products Act (PCPA), their use may contravene the Fisheries Act. As I recommended earlier, DFO must ensure the protection of wild fish stocks and their habitat is its first priority. Sections 35 and 36 of the Fisheries Act prohibit the harmful alteration, disruption or destruction of fish habitat and the deposition of deleterious substances into waters frequented by fish. DFO must ensure that all aspects of aquaculture operations — including pesticide use - do not contravene the Fisheries Act.
In addition, the government must set maximum residue limits for any pesticide in use for farmed salmon going to market in Canada. Limits have not been set for emamectin benzoate and ivermectin — pesticide products still awaiting approval for use in fish. These products, however, have been prescribed and used on farmed salmon in Canada through the Emergency Drug Release program of Health Canada. Residue limits must be set to protect the health of consumers.
Additional Recommendations
In addition to the above suggestions, I have some specific supplementary recommendations. They are as follows:
| • | The federal government should regulate industry to adopt a labelling system for farmed fish. Consumers should be able to make a personal, informed choice between wild and farmed fish. Farm salmon is currently labelled “fresh” or “Atlantic” but for many consumers the relevant distinction is ‘farm or wild’. |
| • | The government should place a permanent ban on the krill fishery within Canadian waters and ban any importation of krill. Krill is a large shrimp like plankton eaten by whales and many fish including herring and salmon. Krill is in high demand by the salmon farming industry as krill acts as an effective feeding stimulant. Scientists have warned that catching fish with lower trophic levels (e.g. krill and herring) may greatly impact the sustainability of fish population. These smaller fish form the building blocks of the marine ecosystem and are food for the larger fish. Harvesting these small fish impacts on the amount of food left for the ‘high trophic level’ fish. |
Conclusion
I want to thank all the members of the committee and witnesses who participated in this report. I trust that you will give my suggestions serious consideration and I thank you for the opportunity to provide my input.
Sincerely,
Peter Stoffer MP
Sackville-Musquodoboit Valley-Eastern Shore