N.S. fish farm rejected: risk to wild salmon.

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A proper study would take Juvenile Coho salmon, treat half with Slice and leave the other half untreated. Tag them and release them. Record survival rates of returning adults and note if there were any differences in survival rates. Repeat for 10 years. That's how you tell if there is any Lice impact, not some farcical mathematic exercise reaching agenda driven conclusions.
would I like to see more research being done on the effects of open net-cages on wild stocks? Yes I would.

Would I like to see more research being done on sea lice, specifically transfer to wild stocks and population-level effect? yes I would.

Do we have to wait 10 years to do something? NO we certainly do not.

We already have a number of lice studies done in BC, and the rest of the world. Certainly enough to invoke the precautionary principle.

Yes there are restrictions in the utilization of mathematical studies and the extrapolation onto non-lab based ocean food webs.

Yes there are assumptions inherent in ALL studies (INCLUDING the Irish one).

Yes, studies utilizing escapement data from DFO (w/o fish fences) are utilizing inaccurate data. Over a broader scale - some of that variable error can be dampened-out - which is what Kroksek did.

Without a fish fence - replicating the Irish study would also have to depend upon escapement data.

The cons to the Irish study would be cost and a long time commitment. Myself and others on this forum already stated that they wouldn't want to see this as a stalling tactic.

There are other equally-valid experimental designs for studies - such as a BACI (Before-After Control-Impact). If you have already pissed in your own soup and NOT done the "Before" part - that narrows your options.

If we had insisted on scientifically-defensible siting criteria - instead of making it convenient- we might not be in this untenable situation.

Instead you may have to do find a “untreated” part of the BC Coast that most closely resembles your situation, and assume that sea lice levels would have been similar to your own BEFORE the farms arrived. This is called a Extensive Post-Treatment Study – which is what Krkosek did. And yes - there are assumptions here, as well.

There is a real nice and brief primer on the setting-up of studies for watersheds at:
http://www.env.gov.bc.ca/wld/documents/wrp/wrpr_1.pdf
 
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It is too bad that no one bothered to do the "Before" monitoring. That would have provided the oppurtunity to answer so many questions right now.

Any newly issued or reconfigured sites now go through extensive monitoring before the cages go in. Are these being monitored on an annual basis and have these results been presented, or reported?

You know the old joke about the 3 statisticians that went deer hunting? They spotted a deer in a clearcut 100 yds away. First Stat jumps up fires and misses 5 feet to the left, Second Stat jumps up fires and misses 5 feet to the right, third statisician jumps up and yells "Yeah we got him".

That's my problem with a purely mathematical study like all of Krkosek's. Would you allow him to calculate the frequency of cars on a busy street, then trust him to tell you when to cross, without looking, based on his analysis? I don't think so. I think you might want to look twice.
 
Andrew,
Both arguments are fuelled by greed. Ever look into the millions of $$$ that are pumped into anti salmon farming campaigns?

Agent,
I don't think that lice levels are included in site assessments. Would be a good idea going forward if any one from DFO is reading this. Unfortunately it hasn't been done in the past. Would have been able to assess each sites impact and remove any that are in excess of acceptable levels.

Couple of good articles there regarding the Skeena area. The rest is Krkosek drivel and of little consequence.
It was interesting to read that Sticklebacks carried Leps. I always thought that Leps were a salmon only species and that Caligus was the lice of many fishes. Is MH still fallowing major migration routes through the Broughton, or are they keeping the lice levels low during out migration?

Always,
Its not that I want to buy time, but that it takes more than a year or 2 worth of data to reach a supportable conclusion.
 
Liked your joke, SF.

Is everyone aware of the siting criteria for fish farms?

Yes, sticklebacks carry Leps – but almost zero carry gravid (egg-bearing) female lice as marine 3-spined sticklebacks have armoured plates and the lice cannot finish their stages on sticklebacks because they cannot feed properly and other sticklebacks eat the lice off each other, and the egg strings (http://www.sfu.ca/biology/faculty/dill/publications/j.1439-0310.2010.01814.x.pdf). They typically grow only up to sub adult stages.

That seems to have gone unreported in the media search for alternative theories as how juvenile salmon get lice when there are few adult salmon in the neighbourhood and a fish farm just offshore. Jones (already discussed his perceived lack of transparency and accountability) was suggesting that sticklebacks could be the alternative source for lice – rather than the farm just offshore.

http://www.theglobeandmail.com/news...lapse-of-sockeye-salmon-stocks/article593332/

The problem with this suggested theory is that there needs to be the ability to transfer lice babies (from eggs to naupilar to infective copepedites) in order for that to happen – a fact I am sure Jones knew (being the “excellent and responsible” scientist) before he suggested that sticklebacks might be a new, unreported source of lice for outmigrating salmon smolts.

In this case – sticklebacks are transmuted into red herrings. They are a sink – rather than a source of lice. It would also be interesting to examine levels of lice and stages on sticklebacks in conjunction with distance or proximity to fish farms – something that Jones (again being the “excellent and responsible” scientist) would of had the opportunity to do (he already had the data) – but never reported, if he did.

Add 1 more lie to the lie box held by our public officials defending the open net-cage industry.
 
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Ah so unless the lice can leap from a stickleback to a salmon smolt, the lice on the stickle aren't a source of infection.

They would actually reduce the number of lice larvae available to infect the smolt. Interesting.

Are there any sources of "infectious" lice other than the salmon in the farms? Herring perhaps, or returning adult salmon?

It would seem that the sites should be managed to have either salmon with minimal lice levels or no salmon at all during the time when the wild smolt pass by. The industry should be actively working toward this. I would figure that MH and Mainstream have sufficient sites that they could juggle there production plans to have no lice on major migration routes during the out migration of smolt in the spring. It might mean a reduction in production, but the extended fallow periods might also have a positive effect on the production potential of the sites, that it might end up being a no loss for the company.

This is also where I see CC facilities fitting in. To minimize the time the salmon are at sea.
 
There is potential for some leaping between fish – but given the sheer potential numbers of free-swimming infective sea lice copepidites produced from fish farms, and the limited distance subadult and adult lice can effectively swim and attach to fish – it would be a very minor infective component.

There are quite a few eelgrass beds in the Broughtons and elsewhere on the coast. Three-spine sticklebacks are found in these eelgrass beds and up to 200m (or so) from these beds.

HOWEVER – not all eelgrass beds are the same. I would broadly class eelgrass beds as either estuarine or marine.

For the estuarine beds, they form from the deposition of suspended particles flocculated and dropped-out from river run-off. These beds are subject to low salinity, but would have potentially large numbers of outmigrating smolts ephemerally transiting through them during late winter to early summer – generally long before the returning adults stage at the river mouths. It is also well known that sea lice do poorly in low salinity, so their residence there would also be ephemeral – no matter what their origin. I think the potential for lice transfer from sticklebacks in estuarine beds would be low for the above reasons.

The marine beds form when fine marine particulate is moved alongshore and settles in back coves. Generally, these beds form between points and away from high-energy hard substrate beaches – which often describes the points where there is a shear zone where juvenile salmon feed.

The species most likely to temporarily utilize these marine beds would be chum and chinook. So if there a likelihood of lice transfer – it would be in these beds with those species listed above.

However, lice can only “jump” a few centimetres – so the fish would have to be in very close association. It's hard to say how effective a strategy this would be or how large a potential lice loading could be attributable to this mechanism.

Certainly as compared to potential billions of sea lice naupilar stages released by a fish farm - it doesn't seem a likely or effective alternative life history strategy:

http://www.watershed-watch.org/publications/files/Orr_2007.pdf

In addition: There's likely ~10 million farmed fish in the Broughton area, likely only 135K sticklebacks or less, and some ~2 million wild salmon that trickle-in and through the Outer Broughtons staying a week or 2 and exiting from June through September.

The most likely wild-to-wild transfer is between the earliest returning adult and/or sub-adult wild salmon (chinook) and juvenile pink salmon:

http://content.imamu.edu.sa/Scholars/it/net/pub_gottesfeld_etal_2009_sea_lice_transfer.pdf
 
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World's first land-based-farm sockeye salmon ready for harvest in B.C.




Langley operation expects to ramp up to production of 500 kilograms of fish every week



By Randy Shore, Vancouver SunMarch 27, 2013


















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•Story
•Photos ( 15 )














Willowfield Fish Farm in Langley is producing the world’s first commercially produced land-based farm sockeye.

Photograph by: Jenelle Schneider , Vancouver Sun


B.C. seafood firm Willowfield Enterprises will begin harvesting next week the world’s first commercial supply of sockeye salmon raised on a land-based farm.

The Langley fish farm expects to produce up to 500 kilograms of sockeye a week under the West Creek brand for wholesaler Albion Fisheries, according to company president Don Read. It will be sold at Choices Markets.

Initially, the harvest will be considerably smaller. Sockeye take about three years to achieve a harvest weight of two to three kilograms. Fish coming to market next week are between 1.1 and 1.5 kilograms.

“We have plans to double our capacity, but we want to take time to grow the market,” said Read, who is taking a conservative approach to growing his business. “We have been farming trout for 20 years, but we have only been profitable for three years.”

West Creek sockeye will carry the Vancouver Aquarium’s Ocean Wise sustainability certification.

“Getting Ocean Wise certification (for West Creek trout) brought a lot of awareness and really helped our business,” Read said. “It allowed us to raise our prices 20 per cent.”

Read and partner biologist Larry Albright experimented with sockeye for more than 15 years before developing a system to raise a commercially viable product.

Willowfield’s farm is based on a flow-through model, rather than recirculation common in land-based salmon farms. Water is drawn from a spring into above-ground sockeye tanks, then it flows into a series of in-ground trout ponds and finally into a holding pond before flowing into a local creek.

“In the natural trout ponds, fish waste and ammonia is absorbed into the native plants,” said Read. “So it’s actually biofiltered.”

Sediment that from the bottom of the trout ponds and the holding pond is dredged out and dried for use as fertilizer by a local farmer.

“Our water has been tested by the Ministry of Environment and certified as non-polluting,” Read said.

While land-based salmon farming is generating headlines and optimism from sustainability certifiers and ocean-based farming opponents such as David Suzuki, closed-containment fin fish aquaculture remains a niche business supplying only about three per cent of farm-grown fish.

B.C. produces about 70,000 tonnes of Atlantic salmon each year from net pens in the ocean.

The largest land-based Atlantic salmon farm in B.C. — run by the Namgis First Nation on northern Vancouver Island — is projected to produce up to 450 tonnes a year when it begins to harvest fish next year.

Willowfield will produce about 25 tonnes a year of sockeye and trout combined this year, while Agassiz’s Swift Aquaculture produces about 10 tonnes of coho a year.

A new steelhead farm near Nanaimo is taking in 50,000 smolts this month and projects harvest of about 100 tonnes a year or 2,000 kilograms a week. Taste of BC Aquafarm will employ a recirculation system that recaptures more than 99 per cent of the water used by the system. Atkinson plans to release effluent from the farm to an on-site wetland and an aquaponic-growing operation.

“I’m absolutely confident of the technology for raising steelhead,” said owner Steve Atkinson.

Atkinson raised about half of the $1.2-million capital cost of his farm from the Department of Fisheries and Oceans’ aquaculture innovation and market access program and B.C.’s agriculture innovation fund.

rshore@vancouversun.com

© Copyright (c) The Vancouver Sun


Read more: http://www.vancouversun.com/life/Wo...eady+harvest/8161539/story.html#ixzz2OrfZ4oDR
 
Agent,

So do you think there are areas where net pens could be sited that would lessen the potential for interaction with out migrating smolts?

Or is having none during the out migration the only solution?

I saw that bit on the Sockeye farm. It isn't a RAS but a flow through system. Production is not very large at 25 tonnes. Sockeye are a wonderful fish to grow. Very docile. Imagine fresh sockeye year round!!!
Whats this Steelhead farm near Nanaimo? Must Google.
 
OF COURSE I think that there are places and times where there is substantially-lowered risk of interactions between cultured and wild stocks, Sockeyefry.

I am assuming you are asking this for the benefit of opening-up that conversation to the rest of the readership. I am also assuming that you will be presenting your vision of reduced time in open net-pens for the final grow-out phase for your product as the other part of the strategy to reduce impacts to wild stocks and keep open net-cages on the coast.

Alright – yes, lets have that conversation. I am open to fully discussing all options. It all depends upon generating and regulation of valid, scientifically defensible siting criteria – and what levels of risk are we comfortable with.

Government has already forced the industry to look at localized benthic impacts that typically extend a few hundred meters past the farm site and impac benthic creatures. They use the DECAMOD modelling and redox potential to model potential loading underneath the cages – as you know. Somehow salmon farmers have no problems with this type of modelling. We have to accept these benthic impacts if we want open net-cages.

I believe we now know enough about sea lice and that potential transfer to wild juveniles to make some valid assumptions about siting and mitigate that transfer risk to wild salmonids.

We have already started monitoring and treating cultured stocks in conjunction with the spring outmigration of wild juveniles. The only thing that is glaringly left to be done is to update the siting criteria to include identification of species-specific migratory routes and nearshore holding areas of juvenile salmon, and transpose estuarine/tidal flow models onto sea lice dispersion models (like they do in Ireland and Scotland and Norway – but not here) – and identify and prevent sea lice loading from plumes of infective naupilar/copepedite stages onto juveniles.

I think we are at the stage to be able to do that – if DFO forces the salmon farm companies to do that on a site-by-site basis.

The BIG unknown is fish health and potential tranSfer of diseases to wild stocks.

It starts with having publicly-available fish health data on a site-by-site basis – which means the Provincial fish vet Gary marty doesn't get to gatekeep, and the industry lawyers can't claim “intellectual property”. It also means surveillance and planning for fish health emergencies and disease outbreaks.

It means we have yet to identify, plan and implement: Environmental Impact Policy, as well as cost-benefit analysis of alternative control/eradication strategies, predictive modeling, retrospective analysis, contingency planning, risk of disease transmissions, establishing incident plans, monitoring effectiveness of control measures, resource planning, response training, biocontainment and movement controls, quarantine orders, setting the response time limits and limits of the disease Control Area, and disposal and disinfection activities.

This is all in addition to doing the basic science for understanding individual disease vectors like ISA, and other native and non-native diseases. CFIA/DFO have an inadequate testing regieme that depends upon already knowing the virus before it is identified – the drawback of the PCR methodology. It may take weeks, or even months to confirm a disease outbreak using current disease testing protocols. Time is critical when responding to disease outbreaks; timescales of days make a difference. Waiting for disease confirmation BEFORE initiating disease response activities, is irresponsible and unprofessional.

We have a very long ways yet to go before we shut the barn door AFTER the horses have already left the barn...
 
Agent,

Agreed. I have no problem with what you are saying.

The problem with the out migration is companies are being forced to medicate fish with slice for lice levels which are very low in order to protect the wild smolts. While I don't have a problem with protecting the smolts, the increased use of therapeutants could lead to resistance.

Disease transfer to wild isn't a problem if the wild already have or are exposed to the disease because it exists in nature. It is the exotic which is brought in that is the problem. There are of course many vectors for this to occur. Yes farmed fish is one, but there are also such things as boats. I've seen alot of boats being towwed to Nootka sound that had out of province and out of country license plates. Don't suppose they were disinfected. I do know the farm industry is much more cognizant of disease transfer and the need for biosecurity measrues than your typical sportfisher or boater.

The testing for virus has always been problematic. it takes a minimum of 21 days for a CPE to occur and for the virus to be typed. The PCR is quick, but can give false positives. And that is as you say only on already ID'ed viruses.

The SOP's have to be in place for dealing with a disease before the disease occurs.

What I would propose is using a net pen sites 6 - 8 months in year 1, have it empty for all of year 2, then restock in Year 3. Essentially a site would have fish only a third of the time. Sites which were determined to be on major smolt migration routes would not be allowed to have fish from say March - June. The seedstock would be provided from CC facilities which would grow the fish from egg to approx. 1 kg, at which time they would go to the net pens.

Obviously there is alot of detail that has to be worked out, but it is not impossible to do a production schedule. The down side for the industry is their production will decrease, and the cost / kg may go up. I say may because if they do their scheduling right they could actually lower the cost of site issues such as low Oxygen, algae blooms and lice won't be a problem because the fish are not in the net pens long enough.

A closed con system like the Namgis will produce 400 tonnes. That is 80,000 5kg market salmon or 400,000+ 1kg seedstock. The overall cost of the CC facility will be the same, but the cost to produce a kg of marketable salmon will be lower with the CC /Netpen method than using a CC alone.

The net pen time I feel is necessary because the cost of the tank volume and water exchange required to grow the last 3 - 4 kgs is where the CC becomes unprofitable. The time in SW is also necessary for product quality. All CC's have a Depuration system built into them because the fish gain off flavours from the Recirc systems.

Getting the companies to do the necessary production scheduling change, and to get their plans synchronized in areas where there are two or more companies farming is a big challenge. It is however not impossible, it just takes the will to do it.
 
Well, I'm glad that some people on the ground in the fish farm industry understand and agree with the need for monitoring and openness on a number of issues, especially sea lice and fish health.

As far as I'm concerned – It's both criminal and treasonous they way some of our public officials in DFO and CFIA has conspired to do everything they can to delay, hide, obfuscate and just plainly lie - in order to hide the truth, and intimidate independent researchers and labs.

The government, currently and temporarily headed by sociopath Harper – have facilitated and pushed upper-level bureaucrats to conform to their anti-democratic, institutionalized, fear-based management style that excludes openness, transparency and inclusiveness. They have long lost the moral authority to govern or even be involved in the management of our resources. They are irrelevant in the context of being scientifically, socially, or morally responsible or responsive.

I have NO faith in any perceived good intent by senior government officials in DFO or CFIA. If we wait for or follow DFO/CFIA's lead – we will never resolve these issues. We cannot look to DFO or CFIA to set the pace, or be responsive or responsible. The upper echelon are unfortunately corrupt, in my experience. I can provide context and example details if need be.

So – how do we engage, connect and resolve these issues?
 
AND speaking of scientifically-INdefensible siting criteria: Is everyone okay with the fact that DFO and industry believes that fish only swim up to 1 km – but no more?
 
What can we do? Honestly, with the federal government following the leadership of harper, there is nothing we the people can do except to vote them out in the next election. Harper is following the ways of the Bush administration and allowing big buisness to write there own rules. Unfortunately just like the U.S housing market/bank failure, Canada is going to have an enviromental disaster leading to an economic loss. Right now its to easy to supply china with cheap oil, feed the world with farmed fish with little to no enviromental constraints....But once a disaster happens the shareholders will have thier money and unfortunatly the good people who work on the fishfarms or work in the oil industry will lose.

Lets face it, if fishfarms were closed contained people would still have jobs and the price of farmed salmon would be the same to remain competitive, but the share holders would lose income, no different than if walmart would pay its workers a fair wage and offer some benifits, products would be the same price but shareholders would lose income and big buisiness aint gonna allow that to happen.

As for the people defending fish farms, they are just trying to save their jobs, we would all do same but maybe not on a sport fishing forums as 99% of the peeps on this site really enjoy bc outdoors and want it to be saved in some sort of prestine way, and are aginst the practices of salmon farming.
 
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Guys

The problem with CC facilities is they do not have a very good history. Businesses need money from shareholders and / or loans from finanacial institutions. It is difficult to get the necssary money for a typical net pen, let alone for technology that does not have a very good track record.

This is why a site such as the Namgis project must be undertaken to prove the technologies and educate the business world. Funding for that project didn't come from the typical finanacial means, but from philantropic organisations.

RAS systems have come a long way in the last 10 years. A RAS system has the best chance at profitability of any of the CC systems. On shore systems such as the one near Nanaimo have the least chance. The RAS system has to be set up and operated on a fairly large scale such as the Namgis to really be able to investigate the inherent advantages, and to get some hard $$ costs. Tiny Coho and Sockeye farms just won't cut it.

Another issue is there are alot of minds in the current industry that have to be changed. And most people resists change.

The availability of people to run the things is another issue. People who run net pen farms aren't necessarily capable of running a RAS. There would have to be alot of retraining, and this costs $$$. Net pen sites quite frankly are not very complicated nor is their management.

I figure the Namgis project is the first step. Do it right and you will see the industry affect the change themselves. Government isn't the organ of change.
However if it fails, then the entrenchment of the industry will become more solid.
 
I figure the Namgis project is the first step. Do it right and you will see the industry affect the change themselves. Government isn't the organ of change.
However if it fails, then the entrenchment of the industry will become more solid.

This has been a very interesting and enlightening debate. Agent Aqua in particular has done a superb job in exposing the bankruptcy of DFO officialdom is dealing with the fish feed lot issues (I do wish they were not referred to as farms; they are feed lots just like cattle feed lots with hundreds or thousand of head in one place and all feed brought to them). Officials speak with forked tongues because they serve two masters - always a recipe for disaster.

The informed scientific knowledge and background of Agent Aqua is self evident and his posts have done a great deal to show up the dirty laundry of this very destructive industry and the complete lack of PREVENTATIVE research and analysis that was (not) done before these open net pens were put on our salmon migration routes. This industry has never heard of the Precautionary Principle and does not care even if they did.

However, at the end of the day this last statement by sockeyefry2 is the clincher. It effectively says that if CC or RAS systems are "uneconomic" then the industry is gonna "retrench". This is the externalisation of costs issues mentioned several times by Foxsea, in spades. It is a "we are are going to carry on and be damned" message and we don't care what happens to wild salmon or the environment. This is the cruel and ignorant face of the businessman who's economic models do not include costs to the environment, other users, or future generations.

It is a fact that, when all costs are really and truly accounted for (including the strip mining of the oceans for making feed pellets), salmon feed lots can NEVER be truly "economic". But as long as this industry is willing to spit in the faces of all those affected, including current and future generations, they will carry on anyway.

Terrible, terrible.....
 
English,

I find your interpretation of my statement unfortunate. What I meant was if the Namgis project proves CC farms to be uneconomic, then it will be further evidence that the industry will use against a move to CC's.

You do realise that all CC's use the same "strip mined pellets" right??

You make it sound like fish farms are sited willy nilly without regard for any thing. That couldn't be further from the truth. Yes there are some things that Agent mentioned which could be included, but I assure you it isn't without regard for anything environmental.

By the way, with regard to calling salmon farms feedlots:

Beef feedlots: used to finish range beef on grain during the last few months of their lives. Reason? Beef which have eaten nothing but range fodder all their lives (brown grass, trees, anything they can put in their mouths) taste like shoes. Finishing beef on grain — i.e. putting them in LOTS and FEEDing them grain for several months — makes them taste GOOD.

Salmon farms: take fish grown in land-based hatcheries, and grow them in the ocean for most of their lives. Fish are not finished on grain, but continue on a similar diet throughout their lives until they are ready for harvest.

Chicken farms: take chicks hatched in land-based hatcheries, and grow them for most of their lives in barns. Chicks are not finished on grain, but continue on a similar diet throughout their lives until they are ready for slaughter.

So English and anyone else, are we clear about why salmon farms aren't feedlots?
 
By the way, with regard to calling salmon farms feedlots:Beef feedlots: used to finish range beef on grain during the last few months of their lives. Reason? Beef which have eaten nothing but range fodder all their lives (brown grass, trees, anything they can put in their mouths) taste like shoes. Finishing beef on grain — i.e. putting them in LOTS and FEEDing them grain for several months — makes them taste GOOD.Salmon farms: take fish grown in land-based hatcheries, and grow them in the ocean for most of their lives. Fish are not finished on grain, but continue on a similar diet throughout their lives until they are ready for harvest.Chicken farms: take chicks hatched in land-based hatcheries, and grow them for most of their lives in barns. Chicks are not finished on grain, but continue on a similar diet throughout their lives until they are ready for slaughter.So English and anyone else, are we clear about why salmon farms aren't feedlots?
sockeyefry2?
Fish farms, just might fall under and be considered feedlots! :eek:
 

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If it smells like a feedlot, sounds like a feedlot, feels like a feedlot, looks like a feedlot, acts like a feedlot and fits the definition of a feedlot, then it is a feedlot!

Definition of feedlot
noun



Net pen salmon feedlots are where the livestock (in this case salmon) are fed or fattened up for sale. Pretty straightforward!
 
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The current siting criteria is STILL a HUGE issue. As I wrote way back in 2008 at http://www.sportfishingbc.com/forum...g-criteria-politics&highlight=siting+criteria

there are serious issues with the siting process itself. It is basically a sham.

The current site applications do not identify things such as larger oceanographic patterns of water circulation, or smolt migration patterns. Scotland not only accepts sea lice transfer to wild stocks as a reality - but uses Canadian modeling technology (i.e. Saucier et al.) to model sea lice plumes and oceanographic circulation patterns in Scotland. So, obviously there has been Canadian scientists within DFO working with Scottish scientists trying to grapple with the problem, there.

Yet DFO still denies it is a problem here, back in Canada.

Instead site applications only look at effects that are within an arbitrary and scientifically indefensible 1 km radius. This speaks to the lack of scope and small scale included in the assessment process, both of which are inappropriate given the wide scope and large scale of potential impacts.

The assumption for the 1 km radius is presumably that fish only swim 1 km, or maybe fish are most experienced with the metric system, verse the standard English system.

The reality is that many inland salmon smolts swim tens, if not hundreds of km downstream to the ocean, and potentially circulate thousands of km first South to North along the coast, then out to the Alaska gyre, and back again along the same route.

The reality is if scoping was included, it would have to be accepted that fish do swim - that they swim more than 1km, and that they swim into Alaska waters. This means that CEAA open net-cage applications would then be bumped into the highest CEAA process - the panel review, due to transboundary effects - and the Alaskans would then be invited to participate on the board. Alaska - where open net-cage Atlantic salmon aquaculture is illegal.

Speaking of comparing salmon farms and feedlots...

We already have buffer zones and siting criteria including migration routes to mitigate between wild bison and domesticated cattle in Alberta and the Yukon - but we can't seem to see the parallels here between wild salmon and farmed salmon? No buffers for fish. Does that make any sense to you? Does an arbitrary 1km make any sense to you?

With terrestrial farming, livestock are more-or-less (usually more) enclosed and separate from wild stock than in the aquatic environment (i.e bison do not float above, below and through the enclosed cattle herd). In the situations where there is potential for wild/cultured stock interactions - Ag Canada (through CFIA) does a risk analysis using data on wild stock habitat usage and migration routes, and creates buffer zones where cattle ranching is prohibited.

Examples include the interactions between bison and cattle in Alberta and NWT:
http://www.srd.gov.ab.ca/fishwildlif...bison/lim.html

and between domestic sheep and goats and Dall sheep in the NWT:
http://www.ccwhc.ca/Publications/NWT...Assessment.pdf

READ THE RISK ASSESSMENT REPORT ON SHEEP ABOVE AND NOTE THE SIMILARITIES WITH POTENTIAL DISEASE AND PARASITE TRANSFER BETWEEN FARMED AND WILD SALMON!!

THIS RISK ASSESSMENT IS NOT DONE WITH WITH OPEN NET-PEN SALMON FARMING. Why not?
 
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Agent,

Neither of those links came up for me.

Why would Alaska become involved? Their smolt don't pass by fish farms in BC. Unless you are talking about them intercepting the BC and lower 49 adult salmon.
 
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