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9) Please explain in detail how wild salmon migrations, both adult fish and juveniles, have been taken into account in the siting of these farms beyond the arbitrary 1 km distance from any stream mouth?
10) The Strategic Salmon Health Initiative, a collaborative research project between the Pacific Salmon Foundation, Genome BC and Fisheries and Ocean Canada is examining pathogens and disease as a factor in high mortality rates of juvenile salmon in BC (
http://www.genomebc.ca/index.php?cID=1235). The first public reporting of results is anticipated for September 2014. This coupled with the conclusion from the Cohen (2012) Inquiry, that pathogens and disease associated with salmon farms are a risk to wild salmon, infers that moving forward with an expansion of new farms sites is not a precautionary direction and further puts our wild salmon economy at risk. Will the results of the BC Genome study around the risks of pathogens and disease be reviewed and incorporated prior to any decision making around these applications?
Abalone:
11) In consideration of the following points, will further assessment for abalone take place?
• The fieldwork for these abalone surveys was conducted between August 6 to August 11. This is a time of year when the amount of growth in the shallows makes abalone detection extremely challenging. The much greater likelihood of detection is before May/June.
• Two transects of the Wanx talis application Transect 8A (northwest side of the bay) and Transect 10B (southeast side within proposed tenure) had densities of 0.11 abalone/m2 (critical threshold density of 0.1 abalone/m2 identified in the 2012 Action Plan for this species [DFO 2012]).
• Figure 5 on page 98 of the pdf; shows significant amount of good abalone habitat within the proposed Wanx talis tenure. Again, the Wanx talis Abalone Population Assessment states; “If this site is chosen for development additional assessments of the area may be required.
• Both the Wanx talis Abalone Population Assessment and the Ghi ya Abalone Population Assessment state “if this site is chosen for development, additional assessment of the area may be required.”
12) Are there videos of the survey swims and will they be made available?
13) What types of abalone monitoring are required for such sites were they to be approved for development?
Marine Mammals:
14) Steller Sea Lions: The notation that Pacificus Biological Services observed a Steller sea lion in Ghi Ya in June of 2011 does not belong in this report as this appears not to be part of any survey but rather is an anecdotal sighting. Sightings of Steller sea lions are frequent in the area and the close proximity of the year-round haulout at Ashby Point means that interactions with Steller sea lions will be inevitable were there to be open net facilities at these sites. With Steller sea lions being recognized as being of “Special Concern” and thereby under protection of SARA, what management will be undertaken? Will there be culls? And if so, under what authority will this exemption from SARA be undertaken?
15) Sea Otters: Since the 2008 Raincoast Conservation Foundation report referenced in the applications, Sea Otters have become common in this area and are recognized as being of “Special Concern”. This is no consideration of Sea Otters in the applications. Will an effort be made to get more recent data regarding Sea Otter use of the area?
16) Cetaceans: Has any effort been undertaken to get sightings data from the DFO Cetacean Research program and the BC Cetacean Sightings Network?
Sediment Sampling:
The Baseline Sediment Assessment Report for Ghi ya was prepared by Mainstream Biological for the Tlatlasikwala First Nation and amalgamates data collected by Marine Harvest Canada (agent for the proponent). The entire Baseline Sediment Assessment Report for Wanx talis was prepared by Marine Harvest Canada (agent for the proponent). These Baseline Sediment Assessment Reports are not independent and allow for conflict of interest. Still, the two reports appear to contain conflicting information regarding the heavy metal results at the three Reference Stations selected. According to Ghi ya assessment, elevated copper levels resulted at one of the three Reference Stations (page 263 of the Ghi ya pdf) yet the Assessment for Wanx talis (prepared by Marine Harvest Canada), indicates mean copper results were above standard for two of the three Reference Stations selected (page 294 of the Wanx talis pdf).
17) Why is DFO accepting a baseline report from an agent of the proponent?
18) Were the three selected Reference Stations the same for both applications?
19) Why were these Reference Stations selected when some produced above-standard mean copper results?
20) Were other potential Reference Station locations considered and sampled?
Please respond to:
Stan Proboszcz -
proboszcz@watershed-watch.org
Jackie Hildering -
jackie@saveoursalmon.ca
References:
Cohen, B. 2012. The uncertain future of Fraser River sockeye. Commission of Inquiry into the decline of Fraser sockeye.
Connors, B. M., Krkošek, M., Ford, J. and Dill, L. M. (2010) Coho salmon productivity in relation to salmon lice from infected prey and salmon farms. Journal of Applied Ecology, no. doi: 10.1111/j.1365-2664.2010.01889.
Hutchings, J.A. and 9 other authors. 2012. Sustaining Canadian marine biodiversity: responding to the challenges posed by climate change, fisheries, and aquaculture. Expert panel report prepared for the Royal society of Canada, Ottawa.
Miller, K. and 13 other authors. 2014. Infectious disease, shifting climates, and opportunistic predators: cumulative factors potentially impacting wild salmon declines. Evolutionary Applications. doi:10.1111/eva.12164.