Salmon Aquaculture

Submission re: Rezoning of Bute Inlet

June 5, 2001

Chairperson and Directors
Comox-Strathcona Regional District
RR 4, 4795 Headquarters Rd.
Courtenay, BC V9N 7J3

(Hand-delivered to Sonora Lodge public hearing, June 9)

Dear Regional Directors:

Re: Application by Heritage Aquaculture for re-zoning of Bute Inlet

The Georgia Strait Alliance (GSA) is made up of organizations, businesses and individual members from around the Georgia Basin, with a common goal: to protect and restore the marine environment and promote the sustainability of Georgia Strait, its adjoining waters and communities. Fifteen of our total of 50 member groups, and approximately about 100 of our individual members live within your Regional District. I am writing to express our concerns about Heritage Aquaculture's proposed siting in Bute Inlet of two relocated fish farms, one new technology pilot project, and one new netcage tenure (awarded to Heritage as an economic incentive for undertaking the pilot project).

We are concerned about the proposed rezoning for the following reasons:

1) Wind and weather conditions:

The "Bute Winds" are extreme and pose severe challenges for any marine-based aquaculture operation, which in our view make Bute Inlet inappropriate for salmon aquaculture. Residents report that the wind often keeps up for a week at a time. A member of our organization who used to run a boat charter operation in the area reports that he often had to get his guests out of Bute Inlet quickly by float plane when a Bute Wind was starting and that if he did not act quickly, the wind soon became too dangerous to land a plane. Sixty mile per hour winds are not unusual and we are told by local residents that winds up to 140 MPH have been recorded. The company has provided data that showed lower wind values, but this data was for other sites and not relevant to Bute Inlet itself.

Winds in Bute Inlet can be very strong year-round, but in the winter, they are particularly dangerous as they cause icing of the salt water spray, which residents report can lead to a 12 to 24 inch ice accumulation. This would add considerable weight to the pens, to the point of possible or even likely sinking in severe winter weather. In such conditions it is unlikely that workers could even remain on the sites, as the wind chill factor would be unbearable and the rough conditions would make the netpen floats dangerous to walk on. Therefore it is highly unlikely that the company could prevent pens from sinking, breaking apart or coming loose from their moorings. Such an event would almost certainly result in escaped fish.

2) Potential colonization of local streams by escaped Atlantics

Heritage plans to use Atlantic salmon at all of the sites. Atlantic salmon are a different species than the five species of Pacific salmon native to BC, with a different evolutionary background and life cycle. The continuing use of this alien species in BC netpens carries a significant degree of risk to indigenous salmon, not only through risk of exotic diseases, but also through colonization of wild salmon habitat.

A large escape of farmed salmon would likely lead to colonization of some local streams by Atlantic salmon. A recent Norwegian parliamentary committee looking into impacts on wild salmon has concluded that farms should not be put in fjords with wild salmon populations. Bute Inlet has several streams with wild salmon populations.

The info given by Heritage in its current application to BC Assets and Lands (which was intended to allay concerns about escaped fish moving away from the farms) was based on experiments with "cultured steelhead trout", not Atlantic salmon, the species that Heritage intends to culture at the proposed sites. We would respectfully suggest, therefore, that the information Heritage provided is therefore irrelevant.

Industry spokespersons have said repeatedly that the marine survival of Atlantic salmon is very low, that they do not appear to be able to feed successfully after escaping and that they are not able to colonize streams. (This was stated in the media by the president of the BC Salmon Farmers Association as recently as April of this year.) But this is clearly inaccurate. The industry arguments are largely based on failed attempts in the 1930's to introduce Atlantics to a river in BC, an experiment which is largely irrelevant now.

The best evidence available regarding Atlantic escape behavior is from the many actual escape incidents that have already occurred in BC. In virtually all cases, commercial fishermen have caught large numbers of Atlantics - even at a considerable distance from the farm site - and in many cases these fish have entered freshwater. Atlantic salmon have been found in over 70 BC streams, mostly on Vancouver Island, but also as far away as 100 miles up the Skeena River (250 miles from the nearest fish farm). Clearly they survive well in the marine environment and they survive in rivers. Worse, juvenile Atlantics of at least two age classes have been found by researchers (led by John Volpe of UVIC) in at least three Vancouver Island streams, indicating that escaped Atlantics have successfully spawned there. The real number of streams now inhabited by either adult escapees or their progeny is probably much higher, since monitoring up until very recently was confined to Vancouver Island.

The long-term impacts of these fish are not known. But leading-edge research by John Volpe shows that Atlantics in our streams are aggressive and efficient feeders and that depending on the timing of their entry into the river, they may successfully outcompete native species. This could spell disaster for the local economy of the Stuart/Sonora Island area, which is highly dependent on sports fishing and therefore needs healthy wild salmon runs.

3) Potential impacts on disease and parasites on marine species

The potential for the transfer of disease pathogens or parasites to wild salmon is also a threat, including juvenile salmon migrating out from several rivers in Bute Inlet. Wild salmon migration patterns are typically close to shore - i.e. along the path where the farms will be located.

In Scotland and Ireland, declines in wild salmon have been significant in all of the areas with fish farms, and in 1999 the Scottish Environmental Protection Agency stated that "damage to stocks of sea trout and wild salmon by sea lice associated with caged fish farming is very serious in certain circumstances, and should now be accepted as beyond reasonable doubt." The Agency recommended that fishfarms be located well away from entry points of smolts to the marine environment - unlike the Bute Inlet sites.

Sea lice have been a problem for fish farm companies in BC as well, including Heritage. In February 2000, the company accidentally killed 7,000 salmon at its Whelis Bay farm in the Broughton Archipelago, with an overdose of Ivermectin, a highly toxic pesticide used to kill sea lice. The BC salmon farming industry has been loathe to provide any information on how sea lice infestations are treated. When a study (jointly funded by the BC government and the industry) was conducted into sea lice treatment, the industry gave assurances to government that no chemicals or drugs were being used. However, freedom of information requests found these claims were not true - that in 1997 alone, 107 kg of Ivermectin were dumped into the ocean at farms on the west coast of Vancouver Island. It is worth noting that Ivermectin's manufacturer does not recommend the pesticide for marine applications because of its toxicity to other organisms.

Ivermectin is applied in fish feed to deal with a sea lice outbreak. Much of the feed that is thrown into the water at salmon farms is not eaten by the fish, and drifts through the netcages, to be eaten by other marine life such as prawns.

The risk of disease transfer to wild salmon is also a concern. In Scotland, infectious salmon anemia (ISA), which was first observed in farmed salmon, has now been found in at least five species of wild fish including salmon and herring. In New Brunswick, infectious salmon anemia from fish farms was found for the first time in wild salmon in rivers late in 1999. We are fortunate in that ISA has not yet been detected in BC. But it seems only a matter of time until it is brought here - since ISA is now found in every country from which Canada imports Atlantic salmon eggs. By placing open netcage fish farms in the path of migrating wild salmon runs it seems that we are courting disaster. ISA is, of course, only one of the many potential diseases that we could be risking.

4) Impacts on the prawn fishery

Prawns were not included in the inventory of fisheries resources that the company provided in its application, yet prawns are fished commercially in Bute Inlet. Waste and/or antibiotics and other chemicals from the farms could impact the prawn fishery.

5) Emergency response

The company's proposed emergency response plan appears inadequate. They propose to situate emergency vessels in Campbell River, to serve all of Heritage's farms in the area (which includes farms in Okisollo and Nodales Channels as well). This might be adequate if there were not a network of narrow, fast-flowing tidal passages separating Bute Inlet from these other farms and all of the farms from Campbell River. Depending on when and where an escape occurs, the emergency crew could need to wait several hours before getting through some of these passages and could therefore be very slow to arrive on the scene - too late to be able to contain a major escape of fish or deal effectively with an emergency.

6) Lack of information

We strongly regret the fact that the public has been unable to see any comments on the suitability of these sites from the Department of Fisheries and Oceans before the Regional  District's public hearing and the public meetings that the company hosted earlier this year. This information should have been provided in advance of any public meetings on these site applications. DFO is required to assess the sites vis-à-vis potential impact on wild salmon and other fisheries, yet has apparently not yet finished their report. Until this is done and the public has had a chance to digest the report, public meetings, referral processes and any decisions on the sites should be on hold.

DFO staff have told us unofficially that DFO has concerns with one of the sites on the east side of the inlet due to low current flow and nearby streams. Such information should be part of the public record from the outset of this process. BC Assets and Lands (BCAL), which is the foreshore tenure issuing agency, has promised us that citizens will have time to comment after DFO's report is released, no matter when that is. But the mechanism and timeline for this is not clear to us and we are concerned that pressure from the company might result in a decision prior to or too quickly after release of DFO's report. In a case that occurred within the Regional District of Nanaimo, BCAL is now being taken to court over a shellfish aquaculture tenure that was granted prior to any public notice, public meetings or public referral process.

For these reasons we urge you to reject the rezoning application at this time.


Laurie MacBride,
Executive Director, Georgia Strait Alliance


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