Submission on Proposed Rezoning of Gunner Point and Yorke Island

Submission to the Strathcona Regional District

Public Hearing for Rezoning of Yorke Island and Gunner Point

April 14, 2009

Re: Bylaw 29, Quadra Island Zoning Bylaw, 1990, Amendment No. 95

Georgia Strait Alliance (GSA) is made up of organizations, businesses and individual members from around the Georgia Basin, with a common goal, which is to protect and restore the marine environment and promote the sustainability of Georgia Strait, its adjoining waters and communities.

GSA has been studying open net-cage salmon farming and its impacts for almost two decades. Thus, we have serious concerns about the zoning application by Grieg Seafood for two open net-cage Atlantic salmon farm tenures at Yorke Island and Gunner Point in Sunderland Channel.

These proposed sites are located along the migration routes of the vast majority of mainland salmon stocks south of the Broughton Archipelago, including Fraser River runs. Sea-going juveniles and returning adults use the bays and back eddies in Sunderland Channel to rest and wait for a favourable tide. Salmon are known to spawn and rear in this area. The addition of two more large farms directly on these migration routes will increase the already damaging incidence of sea lice on migrating stocks.

While sea lice are a naturally occurring parasite on adult salmon out in the ocean, juvenile salmon rarely come into contact with sea lice as they migrate out to sea. However, fish farms located on migratory routes provide sea lice with millions of host adult fish, allowing the lice to proliferate and survive in near shore waters. Juvenile salmon are then exposed to sea lice infection as they pass by the farms.

Recently published science has confirmed elevated levels of sea lice infection on juvenile Pink and Chum salmon near fish farms throughout the northern Georgia Strait area. Juvenile sockeye and herring have been found to be infected with sea lice as well. DNA analysis of the sockeye sampled confirmed that the majority are Fraser River sockeye from 30 different subpopulations, indicating that the impact of sea lice from fish farms has much farther reaching impacts than previously suspected.

Scientific analysis has show that where ever there are open net-cage salmon farms in the world, wild salmon stocks are declining at a faster rate than where wild salmon on not exposed to sea lice from fish farms.

In fact, this board has stated that "it has been scientifically proven that open net-cage fish farms can have serious negative environmental impacts, particularly on wild salmon runs" as part of a resolution passed last July.

While all salmon stocks migrating north past these farms are at risk of infection from sea lice, most immediately impacted by the proposed farms would be salmon stocks in nearby Plum Creek, which would be exposed to sea lice as they leave the stream at an extremely young and vulnerable size. Plum Creek is a fish bearing stream barely outside the required 1 km distance from the Yorke Island proposed tenure at 1.2 km, and only three km from Gunner Point. This stream contains blue listed[1] Cutthroat Trout and Dolly Varden, Rainbow Trout, Coho, Chum and Pink salmon. Also at risk of extremely early exposure are seven other fish bearing streams within 15 km of these two proposed tenures. The anadromous species represented in these streams include the above mentioned as well as Chinook and Sockeye.

At 4,400 MT licenced production for each proposed farm, these would be among the largest salmon farms on BC's coast. Incidences of sea lice infection increase with the size and density of farms, and there are already two fish farm tenures in Sunderland Channel and 33 in the Northern Strait of Georgia area.

The nearest farm to the proposed sites is at Shaw Point less than four km away. Fish on this farm suffer sea lice levels well in excess of the regulated sea lice treatment trigger. Despite being treated for sea lice this past winter, by the time juvenile salmon begin their migration out to sea, the Shaw Point farm reached lice levels more than double the treatment trigger. Since that point, in one month this farm alone produced a conservative estimate of over two billion louse eggs that would not otherwise exist in Sunderland Channel.

Elevated levels of farm-source lice can be found as much as 30 km away from a farm, and not only do 8 salmon bearing streams exist within 15 km of the two sites, but juvenile salmon from as far away as the Fraser River are know to migrate past this area. These small fry will be under significant pressure from heavy infestations before even reaching the proposed farms.

Currently, the only treatment for sea lice is a highly toxic pesticide, SLICE or emamectin benzoate, which is not licenced for use by Health Canada. It is only authorized as an emergency measure under prescription by a veterinarian. However, the use of SLICE has become common practice with most active fish farms needing to apply SLICE at least once per year. Sea lice are showing resistance to SLICE in other salmon farming regions in the world. Clearly this is not an effective fish farm management regime for sea lice.

Since sea lice are crustaceans, these pesticides can also be toxic to shrimp, prawns and crabs; therefore the application of these pesticides by fish farm operators may put the local prawn and crab fisheries at risk. Given the complexity of the sea lice issue, we have enclosed for your reference ‘Sea Lice and Salmon; a Science Primer', which includes a useful reference list of sea lice science.

This zoning application is for permission to farm Atlantic salmon, a non-indigenous, invasive species, with a different evolutionary background and life cycle from the Pacific Salmon species. The continuing use of this alien species in BC net-cage salmon farms carries a significant degree of risk to indigenous salmon, not only through risk of exotic diseases, but also through colonization of wild salmon habitat. Atlantics, which can only have escaped from salmon farms, have been found in over 80 rivers and streams, and since only a fraction of our waterways are monitored for Atlantics, the number could be much higher. DFO's Atlantic Salmon Watch program has recorded 235 Atlantic Salmon in the nearby Salmon River between 1995 and 2002, and Atlantic Salmon have been found as far up the Fraser River as Lillooet.

The open net-cages used by salmon farms worldwide also allow contaminated waste, including waste feed and feces laced with antibiotics and pesticides as well as toxic net coating substances, to fall untreated to the ocean floor. Waste can build up under the pens smothering the ocean bottom, contaminating the marine ecosystem and depriving a number of species of oxygen. This could have a significant negative impact on rockfish populations, especially in light of the sedentary nature of rockfish. Currents in Sunderland Channel are low according to the Johnstone - Bute Coastal Plan and the Plan identifies a significant area of rockfish and ling cod along the channel's southern shores. The Xwémalhkwu First Nation have identified the waters north west of Hardwicke Island as an Xwémalhkwu Rockfish Conservation Area. Ling cod, rock cod and red snapper have been traditionally harvested in this area. Contaminated waste concerns extend to many species in addition to rockfish. Clam beaches identified in the bays located around the proposed Yorke Island site, threatened (COSEWIC) invertebrate species present around Yorke Island, Dungeness Crab in Blenkinsop Bay, Yorke Island and eastward along the shoreline of Hardwicke Island, and prawns throughout both North and South Sunderland shores and Yorke Island would be put at risk.

A partial list of species found at the Gunner Point and Yorke Island sites as noted in Grieg Seafood's Finfish Aquaculture Applications includes, but is not limited to: Lingcod, China Rockfish, Quillback Rockfish, Copper Rockfish, Greenstripe Rockfish, Tube Snout, Pipefish, Striped Seaperch, Pile Perch, Shiner Perch, Flathead Sole, Dover Sole, Rex Sole, Slender Sole, English Sole, Rock Sole, Kelp Greenling, Whitespotted Greenling, Penpoint Gunnel, Longnose Skate, Spiny Dogfish, Tidepool Sculpin, Longfin Sculpin, Spotfin Sculpin, Roughspine Sculpin, Blackfin Sculpin,  Sturgeon Poacher, ratfish, flounders, Blackbelly Eelpout, White Barred Prickleback, Pacific Snake Prickleback, Northern Ronquil, Squat Lobster, Red Rock Crab, Dungeness Crab, Puget Sound King Crab, Tanner Crab, Slender Cancer Crab, Longhorn Decorator Crab, Northern Kelp Crab, Slender Kelp Crab, 5 species of hermit crab, Prawns, Humpback Shrimp, Sidestrip Shrimp, Spiny Pink Shrimp, Dock Shrimp, North Pacific Bobtail Squid, Red Octopus, Giant Pacific Octopus, California Sea Cucumber, Orange Sea Cucumber, Pale Sea Cucumber, Creeping Pedal Sea Cucumber, Red Sea Urchin, Green Sea Urchin, Heart Urchin, Pacific Gaper Clam, Spiny Scallop, whelks, limpets, snails, lampshells, Hooded Nudibranch, Opalescent Nudibranch, 6 species of chiton, Leafy Hornmouth, Frilled Dogwinkle, 2 species of dendronotid, 3 types of barnacles, several types of anemone, over a dozen kinds of sea stars, jellyfish, bull kelp, winged kelp, eelgrass, rockweed, sea lettuce, rock crust, orange cup coral, and many other kinds of marine plants, sponges, squirts, turnicates and worms.

Of the species identified on the sites, 10 of them: Green and Red Sea Urchins, Dock Shrimp, Prawns, Sidestripe Shrimp, Spiny Pink Shrimp, Humpback Shrimp, Red Rock Crab, Dungeness Crab, Slender Cancer Crab, Pacific Gaper Clam and California Sea Cucumber are commercially fished. Additionally Bull Kelp and Eelgrass, found at both sites, are defined by DFO as important species habitat and could be impacted by the deleterious waste.

These proposed sites both exhibit incredibly rich diversity, and the mechanisms in place that are meant to protect that biodiversity would in fact allow fish farming to continue with up to half the biodiversity being lost as a result of untreated waste. The Ministry of Environment regulations, which determine whether a farm can restock after harvesting or is to remain fallow, allows for a 50% loss of biodiversity right next to a fish farm tenure based on measurements of sulfide levels at peak biomass production on the farm.

Open net-cage salmon farming also impacts sustainable activities that are critical to the economy and quality of life of coastal communities. Johnstone Strait is vital to BC's commercial wild fishery, and this fishery can only be sustainable if wild salmon habitat is properly protected. This area is utilized significantly by Area H troll fishery, Area D Gillnetters and Area B Seine fisheries. There is also a commercial crab fishery in Blenkinsop Bay, immediately adjacent to the proposed new farm sites as well as a prawn fishery in the area.

As environmental awareness has grown, wilderness tourism has also established itself as one of British Columbia's most sustainable and non-consumptive industries. The proposed sites would negatively impact tourism operations and outdoor recreationalists by degrading the marine wilderness characteristics that draw visitors to the area. Industrial, open net-cage fish farming is inconsistent with the fundamental characteristics upon which tourism operators in the area depend.

Georgia Strait Alliance supports a vibrant salmon aquaculture industry that contributes to the economy of coastal communities. There are methods in use all over the world which farm fish in manners that are safe and ecologically sustainable. However, salmon farming in open net-cages is not one of these. Salmon aquaculture should be carried out only in closed containment systems that are built to eliminate the risk of escapes, disease and parasite transfer, and waste discharge to the marine environment. This Board has recently supported the development of closed containment technology, as evidenced by the passing of this resolution last July[2]:

WHEREAS the Strathcona Regional District receives significant economic benefits from both wild and farmed salmon and depends on the future security, viability and stability of both sectors;
AND WHEREAS it has been scientifically proven that open net-cage fish farms can have serious negative environmental impacts, particularly on wild salmon runs;
AND WHEREAS emerging closed containment aquaculture technologies offer the ability to separate commercially farmed fish from the natural environment limiting negative environmental impacts especially the transition of diseases and parasites between farmed and wild salmon:
NOW THEREFORE BE IT RESOLVED THAT the Strathcona Regional District board of directors requests that the provincial government allocate funds toward the establishment of a closed system aquaculture innovation and development fund to assist with the implementation of a plan to transition commercial scale open net-cage fin-fish aquaculture to closed containment system aquaculture.

The request of the BC government to fund closed containment technology research and development is supported by Marine Harvest Canada, the Special Committee on Sustainable Aquaculture, the Pacific Salmon Forum, BC's Select Standing Committee on Finance and Government Services, community groups, concerned citizens, and 10 other local governments in BC, including the Village of Sayward.

Approving zoning for two large new fish farms in the Strathcona Regional District and allowing the industry to expand is a step in the wrong direction, causing increased damage to local ecosystems and province-wide salmon runs, requiring future mitigation to reverse the damage already wrought, and reducing any incentive the industry may have to adopt sustainable closed containment fish farming technologies.

Also of concern is the timing of this hearing, which makes it extremely difficult for a number of people who have serious concerns about the installation of fish farms in these two locations to have sufficient input. Many people involved are not available for notification of this hearing let alone able to respond, due to the hearing occurring just after a significant holiday.

In conclusion, we ask that you again recognize the importance of a healthy marine ecosystem and that you take whatever steps are available to you as Regional Directors, to protect and conserve the valuable marine resources upon which our communities depend. We also urge you to uphold the support you have already stated for the development of viable closed containment technology and the future of the wild salmon that pass through these waters. We therefore ask that you, the Regional Directors of Strathcona, deny this application for rezoning by Grieg Seafood to locate open net-cage fish farms in the sensitive ecosystem of Sunderland Channel.

We thank you for the opportunity to participate in this hearing and wish you success in your deliberations. Please see our website for more in depth information at http://www.georgiastrait.org/.

Submitted by
Michelle Young
Salmon Aquaculture Campaigner
Georgia Strait Alliance
michelle@georgiastrait.org
(250) 753-3459

Encl:/
Sea Lice and Salmon: a Science Primer

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[1] Species are assigned to provincial lists depending on their Provincial Conservation Status. Blue listed species include any indigenous species or subspecies considered to be of Special Concern (formerly Vulnerable) in British Columbia. Taxa of Special Concern have characteristics that make them particularly sensitive or vulnerable to human activities or natural events. Blue-listed taxa are at risk, but are not Extirpated, Endangered or Threatened.

[2]  Closed Containment Systems Resolution passed by the Strathcona Regional District per minutes from the July 31, 2008 meeting.