---- Original Message -----

From: Belliveau, Hon. Sterling W (DFA)

To: Claire Williams
cc:  Various
Sent: Thursday, November 01, 2012 1:50 PM
Subject: (Ref. F137)

 Thank you for the opportunity to discuss our government’s position on marine based fin fish farms.  I’ve been asked by my caucus colleagues to outline our position.

 Hundreds of families across Nova Scotia rely on the aquaculture industry to make ends meet.  As a government it’s important we don’t turn our backs on these families.  As such our position on marine based farming is that we need the best regulations possible to protect the jobs of those working in the industry.  We also need to make sure that other primary coastal industries and the environment are protected-as a former fisherman I take this very seriously.

 Our approach represents a significant change from previous governments which chose to openly support the growth of the industry, without implementing a formal strategy.  As a result we had over 25 years of fish farms being approved along our coastline-without much public engagement about how to maximize the benefits and limit the risks to communities.  I believe this led to a mistrust of aquaculture by groups such as yours and it’s a big reason why we committed to, and delivered, this province’s first aquaculture strategy.

 I think we all agree that the strategy is just a first step and more work needs to be done.  That being said at the moment Nova Scotia’s fin fish farming sector is extremely small and occupies only 1.5 km square kms of coastline.  Compared to the other provinces where fin fish farms exist, Nova Scotia’s industry is a mere fraction of the size.  In fact if you look at active sites Nova Scotia industry is only 1/6 size of New Brunswick’s.

 I also must point out that since becoming government we have only approved one new marine based fin fish project, comprised of two new leases in St. Mary’s Bay.  In our strategy we are clear that we are only considering adding a small number of new sites in the future.  The slow rate of development for aquaculture your group is advocating for is the current reality in Nova Scotia.

 At current levels and with limited growth Nova Scotia’s marine based farms are very manageable and sustain hundreds of jobs.  All current active sites were approved and are heavily regulated by the province and several federal government departments.  Any operator that does not meet federal and provincial standards places its lease in jeopardy.  I also think it’s worth noting that fish farmers, just like fishermen, require a healthy marine environment to grow fish.  They too have a stake in protecting our coastal resources.

 Certainly groups such as yours have had their voices heard and have gained our attention.  It’s for that reason my department recently sent you a letter outlining the various actions we have committed to taking through our aquaculture strategy to address many of your concerns.

 

Currently we are working to develop a regulatory system that strikes the right balance for our province.  Part of this involves more dialogue with groups that oppose marine based farms.  Ultimately we want Nova Scotia’s aquaculture industry and regulatory system to be one of the strongest in the world-something all Nova Scotians can be proud of.  World-wide aquaculture has now surpassed the traditional fishery in terms of annual harvest.  With our marine based economy it’s important we remain a global fisheries leader.

 I encourage you to continue to share your thoughts with myself and our government.  You need to be part of the conversation.  I need to stress however, that this conversation must include a complete look at scientific evidence and must respect actual and tangible economic and industry trends.  Most of all it must not lose sight of the fact that right now hundreds of Nova Scotians rely on fish farming to support their families and that we need to create jobs in rural communities.

 I look forward to hearing from you in the near future.

 Yours truly,

 Sterling W.W. Belliveau



LETTER #1
February 21, 2013
 
Dear  recipients of this letter:
 
Each of you were on the distribution list of a letter Minister Belliveau sent to Mrs. Claire Williams (Ref.F 137) on November 1, 2012.  I have elected to provide each of you with additional information about open net finfish aquaculture in Nova Scotia to assist you in coming to your own conclusions. This letter is the first in a series of letters I plan to send to you on this complex and contentious issue. It is a copy of a letter I sent out today to one of your colleagues, Ms. Pam Birdsall. Constructive comments are always welcome.
 
Dear Ms. Birdsall,
I have been following the back and forth between yourself and Silver Don Cameron and thought that the following would be of direct interest to you. Our beautiful home is right on the shore of Shelburne Harbour. It is a wonderful old place that dates back to the 1840s where we have spent a great deal of time and retirement money in improving. We spend about half of our lives there, the balance in New York. My wife is a dual citizen with Nova Scotian roots that go back hundreds of years. We are in Nova Scotia by choice, not by chance, and have worked hard for the betterment of our local community, Shelburne. So what I write here is a personal story of anger, well beyond simple disappointment. It is only one story out of many on the subject of open pen finfish aquaculture throughout the Maritimes and its impact on the environment and people and how governments can defend past wrong decisions which were intended to help, not hurt coastal communities.
 
In Shelburne Harbour, there was both expansion and contraction of open net finfish aquaculture. Based on the Nova Scotia Department of Fisheries and Aquaculture (NSDFA) published data, the five former finfish sites in Shelburne’s inner harbour were all highly polluted. Kelly Cove Salmon, Ltd., a division of Cooke Aquaculture, turned in the leases of these five sites and were never required to clean up the piles of fecal matter that had accumulated under these sites. One such site was the old Sandy Point Site where recent investigations found deep piles of fecal matter with hydrogen sulphide bubbling through it. It is a dead zone. Mr. Belliveau gave Cooke three new replacement sites, one of which is also named Sandy Point. It is only 80 meters away from the old Sandy Point site, in the same shallow water and with the same, almost stagnant water, with speeds less than ten percent of normal walking speeds. There is no reason to believe that this replacement Sandy Point site won’t soon produce its own dead zone. What was expanded was that all three sites increased in size relative to the ones they replaced. The new Sandy Point site is 343% larger than the old Sandy Point site. Also what expanded is the number of fish planned for the new Sandy Point site, 500,000 versus the peak old number of 400,000.
What contracted was the distance between these three sites. The original three sites were already far too close to meet DFO guidelines of a 3 kilometer minimum separation because of bio-security concerns. Now the three replacement sites are packed even closer with the new Hartz Point site only one kilometer from the new Sandy Point site and just half a kilometer away from the new Boston Rock site. In spite of all the outbreaks of ISA Mr. Belliveau doesn’t pay too much heed to bio-security.  What also contracted is the distance between the new and larger Sandy Point site and residential areas: 500,000 fish only 200 meters from our home and those of our neighbors. At maturity, 500,000 fish will produce fecal matter at the rate of  455 metric tons per year… right next to where people live.
The Jordan Bay sites are too close together and the St. Marys Bay sites are too close together. All fail the 3 kilometer DFO separation guidance. Ignoring bio-security seems to be OK as long as Canadian citizens pick up the tab when CFIA orders ISA diseased fish to be slaughtered or consumers eat these sick fish because the CFIA approves of this…and without labels to warn consumers.
When the licenses to the two Jordan Bay sites were issued, it was posted on NSDFA’s website. If one reads these leases they refer to four schedules that are part of the leases , including one on required monitoring. Two of these schedules are posted on the website for each site, and two are missing (including the monitoring one). Several of us have politely requested copies of the missing schedules, after all Cooke has them, why shouldn’t we? We have been stonewalled. We have now been told by the NSDFA contact that we have to submit a FOIPOP to get these missing schedules.
I suggest that you make your own independent assessment of open net finfish aquaculture and how well the Provincial NDP government is serving the people on this contentious subject. Why not test the system and see if you can get these missing two Jordan Bay schedules? They have already been issued to Kelly Cove Salmon, Ltd. and are public documents, so there is no legitimate reason for the NSDFA to delay any request from you to get these schedules. If you should get these schedules, please do forward them to me. It would be greatly appreciated. Thank you.
Sincerely,
Herschel Specter
mhspecter@verizon.net


LETTER # 2
February 23, 2013
 
THE SALMON FARM JOBS MYTH
 
Premier Dexter’s promise of 490 additional salmon farm  jobs by December, 2015 is a myth. Enlarging the salmon farm industry will not prevent the depopulation of rural Nova Scotia. People will not come home to Nova Scotia for dead end jobs at $11.00 per hour.
 
The number of Full Time Equivalent (FTE) jobs per million kilograms of salmon has been steadily declining in Nova Scotia. Based on NSDFA’s own data, in 2011 there were 156 FTE jobs and a production of 5.75 million kilograms of salmon, or  27.1 FTEs per million kilograms. This is down from 35.8 FTEs per million kilograms in 2003. The newly approved sites in Jordan Bay are to hold a million fish, but only require 27 new positions. This is equivalent to 9.6 FTEs per million kilograms of salmon. At this rate it would take about 36 large new sites to achieve Premier Dexter’s job promise or one new site approved each month for three years. Can this be done without a full NSDFA staff? Further, Minister Belliveau has stated “ In our strategy we are clear that we are only considering adding a small number of new sites in the future.”
.  
Cooke Aquaculture advertises fish processor jobs at $10.93/ hour ($19,128/year). Workers would stand for extensive periods of time doing repetitive work in a cold/refrigerated work environment. How many young people would stay in the Province when McDonalds in Alberta pays counter attendants $22,700/year and managers $30,293/year, with far better working conditions?
 
Cooke uses high speed automation to fillet fish in New Brunswick. When such a  machine was placed in Newfoundland, processing shifts were reduced from two to one. Automation has affected value-added salmon products too with high speed machines capable of adding salt, spices,batter,flour and can precisely slice, grade, load, and package fish.
 
The jobs promised by 2015, the number of new sites needed, the low pay scales, the effects of automation, and the lack of an experienced NSDFA staff to process license applications do not fit together. Minister Belliveau needs to publicly present a detailed, verifiable, business plan before any fish site is stocked.
 
Herschel Specter
Friends of Shelburne Harbour
 
mhspecter@verizon.net
 
LETTER # 3
February 24, 2013
 
SALMON FARM JOBS MYTH—PART TWO
  
In September, 2010 an article appeared in the Chronicle Herald where Shelburne’s CAO, Kirk Cox, recently back from being flown over to New Brunswick in a Cooke Aquaculture private plane, stated that Shelburne wanted 350 full time fish processing jobs with a $150 million dollar investment in a new fish processing plant. All this was to be operational by the end of 2011. It didn’t happen.
 
In July, 2011 Nell Halse, a Cooke Aquaculture V.P., stated at a public meeting in Shelburne “Our plan was to open a processing plant in the fall of 2012 [that] was the schedule and we are a little later in getting fish in the water than we thought, but there is no reason if everything goes well that we can’t follow that timeline.” Well everything hasn’t gone well. 2012 is over and still no jobs.
 
In July, 2012, at the $25 million dollar giveaway in Shelburne of taxpayer dollars by Premier Dexter to Cooke Aquaculture, Ross Butler, VP of Cooke Aquaculture, and Premier Dexter made identical promises: 490 additional full time jobs in the open net finfish industry by December, 2015…another multiyear schedule slippage with no explanation for the delay. Such a large increase in the additional number of jobs by 2015 seems to be unachievable. The statistical data on the NSDFA website show that until now it took about one million kilograms of harvested salmon per year to employ 27.4 equivalent full time workers. In order to create 490 new jobs an additional 17.9 million kilograms of salmon would have to be harvested each year at the historical employment rate. In 2011 the Province produced 5.4 million kilograms of farmed salmon. To reach  an additional 17.9 million kilograms per year Nova Scotia’s annual production rate of farmed salmon would have to increase by 423% between now and 2015. Nova Scotia has never seen such a rapid increase in farmed salmon. The 2012 open net finfish employment and production levels have not been posted yet on the NSDFA  website,  but there likely will be a decrease because of closed sites due to the spread of infectious salmon anemia (ISA).  Recently 27 new salmon farm jobs have been promised when the two sites in Jordan Bay were licensed this year. These sites are scheduled to contain 500,000 fish per site. Using the DFO number of 5.65 kilograms per fish and a two year production cycle, this would come to an annual salmon production of 2,825,000 kilograms just from Jordan Bay, that is, about 9.56 jobs per million kilograms of salmon produced. This is a very large decrease from historical employment number of 27.4 full time jobs per million kilograms of harvested salmon. To get to the 490 additional full time jobs, using the recent Jordan Bay numbers, would require an additional 51.3 million kilograms of salmon harvested each year. This would require an increase of  950% in salmon production over and above what is produced today, all to be accomplished in less that three years.
 
Let’s examine this promise of 490 additional full time  jobs from the perspective of the number of new fish sites that would be needed to fulfill  this promise. Assuming large sites at 500,000 fish per site and the historical employment figure of  27.4 full time jobs (equivalent) per million kilograms of salmon then an additional 13 open net finfish sites would be needed. If, however, we use the most recent number of 9.56 full time jobs per million kilograms of fish, then 37 new large sites would be needed between now and the end of 2015. Yet  Minister Belliveau has written  “In our strategy we are clear that we are only considering adding a small number of new sites in the future.” New Brunswick has attempted to reduce open net finfish aquaculture environmental problems by going to longer production cycles, longer fallowing times, and fewer fish per site than we have in Nova Scotia. If NSDFA followed the New Brunswick lead, even more new fish sites would be needed to meet the December, 2015 processing plant opening date or additional delays to open a new processing plant would have to take place.
 
If these future projections look murky, let’s look back to 2009 when the NDP took office in Nova Scotia. In 2009, 2010, and 2011 the number of kilograms of salmon that were harvested out of Nova Scotia’s waters was reported by NSDFA as 7,437, 590: 4,959,828: and 5,444,801, respectively. If one assumes that the 2012 data, when posted, show a production rate equal to that of 2011, then since NDP took office a total of about 23.3 million kilograms of salmon would have been produced. How many salmon processing jobs in Nova Scotia did these 23.3 million kilograms of salmon produce?  If Cooke Aquaculture took charge of all the fish processing, then these 23.3 million kilograms of salmon produced zero processing jobs in Nova Scotia. This is because Cooke Aquaculture processes all of the salmon it harvests in Nova Scotia in its processing plant in New Brunswick. Worse yet, this only has limited benefit for the people in New Brunswick. Cooke Aquaculture employs a significant number of fish processor workers from Romania and the Philippines.
 
NSDFA statistics also show that the value of these salmon, assuming 2012 is similar to 2011, totals  about $126.9 million dollars since the NDP took office. Based on an April, 2010 analysis performed by DFO on open net finfish aquaculture, for every dollar of revenue about 25 cents ends up as profit for the aquaculture industry. Using this DFO figure, the waters of Nova Scotia provided a profit of about $32 million dollars for the aquaculture industry since the NDP took office. This same DFO economic analysis report calculates that for every dollar of revenue labour earns 6.2 cents. Since the NDP came to office the salmon aquaculture industry would have paid labour about  $7.9 million dollars. Of course not all of this labour income is in the pockets of Nova Scotians since the fish processing is done in New Brunswick…and then, not necessarily by local citizens.
 
What is most puzzling is why doesn’t the Nova Scotia government insist that all salmon  grown in Nova Scotia waters, starting immediately, be processed in Nova Scotia facilities? There already is a large overcapacity of fish processing facilities in this Province. If schedules continue to slip, at least these Nova Scotian workers would have employment. Wouldn’t the $25 million dollars given to Cooke Aquaculture been better spent getting local facilities refurbished, if necessary?  As it is, the $25 million dollars is at least three times more money than Provincial labour made in salmon aquaculture in all the time the NDP has been in office. There would be another benefit to requiring that Nova Scotian grown salmon be processed in Nova Scotia. We would soon learn if such processing jobs stem the flow of younger people from the Province. If it does not, then the promised large processing facility in Shelburne won’t be filled with local young people and the exodus will continue.
 
Herschel Specter
mhspecter@verizon.net
 
LETTER # 4
February 27, 2013
  
PROTECTING CANADIAN FOOD EXPORTS
 
Canada produces wonderful food, but its ability to export food depends on its reputation of producing healthy food fit for consumption. The Canadian Food Inspection Agency (CFIA) is charged with assuring that all Canadian grown food meets high standards. However, the CFIA has stumbled badly by allowing Canadian beef with e-coli to be shipped to the United States, only to be discovered by inspections there. Now there is a new issue: Exporting farmed salmon exposed to Infectious Salmon Anemia (ISA). The USA is unlikely to allow the importation of ISA diseased fish, but the importation of fish just exposed to ISA, but not manifesting signs of this disease, may be permissible.
 
The CFIA messages on farmed salmon have been confusing. First it compensated large aquaculture companies with tens of millions of taxpayer dollars when it ordered such diseased fish to be slaughtered. Then, when additional ISA outbreaks occurred and new ISA strains were identified, the cost implications of continued compensation might have seemed enormous to CFIA. CFIA gave the appearance of changing its policy by allowing Cooke Aquaculture, for the first time, to process ISA diseased salmon which would then enter the food market. This decision has unleashed a large backlash from consumers and, oddly, CFIA now claims that it hasn’t changed its policies.  This clarification created new confusion: Did CFIA allow ISA infected fish to be sold at fish markets in the past and does CFIA now plan to return to supporting the large aquaculture industry with even more millions of taxpayer dollars whenever ISA breaks out? Is CFIA permitting the sale of ISA infected fish or are they limiting sales to fish that have been exposed to ISA but have not contracted this disease which is deadly for salmon and other types of fish? When carefully monitoring the ISA outbreak on Coffin Island did the CFIA separate the fish that clearly had signs of ISA from those that did not manifest signs of ISA which might suit the USA market? CFIA has compounded this confusion by never publicly publishing a report on where the ISA came from, if there was any connection between the ISA outbreak in Coffin Island and McNutts Island and possibly equipment taken from the highly polluted old Sandy Point site in Shelburne’s inner harbour. If the number of fish that clearly had ISA is a small fraction of what Cooke Aquaculture grows, as  proclaimed by Nell Halse, Cooke Aquaculture spokeswoman, why not just slaughter these obviously diseased fish instead of  processing them under strict controls where even the waste water from tanker trucks that transport these diseased fish has to be controlled. Cooke Aquaulture is a huge company with recent revenues equal to $570 million dollars. They can and should pay the costs of slaughtering their own diseased fish, not the Canadian taxpayer.
 
When it comes to food, there are perception issues, like low confidence in the food regulators, that can override good science. Perhaps it is time for Dr. Roland Cusack, NSDFA Fish Health Veterinarian, cusackrr@gov.ns.ca  to write an article for all of us that supplies the science behind statements like “ ISA is a fish health issue, not a human health issue” and address if this also applies to all the new ISA strains recently discovered. People have been drawing parallels between fish flu and avian flu and recall that there was a worldwide fear a few years ago that one more mutation of avian flu would unleash a pandemic. Unaddressed fears lead to a general lack of confidence in the regulatory process.
 
This lack of confidence spreads very quickly in this age of the internet. Already Mark Bittman, Food Critic for the New York Times, has alerted his readers this week:
 “Current research does not give us the kind of detail many of us crave. It may well be that the reason red meat appears to be “bad” for us lies in the way cattle are raised. It may well be that the reason wine appears to be “good” for us is that it’s usually consumed as part of a leisurely meal with family or friends. My guess is that wild fish — which is in general endangered and cannot in good conscience be eaten as often as I, for one, would like to — is far more beneficial than farm-raised fish, which has mostly understated environmental issues.” http://www.nytimes.com/2013/02/27/dining/when-diet-meets-delicious-the-mediterranean-approach.html?pagewanted=2&ref=dining
 
 
Major grocery chains are reviewing their own policies and may not buy ISA infected salmon. The more this subject is openly discussed, the more customers will turn away from all farmed salmon products, regardless of CFIA claims that eating ISA infected salmon does not pose a health risk to humans. Customers will demand that the choice whether or not to buy ISA diseased salmon or even ISA exposed fish is their rightful decision, not that of the aquaculture industry nor some remote government bureaucrat.  At present, ISA infected farmed salmon are not labeled. If customers can not identify which farmed salmon have ISA and which are ISA-free, then no purchase of any farmed salmon would be the prudent thing to do. Worse, marketing unlabeled diseased Canadian farmed salmon can raise doubts about other Canadian food exports such as beef from Alberta, lobsters from New Brunswick and Nova Scotia, and mussels from Prince Edward Island.
 
There is a simple resolution to this problem: Label the salmon. Cooke Aquaculture’s farmed salmon already carries an ECO Label. According to Nell Halse, when addressing the purpose of ECO Labels “ We have to make sure each customer has the material they need so that they can answer questions accurately” It would be consistent with past ECO Label practice to inform customers about ISA so that they can make accurate decisions. All that need be done is to expand the Eco Label to include two words “ISA Free”. Such a label would mean that the salmon were neither exposed to ISA nor infected with ISA. As Halse pointed out, only  a small percentage of the salmon they produce have ISA. They could be easily identified as they are processed through a strictly controlled facility. Those salmon that have contracted ISA might still have ECO Labels without the words “ISA Free” if that meets the standards of the Seafood Trust and if the food industry wants to risk a rebellion by its customers on perceived food safety issues. If  marketing ISA infected salmon doesn’t meet the standards of the Seafood Trust, this should be announced without delay.
 
There is intense competition between Chile, Norway, Scotland, and Canada in selling farmed salmon internationally. If these other countries place a “ISA Free” label on their fish and Canada does not, Canada will be the big loser. So to protect all other Canadian food export products and to also protect the sale of its own disease- free salmon, the Canadian farmed salmon industry should label its healthy salmon as ISA–free without further delay.
 
Herschel Specter
mhspecter@verizon.net

LETTER # 5
March 2, 2013

THE ENVIRONMENTAL SCORECARD 

Letters #1 through #4 focused on the difficulties in creating 490 additional full time open net finfish aquaculture jobs by December, 2015.  NSDFA is encouraged to refute the statement that obtaining these full time jobs by December, 2015 is a myth. It should demonstrate that achieving this additional employment is realistic by publicly providing a verifiable business plan that details the number of new sites that would have to be opened by this date, the number of fish to be stocked per site, the impact of automation on employment, the pay scales of workers in the proposed fish processing plant, and the lack of an experienced staff at NSDFA to process large numbers of new license applications. To present a comprehensive analysis, this business plan should identify the jobs lost in traditional and sustainable aquaculture because of such an expansion of finfish aquaculture, the losses to the tourist industry from fouled waters and unsightly open net pens, and the decreases in property values due to locating fish feedlots in residential areas. This business plan should quantify the negative economic impacts of escaped open net salmon, losses due to diseases like ISA and to sea lice, the effects of growing salmon which are forced to swim only a meter or two above their own pile of fecal matter, high levels of “morts”, the costs of running noisy oxygenators to prevent the salmon from suffocating due to low oxygen levels in increasingly warm water because of  the effects of climate change, the costs of replacing equipment damaged by severe storms and salmon losses due to super chill. 

This letter examines open net finfish aquaculture from a second perspective; its impact on the environment. This letter only looks at one aspect of the environmental impact: measured sulphide levels in the seabed at fish farms. Sulphide measurements are made because they can be an indicator of environmental damage to the macrofauna that live in the seabed. The macrofauna themselves form a critical link in the aquatic food chain. Other indicators of environmental damage from open net finfish aquaculture such as high zinc and copper levels in the seabed, direct measurement of the loss of macrofauna, large increases in undesirable flora due to overly nutrient rich sea water, impacts on wild salmon, etc., are not considered here. 

In his November 1, 2012 letter to Ms. Claire Williams (Ref. F137), Minister Belliveau blamed the present mistrust of open net aquaculture on previous governments which, he claimed, did not do much in the way of public engagement for the past 25 years. Well the public is very much engaged now and there is widespread anger. The very same rural coastal communities that are supposed to benefit from open net finfish aquaculture are strongly opposed to these polluting industrial salmon feed lots, with the exception of some people in communities where the prospect of many jobs has been dangled before them. 

Blaming previous governments for present public outrage on open net finfish aquaculture doesn’t withstand scrutiny. In February, 2013 a comprehensive report was issued “Nova Scotia Environmental Monitoring Program for Finfish Aquaculture –An Update (2006-2011)” by Inka Milewski, a marine biologist with the Conservation Council of New Brunswick.[ See http://www.ecologyaction.ca/ “Nova Scotia Fish Farms Impacting Environment: Report]. Milewski obtained sulphide data through 2011 from NSDFA on fish farms in Nova Scotia and compared these data to a 2006 NSDFA report  that covered sulphide measurements during the period from 2003 to 2005. The earlier report had stated that only a few monitoring stations in the Province showed sulphide levels in the polluted range and only one station reported sulphide levels that indicated a grossly polluted situation. This earlier report concluded that “Overall findings from the baseline sampling revealed that the majority of these sites showed no significant impact.” The passage of time has not supported this earlier optimistic assessment. Before 2005 there were eight measurements in the Province that reported a polluted condition. After 2005 this number jumped to 42 measurements identified as polluted. Before 2005 only one measurement reported a grossly polluted situation, after 2005 this grossly polluted designation rose to 27 measurements. Grossly polluted conditions correspond to anoxic conditions or in non-scientific words, dead zones. Clearly the optimism in the earlier report of “no significant impact” can not be honestly supported today. 

These high sulphide levels, based on NSDFA’s own data, and reported by Milewski, show that many of the worst sulphide measurements occurred since June, 2009 when the NDP took office in Nova Scotia. Please see Figure 2 of the Milewski report. The failure to meet environmental criteria, i.e., to stay within the normal or “oxic” range, continues to this day. At St.Marys Bay’s Freeport and Grand Passage sites computer analyses performed by the federal Department of Fisheries and Oceans (DFO) predicted that these sites will reach sulphide levels bordering on the anoxic range ( dead zones with a loss of macrofauna greater than 90%) within about 15 months of operation. Recent sulphide measurements at these sites already confirm that sulphide levels above the oxic, or normal, range are being approached and this only reflects the impact of the first production cycle.  At Port Mouton, important scientific analyses of the affects of fallowing at this formally highly polluted site have been terminated when the NSDFA permitted restocking of this site. Sulphide levels there are on the rise again. The new Sandy Point site in Shelburne’s inner harbour, and within the shadow of the former Sandy Point site, is bound to rapidly create high sulphide levels once it is stocked. At the Owls Head fish farm site (lease #0772) high sulphide readings were recorded in 2009 with 12 of 18 sampling stations above the oxic range and 5 stations above a sulphide level of 3000 uM, i.e. well into the polluted range. Yet when NSDFA made sulphide measurements in 2012 they chose locations over 100 meters from the fish farm site. This appears to be in violation of the required monitoring locations called for in NSDFA’s Standard Operating Procedures and will lead to misleadingly low sulphide measurements. This also prevents meaningful comparisons between 2009 and 2012 data. Local citizens have asked, but have yet to receive, a reply as to why these improperly located monitoring stations were permitted. There have been complaints from people near the Coffin Island site that monitoring stations there are also improperly located. Improper locations is not a new issue. Several years ago fish cages in both the old Sandy Point site and the old Boston Rock site were improperly relocated, even to the point that they were pushed outside of the sites’ legal boundaries. [Go to pages 6 and 12 in the appendix in the following link http://www.friendsofshelburneharbour.org/uploads/Letter___17.pdf] The illegal repositioning of these fish cages was known to the NSDFA since it appears in the record provided by the Minister in a Nova Scotia Supreme Court case. 

With year-after-year of unacceptably high sulphide measurements at many sites, why didn’t NSDFA require that mitigative actions be taken to limit/reduce these high sulphide levels to normal (oxic) conditions? This question will be addressed in letter #6. 

Herschel Specter
mhspecter@verizon.net

LETTER # 6
March 4, 2013
 
THERE ARE NO PROVEN MITIGATION METHODS
 
Can open net finfish aquaculture sites increase the sea bed sulphide levels beneath their fish cages without limit? Obviously not, otherwise there would be no need for the extensive monitoring system that both the NSDFA and the federal Department of Fisheries and Oceans (DFO) have instituted. So at what measured sulphide level must aquaculture operators begin to take corrective actions? This trigger for corrective action appears to be at the sulphide level where a site is leaving the normal or “oxic” range and is entering the polluted or “hypoxic” range. In terms of numbers, the polluted range starts at a sulphide level of 1500 units ( each unit is called a micromole or uM). At 1500 uM the macrofauna in the sea bed, a critical part of aquatic sea life, have already taken a significant loss because of the effects of fecal matter and other substances related to open net finfish aquaculture. At 1500 uM, DFO science places this loss at about 42 percent. At 6000 uM the grossly polluted or “anoxic” range begins and macrofauna losses exceed 90%, i.e., dead zones are created.
 
The importance of this 1500 uM level has been emphasized by both DFO and NSDFA. For example, in her November 18, 2010 letter to Transport Canada about the then three proposed sites (now approved) in Shelburne’s inner harbour, Ms. Tammy Rose-Quinn, a DFO Senior Advisor, wrote “Therefore, Kelly Cove Salmon, Ltd. should operate its sites such that the sediment sulphide concentration levels beneath the site remain below Hypoxic A. If, at any time, the environmental monitoring reveals that the site classification is approaching or has exceeded Hypoxic A, Kelly Cove Salmon, Ltd. must consult with DFO-HPSD immediately (emphasis added)
to discuss management options for the site such that performance measures are achieved.” [ Hypoxic A is the 1500uM to 3000uM range] NSDFA, in its March, 2011 Environmental Monitoring Program (EMP) Framework report stated that the “marine Environmental Quality Objective is to maintain oxic conditions”. If oxic conditions are not met, sites must inform NSDFA of the efforts taken to improve site conditions.
 
So with clear instructions to stay within oxic conditions and with an elaborate monitoring program in place, why have open net finfish sites been allowed to operate above the oxic range and, as pointed out in letter # 5, increasingly have had polluted and grossly polluted sulphide levels, especially since NDP took office? Why hasn’t the NSDFA insisted that  mitigation methods be applied to return sites to the oxic level? The simple answer to this obvious question is “There are no mitigation methods that have proven to be effective.” Just as there is a finfish aquaculture jobs myth, there is a mitigation myth.
 
A few examples demonstrate the mitigation myth. NSDFA’s March, 2011 EMP Framework document states if open net finfish sites exceed acceptable sulphide levels, they are to increase the frequency of monitoring. In fact, this EMP Framework document calls for increased frequency of monitoring if a site has exceeded acceptable limits. This call for increased monitoring frequency is even applied to the anoxic, or dead zone, level. This is absurd. It is equivalent to taking the pulse of a dead person more frequently. What does it prove? More importantly, why would NSDFA allow the site to enter the anoxic range in the first place? The EMP Framework document doesn’t even discuss under what conditions would NSDFA shut down a site; something it has never done. Monitoring is supposed to indicate when mitigation is needed and, later, if it has been effective. Monitoring is not mitigation.
 
The Provincial Aquaculture Strategy document also contributes to the mitigation myth. On page 11 the Strategy document states “ We know that appropriate adaptive management practices, such as improved feeding techniques, lower stocking densities, and site fallowing, can minimize environmental impact.” Upon closer examination these practices would not provide the necessary mitigation to return a finfish site to the oxic range.
 
Fish feed is the dominant expense in raising salmon through the open net process. According to the DFO economic analysis of finfish operations, the cost for feed exceeds the cost of all labour by 600 percent. As a consequence, to minimize losses of this high cost component, the finfish aquaculture industry has gone to considerable lengths to  reduce the amount of uneaten feed that passes through fish cages. For example, they have even installed underwater cameras to track the effectiveness of the fish feeding process. As a result of these efforts very little feed is wasted, leaving very little room for further improvement. If there were ways to improve feeding techniques, the aquaculture industry would utilize them immediately to save money and not wait until site conditions had deteriorated. Improved feeding techniques is not a significant mitigation process.
 
Lower stocking densities will result in a reduced rate of fecal matter produced  at these fish feedlots. However, this should not be an after-the-fact adaptive management practice as suggested in the Province’s Aquaculture Strategy. Finfish sites can get polluted rather quickly, but recoveries, if they occur, happen quite slowly. The time to set stocking levels is before the first production cycle, not after. If the first production cycle has left the fish site in the oxic range, somewhat higher stocking levels in the next production cycle might be considered if there is a good possibility that the site would remain in the oxic range. The second production cycle might even have lower stacking levels because of the environmental impacts left from the first production cycle.
 
A clear example of improper stocking was provided by DFO in its computer analysis of the Jordan Bay and Blue Island sites. Extrapolations of these DFO analyses indicate that the Jordan Bay site would have to be limited to 25,000 to 30,000 fish for the first production cycle to stay within the oxic level. For the Blue Island site, the extrapolated DFO analyses indicated that stocking levels should be limited to 37,000 to 102,000 fish to stay within the oxic level. These stocking levels are well below the 500,000 fish level approved by the Minister of NSDFA for each of these two sites. It is expected that significant environmental damage will occur at both sites within the first or second production cycle.
The precautionary principle states if an action or policy has a suspected risk of causing harm to the public or to the environment, in the absence of scientific consensus that the action or policy is harmful, the burden of proof that it is not harmful falls on those taking an act. This principle should be applied to stocking levels. It is far better to adjust stocking levels upward from a first production cycle that has proven to stay within the oxic range, than attempt to achieve oxic levels by reducing stocking levels after excessive damage has been done to the sea bed macrofauna. The Provincial Strategy document has the process backwards by seeking adaptation after the first production cycle. What if it becomes clear midway in a production cycle that oxic levels will soon be exceeded? Would NSDFA order the site operator to harvest undersized fish then or would NSDFA allow the production cycle to go to completion, thereby adding to the sea bed damage? Since the stocking level would best be set before operations begin, it is not a mitigative process which occur after operation has begun.
Contrary to claims made by NSDFA, fallowing as practiced today by the finfish aquaculture industry in Nova Scotia, is not to protect the environment but is an economic decision. Open net salmon are generally grown on a two year cycle. Part of these two years is spent in growing the salmon, typically for about 18 months. The balance of the two years is designated as a fallowing time to give relief to the environment, but its real purpose is to keep the site on a two year cycle. If salmon could be grown in just one year, the present fallowing period for open net aquaculture would likely disappear. There is no doubt that sulphide levels will decrease during fallowing, but this does not mean that the dead macrofauna will somehow return to life.
Further, where there have been periods of fallowing, such as at the old Sandy Point site and at Port Mouton, sea bed sulphide levels quickly rose once operations began again. Fallowing in these cases did nothing to permanently reduce sulphide levels. Some efforts have been made in New Brunswick at longer fallowing periods and these were unsuccessful in improving environmental conditions. The NSDFA has not invested in research to investigate how fallowing affects benthic life at an idle finfish site or the time it would take to achieve oxic conditions again. What limited data are available on how fallowing affects the environment comes from efforts and contributions by concerned citizens. The limited knowledge base of the NSDFA on fallowing and its impact on the environment can be quickly demonstrated: Take any grossly polluted site in Nova Scotia and ask NSDFA how long it will take to restore this site to oxic conditions.
Other so-called mitigation schemes have been discussed such as eliminating net washing on site, integrated multi-trophic aquaculture where the waste from one aquatic species becomes the input for a different species like salmon wastes would be input to strings of mussels that share a finfish site. All of the mitigation schemes share one thing in common: they either don’t work or they have not been shown to work.
In letter # 3 NSDFA was requested to provide a detailed business plan that would respond to the claim that it was a myth that large increases in employment in finfish aquaculture would occur by December, 2015. In this letter it is requested that NSDFA publish a report listing all the mitigation measures that might be used to restore a site with high sulphide levels to oxic conditions. For each mitigation measure specific proof of its effectiveness should be provided. Until such a document is produced mitigation  should be considered a myth. The only circumstance when mitigation “worked” is when finfish operators moved to a different site after contaminating their original site.

Herschel Specter
mhspecter@verizon.net


LETTER # 7
March 7, 2013

DON’T EXPERIMENT WITH JORDAN BAY

The buoys are being put into the water and soon the salmon smolts will be put into the fish cages at two large sites, Jordan Bay and Blue Island. NSDFA has started another experiment which is doomed to fail. This is a very large experiment where a million salmon are to be grown every two years. In 2011 it took all of Nova Scotia to produce about a million salmon.

There is no reason to believe that this experiment will be successful. The whole open net finfish experiment in Nova Scotia for the past decade has been an environmental failure. Fanciful promises of large number of jobs have been like an ever receding mirage. Marshall Giles, top bureaucrat at NSDFA, stated in a 2006 NSDFA environmental report that “Overall findings from the baseline sampling revealed that the majority of these sites showed no significant impact”.  This assessment has not been borne out over time with significant environmental impacts at all salmon sites throughout the whole Province. We know now that there is not even one environmentally acceptable salmon aquaculture site in all of Nova Scotia.  For a recent assessment see http://www.ecologyaction.ca/  “Nova Scotia Fish Farms Impacting Environment”.

There is no reason to believe that this experiment will be successful. All the salmon aquaculture sites along Nova Scotia’s south shore have common characteristics that are unfavorable for salmon aquaculture. They are in shallow water with very slow moving currents. Jordan Bay has a mean current speed of 6.3 centimeters per second. Normal walking speeds are about 110 centimeters per second. To the west of Jordan Bay all five original sites in Shelburne’s inner harbour were environmental failures and were turned back to NSDFA by Kelly Cove Salmon, Ltd., the same company now licensed to operate the two Jordan Bay sites. The old Sandy Point site in Shelburne’s inner harbour which Kelly Cove Salmon, Ltd. operated, still has a deep pile of fecal matter below it. To the east of Jordan Bay there is the Port Mouton site, another environmental failure, with a deep pile of fecal matter beneath it. Right next to Jordan Bay there is McNutts Island where over 700,000 salmon had to be destroyed because of an outbreak of ISA, infectious salmon anemia. Further along the south shore there is Coffin Island with another ISA outbreak and more salmon losses. What makes the Jordan Bay and Blue Island so different from these other south shore sites so that they will have a better result? Nothing!

There is no reason to believe that this experiment will be successful. The Department of Fisheries and Oceans (DFO) has investigated the effects of different stocking levels at Jordan Bay and Blue Island. Based on the DFO analyses the NSDFA approved stocking level of 500,000 fish at each site is far too large. In order to stay within the normal or oxic range the initial stocking level of the Jordan Bay site should not exceed  about 25,000 to 32,000 salmon and the Blue Island site should not exceed 38,000 to 48,000 salmon, not 500,000 salmon at each site. Even at stocking levels ten times or more smaller than what NSDFA approved, future stocking levels at these sites would likely have to be even lower to stay within the normal or oxic range because of the buildup of fecal matter under the cages.  These sites may not be sustainable nor the jobs that would depend upon them. See http://www.friendsofshelburneharbour.org/uploads/Letter__23.pdf

There is no reason to believe that this experiment will be successful. These sites are particularly exposed to outbreaks of ISA. They are very close to McNutts Island which had a huge outbreak of this deadly virus. Further, these two sites are located too close to each other. DFO guidelines call for a minimum spacing of 3 kilometers to reduce bio-security risks. These sites are about 1.3 kilometers apart. Additionally, ISA can be transmitted from one location to another through contaminated equipment. Figure 13 of the Environmental Impact Assessment for these sites is a navigation chart of the area. This figure shows that the vessels that will service these two sites come very close to McNutts Island, swing past the dead zone areas in Shelburne’s inner harbour and share three of the same wharfs. One contaminated vessel could affect all sites in this area.

Note that although the Canadian Food Inspection Agency made an investigation of the ISA outbreak in McNutts Island, its results have never been published. This secrecy leaves open the possibility that the origin of the ISA virus came from the highly polluted old Sandy Point site and also the possibility that equipment from this site was the source of ISA outbreak at Coffin Island. To set the record straight the CFIA analyses should be made public now. Further, NSDFA should explain how it is using the lessons learned from the CFIA investigation. NSDFA should show, without further delay, what steps it is taking to prevent the vulnerable Jordan Bay and Blue Island sites from future ISA attacks.

There is no reason to believe that this experiment will be successful. The Jordan Bay and Blue Island sites are in shallow water. For example, the Jordan Bay site has a depth of only 12.7 meters. This means that the distance between the bottom of the cage and the sea bed is quite limited. At low tides, during storms, and because of possible resuspension of fecal matter by currents, these caged salmon could be exposed to their own fecal matter. This situation would get steadily worse as piles of fecal matter accumulate under these cages.

There already are issues about marketing ISA exposed salmon, sea lice have been detected in farmed salmon in a store in Nova Scotia, and anti-biotics are introduced into the feed given to these salmon. Some people fear that, over time, this practice of putting anti-biotics into the human food chain weakens the effectiveness of anti-biotics needed by humans. If salmon are raised in shallow waters are identified as “fecal fish”, this could be the tipping point in public acceptance for many of the food products exported from the Maritimes. Fecal fish are not a product that Nova Scotians would be proud of.

Nothing is to be gained by this experiment. The Provincial Aquaculture Strategy has a goal of producing sustainable aquaculture for rural coastal communities. Well this goal has been achieved long before NDP came to office by caring coastal communities that, for generations, have gathered lobsters, herring, eel grass, sea urchins and other aquaculture products. They have kept Nova Scotia waters clean and have been the backbones of the communities they live in. Local fishermen in the Jordan Bay area will be pushed aside by the encroachment of a large, multi-national aquaculture company from New Brunswick. How has the government balanced actual sustainable jobs by local people against theoretical jobs that never quite materialize from large companies that are headquartered outside of Nova Scotia?

Governments come and go, but some can do lasting damage. These waters belong to the people of Nova Scotia, not to their governments. Governments are supposed to serve the needs of the people, but in farmed salmon this isn’t happening. Experiments should be run in the laboratory, not in areas which good people use to sustain themselves and their families.

STOP THE STOCKING OF THE JORDAN BAY SITES

Herschel Specter
mhspecter@verizon.net

LETTER # 8
March 8, 2013
A CLEAR MORAL ISSUE

Increasing production in open net finfish aquaculture is often described as a way to help feed the world’s growing human population and with the great decline in wild fish this objective is ever more important. Is this really true? To put things into perspective, according to the United Nations Food and Agriculture Organization plants and animals still represent about 80% of the primary source of protein for most of the world’s population. And open net finfish aquaculture represents only 2.9% of global aquaculture production. Therefore open net finfish aquaculture is an extremely small contributor to meeting world food needs.

An even closer look at open net finfish aquaculture raises questions about who is getting fed and who is not. In 2005 28 million tonnes of forage fish were used to produce 5.5 million tonnes of fish meal*. This is a very wasteful way to distribute protein because the forage fish themselves are edible protein. Much of the forage fish comes from poor countries. If one is truly interested in providing protein to hungry people, then these forage fish should be consumed locally. So what we really have is a situation where richer developed countries like Canada and the United States are consuming food from the poorer countries because the richer countries can afford to pay high prices for the forage fish while local people usually can not. In the meanwhile the stocks of forage fish are declining. Unless substitutes for forage fish are found, all forms of finfish aquaculture will not be sustainable, nor will the jobs that depend upon this industry. New technologies are being investigated to supply fish feed, such as using the wastes from brewing processes, but this does not appear to be in use in Nova Scotia.

Open net finfish aquaculture does not and can not feed the world, but it can take from the poor and give to the rich, all the while making very large profits for a select few people. This is a clear moral issue, especially since these richer nations can develop aquaculture technologies to grow finfish without taking food from others.

* See “ From Fish to Meal to Meat”, Liesbeth van der Meer, Fishbytes, Volume 18, Issue 5, September/October 2012

Herschel Specter
mhspecter@verizon.net

LETTER # 9
March 9, 2013
 
SPIN CITY –NUMBER ONE

 “ Nothing could be simpler than invading and conquering some sleepy fishing village”, Sherri Harris, et al, Halifax Chronicle Herald, 1989

1.0 GAMING THE NUMBERS: In October, 2009 a senior representative from Cooke Aquaculture made a presentation to the Shelburne Municipality Council on four finfish sites in Shelburne’s inner harbour; the old Sandy Point, Boston Rock, Hartz Point, and Shelburne Trout sites. All four sites were claimed to have low sulphide readings in the Oxic B range, i.e., in  the normal range. With such low sulphide numbers these sites looked rather benign. This was good news because Cooke Aquaculture was planning a large expansion of open net finfish aquaculture in that area and elsewhere in Nova Scotia.

However, the numbers that were presented in 2009 were wrong. Instead of just considering the sulphide numbers measured within the cage areas at these sites, the presented numbers were a blend of fish cage sulphide measurements and measurements at reference stations. Reference stations are intended to measure the effects of finfish operation at some distance from the site, not what was happening within the site.  Since reference station measurements are always lower than sulphide measurements taken within the cage areas, blended numbers are inappropriately too low.

Instead of all four sites being in the Oxic B range, only one was. The other three were in the polluted or grossly polluted range. Further, this October, 2009 presentation significantly misrepresented what had previously happened at the old Sandy Point site because it only presented sulphide measurements for 2009 when this site was fallow. Sulphide measurements during fallowing periods are low and are not reliable indicators of the effects of finfish aquaculture on the environment. In 2008 the old Sandy Point site already was Anoxic, i.e., a dead zone. Even years later this site remains a dead zone, still with a pile of fecal matter on the sea bed. So the Oxic B classification presented for the old Sandy Point site was doubly wrong; it should not have included reference stations and did not reflect the fact that the site was already a dead zone, regardless of any 2009 sulphide measurement. This experience calls into question the regulatory wisdom of allowing a site operator to conduct his own monitoring. Site monitoring should be done by an independent third party, paid for by the site operator. Environmental measurements should be published on the NSDFA website, without delay.

The table below compares the KCS (Kelly Cove Salmon, Ltd.), a subsidiary of Cooke Aquaculture, classifications to ones that do not mix reference stations in with fish cage measurement stations and also accounts for Anoxic levels at the old Sandy Point site the year before,

 
Had the actual classifications been presented, it likely would have raised questions by the Municipality Council members. NSDFA’s response to Friends of Shelburne Harbour for exposing this inappropriate use of reference sites was to prohibit such future manipulations of the data, as stated in its March, 2011 Environmental Monitoring Program (EMP) Framework document. Unfortunately this EMP document appears to have introduced a new form of this malpractice. For the first time since NSDFA had been gathering sulphide measurements, the EMP document introduced something called an assigned historic sampling station. While exact monitoring locations are spelled out in the EMP’s companion document, the Standard Operating Procedures (SOP), the location of the assigned historical sampling station is not known, nor is it clear who makes the decision of where to locate it. Sulphide levels can decrease significantly with time and with distance from the cages. Blending low sulphide measurements from an assigned historical station with the SOP monitoring stations could result in too low an overall classification of a site. A low classification likely would avoid the need to attempt mitigation measures (which don’t work anyhow) and could prevent calls to shut the site down. NSDFA has never explained how assigned historical stations provide a better understanding of how well a finfish site is performing. One problem with the EMP document is that it is the product of the NSDFA and the aquaculture industry and was done without the participation of the public or environmental groups.

2.0 GAMING THE WORDS: Minister Belliveau has stated “ In our strategy we are clear that we are only considering a small number of new sites in the future.” As pointed out in Letter # 3 it would take between 13 to 37 sites, each at 500,000 fish, to produce 490 additional full time jobs. An obvious question is then how does one get to produce 490 additional full time jobs by the end of 2015 with just a small number of new sites? Part of the answer to this question is the attempt to go to very large sites, like one million or more fish per site. Such huge sites have proven to be unlikely since DFO analyses show that even at sites with deep water and fast currents, like the sites in St. Marys Bay, enormous amounts of fecal matter just overwhelm the sites, even the better sites. So the key word in Minister Belliveau’s statement is new. If a site is not new it does not have to have a public meeting. There are many additional new locations where salmon (or trout) that have come into operation during the NDP administration that are not considered as new sites. The three sites in Shelburne’s inner harbour were not considered new, but were treated as merely amendments to existing sites, even though they physically were in different locations and the cages at the old sites were dismantled. To keep up appearances, they were even given the same names as the predecessor sites they replaced. The site at Coffin Island was not considered as a new  site, just a change in ownership. The previous owner did not grow farmed salmon at this site and therefore did not present a threat to the wild salmon in the Medway River if escapes occurred. The creation of this new threat  was not sufficient to classify this site as a new site or to have a public meeting. The restocking of the site at Port Mouton did not initiate a public meeting, even though its history and special scientific analyses showed that this site was exceptionally unfit for open net finfish aquaculture.

The site at Port Wade wasn’t considered a new site because it was an old dormant site that was purchased by Cooke Aquaculture. Is it NSDFA’s unstated strategy to rapidly approve other dormant sites? The Province’s Aquaculture Strategy, on page 17, points to a continuation of this unsavory practice where it is stated “ The reassignment of a license does not require public engagement.” Further, once a dormant site has been reassigned without public engagement or an environmental review it can then be significantly enlarged, if such enlargement is labeled as merely an amendment to an existing license. The amendment and enlargement scheme was used when the three latest sites in Shelburne’s inner harbor were licensed in 2011. This week three additional cages were attached at Port Wade, literally in the middle of the night. The Province’s Aquaculture Strategy was written without the participation of the public or environmental groups.

All of the above sites, and possibly more to come, might not, in a narrow legalistic way, be classified as new sites because they were approved as amendments to existing sites, or as a change of ownership, or became operational when the aquaculture industry was allowed to acquire a lease of a long dormant site. However, a bad site remains a bad site regardless of who operates it. Everything else is just gaming the words.

Herschel Specter
mhspecter@verizon.net

LETTER # 10
March  11, 2013

SPIN CITY - NUMBER TWO

“ Nothing could be simpler than invading and conquering some sleepy fishing village”, Sherri Harris, et al, Halifax Chronicle Herald, 1989

1. Mocking alternative technologies:  Growing salmon with alternative technologies is much more expensive than the open net pen finfish process.

The Truth: Proponents of open net finfish aquaculture often rely on a DFO economic study* that compared open net finfish economics with several alternative technologies including two closed containment systems and a land- based system. This study concluded that the present open net pen system was the least expensive. The problem with this DFO study is its narrow scope.  As stated on page 5, “For the purpose of this study, factors other than financial elements are not considered.” To put this into perspective, years ago raw sewage used to be dumped into city streets and waterways. Today this is forbidden. People have long ago decided that the additional expense of sewage treatment was well worth it. Yet a cost comparison between the raw sewage situation and one with sewage treatment would undoubtedly show that that using sewage treatment is more expensive. Because the DFO report’s narrow scope, it does not place any value on a healthy environment. For that matter, this DFO report doesn’t account for economic losses due to ISA, sea lice, morts, extreme weather, the cost of running oxygenators when water temperatures get too high, or storms that wreck fish pens or the financial losses other members of society experience when displaced by open net aquaculture. This DFO report doesn’t account for a variety of subsidies the finfish aquaculture industry gets, from $25 million tax dollar giveaways, to paying for salmon that died from ISA attacks, or for the Province even taking tax dollars to promote this industry.

What this DFO report does show is the enormous profit this low technology can produce. This DFO report states that the return on investment (ROI) for open net pen operators is an astounding 53% and that is just for the first production cycle. After the equipment is paid for the ROI might even be higher. Such extreme ROIs seem plausible. The first of two huge, 700,000 fish each, open net sites in St. Marys Bay is now being harvested. At about six kilograms per fish and salmon prices at $4 to $5 per pound, the combination of both sites could produce, after processing losses, around $61 to $77million per production cycle. At a total area of 84.4 hectares and a production cycle of  31 months the revenue from St. Marys finfish aquaculture comes to about $281,000 per hectare per year.  This can be compared to what NSDFA charges open net finfish operators for the use of the people’s waterways. The NSDFA yearly lease fee for aquaculture is $12.15 per hectare. So the ratio of the finfish operator’s annual revenue per hectare to the Province’s fee for the use of the people’s waterways is 281,000/12.15 = 23,128. This looks like NSDFA “gave away the store”.

*Economic Study of Closed –Containment Options for the Canadian Aquaculture Industry”, DFO, April 21, 2010, Second Draft

 2.   Mocking the lobster industry: Salmon pens are good for the lobster industry.

The Truth:  While it is true that lobsters are initially attracted to salmon pens because of food waste, experience has shown that each pen quickly produces a “benthic dead zone” where no marine life can exist and before long lobsters stay well away.  The toxins spreading out from the pens present a threat to a variety of marine organisms, lobster included. In Scotland, the prawn fishery has been damaged by the prevalence of salmon pens on the west coast.  Several years ago, salmon growers settled out of court and provided compensation following a huge lobster kill in New Brunswick. More recently, the largest operator in eastern Canada, Cooke Aquaculture, is facing 19 charges of lobster poisoning in New Brunswick.  Lobster exporters are expressing concern that if Nova Scotia loses its international reputation for pristine near shore lobster grounds because of toxic pollution and shoreline fouling by the salmon feedlot industry, then significant damage could be done to the export market.

3.  Mocking people:   The government and the paid industry spin doctors claim opposition to open pen salmon feedlots in Nova Scotia is coming from a small group of naysayers who will oppose just about any kind of progress.

The Truth: The Coalition of Communities comprises 116 diverse groups from across Nova Scotia representing commercial lobster, tourism, environmental, wild fish conservation, and recently-formed community organizations concerned about the salmon feedlot threat to their quality of life.  The Tourism Industry Association of Nova Scotia (TIANS)—representing the entire private sector industry in the province (worth $1.8 billion per year to the economy and supporting 40,000 jobs) is involved and expressing alarm.  Representatives of Nova Scotia’s iconic $300 Million a year lobster industry employing 12,000 people directly plus indirect spinoff employment are involved and expressing alarm.  The simple, and reasonable, request for caution and further study of the potential negative impacts of this industry before expanding it any further mirrors the formal position of the Canadian Wildlife Federation with more than 500,000 members and supporters across Canada. It is the same formal position as the New Democratic Party of Canada. The final recommendations late last year of the $26 million Cohen Commission advised extreme caution and a moratorium on open pen salmon rearing unless the government can decisively demonstrate there is no risk to wild species (and it can’t).  Every single credible international wildlife organization on the planet (The World Wildlife Fund, Suzuki Foundation, Greenpeace etc) is alarmed about this industry.  Hardly a small minority of naysayers! Rather we are simply the latest local manifestation of worldwide concern about this industry in Scotland, Norway, Ireland, Chile, New Zealand, United States, British Columbia, Newfoundland and New Brunswick. Wherever it exists, it is controversial in the extreme. 

4. Mocking nature:  When an industry crowds huge numbers of fish into a small cage, feeds these caged fish on other fish, adds anti-biotics to the feed, uses sites that are  so shallow and with very slow moving currents so that some fish are exposed to their own fecal matter, adds colourant so that the fish resemble their wild species instead of having their natural gray colour, endangers the existence of other fish species, destroys the benthic sea life on the ocean floor, and poisons the water to kill sea lice and kills lobsters in the process, mother nature just might get angry.   Mother nature has her own way of getting even. Crowded fish feed lots are breeding grounds for sea lice and ISA. Fish die from extreme weather. Fecal fish may become morts. Huge storms can wreck fish cages. Sea lice adapt to different poisons and become immune. Climate change can cause the sea water temperature in open net cages to get so high that fish will suffocate for lack of dissolved oxygen unless outside oxygen is pumped in. 

Mother nature always bats last and she always bats 1000.

Herschel Specter
mhspecter@verizon.net

LETTER # 11
March 12, 2013
 LEGACIES

This is letter #11 and the final letter in this series. It would have been easy to write another letter about the spinmeisters. For example, our NSDFA Minister tries to comfort us by pointing out that all the finfish aquaculture sites in Nova Scotia, so far, only occupy about 1.5 square kilometers. Does this small area mean that it is OK if this area is sacrificed and becomes dead zones? If so, why bother monitoring these sites and then who needs the NSDFA regulatory staff anyway? A more telling description is that with the vast ocean area surrounding Nova Scotia, NSDFA has yet to find a site that is environmentally acceptable. Is the Minister proud of creating in his own riding what will be a cesspool of 500,000 fish just 200 meters from a residential area? Even a bird knows not to soil its own nest.

It would have been easy to write more about the lopsided economics of finfish aquaculture. Revenue for Cooke Aquaculture has recently been reported at $570 million dollars, up sharply from previous years. At a profit of 25.2 cents per dollar of revenue, as calculated in DFO’s economic analysis report, this would yield $144 million dollars in profit for a single-family-owned company for just one year. Isn’t that enough? Farmed salmon revenue in 2011 in Nova Scotia came to $27.3 million dollars. At labour costs around 6 cents per revenue dollar, labour earned $1.6 million dollars in 2011, some of which was earned at the Cooke Aquaculture processing plant in New Brunswick.  If the ratio of Cooke’s profit to Nova Scotia’s labour income of about a hundred to one seems lopsided, recall what was said in Letter # 10. It was shown that the St. Marys sites generate 23,128 times more revenue per hectare for Cooke Aquaculture than the fees charged by NSDFA. Incidentally, when NSDFA charges the finfish aquaculture industry a fee of $12.18 per hectare per year, that fee is even tax exempt.

It would have been easy to write about NSDFA’s top bureaucrat. Under his leadership we have seen salmon sites go from his rosy assessment in 2006 that “Overall findings from the baseline sampling revealed that the majority of these sites showed no significant impact” to the assessment that many finfish sites in Nova Scotia already are  polluted and some, grossly polluted. Further, with no proven effective mitigation processes, all new sites are bound to end up in the polluted to grossly polluted status, unless for the first time ever, NSDFA enforces its own regulations and shuts contaminated sites down. Less discussed is the dismantling of the regulatory process under this bureaucrat’s leadership. All one has to do is to compare the 2007 Aquaculture Lease/License Review Process flow chart to the present one*. The responsibilities of Public Notice and Consultation function, of the Technical Review function and of the Licensing staff function have all been severely watered down. Other examples of the dismantling of the regulatory process can be cited, such as the lack of enforcement, the acceptance of incomplete environmental assessments from the  aquaculture industry, and the acceptance of audits of highly contaminated sites where such audits were not conducted by independent third parties, but by the very same finfish aquaculture industry company that worked for the site operators. Perhaps the ultimate reflection of the dismantling of the NSDFA regulatory process came when the former NSDFA staff chose to leave NSDFA rather than be relocated outside of Halifax.

It would have been easy to write about the hardships NSDFA has imposed on everyday Nova Scotians. Lobstermen in St.Marys Bay who have worked their trade for generations and had paid for valid licenses, found that they could not return to areas they had traditionally used because of cordoned-off aquaculture sites. Honest people who bought  a home in Port Wade had a dormant fish site rapidly reactivated when its old license was purchased. This site did not appear on any maps of the area, there was no warning, no public hearing, and no environmental review. Their property has been downgraded from a residential classification to an industrial classification. This is all acceptable to the NSDFA because, as stated on page 17 of the Province’s Aquaculture Strategy, “ The reassignment of a license doesn’t require public engagement.” Water quality in Shelburne Harbour has already degraded due to the operation of the old Sandy Point site and will only get worse when the fish are stocked in the bigger new Sandy Point site, just 100 meters away. The whining noise of oxygenators is so loud that local residents have been forced inside their homes behind closed windows and doors. Beautiful Carters Beach at Port Mouton now has something in the water that causes bathers to break out in rashes. The large fish site nearby is the suspected cause. When Jordan Bay is stocked, local lobstermen plan to leave the area, after spending decades of their lives there and being the economic backbones of their community. Elsewhere in Nova Scotia people who have, for many years, operated  a summer resort with a nearby beach fear that their livelihood is over because a open net finfish site has now been placed just where guests like to swim. The efforts of volunteers to restore wild salmon to the Mersey River is now under threat if the farmed salmon at the nearby Coffin Island site escaped. Under NSDFA direction, this site was, for the first time, allowed to grow farmed salmon. Hundreds of thousands of aquaculture fish have escaped over the years and now their inferior genes infest more than 80% of the Bay of Fundy streams. Lost are  the wild salmon runs in 33 Bay of Fundy rivers, 23 of which are in Nova Scotia. The chief suspect is the open net pens because these wild salmon mingle and feed near those pens in the outer bay where they are subject to infection from parasites and disease. Etc., etc.

Sooner or later all this will collapse because it is not sustainable. The jobs that depend on this low technology form of finfish aquaculture will also collapse. The results of this terribly wrong experiment will be the legacies of the Premier, the Minister, and the top NSDFA bureaucrat. It need not be yours if you act now. Nova Scotia needs two fundamental changes if finish aquaculture is to ever succeed. It needs a modern non-polluting technology and it needs the Fisheries Resource and Coastal Act to be rewritten so that the promotion of aquaculture and the regulation of aquaculture are placed in different ministries.

* http://www.friendsofshelburneharbour.org/uploads/Letter___22.pdf    Figures 3 and 4.

Herschel Specter
mhspecter@verizon.net

In spite of saying that letter 11 was my final letter, I have created  letter 12. It is perhaps the most damning of all. It shows that while NSDFA’s Environmental Monitoring Program Framework document (March, 2011) was supposed to be a significant advance in the monitoring process of aquaculture in Nova Scotia, its implementation would actually destroy any meaningful monitoring process.

LETTTER # 12
March 26, 2013

SPIN CITY - NUMBER THREE
“HOW TO LOOK GOOD WHILE DAMAGING THE ENVIRONMENT”

Monitoring aquaculture sites and enforcing regulations are essential to proper regulation, yet NSDFA’s monitoring and enforcement history has been dismal, at best. For years, sulphide levels in the polluted to grossly polluted range were recorded at many salmon farm sites, but neither NSDFA nor DFO took any corrective actions*.

Monitoring and enforcement problems continue to this day. NSDFA’s Minister has not provided monitoring information for the Jordan Bay and Blue Island sites in spite of numerous requests from concerned citizens. Monitoring is a serious issue at these poorly located sites. DFO has called for enhanced monitoring at these sites, even during the first production cycle. The requested monitoring information is contained in a schedule that forms part of the licenses issued by NSDFA to Kelly Cove Salmon, Ltd. (KCS), a subsidiary of Cooke Aquaculture. So KCS has the monitoring information, but the public does not.
 
Similarly, NSDFA’s Minister has not responded to requests from citizens who live near the Owls Head aquaculture site to explain why monitoring actions there are being conducted in a manner that is inconsistent with instructions in NSDFA’s Standard Operating Procedures (SOP)** document. Some 2012 sampling stations are over 100 meters from the farm site. Monitoring stations should be placed along the centerline of the fish cages (See Figure 1, SOP document), not over 100 meters away. Sulphide readings 100 meters away from the fish cage centerline give a false indication of the site’s condition; they would be much lower than centerline measurements. NSDFA’s actions at Owls Head undermine the whole purpose of its own monitoring program.

Recent computer analyses conducted by DFO using its DEPOMOD program have pointed out another severe monitoring problem which would likely occur during the first production cycle. In site after site, DEPOMOD analyses predict very high sulphide levels, usually in the Anoxic range, in an area right where the SOP document instructs site operators to place their monitoring stations. With high sulphide levels at the centerline monitoring stations predicted prior to site operation, then later, with measurements that would confirm these predictions, and with no effective mitigation processes, what could NSDFA do that would justify keeping these aquaculture sites operating?

Everyone should be warned that NSDFA’s past and present disregard for proper monitoring and enforcement may be replaced in the future by a much more subtle form of achieving the same end results. Looking ahead, it appears that NSDFA has developed an elaborate way to circumvent the purpose of monitoring salmon farms and has embedded this process into its March, 2011 Environmental Monitoring Program (EMP) Framework*** document.  Meaningful monitoring could end if this scheme is implemented because it will be possible to classify any site as being in the Oxic range when, in fact, the site would be experiencing significant environmental damage. Please recall that the EMP Framework document was jointly developed by NSDFA and the aquaculture industry without any public or environmental group’s input.

In order to understand how this scheme could work, the relationship between oversized lease areas and NSDFA’s EMP Framework document must be understood. In the past few years, NSDFA has granted oversized leases. The new Sandy Point site in is 343% larger than the former Sandy Point site. At Jordan Bay and Blue Island, each lease gives KCS 40 hectares. However  less than 7% of the lease area would be needed to grow salmon, leaving about 93% of each lease area open. This gives KCS lots of room to relocate fish cages at the end of one or more production cycles. Having oversized leases is essential if there is to be the appearance of low environmental impact from open net finfish aquaculture.

The EMP Framework document promotes the following process:

(1) At the end of the first production cycle, because the sulphide numbers are high and likely in the Anoxic range, relocate the cages to another area within the oversized site. (See EMP Framework document, page 17, second bullet). One benefit of relocating after the first production cycle is that this permits the operator to have a second production cycle regardless of the contamination that was caused during the first production cycle. As a second benefit, this relocation would create an initial batch of useful historical stations. Historical stations are monitoring stations with a history of high sulphide levels greater than 3000 uM. The initial batch of historical stations would likely be the original monitoring stations along the cage area centerline used during the first production cycle. Sulphide levels at these “historic stations” would rapidly decrease after the first harvest and when the salmon are grown in a different location within the site. Note that even when historic stations achieve low sulphide levels this does not mean that the loss of macrofauna under them has been reversed. Sulphide levels can decrease rapidly, but the return of the macrofauna in the sea bed can take many years, if they come back at all. So the area in the sea bed below these historic stations that was classified as Anoxic because of its high sulphide level remains a dead zone, regardless of low sulphide levels at these historic stations after the relocation of the fish cages.

(2) The EMP Framework document requires that the historical stations be used, along with centerline stations, to classify the site (See EMP Framework document, page 8, fourth paragraph). At the end of the second production cycle, blend in the number of centerline monitoring stations with the initial batch of historical stations. Even if the centerline monitoring stations were all Anoxic the overall site classification would likely be classified as Hypoxic A or Hypoxic B. This is because the EMP Framework classification process requires > 70% of the sampling stations to exceed 6000 uM in order to have a site classified as Anoxic. However, with the number of low sulphide level historic stations equal to the number of  Anoxic centerline stations the > 70%  figure can not be exceeded. So the first effect of blending historic stations with centerline stations would be to lower the site classification from Anoxic in the first production cycle to Hypoxic in the  second production cycle, even though the damage to the sea bed below the cages would be just as severe in the second production cycle. Perhaps this would be announced as an indicator of environmental progress being made at this site. By this time there would be historical stations from the first production cycle and from the second production cycle. The next step would be to move the fish cages yet again and start the third production cycle.

(3) Once again the sea bed damage under the centerline monitors would likely  be in the Anoxic range. However, the number of historical stations could be twice the number of the centerline monitoring stations of the third production cycle. According to the EMP Framework classification process all that is needed for a site to be classified as Oxic is to have one more historical station below1500 uM than the number of centerline monitoring stations, regardless of how high their sulphide levels are. (See EMP Framework document, page 8, site classification box ). Once the number of historic stations exceeds the number of centerline stations, the monitoring program becomes useless. The EMP Framework document’s classification scheme plus the use of historical stations plus an oversized site would permit Oxic site classifications regardless of actual sea bed damage. Great environmental progress could be declared since a site’s classification would have gone from the Anoxic level during the first production cycle to the Hypoxic level in the second production cycle to Oxic during the third production cycle. In addition, once a site is declared Oxic for two production cycles, the site operators would be rewarded by NSDFA by having the frequency of monitoring at the site reduced. (See EMP Framework document, page 8, last paragraph). The end point of all this is that a very large DEAD ZONE would be created while all along the reports from NSDFA could be that “all is well, the site was steadily improved with each production cycle,  and now the site continues to operate in the Oxic range”.

If the Province’s monitoring plan is to announce only the site’s overall classification at the end of each production cycle and not the specific sulphide levels at all monitoring stations and the effect of using historical stations in the classification process, the public would never know that the claimed classifications were the result of inappropriately blending in historic stations. Perhaps the reason that the monitoring schedules at Jordan Bay and Blue Island have not been made public is tied to this scheme.

The NSDFA’s EMP Framework document should be withdrawn and rewritten with public input. Until such time, NSDFA does not have a defensible monitoring process and no new stocking of sites should take place until it does.

*     See www.ecologyaction.ca/content/nova-scotia-fish-farms-impacting-environment-report

**   See www.gov.ns.ca/fish/aquaculture/ns-emp-sops-march2011.pdf

*** See  www.gov.ns.ca/fish/aquaculture/ns-emp-framework-march2011.pdf


Herschel Specter
mhspecter@verizon.net
                             



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