Canadian Sablefish Association
POSITION ON SABLEFISH AQUACULTURE

April 2004

1. 0 INTRODUCTION

The Canadian Sablefish Association (CSA) represents the interests of British Columbia's commercial sablefish fleet. First and foremost we seek to ensure the long-term sustainability of wild sablefish stocks.

For over a decade the CSA has co-managed the sablefish resource together with Fisheries and Oceans Canada (DFO) in what is considered a world-class model of fishery management. We contribute over $2.4 million annually to scientific research, stock assessment, monitoring, enforcement and fishery management. The CSA is a responsible, accountable and proud steward of this valuable resource.

Sablefish aquaculture has advanced rapidly in recent years is nearing commercial viability. Fifty salmon farms coast-wide have been licenced to farm sablefish and the first sablefish hatchery is under development on Saltspring Island, BC. Sablefin Hatcheries Ltd. plans to produce ten million fingerlings annually, a volume greater than the worldwide sablefish catch.

Alarmingly, this has all taken place in complete absence of environmental or economic impact studies.

The CSA is concerned for the future of the wild fishery. We have carefully monitored the progress of sablefish aquaculture in BC and thoroughly considered information (or lack thereof) on how aquaculture impacts the environment and our economy. Our research consistently reveals growing international and domestic evidence of wide-ranging problems that threaten to devastate wild fish stocks and their habitats and undermine successful, sustainable fisheries and communities.

This paper details CSA concerns over how sablefish aquaculture will impact the wild sablefish resource and fishery.

2.0 ENVIRONMENTAL CONCERNS

Sablefish, a deepwater species, is unique to the northeastern Pacific Ocean. Juveniles mature in the coastal inlets of Washington, British Columbia and Alaska. What will happen if farm sablefish are introduced to open-water net pens in these sensitive rearing grounds? So far no one has bothered to find out. Unfortunately the lessons from salmon farming are disturbing to say the least. Diseases and parasites have devastated wild stocks. Escaped farm and wild fish have interbred, undermining natural genetic diversity. Toxic sewage, pesticides and drugs have polluted pristine rearing habitats. And because sablefish are known to be highly migratory and long-lived, the potential threat increases from BC's sablefish to the entire species.

Some may question whether salmon farming can serve as a model when considering the farming of new species such as sablefish. While we recognize the notable differences in the two species of finfish, it is the striking similarities in industry development that make salmon a relevant point of reference. As salmon aquaculture boomed ahead of effective environmental regulatory measures, industry confidently denied any threat to wild stocks, ecosystems and fisheries. The reality is that most major fears expressed have come true and salmon farming countries worldwide are now suffering the consequences.

2.1 Disease and Parasite Transfer

The unnaturally high densities of fish in the feedlot environment of net-pens makes a prime breeding ground for disease and parasites. Recently in BC, farm derived parasites were implicated as the causal agent leading to the largest salmon cohort collapse on record anywhere in the world. A. Morton et. al. Sea lice infection rates on juvenile pink and chum salmon in the nearshore marine environment of British Columbia, Canada, Canadian Journal of Fisheries and Aquatic Sciences, March 2004.

2.2 Genetic Interaction

Scientific studies have demonstrated that escaped farm salmon will compete for wild spawning grounds and breed with wild salmon. Sadly the hybrid offspring survival rates decline with each successive generation threatening extinction of the run. McGinnity, P. et. al. Fitness reduction and potential extinction of wild populations of Atlantic salmon as result of interactions with escaped farm salmon, The Royal Society Proceedings B, October 2003.

2.3 Habitat Destruction

Salmon farms spoil fragile marine ecosystems with raw sewage, pcb-laced feeds, pesticides and antibiotics. A single salmon farm can contaminate coastal inlets with as much raw sewage as a town of 65,000 people. Malcolm MacGarvin, Aquaculture, nutrient pollution eutrophication and toxic blooms. World Wildlife Federation Scotland, September 2000.

3.0 SOCIO-ECONOMIC CONCERNS

The annual landed value of Canada's commercial sablefish harvest is approximately $30 million. Industry investment in commercial licences, quota and vessels is nearly $300 million. The fishery employs 300 fishermen directly and 300 more in offloading, processing and distribution. Commercial licenceholders invest more than $2.4 million annually in sablefish science and fishery management. Harvesting methods sustain minimal by-catch and stock abundance is as strong as when the fishery began.

Wild sablefish is one of the most responsibly managed fisheries resources in North America, due in large part to industry's commitment to the long-term sustainability of the resource. In many cases it provides a much-needed means of diversification for struggling fishermen from other sectors such as salmon. By allowing them to remain viable, the sablefish fishery helps to sustain the commercial fishing industry as a whole.
The following socio-economic concerns outline important issues to consider before sablefish aquaculture is allowed to proceed.

3.1 Market Collapse

Sablefish markets are located primarily in Asia, mainly Japan and Hong Kong. Exports bring valuable net-income to Canada, as opposed to redistribution of income within the country. This high-end niche market is small but very well-established based on high product quality. Should Sablefin Hatcheries proceed with production on the scale proposed, they will more than double the current supply of sablefish to the market. This excess supply will push market prices to drop substantially. Such a serious market crash would render both the wild fishery and the sablefish farms economically unviable.

As with salmon farming, the technology and expertise will be exported to countries with much lower costs of production. The large multi-national corporations that own and operate the aquaculture industry have no commitment to Canada or our wild resources. With no accountability, it is inevitable BC will serve merely as a means to an end. For wild and farm industries it will be is a lose-lose situation.

3.2 US Relations

Alaska's commercial sablefish harvests are valued at $120 million, while Washington State harvests bring in approximately $20 million. Their combined landed value is more than four times that of BC's harvest.

Unfortunately, what BC does could seriously affect these US fisheries. Sablefish stocks are highly migratory, traveling from coastal inlets further south than California, as far north as Alaska's Aleutian Islands, and vice-versa. This puts the entire species at risk from the threats posed by BC's shamefully blind development of sablefish farming.

With Alaska's "no aquaculture" policy clearly prioritizing wild stocks over fish farming, BC's actions will do little to foster healthy Canada/US relations on fisheries.

3.3 Depletion of Global Fish Supply

It takes three to six pounds of wild fish (as feed) to produce one pound of farmed salmon. Contrary to common belief, aquaculture actually depletes the world supply of fish by taking more out as feed than it produces. By promoting over-fishing of the bottom end of the food chain, the balance of nature is compromised and long term effects could be disastrous. Naylor, R. L. et. al. Effect of Aquaculture on World Fish Supplies. Nature, Vol. 405: pp. 1017 - 1024, June 2000.

3.4 Public Health Risk

Analysis of salmon fillets from about 700 farmed and wild salmon produced in eight major farmed salmon producing regions and purchased in 16 large cities in North America and Europe found significantly higher concentrations of pcb and dioxin contaminants in farmed salmon than in their wild counterparts. Hites, R. A. et. al. Global Assessment of Organic Contaminants in Farmed Salmon, Science Vol 303, January 9, 2004.

4.0 RECOMMENDATIONS

The CSA recommends an approach to sablefish aquaculture consistent with federally mandated precautionary approach to resource management as follows:

4.1 Moratorium

Until effective measures have been put in place to protect the wild sablefish resource and ensure the responsible development of sablefish aquaculture, provincial and federal governments must place all existing sablefish aquaculture permits on hold, and halt the issuance of new sablefish aquaculture permits. It is imperative that no farm sablefish be permitted in open-water net pens until all risk factors have been properly addressed.

4.2 Environmental Assessment

Evidence of ecological threats posed by aquaculture constitute an unacceptable risk to the wild sablefish resource. Sablefish aquaculture must undergo a species-specific Canadian Environmental Assessment Agency (CEAA) environmental assessment. This assessment must be based on the federally proposed volume of 150,000 tons annual production. Regional sablefish scientists must be included in the assessment process and open and transparent stakeholder consultation must take place.

The CEAA assessment includes an Aquatic Organism Risk Analysis which claims to evaluate the risk of genetic, ecological, disease and parasite impacts. To effectively assess the risk factors associated with sablefish aquaculture, this analysis must address the probability and consequences of the following:

4.2.1 Farm sablefish escape from open-water net pens

4.2.2 Wild juvenile sablefish exposure to farm sablefish spawn

4.2.3 Genetic interaction between farm sablefish and wild sablefish

4.2.4 Disease and/or parasite transfer from farm sablefish to wild sablefish

4.2.5 Disease and/or parasite transfer from farm salmon to wild sablefish

4.2.6 Genetic impacts of farm sablefish spreading to wild sablefish outside BC

4.2.7 Disease and/or parasite infestation from farms spreading to wild sablefish outside BC

4.2.8 Wild sablefish exposure to sablefish farm sewage, feeds, pesticides and antibiotics

4.2.9 Juvenile sablefish rearing habitat destruction resulting from sablefish farms

4.2.10 Sablefish aquaculture lighting techniques negatively impacting wild juvenile sablefish stocks

4.2.11 Domestic selection process impacts on farm sablefish or wild sablefish

Mitigation measures must be taken for all risk factors where a probability of negative impact exists, before sablefish aquaculture proceeds.

4.3 Socio-Economic Cost/Benefit Analysis

A comprehensive socio-economic cost/benefit analysis must be conducted to determine the impact of sablefish aquaculture on:

4.3.1 The wild sablefish fishery and markets

4.3.2 The commercial fishing industry in general

4.3.3 Coastal communities reliant on the sablefish industry

4.3.4 Provincial and federal economies

4.3.5 US relations and sablefish fisheries

4.3 Traceability

Conservation and protection of wild sablefish stocks will require implementation of traceability measures to clearly distinguish farm from wild sablefish at all levels of production, harvesting, distribution, marketing and sales.

4.4 Security of Access

DFO policy to prohibit reallocation of wild sablefish resources for aquaculture or holding pen research initiatives, without compensation to resource stakeholders.

5.0 CONCLUSION

Globally, aquaculture is an industry that has grown too rapidly to be regulated effectively. Countries worldwide have failed to implement and enforce effective measures to protect coastal ecosystems, fisheries and communities. At the same time, aquaculture has fallen under the control of very short list of foreign multi-national corporations. Companies that have political influence but hold no accountability to the ecosystems, fisheries and communities they devastate. BC is struggling for survival in this intensely competitive global market and the downturn is expected to continue. Salmon farmers are increasingly desperate to diversify. As the aquaculture industry pressures governments to allow hasty expansion to lucrative new species, a blind eye is turned to evidence of salmon farming's widespread environmental devastation.

The CSA remains committed to doing everything necessary to protect the wild sablefish resource and ensure that is does not fall prey to the tragic events unfolding in salmon aquaculture. We will direct our efforts to government, politicians, courts of law, media, industry and the public to fulfill our responsibility as proud stewards of the sablefish resource.