April 16, 2004

Alaska State
Governor Frank Murkowski
Senator Paul Seaton
House Fisheries Special Committee

Washington State
Governor Gary Locke
Senator Jean Kohl-Welles
Senate Committee on Parks, Fish & Wildlife
House Committee on Fisheries, Ecology & Parks

United States
Alaska Senator Ted Stevens
Alaska Senator Lisa Murkowski
Washington Senator Maria Cantwell
Washington Senator Patty Murray
Senate Subcommittee on Fisheries, Wildlife & Water
Senate Subcommittee on Oceans, Atmosphere & Fisheries
House Subcommittee on Fisheries Conservation, Wildlife and Oceans

Dear Alaska and Washington State Politicians:

$120 MILLION US SABLEFISH FISHERY IN JEOPARDY

The Canadian Sablefish Association (CSA) represents Canada's commercial sablefish (blackcod) fleet. Our average annual harvest of 4,500 tons, exported primarily to Asia, is worth approximately $27 million. Alaska's annual harvest of 20,000 tons represents an export value of $120 million. Washington State's annual harvest of 5,000 tons is valued at approximately $20 million. These extremely well-managed, sustainable fisheries are a source of pride for both our countries.

We are writing to alert you of the rapid development of sablefish aquaculture to British Columbia. A risky venture that poses a very real threat to the wild sablefish stock and commercial sablefish fisheries of Alaska, British Columbia and Washington State. Development is proceeding blindly in complete absence of environmental and economic assessments.

Enclosed is a January 2001 letter from Alaska's Fish and Game Commissioner to BC's Ministry responsible for aquaculture development. Frank Rue raised several serious concerns over salmon farming in BC. We are ashamed to report that the Commissioner's fears were completely ignored. In fact, since the letter was written BC's moratorium on salmon farming was lifted and salmon farms have expanded, particularly in northern British Columbia near the Alaska boundary.

Further, through ongoing research and monitoring of aquaculture impacts, we confirm that:

• Aquaculture threatens wild stocks with diseases and parasites. Recently in BC, farmed 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.
  
  
• Escaped farm fish endanger wild stocks when they interbreed. Farm salmon escaped from farms, fish beat out wild fish for spawning grounds only to suffer much higher mortality. Hybrid offspring survival rates decline with each successive generation leading inevitably to 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.
  
  
• Fish farms devastate precious ecosystems with toxic sewage - a single salmon farm can contaminate pristine waters 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.
  
  
• Globally aquaculture depletes the world supply of fish by taking more out as feed than in produces, undermining the balance of nature by over-fishing the bottom end of the food chain. It takes three to six pounds of wild fish (feed) to produce one pound of farmed salmon. Naylor, R. L. et. al. Effect of Aquaculture on World Fish Supplies. Nature, Vol. 405: pp. 1017 - 1024, June 2000.
  
  
• Aquaculture is controlled by a very short list of foreign multi-national corporations which return insignificant profits to local peoples and wreak economic havoc on once viable coastal communities and fisheries. Naylor, R. L. et. al. Salmon aquaculture in the Pacific Northwest: a global industry with local impacts, Environment, October 2003.
  
  
• Farmed salmon pose a health risk to consumers. Aquaculture feed contains more dioxins than any other livestock feed and farmed salmon has ten times more PCB's than wild. Hites, R. A. et. al. Global Assessment of Organic Contaminants in Farmed Salmon, Science Vol 303, January 9, 2004.
  
  
• BC salmon farms are struggling for survival in an intensely competitive global market. With the downturn expected to continue, salmon farms are increasingly desperate to diversify.

Which bring us to world's first-ever commercial sablefish hatchery. Located on Saltspring Island, BC, this government-funded venture forecasts sablefish farm production equal to the US and Canadian catch combined. This will undoubtedly crash the market, but an even greater fear is the threat to the wild sablefish.

Sablefin Hatchery is just months away from releasing farmed sablefish to over 50 salmon farms coastwide. Many of these sites are situated in inlets clearly identified as wild juvenile sablefish rearing areas. Will sablefish suffer the same fate as our wild salmon? Two factors make this a sadly probable outcome. In contrast to salmon, sablefish are very long-lived and highly migratory. Tagging studies indicating BC stock migrate as far north as Alaska's Aleutian Islands and south below the lower 48th parallel. Kimura, D.K., A.M. Shimada, and F.R. Shaw. 1998. Stock structure and movement of tagged sablefish, Anoplopoma fimbria, in offshore northeast Pacific waters and the effects of El Nino-Southern oscillation on migration and growth. Fishery Bulletin 96: 462-481. This will put the entire species at risk and warrants serious concern.

We strongly urge you to contact BC Premier Gordon Campbell and Canada's Federal Minister of Fisheries and Oceans Geoff Regan to demand action to protect our valuable sablefish resource. Essential environmental and economic impact studies will take the kind of time and money only realized through leaders who strive for a legacy of stewardship that we can all be proud of.

We look forward to a successful joint effort to protect our fisheries and at a minimum, ensure precautionary development of sablefish aquaculture. Please advise how you can help and if there are any questions or concerns we might address.

Sincerely,

Eric Wickham
Executive Director