1. Fish escape. They then breed with wild salmon contaminating the natural gene pool. This reduces wild salmon populations. Escapes also carry viruses in their genes that can be passed on to wild fish directly or through breeding with them.
2. The aquaculture industry is not financially sustainable and stable. Without Government handouts, these net pens would not be viable. Ex. - Government has committed $45 million to the current Grieg proposal. This conflict of being both promoter and regulator has resulted in corner cutting and unreporting of environmental and disease issues.
3. Salmon feed pellets contain toxic additives, high levels of persistent organic pollutants, and broadcast non targeting antibiotics.
4. Excessive antibiotics are used in the pens to control salmon diseases. This has been shown to cause intensive and widespread (greater than 8 Km) antibiotic resistance that spreads to human and animal pathogens. This is a concern of the OIE, WHO, and all organizations that are concerned with antibiotic resistance.
5. Excessive pesticides are used in these pens to control sea lice. This usage is amplifying as the lice are showing resistance to all the chemicals used.
6. The pens amplify sea lice and other parasites by the trillions under the unnatural conditions ocean net pens provide. The lice are natural parasites to the salmon but as few as 7 to 11 lice can kill a young salmon as it migrates past these pens to the open ocean. Far fewer lice can reduce their chances of survival in nature. Studies show that more than 98% of a very large wild salmon annual run can be eaten alive by ocean open net pen amplified lice.
7. Pathogens such as bacteria, protozoans, and viruses are amplified and made more virulents in open net pens and these are passed on to wild fish.
8. " Dead Zones" are found under these pens. These zones contain feces, undigested food, antibiotic resistant pathogens, and chemicals. These are often many feet deep.
9. The pens contaminate other species of fish that live in the area permanently or seasonally. Would you eat a lobster or codfish caught near one of these pens?
10. These pens can be a hazard to marine and winter navigation, especially when lost or damaged.
11. Predator migration disruption and attraction is common with these pens. They often entrap seals, otters, mink, bluefin tuna, endangered sharks, whales, osprey and bald eagles. The pens are often cut or ripped open by these attracted predators. These same attracted predators result in unnatural predation on nearby wild fish stocks.
12. Wild fish stocks such as juvenile pelagics, squid, and small fish like lance are attracted from vast distances by the feed pellet dust and lights. The penned fish are thus illegal fed wild fish. These attracted fish also attract large pen damaging predators.
13. It takes 2 or more kg of wild fish to make enough salmon pellets to produce just 1 kg of salmon filet under ideal conditions. 80% of these fish made into feed pellets were fit for human consumption before being fed to salmon. The current trend is to replace the fish content with cheaper more price stable pig/chicken scraps and plant by-products.
14. Statistics show nearly 20% of the fish die annually in open net pens.
15. When the salmon are harvested, the offal is extremely toxic. This waste is not disposed of in a safe manner by the plant operator.
16. Processing plants have ineffective or simply no effluent treatment and thus spread amplified parasites and pathogens to bays far and wide throughout Atlantic Canada.
17. Many of the unfrozen fish are sold while carrying transmissible epizootic pathogens, still other pathogens can withstand freezing and be spread. This is a serious issue we are still learning about. Net pens facilitate this.
18. The industry is by and large self regulating using voluntary reporting without any independent oversight for critical issues like neurotoxin use, antibiotic use, parasite counts, disease reporting, stocking and harvesting numbers, etc
19. Salmon epidemiology is still in its infancy and most pathogens are surveyed in an Ad Hoc manner many are not tested for at all.
20. Effective, trustworthy, and timely public reporting is virtually non-existent.
21. Fish counting and mortality tracking is so poor it allows up to 6% of the fish to simply "vanish" without any effective oversight. This has resulted in under-reporting escapes and illegal dumping at sea.
22. Lack of adequate environmental assessments.
23. Coastal nutrification is illegal in Canada but is ignored when regarding open net pens. This has amplified salp, tunicate and toxic algal blooms.
1. Industry operates without any social license as evidenced in every poll and survey.
2. Locals have little to no input or recourse regarding management and issues.
3. In small, often remote villages, residents are often forced to take jobs at open net pen and processing sites without effective voices; adequate operational, health, and safety guidelines; or information regarding job related risk assessments.
4. Within family and community strife is induced between industry workers and those seeking industry change.
5. Jobs are never stable in open net pen companies and sudden and unexpected unemployment is common.
6. Government is both a major investor and regulator without enough independent oversight bringing lop-sided promotion, support and ineffective enforcement.
7. Open net pen detractors are ignored.
8. Whistleblowers are dealt with harshly and public reporting downplayed, ignored, or worse.
9. Ocean and land use conflict issues are typically decided in favour of industry.
10. Open net pen salmonids no longer remotely resemble the nutritious wild fish consumers are expecting when purchasing.
11. Too many toxins are in the fish.
12. Nearby wild fish and other wildlife can become chemically contaminated degrading the marketing image, value, and availability of wild harvested fish and tourism; and socially important natural food sources.
13. Pathogens are amplified, mutated to become more virulent, and are spread to wild populations reducing their numbers thus limiting natural food, and affecting other industries and jobs.
14. Antibiotic resistance is a major concern and can be transmitted to human and animal pathogens far and wide. No monitoring or testing is ever done.
1. The province needs to implement marine water lease fees on scale with marine lease fees currently in place in other jurisdictions such as Norway.
2. All companies, new and existing, are required to post bonds to be used for clean-up and remediation.
3. Freeze all government compensation for loss of fish that must be destroyed because of viral infections, disease infestation, or death from natural causes (such as super chill, etc).
4. Implement stiff fines and penalties for all violators of regulations, including possibility of loss of operating privileges for serious violations or repeat offenders.
5. The province not enter into a conflict of interest by acting as regulator while holding significant investment and/or ownership in aquaculture projects at the same time.
6. Balance direct and indirect government support with other food production methods.
7. Financial and regulatory support of environmentally unfriendly open net pens over RAS land based closed containment systems simply due to increased profit margins and reduced capital expenditures.