11 December 2009
Fiona Cameron, The Atlantic Salmon Trust (AST) and The Sea Trout Group (STG)
These comments are supported by the Scottish Anglers National Association (SANA)
1. General comments
The AST and STG are opposed to the promulgation of a Standard which may foster public perception of farmed salmon as an environmentally sustainable product, while there is a risk that accredited farms may still be inflicting significant adverse impacts on wild salmonids and marine & freshwater habitats.
We would point out that the salmon farming industry continues to adversely impact wild salmonids even in countries which currently have (apparently) robust regulatory systems. The only justification for a new Standard is as a means of driving up standards considerably, and on a continuous improvement basis, and thus tackling the deep-rooted problems associated with open system salmon aquaculture.
a) The draft document, as it stands at present, risks simply standardising farming practices which are flawed, and represent the lowest common denominator. There are insufficient signs that the Standard will present challenging targets which will drive up standards in the industry. In particular, this relates to addressing the problems caused by: amplification of parasites and disease; escapes from marine and freshwater cages; pollution of the environment by fish waste and uneaten feed.
b) We feel that the indicators as currently drafted do not provide adequate protection from such a risk, for these principal reasons:
1. Many of the parameters and measurements suggested as indicators represent areas of knowledge which are incomplete and under-researched – for example, salmon migration routes, sea lice dispersal patterns, sea trout feeding patterns. It remains unclear how the Standard will deal with measurements set against a background of scientific uncertainty. The only pragmatic solution would appear to be robust attention to the Precautionary Principle in stipulating where accredited farms may be sited. A long-term solution would also require to make provision not only for a built-in review process for criteria and indicators, but also for revision of accredited status in light of emerging science.
2. Several of the terms used within the document are insufficiently defined: for example “environmental sustainability”, “sensitive” stocks. We would query whether a word such as “sensitive” can be sufficiently robustly defined to belong in a Standard which depends on detailed measurement of impacts.
3. The draft indicators require very substantial revision and re-shaping, to reflect the fact that many of the impacts which must be measured cannot logically or practically be measured at farm level.
It will be necessary to make provision for measurement of certain impacts (for example, lice infestation of wild salmonids) on an area basis, and to set farm-level measurements within this framework.
c) We can see nothing within the Draft Indicators which would be likely to encourage the salmon farming industry to move towards closed containment – a solution which we believe is, ultimately, the only way to ensure environmentally sustainable operations. It would be a pity to lose the opportunity to set the bar high enough to make investment in closed containment an attractive option for salmon farmers. The only way in which this can be achieved is to significantly strengthen overall operating standards within the industry, and to ensure that these are enforced, otherwise any accreditation scheme is in danger of giving a completely false impression to consumers as to the sustainability of salmon farming.</u>
d) The indicators do not currently acknowledge the importance of the impact on sea trout (Salmo trutta) populations. Since these fish remain in coastal waters throughout most of the marine phase of their life cycle, and therefore may be more vulnerable to local parasite and disease transfer, their interests must be specifically included.
2. Specific comments on Principle 3: Protect the health and genetic integrity of wild populations.
3.1.1. This documentation must be publically available. This should be extended to require the certified companies to make publically available information on their internal research programmes. We believe it’s also very important that where diseases such as PD (Pancreas Disease), which are no longer on the notifiable list in the UK, exist in farm stock, farms should be required to make information on their disease status available to all interested parties; there is clearly a strong link between sea lice infestation of farmed fish and heightened susceptibility to disease; this in turn links to greater problems in administering sea lice treatments (the fish may be off-feed, or the salmon farming company may judge that the fish cannot stand the added stress of a bath treatment). Since it is impossible to monitor the progress of non-notifiable diseases in countries such as the UK, it is important not to lose the learning opportunity which a full disease database would represent, in terms of observable patterns of disease and links to other factors such as lice infestation.
3.1.2. If non-endemic notifiable diseases are detected on a farm, it should lose its certification until the cause of disease can be scientifically established, and the threat removed. The suggestion that the individual farm should be required to show through environmental testing that diseases have not “jumped into the wild” is impractical and unenforceable, and should be removed.
3.1.4. This should be changed to: ‘Maximum on-farm lice levels, related to a maximum agreed area lice level’. An effective lice dispersal model must be developed as part of this accreditation scheme in order to assess acceptable maximum farm/area lice levels. In some locations the lice dispersal model may indicate where more stringent standards are necessary to protect wild fish populations.
3.1.7b.There is a need for further research to gain additional knowledge of this, as “safe” area-level maxima will vary according to area. Again, in light of scientific uncertainty, a precautionary approach should be adopted.
3.1.7c. There is a need for specialists to create a standardised protocol for recording numbers of lice on wild fish (e.g. photographic images from counting stations), and a requirement for farms to invest in area/regional monitoring structures. Arriving at a pragmatic solution for adequately-resourced independent monitoring of lice on wild fish is the only way to monitor the impact of potential amplification of lice in salmon cages, in a manner which will gain the confidence of all stakeholders.
(See also point 8 in Recommendations)
3.1.8.b. We recommend acceptance of the suggestion (made by John Volpe) that a measurement of “number of fish” is added to the measurement of kilos of fish, since size of hosts is the significant factor.
3.1.8c. We do not believe that it is wise to attempt to define a widely-applicable ‘minimum safe distance’. It is impossible to make a generic prediction of a safe distance, given the site-specific nature of these impacts. This is complicated by the nature of the fjordic systems currently favoured by the salmon farming industry, due to their complex hydrography and exposure to strong winds and currents. Similarly, the most usual situation is for several salmonid rivers to issue into a single fjord or sea loch: do we therefore define distances from rivers or from the entire fjord? The example of damaging sea lice infestations being found on fish in the rivers of Trondheimsfjord (a fish-farm-free National Salmon Fjord) demonstrates the complexity of the situation. A lice dispersal model must be established to determine, as far as possible, the potential impact on wild salmonids. Knowledge of migration routes should also be taken into account as it becomes available, as should the list of sensitive and economically important inshore sites. This will, in the first instance, involve dealing with considerable scientific uncertainty.
3.2.1. The draft suggests that non native species can be introduced if they are assessed to pose an ‘acceptable level of risk’. We question how an ‘acceptable’ level of risk can be determined when we do not understand the ecosystem level impacts of non-native species, and when open systems allow full interactions with the surrounding environment. The impacts of non-natives can be very complex and take time to become apparent. We believe non-native salmon aquaculture should not be permitted for accreditation, unless within closed systems - where stricter control can be exercised and environmental impact genuinely minimised. We also believe that the Standard should recognise the potential for undesirable impacts from non native species introduced to salmon pens as cleaner fish, or as part of a multi-trophic aquaculture system.
3.3. We support prohibiting transgenic salmon on farms, and recommend that the Steering Committee seeks a clear legal definition of ‘transgenic’ from the technical specialists involved.
3.4. The NASCO Aquaculture Task Force recommendations should be included in the Accreditation scheme. The current indicators state; ‘they seek only to minimise escapes from a farm’. It is important that funds are also made available to advance work on the impact of escapees on wild salmonids. The accreditation body must establish a mechanism for collecting area level funds from accredited farms for an independent body (such as local River/Fisheries Trusts in the UK) to genetically sample adult and parr salmonids in local river systems to determine the impact of farm escapees. This data should be used in the future to set standards on ‘acceptable’ impact.
3.5. It must be explicit that certain farms cannot be certified due to their location, as indicated through the list of environmentally sensitive and economically important sites, including all Special Areas of Conservation with Atlantic salmon named as a primary or qualifying species, the use of the lice dispersal model and any known – and future - information on migration routes.
Recommendations
1. The AST and STG agree with other wild fish interests in suggesting that the Standard should provide a vehicle for moving the global salmon farming industry towards a strengthened Code of Practice, reflecting agreements made within the NASCO Salmon Aquaculture Task Force, in conjunction with the ISFA, and to which all NASCO countries are signatories. These objectives can be found by linking to http://www.nasco.int/pdf/aquaculture/BMP Guidance.pdf - 'Guidance on Best Management Practices to address impacts of sea lice and escaped farmed salmon on wild salmon stocks'.
2. We strongly support annual certification, and believe that farms must be required to show yearly operational improvements, beyond the set standards, to continue being accredited. There are numerous precedents for a requirement to demonstrate continuous improvement in order to retain accredited status.
3. The standards document must be restructured, so that the list of indicators is split into those required at individual farm level, and those required at an area level, taking account of the cumulative effect of several farms in a given management area. In order for this certification process to assess the impact on wild salmonids, the industry must be required to invest in independent monitoring at an area level. The logical conclusion of this is that it is unlikely that an individual farm would be accredited within a farming area unless all other units are included in the relevant area scheme; this level of control will be necessary in order to gain buy-in from wild fish and environmental interests.
4. An effective lice dispersal model must be developed as part of this accreditation scheme in order to assess acceptable maximum farm/area lice levels. Where wild salmonid migration routes are known using both current and future data - farms should only be established if the lice dispersal model shows minimal impact on salmonids using these routes. This model will also be relevant in determining the impact of lice from offshore farms. The costs of additional research required must be shared by the industry, and fair contribution to such costs should be assessed as part of the accreditation process.
5. The location of farms is vital in determining their impact on native salmonids. This is lost within the current indicators. It must be explicit that certain farms, such as those located close to wild salmonid migration paths, cannot be certified, because it is impossible to eliminate escapes and disease transfer within open system aquaculture. The precautionary principle must be enforced in two ways:
The industry, in conjunction with wild fish interests (including Rivers and Fisheries Trusts where appropriate), must draw up a list of sensitive aquaculture sites where farms cannot be certified, both now or in the future, because of their potential impact on wild salmonid stocks. The industry, in conjunction with wild fish interests (including Rivers and Fisheries Trusts where appropriate), must draw up a list of economically and genetically important catchments where there should be a presumption against future aquaculture development (where there is currently none) or a presumption in favour of relocation and restoration (where farm units already exist).
6. The indicators must include the environmental impact on sea trout (Salmo trutta) populations, as they remain in coastal waters throughout most of the marine phase of their life cycle, and therefore may be more vulnerable to local parasite and disease transfer. The lice dispersal model must therefore inform potential to impact sea trout populations, taking into account current research being undertaken into the habits and movements of sea trout in their marine phase.
7. All certified farms must be required immediately to stock smolts produced in enclosed freshwater systems, or in systems that have no significant wild salmonid populations – either present or historical – and are situated within the same country; we do not believe that the Standard should condone international trade in live fish, due to risks of transfer of disease and parasites (particularly non-native parasites). Net smolt pens in freshwater pose a greater risk of introgression, due to serial escapes, than marine cage sites, given the life stage at which escapes occur. Norway already prohibits smolt units on rivers containing wild salmonids. This should be the compulsory basic standard for certified farms, since the technology for such production is available, and proven at commercial scale.
8. We are anxious that the Standard should not offer immediate entry to the accreditation procedure for farms newly established in pristine areas. We believe that the farm should be required to establish a track record in monitoring environmental and ecological impacts before entering the procedure. Similarly, any farm in an area where no such monitoring of impacts has hitherto been carried out should be required to demonstrate an established monitoring protocol – if only to determine a base-line against which to measure improvement or deterioration in factors such as the ambient lice burden of wild salmonids. There are precedents for such a requirement to build up a ‘track record’ – for example, the more robust organic certifications for terrestrial farms, both arable and animal-rearing.
Fiona Cameron, The Atlantic Salmon Trust (AST) and The Sea Trout Group (STG)
These comments are supported by the Scottish Anglers National Association (SANA)
1. General comments
The AST and STG are opposed to the promulgation of a Standard which may foster public perception of farmed salmon as an environmentally sustainable product, while there is a risk that accredited farms may still be inflicting significant adverse impacts on wild salmonids and marine & freshwater habitats.
We would point out that the salmon farming industry continues to adversely impact wild salmonids even in countries which currently have (apparently) robust regulatory systems. The only justification for a new Standard is as a means of driving up standards considerably, and on a continuous improvement basis, and thus tackling the deep-rooted problems associated with open system salmon aquaculture.
a) The draft document, as it stands at present, risks simply standardising farming practices which are flawed, and represent the lowest common denominator. There are insufficient signs that the Standard will present challenging targets which will drive up standards in the industry. In particular, this relates to addressing the problems caused by: amplification of parasites and disease; escapes from marine and freshwater cages; pollution of the environment by fish waste and uneaten feed.
b) We feel that the indicators as currently drafted do not provide adequate protection from such a risk, for these principal reasons:
1. Many of the parameters and measurements suggested as indicators represent areas of knowledge which are incomplete and under-researched – for example, salmon migration routes, sea lice dispersal patterns, sea trout feeding patterns. It remains unclear how the Standard will deal with measurements set against a background of scientific uncertainty. The only pragmatic solution would appear to be robust attention to the Precautionary Principle in stipulating where accredited farms may be sited. A long-term solution would also require to make provision not only for a built-in review process for criteria and indicators, but also for revision of accredited status in light of emerging science.
2. Several of the terms used within the document are insufficiently defined: for example “environmental sustainability”, “sensitive” stocks. We would query whether a word such as “sensitive” can be sufficiently robustly defined to belong in a Standard which depends on detailed measurement of impacts.
3. The draft indicators require very substantial revision and re-shaping, to reflect the fact that many of the impacts which must be measured cannot logically or practically be measured at farm level.
It will be necessary to make provision for measurement of certain impacts (for example, lice infestation of wild salmonids) on an area basis, and to set farm-level measurements within this framework.
c) We can see nothing within the Draft Indicators which would be likely to encourage the salmon farming industry to move towards closed containment – a solution which we believe is, ultimately, the only way to ensure environmentally sustainable operations. It would be a pity to lose the opportunity to set the bar high enough to make investment in closed containment an attractive option for salmon farmers. The only way in which this can be achieved is to significantly strengthen overall operating standards within the industry, and to ensure that these are enforced, otherwise any accreditation scheme is in danger of giving a completely false impression to consumers as to the sustainability of salmon farming.</u>
d) The indicators do not currently acknowledge the importance of the impact on sea trout (Salmo trutta) populations. Since these fish remain in coastal waters throughout most of the marine phase of their life cycle, and therefore may be more vulnerable to local parasite and disease transfer, their interests must be specifically included.
2. Specific comments on Principle 3: Protect the health and genetic integrity of wild populations.
3.1.1. This documentation must be publically available. This should be extended to require the certified companies to make publically available information on their internal research programmes. We believe it’s also very important that where diseases such as PD (Pancreas Disease), which are no longer on the notifiable list in the UK, exist in farm stock, farms should be required to make information on their disease status available to all interested parties; there is clearly a strong link between sea lice infestation of farmed fish and heightened susceptibility to disease; this in turn links to greater problems in administering sea lice treatments (the fish may be off-feed, or the salmon farming company may judge that the fish cannot stand the added stress of a bath treatment). Since it is impossible to monitor the progress of non-notifiable diseases in countries such as the UK, it is important not to lose the learning opportunity which a full disease database would represent, in terms of observable patterns of disease and links to other factors such as lice infestation.
3.1.2. If non-endemic notifiable diseases are detected on a farm, it should lose its certification until the cause of disease can be scientifically established, and the threat removed. The suggestion that the individual farm should be required to show through environmental testing that diseases have not “jumped into the wild” is impractical and unenforceable, and should be removed.
3.1.4. This should be changed to: ‘Maximum on-farm lice levels, related to a maximum agreed area lice level’. An effective lice dispersal model must be developed as part of this accreditation scheme in order to assess acceptable maximum farm/area lice levels. In some locations the lice dispersal model may indicate where more stringent standards are necessary to protect wild fish populations.
3.1.7b.There is a need for further research to gain additional knowledge of this, as “safe” area-level maxima will vary according to area. Again, in light of scientific uncertainty, a precautionary approach should be adopted.
3.1.7c. There is a need for specialists to create a standardised protocol for recording numbers of lice on wild fish (e.g. photographic images from counting stations), and a requirement for farms to invest in area/regional monitoring structures. Arriving at a pragmatic solution for adequately-resourced independent monitoring of lice on wild fish is the only way to monitor the impact of potential amplification of lice in salmon cages, in a manner which will gain the confidence of all stakeholders.
(See also point 8 in Recommendations)
3.1.8.b. We recommend acceptance of the suggestion (made by John Volpe) that a measurement of “number of fish” is added to the measurement of kilos of fish, since size of hosts is the significant factor.
3.1.8c. We do not believe that it is wise to attempt to define a widely-applicable ‘minimum safe distance’. It is impossible to make a generic prediction of a safe distance, given the site-specific nature of these impacts. This is complicated by the nature of the fjordic systems currently favoured by the salmon farming industry, due to their complex hydrography and exposure to strong winds and currents. Similarly, the most usual situation is for several salmonid rivers to issue into a single fjord or sea loch: do we therefore define distances from rivers or from the entire fjord? The example of damaging sea lice infestations being found on fish in the rivers of Trondheimsfjord (a fish-farm-free National Salmon Fjord) demonstrates the complexity of the situation. A lice dispersal model must be established to determine, as far as possible, the potential impact on wild salmonids. Knowledge of migration routes should also be taken into account as it becomes available, as should the list of sensitive and economically important inshore sites. This will, in the first instance, involve dealing with considerable scientific uncertainty.
3.2.1. The draft suggests that non native species can be introduced if they are assessed to pose an ‘acceptable level of risk’. We question how an ‘acceptable’ level of risk can be determined when we do not understand the ecosystem level impacts of non-native species, and when open systems allow full interactions with the surrounding environment. The impacts of non-natives can be very complex and take time to become apparent. We believe non-native salmon aquaculture should not be permitted for accreditation, unless within closed systems - where stricter control can be exercised and environmental impact genuinely minimised. We also believe that the Standard should recognise the potential for undesirable impacts from non native species introduced to salmon pens as cleaner fish, or as part of a multi-trophic aquaculture system.
3.3. We support prohibiting transgenic salmon on farms, and recommend that the Steering Committee seeks a clear legal definition of ‘transgenic’ from the technical specialists involved.
3.4. The NASCO Aquaculture Task Force recommendations should be included in the Accreditation scheme. The current indicators state; ‘they seek only to minimise escapes from a farm’. It is important that funds are also made available to advance work on the impact of escapees on wild salmonids. The accreditation body must establish a mechanism for collecting area level funds from accredited farms for an independent body (such as local River/Fisheries Trusts in the UK) to genetically sample adult and parr salmonids in local river systems to determine the impact of farm escapees. This data should be used in the future to set standards on ‘acceptable’ impact.
3.5. It must be explicit that certain farms cannot be certified due to their location, as indicated through the list of environmentally sensitive and economically important sites, including all Special Areas of Conservation with Atlantic salmon named as a primary or qualifying species, the use of the lice dispersal model and any known – and future - information on migration routes.
Recommendations
1. The AST and STG agree with other wild fish interests in suggesting that the Standard should provide a vehicle for moving the global salmon farming industry towards a strengthened Code of Practice, reflecting agreements made within the NASCO Salmon Aquaculture Task Force, in conjunction with the ISFA, and to which all NASCO countries are signatories. These objectives can be found by linking to http://www.nasco.int/pdf/aquaculture/BMP Guidance.pdf - 'Guidance on Best Management Practices to address impacts of sea lice and escaped farmed salmon on wild salmon stocks'.
2. We strongly support annual certification, and believe that farms must be required to show yearly operational improvements, beyond the set standards, to continue being accredited. There are numerous precedents for a requirement to demonstrate continuous improvement in order to retain accredited status.
3. The standards document must be restructured, so that the list of indicators is split into those required at individual farm level, and those required at an area level, taking account of the cumulative effect of several farms in a given management area. In order for this certification process to assess the impact on wild salmonids, the industry must be required to invest in independent monitoring at an area level. The logical conclusion of this is that it is unlikely that an individual farm would be accredited within a farming area unless all other units are included in the relevant area scheme; this level of control will be necessary in order to gain buy-in from wild fish and environmental interests.
4. An effective lice dispersal model must be developed as part of this accreditation scheme in order to assess acceptable maximum farm/area lice levels. Where wild salmonid migration routes are known using both current and future data - farms should only be established if the lice dispersal model shows minimal impact on salmonids using these routes. This model will also be relevant in determining the impact of lice from offshore farms. The costs of additional research required must be shared by the industry, and fair contribution to such costs should be assessed as part of the accreditation process.
5. The location of farms is vital in determining their impact on native salmonids. This is lost within the current indicators. It must be explicit that certain farms, such as those located close to wild salmonid migration paths, cannot be certified, because it is impossible to eliminate escapes and disease transfer within open system aquaculture. The precautionary principle must be enforced in two ways:
The industry, in conjunction with wild fish interests (including Rivers and Fisheries Trusts where appropriate), must draw up a list of sensitive aquaculture sites where farms cannot be certified, both now or in the future, because of their potential impact on wild salmonid stocks. The industry, in conjunction with wild fish interests (including Rivers and Fisheries Trusts where appropriate), must draw up a list of economically and genetically important catchments where there should be a presumption against future aquaculture development (where there is currently none) or a presumption in favour of relocation and restoration (where farm units already exist).
6. The indicators must include the environmental impact on sea trout (Salmo trutta) populations, as they remain in coastal waters throughout most of the marine phase of their life cycle, and therefore may be more vulnerable to local parasite and disease transfer. The lice dispersal model must therefore inform potential to impact sea trout populations, taking into account current research being undertaken into the habits and movements of sea trout in their marine phase.
7. All certified farms must be required immediately to stock smolts produced in enclosed freshwater systems, or in systems that have no significant wild salmonid populations – either present or historical – and are situated within the same country; we do not believe that the Standard should condone international trade in live fish, due to risks of transfer of disease and parasites (particularly non-native parasites). Net smolt pens in freshwater pose a greater risk of introgression, due to serial escapes, than marine cage sites, given the life stage at which escapes occur. Norway already prohibits smolt units on rivers containing wild salmonids. This should be the compulsory basic standard for certified farms, since the technology for such production is available, and proven at commercial scale.
8. We are anxious that the Standard should not offer immediate entry to the accreditation procedure for farms newly established in pristine areas. We believe that the farm should be required to establish a track record in monitoring environmental and ecological impacts before entering the procedure. Similarly, any farm in an area where no such monitoring of impacts has hitherto been carried out should be required to demonstrate an established monitoring protocol – if only to determine a base-line against which to measure improvement or deterioration in factors such as the ambient lice burden of wild salmonids. There are precedents for such a requirement to build up a ‘track record’ – for example, the more robust organic certifications for terrestrial farms, both arable and animal-rearing.
[V]
