Submission 0040-CLARK

Submitter: Dale Clark

Community: Mission

Date Submitted: May 2, 2010

Summary:
The shortfall witnessed in the 2009 Fraser sockeye salmon run was a localized issue caused by open pen fish farms. The solution is fish farm containment. Environmental matters are multi-jurisdictional and should include community feedback.

Submission:
May 01 2010

We buried one of my uncles today; he lived all but 2 of his 81 years within 100 meters of his place of birth.

Regarding your commission directive of investigating and making recommendations regarding the overall Fraser River decline of sockeye salmon and 2009’s 90% short fall in the Department of Fisheries and Oceans (DFO) prediction for returns on said species.

The Fraser overall decline thing relates to long term stuff like North Pacific gyres, global regimes and the like where as 2009 was less than that. Two thousand and nine was a human caused thing and it was very localized. Two thousand and nine was a bureaucratic thing where provincial people were licensing federal stuff and federal people well I think they may have been out of loop for a bit and then …. had other things to do ie political directive. That being said and OPEN PEN FISH FARMS being implicated by saying it I, begrudgenly, would like to defend DFO on their management of Fraser stocks. The people on the ground can not be blamed and fingers need not be pointed else where. Here we have a cause and we have a solution, FISH FARM CONTAINMENT PERIOD, those that do not like this can simply leave now and we will not pursue them for environmental damages. I am a great believer in recovery and retain confidence in our environments ability to rejuvenate itself.


Regarding your recommendations to be made on DFO policy/act/behaviour/attitude etc.

Do not confuse me with someone who retains any respect for DFO what so ever, after the extinction, by DFO personal, of Basking sharks from our coast and personal encounters with mid management personnel at the department they would have to do a lot to re earn my respect.

Personal feelings aside my thought is that environmental matters are a multi jurisdictional
issue at all times and that makes them a 2 way street verse the current perception of a top down, to municipal, approach. My theory is that if a DFO person wants to come on my family land then that person should have to come through at least my local government and preferably a community committee also. Conversely as a land owner I would have to start with the local committee – no exceptions. People are not stupid and given a chance good will happen.
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Comment List

Name: Ron Kinch

Date Created: May 12, 2010


Comment:
I think the comments of Mr. Dale Clark are right on. If the open pen licensing of Georgia Strait Fish Farms was by the Prov. of B.C., they must have done so with approval of the Federal DFO and that has to be where the solutions must come. Can anyone clarify this for me?

Name: Priscilla Judd

Date Created: May 15, 2010


Comment:
I agree with this letter - thank you for your submission.

As to the the question on licensing: The BC Government declared "farming" in ocean waters "protected" from legal action in cases of nuisance under the "Right to Farm" Act. As a consequence, BC became the regulator of fish "farms" and fish "farm" licenses.

Since nuisance includes, protects (allows) trespass by farm operations, the undesirable practice of ocean farming ie: tons of fish poop, sea lice, pesticide and chemical use, ocean lights, unsanitary feed lot conditions in open net pens etc. continue because they are the "normal" practice of fish farm operations.

Until recently "Normal" has been the criteria for operating under the Act. Now DFO is assuming responsibility for fish farm regulation so it is imperative that DFO not adopt this regulatory model. Normal fish farms don't protect wild salmon or ocean life but can you prove that it is those practices, not something else that harms wild fish?

Name: Cath Stewart

Date Created: June 15, 2010


Comment:
In response to Ron, yes the Province of BC issued both the licenses and tenures for existing fin fish farms and the approval of both DFO and Transport Canada (Navigable Waters) was required before licenses were issued. In response to Priscilla, DFO has, for years, promoted, marketed, supported and funded research to aid the existing open net-cage salmon farming industry and currently has a program in place (NASAPI) to facilitate the expansion and growth of aquaculture nation-wide.
DFO is currently drafting the federal regulations that will govern fin fish aquaculture in BC as of Dec, 2010. The regs will be posted in the Canada Gazette by approx the end of June/early July. This will be followed by a two month public comment period, which is our chance - as citizens - to comment if the federal regulations are not better than the 'norm' set by BC. We can only hope. And speak out if the regulations won't protect our marine ecosystems and wild salmon. Watch for them - end of June/early July