I'd like to thank the chair and members of the committee for inviting me here to testify before you.
My name is Matthew Abbott, and I'm the Fundy Baykeeper based in St. Andrews, New Brunswick.
Fundy Baykeeper is a member of the over 200-member strong Waterkeeper Alliance, headed up by Robert Kennedy, Jr. It's an international alliance.
Fundy Baykeeper maintains an on-the-water watchdog presence in the outer Bay of Fundy.
In late 2010, Baykeeper spearheaded the formation of the Atlantic Coalition for Aquaculture Reform, a coalition of fisheries associations, conservation groups, and community groups in Atlantic Canada that are concerned about the impact of open-net pen salmon aquaculture and that are committed to protecting our coastal ecosystems.
I think you've already heard from another coalition member, the Atlantic Salmon Federation.
The problems associated with salmon aquaculture are entirely predictable and are inherent to open-net pen technology. Baykeepers have long advocated for a transition to closed containment, for reasons I'll elaborate on. Removing farms from the ocean is the only way to address the impacts of open-net pen farms.
In the interest of clarity, I'll focus on one single concern. I'm here to speak with you about the environmental impact of pesticide treatments for recurring parasite infestations in open-net pen salmon farms.
Sea lice, small crustaceans, are naturally occurring parasites on salmon and other fish. Indeed, salmon anglers sometimes consider a small number of sea lice an indication that the fish they have caught is fresh from the ocean. However, sea lice proliferate in salmon farms due to the high density of fish held together for their entire life cycles.
The salmon aquaculture industry has resorted to pesticide use to control these sea lice infestations. Pesticides designed to kill sea lice are generally also toxic to other crustaceans, including lobster, shrimp, crab, krill, and the numerous other small crustaceans that make up the zooplankton community. Indeed, in many dynamic marine ecosystems, such as the outer Bay of Fundy, these small crustaceans form the base of the food chain.
It's worth pointing out that lobster is Atlantic Canada's most valuable seafood product.
The trajectory of sea lice infestations and pesticide use has followed a similar pattern globally. I'll talk about our experience in New Brunswick, though keep in mind that the same problems have occurred in other salmon farming regions.
As you're no doubt aware, the use of eco-toxic pesticides in the salmon aquaculture industry has been controversial globally, and has been particularly so in New Brunswick recently, since there were a number of lobster kills near salmon sites in 2009. Cypermethrin, a pesticide not approved for marine use in Canada, was found on these dead and dying lobsters. A major New Brunswick aquaculture company and three of its executives were charged by Environment Canada earlier this month in relation to illegal pesticide use in this case. The alleged use of illegal pesticides by some aquaculture industry operators serves to highlight the extent of the problem in southwest New Brunswick.
To give a sense of the scale of the problem, a New Brunswick industry representative told La Presse, a Montreal newspaper, that in 2010 they were facing infestation levels of 200 lice per fish. This is quite a remarkable number, as I'm sure you'll note.
The most common pesticide treatment used has been Slice, an in-feed treatment, meaning that the pesticide is incorporated into the salmon feed. Slice, when consumed, kills sea lice attached to the treated salmon. Slice from uneaten feed and feces has been detected in sediments under and around treated farms and has been shown to cause harm to non-target organisms. However, given that Slice has been the drug of choice for over a decade, it is unsurprising that sea lice on New Brunswick farms have been showing resistance to it, meaning that it's lost its effectiveness in killing sea lice. This has led to the increasing use of bath treatments: a liquid pesticide is added to the water containing the salmon and sea lice and is then released into the open marine environment.
The aquaculture industry continues to lobby all levels of government to make more pesticides available for their industry's use. While there are some non-pesticide control mechanisms being investigated, it's accepted that pesticides will continue to be used to kill sea lice in open-net pens. The problems with illegal and thus totally uncontrolled use of pesticides are obvious.
However, pesticides approved by Health Canada's Pest Management Regulatory Agency, PMRA, also cause significant concern. Recent research carried out by DFO scientists led by Dr. Fred Page and Dr. Les Burridge out of St. Andrews to assess the potential impact of pesticide use should serve to highlight the danger of the pesticides being used in our shared waters.
The researchers mixed a non-toxic marine-safe dye with pesticides being used to treat sea lice so that the plume of pesticides could be tracked in the unpredictable Bay of Fundy tides. They found that with certain pesticides in certain conditions the plume contained levels of pesticides lethal to crustaceans between 100 metres and 1,000 metres from the treated farm.
Allow me to pause to emphasize that in a recent DFO study pesticide plumes have been found to remain toxic for a kilometre from the treated farm in one of the most biologically productive regions of the Bay of Fundy. Further, the dye and pesticide plumes in some instances have been tracked for several kilometres.
One serious consideration with the use of bath treatments is that the effluent from one treatment could pass partially diluted through another farm, potentially speeding up the development of resistance in sea lice exposed to a sub-lethal dose of pesticides.
The case of deltamethrin serves as a particularly potent example of why the increasing use of pesticides in the open-net pen salmon aquaculture industry is such a great concern. AlphaMax, the active ingredient of which is deltamethrin, was approved for emergency use in 2009-10. Deltamethrin is classified as super-toxic and can kill lobsters at levels as low as three parts per billion.
It's no surprise that fishers and others who depend on a healthy marine ecosystem become very concerned when such toxic substances are permitted to be released into our shared waters. The aquaculture industry continues to claim that pesticide usage is heavily regulated, while downplaying the potential impact of pesticides on non-target organisms. However, as federal government research continues to show, many of the pesticides used are toxic to non-target organisms, can remain toxic for a considerable distance from treated cages, and in some cases can remain detectable in sediments for over a year after treatment.
You may be wondering why I've spoken so much about sea lice and pesticides and so little about closed containment. It's simple. If salmon were grown in closed containment facilities I would have very little to say about pesticide usage.
Parasite infestations, and indeed disease outbreaks, which I haven't touched on here, are problems caused by an almost complete absence of biosecurity in open-net pens. I've referenced some of the excellent research being carried out by government scientists to identify impacts and potential impacts from pesticide usage and possibly provide some mitigation. However, we are in effect chasing mitigation heroically against all odds when the problem is in the technology we are using to grow fish. Problems such as parasite infestations, disease, and nutrient pollution cannot be adequately addressed in open-net pens.
If the Canadian aquaculture industry is as innovative as it claims to be, can we not expect it to find ways to grow fish without releasing untreated waste and chemical effluents into our shared coastal waters?
We would advocate a transition toward closed containment technologies. In addition, as something to put before the committee, an essential first step in this transition toward more sustainable practices in closed containment would be a ban on the use of pesticides in the open marine environment.
I thank you very much for your time, and I look forward to your questions.