Thank you, Mr. Chairman, and thank you for the opportunity to speak to the committee today on closed containment.
My name is Peter McKenzie. I'm a veterinarian. I've been working in the aquaculture industry for over 10 years and I've worked with multiple different versions of closed containment systems through that time. I've also spent a few years with the Canadian Food Inspection Agency as a national manager for import-export for the aquatic animal health division.
Today I'd like to speak to the committee on behalf of Mainstream Canada as their veterinarian and fish health manager.
Mainstream is one of the largest aquaculture companies in British Columbia and is a part of the global Cermaq Group, whose business is responsible for fish feed and farming in operations in Norway, Chile, Scotland, and Canada.
Cermaq and Mainstream's corporate mission statement is for sustainable aquaculture, and our corporate vision is to be the global leader in sustainable aquaculture.
Today I am here to convey Mainstream Canada's views on the existing closed containment technologies for the purposes of commercial finfish production. However, considering my knowledge base and my expertise in the area of fish health, I would like to touch on the biological limitations that are in place with closed containment technologies, particularly in the area of fish health, disease transmission, and animal welfare.
Mainstream Canada strongly believes that the existing open-net pen technology and our production practices allow for sustainable aquaculture, and we aim at demonstrating this through our daily operations and monitoring activities.
We'd like to start by saying that we recognize that the only true closed containment technology is the fully land-based recirculating aquaculture system, or RAS technology, where there is complete physical separation of water and animals from the surrounding environment. Mainstream believes this technology can be very effective in early life stages of fish culture, and as a result has invested in this technology in our land-based facility in Duncan, British Columbia.
In our opinion, the use of closed containment technology for the purposes of production of salmon to market size is not sustainable. Aquaculture sustainability by definition is a mixture of social, environmental, and economic sustainability for long-term survival of the industry.
True, RAS technology, as I mentioned, can address the environmental sustainability issues that have been mentioned previously by eliminating those interactions with the surrounding environment and controlling inputs and outputs from the system. However, concerns remain regarding energy use and fish health and welfare implications that I will touch on in a minute.
Closed containment systems like the RAS system also do not support principles of social sustainability, as we understand them. The main social impact of open-net pen systems is the benefit for rural and coastal communities in British Columbia, the majority of those being first nations with limited access to other sources of jobs. Closed containment, if it is used on a massive scale, would need to be strategically located in the proximity of urban zones or markets where they have access to energy and land.
Closed containment, such as the RAS system, is also not economically sustainable, in our view. The models are highly dependent on massive capital expenditures for start-up, availability of large parcels of land near the ocean, and consistent high prices from customers for the product, all of which are not easily accessible in Canada today.
The reality is that our fish are sold on a commodity basis, and current commodity prices will make all existing models unprofitable, subsequently making it impossible to access the necessary capital to start up these endeavours. Customers are not willing to pay a premium price for a product produced in a closed containment system in a commodity market. Premier prices will only be realized in limited niche markets.
Worldwide production of Atlantic salmon is estimated at 1.5 million tonnes in 2011 and an additional 200,000 tonnes for 2012. This will just put increasing pressure on the commodities market. Therefore, it is our view, as a global commodity, that closed containment will never be a viable alternative for the production of Atlantic salmon on a commercial scale.
In addition to the shortcomings in social and economic sustainability, all closed containment models that have been reviewed through DFO's SEP process were highly dependent on biological performance of the fish that comes very close to, if not surpassing, the physiological limitations of fish.
As of now, much of the debate on closed containment systems has revolved around engineering theory, theoretical profitabilities, and financial models; however, the one thing that every model culture system is solely dependent on is the biological performance to be successful. For this reason, the fish health and welfare considerations need to be considered.
These physiological limitations need to be considered. Closed containment technologies rely heavily on the manipulation of water temperatures, chemistries, densities, and the surrounding environment in order to hit theoretical values for maximum survival and production. There has been little consideration for the biological limitations of animals and conditions necessary for allowing a natural swimming behaviour and low-stress environments. As a result, I would like to just briefly touch on the implications of closed containment systems on animal welfare and disease transmission.
Fish welfare has been recognized globally as a critical aquaculture consideration. The World Organisation for Animal Health, or OIE, the Royal Society for the Prevention of Cruelty to Animals, the Canadian Council on Animal Care, and the Compassion in World Farming associations are examples of welfare experts who have taken the time to go through the science and develop standards for fish culture. All of these groups have come to the same conclusion, that water quality and fish density are critical parameters for maintaining fish health and welfare.
In summary of their standards, increasing densities result in elevated stress levels on fish, increased competitive interactions, restrictions to natural behaviours, and reduced water quality. Therefore, they've come up with maximum recommended levels of 17 to 22 kilos per cubic metre. Open-net pen systems currently operate with maximums of 15 to 17 kilos per cubic metre. However, the RAS technologies that have been discussed previously rely on densities of 55 to 65 kilos per cubic metre in order to be viable.
Natural swimming behaviour is also limited in these situations, as constant water flows are required in order to remove organics and to preserve water quality levels. Fish rely on transitions in water currents, slack tides, and salinity changes in order to perform their natural behaviours.
In the area of disease, with increasing densities and other stressors such as water quality compromises, fish will produce elevated levels of the stress protein known as cortisol. Elevated cortisol levels will react directly on the immune system of the fish, reducing the immune system and making these fish even more susceptible to disease.
Closed containment systems need to rely on water reuse and elevated temperatures to evaluate production goals. However, the manipulation of these temperatures also creates the perfect environment that enhances pathogen culture. As a result, with increasing densities and water quality compromises, there is a high risk of disease occurrence and outbreaks. Disease transmission can occur in any production system and is directly dependent on the frequency of animal interactions and water replacement rates. The number of fish interactions is a direct result of fish density. Therefore, increasing densities increase the speed and risk of disease spread within a population. Increasing water reuse and densities will also result in higher pathogen concentrations, leading to more severe outbreaks of disease.
In summary, Mainstream Canada recognizes the only true closed containment technology is the RAS technology. However, we do believe that it is not a sustainable solution for the commercial production of salmon to market size. We recognize that this technology can be utilized effectively for the production of Atlantic salmon during early life stages, and possibly for commercial production of salmon for the purposes of small niche markets.
Mainstream Canada is also committed to utilizing production systems and practices that optimize fish health and welfare standards, allowing our fish to perform and our operations to remain sustainable and to produce a healthy, affordable product.
My hope, in speaking to the committee today, is that you will realize that there are biological limitations to the systems we are working with and that it is not simply an engineering or economic discussion.
Thank you.