Wednesday, August 25, 2010

No to proposed Federal Pacific Aquaculture regulations

Ed Porter, Team Leader, Regulatory Operations
Fisheries and Oceans Canada

Dear Mr. Ed Porter:

I am responding to the 60-day public comment opportunity on the proposed Federal Pacific Aquaculture Regulations (left column “Part I Notices and Proposed Regulations” Vol. 144, No. 28, page 1933).

It was brought to my attention by Ms. Alexandra Morton that the purpose of the proposed amendments is to reduce, not increase, the safeguards in place to regulate aquaculture along Canada’s Pacific coast. In particular, the proposed new regulations would provide government with the ability to grant and renew licenses without public or First Nations input nor further environmental assessments. One of the reasons given for this amendment in the Canada Gazette of December 19, 2009 is to enhance our aquaculture industry’s ability to compete on international markets. These draft regulations, I am told, ignore the International (OIE) and the Canadian Food and Health Inspection Agency standards by exempting salmon feedlots from full disease reporting.

This is so wrong on so many levels.

First, at a time when sockeye runs are collapsing (this year’s exceptional and joyfully abundant return notwithstanding), more – not less – regulation is required to ensure that the aquaculture industry does not interfere with the threatened life cycles of our beloved wild salmon.

Second, introducing regulation which is aimed at keeping the public and First Nations out of the decision making process is yet another instance of the neoliberal “privatization of the commons” agenda, resulting in massive transfer of public wealth in the hands of private interests. It is yet another attack against our society’s democratic principles.

Third, the government’s official rationale for introducing such changes (as stated in the Gazette) are extraordinarily and inexplicably short-sighted. What is the point of enhancing Canada’s potential ability to compete on international markets for, say, the next 3 or 4 years, if after that period there is no aquaculture left to compete over? The 2009 sockeye collapse and ongoing Cohen Commission are tangible proof, if needed, that the disappearance of our fisheries has ceased to be a merely theoretical threat.

In this context, such amendments make no sense at all, unless the non-stated goal is to eradicate wild salmon runs altogether as a means of establishing the fish farming industry’s monopoly over the “production” of salmon. An extravagant and outlandish conspiracy theory, no doubt! Yet, it is one which is gaining traction in the general public, as people attempt to rationalize a truly irrational set of decisions on the part of their government in recent years and months. For my part, I refuse at least for now to believe that our government could be involved in such a cynical, abject, and counter-nature plan.

Mr. Porter, I am asking you to help me restore my trust in my government’s truthful intentions. The aforementioned proposed amendments to the existing aquaculture regulations must be rejected.

Yours truly,

Ivan Doumenc
Vancouver, BC