A summary of the Indigenous and Multi-stakeholder Advisory Body (IMAB) on aquaculture engagement process
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- Overview of Engagement Process
- Next Steps
This document entitled: A Summary of the Indigenous and Multi-stakeholder Advisory Body (IMAB) on Aquaculture Engagement Process is an overview of the views and comments received by the Department of Fisheries and Oceans during in-person engagement sessions held with members of Indigenous communities and organizations, the Government of British Columbia, regional governments, environmental non-governmental organizations (ENGOs) and the finfish and shellfish aquaculture sectors from August 2019 until June 2020 as well as additional comments submitted in writing until August 7, 2020.
The purpose of the engagement sessions and reports produced through the process are to inform the Department’s future actions regarding the sustainable management of aquaculture activities, including both finfish and shellfish aquaculture, in British Columbia.
We would like to thank all of the IMAB members and their representatives who actively participated in the engagement process, including its supporting Technical Working Groups (TWGs), for the knowledge, expertise and advice that they keenly provided during each meeting and in the development of the three TWG reports. While there may not have always been full agreement among the members on all issues examined, the process resulted in new knowledge, new ideas and new relationships that will inform improvements to the aquaculture industry in British Columbia for years to come.
Aquaculture, including both finfish and shellfish production, is an economically and socially important industry in British Columbia worth over $814 million and generating approximately 1600 direct jobs and spin-off opportunities many of which are located in rural and Indigenous communities. Despite the sector’s economic importance, some Indigenous communities and other stakeholders continue to express concerns related to the potential impacts of the industry on aquatic ecosystems and species, notably wild salmon.
In response to these concerns, in December 2018, the Minister of Fisheries and Oceans announced that “Canada would work in partnership with the provinces and territories, industry, Indigenous partners, environmental groups and other stakeholders to ensure an economical and environmentally sustainable path forward for aquaculture.” As a step toward fulfilling this commitment, on June 4, 2019, the Minister announced the creation of a senior-level Indigenous and Multi-stakeholder Advisory Body (IMAB) on aquaculture that would be supported by three Technical Working Groups (TWGs) including a Salmonid Alternative Production TWG, a Marine Finfish and Land-based Fish Health TWG, and an Area Based Management TWG. The IMAB included twenty-seven members, official observers and ex-officio members from the federal and provincial government, local government, Indigenous organizations and communities, ENGOs and the aquaculture finfish and shellfish industries. Each of these organizations then nominated members to participate on each of the three TWGs. Each TWG was assigned specific terms of reference aimed at advancing the IMAB’s objectives of promoting exchanges of knowledge, identifying opportunities for collaboration and developing specific recommendations to improve the sustainability of aquaculture in British Columbia.
Overview of engagement process
The IMAB engagement process included three face-to-face meetings (two in-person and one virtual meeting due to the COVID-19 pandemic) as well as several written exchanges and submissions toward the end of the process in Summer 2020. The engagement process was formally launched with a kick-off meeting in August 2019 during which IMAB and TWG members were introduced and draft terms of reference for the IMAB and its three supporting TWGs were distributed for review and endorsement. Following numerous meetings and extensive work by the three TWGs during Fall and Winter 2019-20, a second IMAB meeting was held in February 2020 to review the progress they had achieved and allow the IMAB members to comment and provide advice to the TWGs for completion of their mandates. Following the submission of TWG final reports, a final (virtual) IMAB meeting was held on June 15, 2020 to review and discuss the results and recommendations presented by each of the TWGs. The engagement process closed with the submission of remaining comments from IMAB members by August 7, 2020.
The final results of the engagement process include this summary document, A Summary of the Indigenous and Multi-stakeholder Advisory Body (IMAB) on Aquaculture Engagement Process, along with links to the three TWG reports provided below:
- Salmonid alternative production technologies TWG report
- Marine finfish and land-based fish health TWG report
- Area Based Management TWG report
A formal response to the recommendations contained in the three TWG reports will be provided in late Fall 2020.
General comments about the IMAB process
Based on discussions held during the three IMAB and the TWG meetings, and comments received in writing, it was clear that members were passionate about the role of the aquaculture industry in British Columbia and its potential impacts on marine ecosystems, notably wild salmon species. The importance of wild salmon to Indigenous peoples for food, social and ceremonial purposes was particularly highlighted throughout the discussions.
The majority of the representatives who participated on the IMAB and/or one of its three TWGs, expressed positive opinions about the engagement process highlighting the value of drawing together diverse interests to share information and perspectives and to collectively identify strategies and actions with the potential to improve the sustainability of aquaculture. Several participants acknowledged how the process had helped to bring forward new information and ideas and develop new connections and collaborations with some expressing a desire that discussions continue past the end of the formal engagement process. Others applauded the strong focus on science and recognition of the importance of incorporating traditional knowledge to improve the availability of data and information as well as the recommendations by all TWGs for enhanced communication on efforts to manage the industry with aquatic stakeholders. The Deputy Minister of Fisheries and Oceans Canada remarked that the engagement process had been very productive resulting in substantial submissions and recommendations for improving the sustainability of aquaculture in British Columbia.
Nonetheless, there were some participants who expressed less positive opinions about the overall engagement process and the Fish Health TWG in particular. Concerns were expressed over DFO’s leadership of the process, with the suggestion that it should have utilized an independent process, as well as the limited representation of Indigenous participants on the IMAB and the three TWG’s. Some Indigenous participants also suggested that their concerns were not always captured or watered down. It was also observed by some members that the process should have been further oriented to advance the Minister of Fisheries and Oceans commitment to transitioning open net-pens in British Columbia. With respect to the FH TWG, specific concerns were raised over: the scope of the working group’s mandate (suggesting it should have included a wider consideration of the health and productivity of wild salmon species); the limited amount of time allowed for discussions as well as the preparation and review of key technical documents; the participation of ex-officio members in FH TWG meetings; and perceptions of bias by the Chair. Despite these concerns, these participants were unanimous in their view that the Department should continue to support multi-stakeholder engagement on issues related to aquaculture management in British Columbia.
Irrespective of the views on the engagement process itself, a key message that was expressed by those both for and against aquaculture is the need for Indigenous communities to have a direct voice in the types and/or levels of aquaculture activities that occur on their territories.
Salmonid alternative production technologies
According to its terms of reference, the SAPT TWG was assigned to:
- Review relevant reports and information related to intensive aquaculture (e.g. The State of Salmon Aquaculture Technologies, the Fraser Basin Council’s RAS Atlantic Salmon Industry on Vancouver Island Financial Model & Economic Impact Analysis) and any other relevant information to assist the TWG in meeting its objectives; identify gaps; and provide recommendations.
- Propose for consideration, a series of objectives for alternative technologies which lower environmental risk factors related to pathways of effects (reduce interactions with wild fish; reduce benthic impact; reduce or eliminate genetic interactions, reduce environmental impacts) and/or improve the efficiency/cost/environmental health outcomes for marine finfish aquaculture.
- Identify opportunities for collaboration and partnership for all stakeholder groups and Indigenous communities that can advance improvements which can be made relating to the potential adoption of new technologies in the Pacific Region.
- Identify key risk factors that may hinder or slow the adoption of alternative technologies. Propose solutions to minimize risk factors.
- Propose actions (i.e. ideas and strategies) that could attract investment into the BC aquaculture sector, allowing for sustainable growth.
In response, the SAPT TWG provided a report to the IMAB including a detailed analysis of existing hindrances and proposed recommendations to assist the development and adoption of alternative production technologies in four key areas including: Land-based closed containment (i.e. Recirculating Aquaculture Systems); Floating semi-closed containment systems; Hybrid systems (combination of land-based or floating semi-closed containment with traditional marine-based systems); and offshore systems. Strategic recommendations of the TWG focused on the need for:
- A site permitting, licensing and regulatory framework including:
- Establishment of a permitting and regulatory framework with clear requirements, service standards and license durations to attract investment;
- Introduction of the concept of developmental licenses/tenures.
- Financial incentives;
- DFO and Provinces work together to develop financial incentives such as loan guarantees, tax exemptions, capital cost allowances, and Grants and Contribution support.
- Development of a Community Futures Fund (seed funding);
- Enhanced access to terrestrial farming financial support tools (e.g. Business Risk Management); and
- Capacity support including knowledge, human resources, and access to seed stock (biotechnology) including:
- Support for science and industry driven R&D
- Support for education and training in alternative production systems; and
- Enhanced access to genetic materials (e.g. eggs) for alternative production systems.
While there was general support for the SAPT report and its recommendations, there was considerable debate amongst a few IMAB members over two key elements including: (1) the completeness of the cost data used in the analysis of land-based (RAS) production; and (2) whether or not there is sufficient data from large-scale (>3000 mt) production facilities from which to adequately determine cost estimates.
On the first issue, there was criticism of a chart included in the report providing estimated costs for the different types of alternative production systems as it was indicated that it was missing data from a 2019 Gardner-Pinfold study which identified lower capital costs for land-based aquaculture production. The omission was acknowledged and the table in the TWG report was updated to show a greater range in capital costs for land-based production.
On the second issue, there was denunciation of a statement prefacing the cost table that “… there are no large-scale (>3000 mt) land-based RAS facilities in production” with an IMAB member pointing to the Atlantic Sapphire’s Miami Bluehouse facility in Florida as an example of a large-scale production facility. This example was opposed by an industry representative who pointed out that while the Atlantic Sapphire is a large scale facility, that it has yet to harvest fish and thus prove its commercial viability. The previous member indicated, however, that harvesting from the facility had begun as of July 2020Footnote 1. Additional differences in opinion were also expressed over whether or not such a facility, which currently discharges waste into a subterranean aquifer in Florida, could be utilized in British Columbia given substantial differences geological formations between the two regions.
Finally some ENGO members raised concerns over recommendations supporting floating semi-closed containment and hybrid production systems which they suggested are unable to eliminate wastes from entering the ocean and control the transmission of parasites or pathogens from farms to wild Pacific salmon.
Marine finfish and land-based fish health
According to its terms of reference, the FH TWG was assigned to:
- Undertake a review of existing marine finfish aquaculture fish health management regimes internationally, including data collection requirements, standards and management metrics, and corresponding management approaches to fish health;
- Review previous audits and assessments of Fisheries and Oceans Canada’s fish health management regime; and
- Recommend improvements to the Pacific Region’s fish health management regime, including:
- Looking at what is measured and why;
- Recommending standards and metrics for tracking and reporting and enhancements to the rigor and transparency of data;
- Recommendations for creating ‘greater certainty’ in fish health, reducing risk, or mitigating potential adverse outcomes;
- Recommendations for how to better detect, respond to and manage fish health; and
- Recommending more clear rules for compliance and penalties for non-compliance.
The FH TWG was the most active of the TWGs meeting a total of ten times between August 2019 and May 2020. Additionally, with support from DFO to implement one of their early recommendations, they convened a two-day workshop of veterinarians and veterinary pathologists to review the Department’s current case definitions for HSMI and Jaundice Syndrome. The FH TWG was unique in that it was co-chaired by DFO and the Canadian Food Inspection Agency (CFIA) as both departments share a responsibility for the management of aquatic species health.
Discussions among the participants mostly focused on DFO’s overall management of fish health at aquaculture facilities with a particular concentration on the assessment and management of risks associated with Piscine Orthoreovirus (PRV), Heart and Skeletal Muscle Inflammation (HSMI), Jaundice Syndrome and, sea lice.
While all TWG participants were highly engaged, working group members often held divergent views regarding the interpretation of scientific data, what scientific data was relevant, and appropriate management responses, along with real and/or perceived biases that often resulted in friction among the participants. Despite this, the FH TWG was successful in reaching agreement on several issues and tabled consensus recommendations to DFO to address identified science, communication and management gaps related to aquaculture fish health management, environmental impacts and associated public confidence.
Specific recommendations included:
- Improvements to the existing Pacific Marine Aquaculture Management Regime which included:
- improvements in communications and increased accessibility to data by the public;
- improvements in access to scientific data, including that collected by external organizations,
- development of tools to enhance fish welfare and establishment of quantitative indices of fish health (wild and cultured); and
- strengthening of an “adaptive management” framework, including performance management, improved enforcement tools (e.g. ticketing) and adoption of international best practices as the minimum standard of fish health management.
- Improvements to Conditions of License for on-farm management of sea lice including:
- Strengthened enforcement tools, increased sea-lice monitoring (including establishment of area-level thresholds), conducting pre- and post-treatment lice counts, implementation of integrated pest management, and mandatory requirements to submit environmental data.
- Improvements to knowledge and management of sea lice including:
- Implementation of spatial and temporal monitoring, making sea lice data publicly available in near real-time, research on sea lice viability following chemical treatments, and consideration of third-party certification bodies; and
- Some actions to address concerns over the management of PRV, HSMI and Jaundice Syndrome including:
- PRV challenge studies on all species of salmon, review of case definitions for Heart and Skeletal Muscle Inflammation (HSMI) and Jaundice Syndrome to ensure conformity with international best practices and strengthened collaboration with CFIA to ensure effective monitoring of emerging diseases as well as sub-lethal signs of disease.
Several IMAB members positively acknowledged Fisheries and Oceans Canada’s responsiveness to incorporate early recommendations from the FH TWG into its 2020 revisions to Conditions of License to improve sea-lice management. Other members, however, expressed the view that the revisions fell far short of what was needed to mitigate the impacts of sea lice transmission from aquaculture farms to vulnerable wild salmon populations.
Some IMAB members also acknowledged the Department’s support to hold a workshop of qualified experts to review its current case definitions for HSMI and Jaundice Syndrome to ensure that the definitions are robust and conform to international standards. Although all TWG members were invited to nominate a facilitator and participants for this workshop, some IMAB members were critical that the workshop was not open to observers, with some indicating little trust in the outcomes of a process they were not able witness.
A few IMAB members were also critical of the management of the FH TWG. Particular concerns were expressed over the number of ex-officio DFO and CFIA officials who participated in TWG meetings, the amount of time given to review and discuss materials shared with TWG participants, and how members views were captured in the final FH TWG report. These concerns contrasted with those of other participants who deemed the participation of the ex-officio members to be essential to ensure the group’s understanding of detailed scientific and technical information related to fish health and the department’s current monitoring, auditing and evaluation practices.
As the FH TWG was unable to reach agreement on several issues including: the role of PRV in disease development, in particular HSMI and Jaundice Syndrome; the need for surveillance of additional strains of PRV in British Columbia; the role environmental conditions play in the development and transfer of sea lice to wild salmon; and the extent to which poorly performing farm-raised fish serve as indicators of the health of farmed and/or wild salmon; some IMAB members expressed an interest in continuing engagement on these and other Fish Health issues but expressed a preference that these discussions take place through an independently-led process.
Area Based Management
According to its terms of reference, the ABM TWG was assigned to:
- Conduct a review which highlights the following:
- Relevant examples of approaches to Area Based Management in a fisheries and aquaculture context.
- Use of various geographic scales as a management tool and assess their appropriate role in an Area-based Management of Aquaculture approach.
- Information management technologies used in other related initiatives (like conservation planning, GIS analysis).
- Develop a recommendation for a shared definition/vision for Area Based Management of Aquaculture within Pacific Region.
- Supported by the above, recommend the use of appropriate scale/models for application in an area based aquaculture management approach in the Pacific Region (linkages to governance and engagement; planning; assessment of applications; management, monitoring, and science/research).
- Recommend appropriate technologies or approaches which could support the above.
Participation on the ABM TWG was highly collegial with good progress made against almost all of its assigned objectives. Several members of the TWG indicated that they would be happy to remain involved to assist with further development of the approach and framework for implementation including:
- The establishment of a new tripartite (Indigenous-Federal-Provincial) governance structures responsible for the planning, management and monitoring of all forms of aquaculture in B.C.
- The new governance structures should include: a province-wide Area-based Aquaculture Management Committee (BC ABAMC) and sub-regional Area-based Management Committees (ABMCs) supported by a Science/Knowledge support committee and an ABAM secretariat;
- Adoption of a nested approach including establishment of pilot areas identified through proactive engagement with Indigenous rights and title holders;
- That ABAM areas be selected based on: Indigenous consent; consideration of environmental goods and services; Industry presence and/or potential; existing administrative boundaries; and other relevant factors;
- That financial and human resources be sought by all parties to support adoption of an area-based approach;
- That the approach consider the recommendations of the SAPT and FH TWGs;
- Additional assessment of tools supporting the adoption of an area-based approach and the establishment of a unified federal-provincial-Indigenous data sharing platform; and
- The integration of Area-based Management within the new federal Aquaculture Act.
Most IMAB members were supportive of the ABM TWG’s recommendations. There was particular support for the recommendation to establish a tripartite governance structure for the planning and management of aquaculture activities in B.C. which some suggested would be consistent with the United Nations Declaration on the Rights of Indigenous Peoples.
Some questions were raised about the proposed framework, including whether the boundaries of Indigenous territories were considered and how Indigenous communities would be involved in the future development and implementation of the proposed framework. Some members explicitly expressed the requirement to recognize the rights and autonomy of First Nations to participate and that financial support be provided to build capacity and enable them to play meaningful roles in the proposed framework.
Additional concern was expressed over whether or not existing aquaculture activities should be included in the determination of proposed boundaries for management areas, suggesting that this would effectively grandfather these activities. Concerns were also expressed that the proposed framework must be able to address cross-boundary issues such as salmon migration. There was positive acknowledgement of how the adoption of an area-based approach could be used to help address sea lice issues.
Finally, some IMAB members expressed that they wished the TWG had gone further towards implementation, including the definitions of roles and responsibilities, and using the proposed framework to advance the Minister of Fisheries and Oceans mandate commitment of transitioning open net-pens in British Columbia.
The next steps for the Indigenous and Multi-stakeholder Advisory Body on Aquaculture will include providing the Minister of Fisheries and Oceans this summary document, the three TWG reports, IMAB meeting minutes and written submissions received from IMAB members. Fisheries and Oceans Canada will formally conclude the IMAB engagement process by responding to the recommendations contained in the TWG reports in late Fall 2020.
We wish to once again thank all of the IMAB members and their TWG representatives for their dedication of time, knowledge and experience to this informative process.
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