Salmonid alternative production technologies technical working group report and recommendations

Salmonid alternative production technologies technical working group report and recommendations
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On this page

• Executive summary
• Context
• Salmonid alternative production technologies technical working group (TWG)
• Recommendations
• Annex 1 - Salmonid aquaculture production technologies technical working group participants
• Annex 2 - Table of hindrances and incentives
• Annex 3 - Example of a defined permitting process – Maine’s land-based aquaculture: A guide to successful & timely permitting (separate document)
• Bibliography

Executive summary

On June 4, 2019, Fisheries and Oceans Canada (DFO) announced the creation of an Indigenous and Multi-stakeholder Advisory Body (IMAB) and three technical working groups to develop recommendations related to aquaculture management in British Columbia (B.C.). Among these, the Salmonid Alternative Production Technologies Technical Working Group (TWG) was created to investigate and support the development and adoption of technologies that enhance the sustainability of salmon aquaculture in B.C. to support the protection and conservation of wild fish in the Pacific Region.

While there are a range of technologies that could enhance the sustainability of existing salmon aquaculture production in B.C., the TWG focused primarily on alternative production systems to narrow the scope of the discussion. In contrast to traditional production systems (i.e., marine-based net-pens), the term “Alternative Production Systems” in this report refers to the following:

• Land-based closed containment (i.e., Recirculating Aquaculture Systems (RAS));
• Floating semi-closed systems;
• Hybrid systems (a combination of land-based RAS or floating semi-closed and traditional marine-based net-pens);
• Offshore systems.

The majority of the TWG’s discussions focused on the hindrances and obstacles to the development and adoption of alternative production systems in B.C. and solutions to overcome them. These are not unique to the production systems reviewed but also apply to alternative production technologies - technologies that enhance the environmental sustainability of the systems listed above as well as traditional marine-based net-pens. In this regard, this report and its recommendations, while focused on alternative productions systems, are also relevant to these alternative production technologies.

The TWG identified the following themes that form the basis of the recommendations:

1. Site permitting, licensing and regulatory barriers
2. Financial barriers
3. Knowledge, human resource, and seed stock access (biotechnology) barriers

Notably, there was consensus among the TWG that the current outdated and unclear regulatory regime is a significant barrier to investment in alternative production systems and technologies in B.C. The development of a modern and clear regulatory/licensing/permitting regime is essential to help to instill confidence and attract investment to facilitate the adoption of alternative production systems and technologies. This was echoed by several reports that the TWG reviewed.

Investment in alternative production systems is hindered by high capital costs estimated at $5 - $40 per kg of production capacity; permitting risks (e.g., uncertain timing and costs due to an unclear process); the lack of a proven track record at commercial scale; and lengthy times to the first positive cash flow. Given the risk profile associated with the development of alternative production systems, it is extremely difficult for project proponents to access conventional sources of funding. The TWG recommends, therefore, that government lower the risk-profile for early adopters of alternative production systems and open up conventional sources of financing by sharing the financial risk through loan guarantees, offering co-shared grants and contributions, broadening provincial sales tax exemptions and accelerated capital cost allowances, and other innovation financial accelerators.

While the TWG recognized that all of the recommendations are interconnected (e.g., knowledge informs the regulatory framework), it prioritized them as follows:

1. Site permitting, licensing and regulatory framework
   1. Establish a modern and clear permitting and regulatory framework, with consistent requirements, clear and timely service standards, and licence durations that help provide security to attract investment and facilitate the adoption of alternative production systems and technologies in B.C.
   2. Introduce the concept of developmental licences/tenures
      
      
2. Financial incentives
   1. Lower the risk-profile by having various levels of government share the financial risk for early adopters of alternative production systems
      
      
3. Knowledge
   1. Support science and industry-driven R&D and collaboration at the domestic and international level
   2. Human resources
      Increase support for education and training in alternative production systems and increased access to foreign workers
   3. Seed stock access (biotechnology)
      Improve access to or development of the best performing genetic material (eggs/ova) for each alternative production system

In terms of the TWG’s mandate, it was recognized that all recommendations for facilitating the development of alternative production systems and technologies should be made with due regard to the federal government’s commitment to applying the precautionary approach, particularly with respect to the conservation of wild Pacific salmon. It was also generally agreed that further research is required to fully understand the environmental impacts of salmon aquaculture and the group acknowledged that the Marine Finfish and Land-Based Fish Health TWG was the most appropriate group to focus on these issues.

Moreover, it was noted that while other domestic and international jurisdictions have growth strategies for their aquaculture sectors, B.C. does not. There was general agreement that a growth strategy that provides security, including attracting investment for industry development is required.

The TWG’s recommendations are an important contribution towards enhancing the sustainability of salmon aquaculture in B.C. The recommendations will also inform efforts to deliver on the Government of Canada’s current international and domestic priorities, including the Minister of Fisheries and Oceans’ mandate letter which includes instructions to: develop a comprehensive blue economy strategy; work with the Province of B.C. and Indigenous communities to create a responsible plan to transition from open net-pen salmon farming in coastal B.C. waters; and begin work on an Aquaculture Act.

Context

There are a number of factors that are driving strong interest from government, industry, non-government organizations, and Indigenous peoples to investigate and support the development and adoption of alternative salmon aquaculture production systems and technologies in British Columbia (B.C.) to minimize environmental impacts of traditional marine-based net-pen salmon farming and operational risks (e.g., sea lice, fish pathogens, and algae blooms), while supporting economic growth and opportunities, primarily in coastal and rural areas.

Environmental drivers

There are a number of environmental impacts (e.g., sea lice, fish pathogens, and algae blooms) that have caused mass fish die-off events such as those in Chile (2016 - algae bloom and 2007 - infectious salmon anemia outbreak) and Newfoundland (2019 - warm water temperatures) for traditional marine-based net-pen salmon producers. Climate change is exacerbating these risks and is presenting new challenges that the industry, by applying adaptive management techniques, is working hard to overcome.

The development of alternative production systems and technologies have been largely driven by the need to address these risks, as well as the growing imperative to reduce potential impacts on wild salmon and the marine environment. These systems include land-based recirculating aquaculture systems (RAS), offshore systems, semi-closed containment systems, hybrid systems which include a combination of land-based RAS or floating semi-closed and traditional marine-based systems, as well as technologies that enhance these systems and traditional marine-based net pens.

As noted in the 2019 “State of Salmon Aquaculture Technologies” report^{Footnote 1}, each system addresses the environmental risks posed to farmed salmon and the risks posed to wild salmon in different ways and to varying degrees. These alternative production systems are also at varying stages of development, which brings its own set of operational and financial risks. Mass die-off and fish escape events have occurred in some of the systems due to poor design, storm damage, mechanical failures, or inadequate maintenance protocols.

International drivers

According to the Food and Agriculture Organization (FAO) of the United Nations, aquaculture continues to grow faster than other major food production sectors. In 2014, global human consumption of farmed fish overtook that of wild fish for the first time; by 2030, aquaculture is expected to provide 60% of the fish available for human consumption^{Footnote 2}. With most fishery stocks expected to remain at or exceed maximum harvest capacity for the foreseeable future, aquaculture will be required to meet the demand from a growing global population. Moreover, aquaculture is recognized as one of the most efficient animal protein production methods, with the lowest carbon footprint, best feed conversion rates, and lowest consumption of freshwater per kilogram (kg) of protein produced^{Footnote 3}.

Canada is participating on the High Level Panel (HLP) for a Sustainable Ocean Economy^{Footnote 4}, a group of 14 world leaders committed to developing, catalyzing and supporting solutions for ocean health and wealth in policy, governance, technology and finance. The HLP has commissioned 16 blue papers on a range of topics, including one on “The Future of Food from the Sea”^{Footnote 5}. It is expected that this panel will develop recommendations in 2020 pointing to aquaculture as a key contributor to a sustainable ocean economy.

Major investments in alternative production systems and technologies are emerging in other jurisdictions such as Norway, the United States (U.S.) and China. For example, an October 2019 Rabobank report^{Footnote 6} indicates that there are over 50 announced RAS projects (and counting) around the globe for salmon farming, with an estimated production of 700,000 metric tonnes (mt) within the next decade. Though the proposed projects are spread across the globe, the majority are planned for Norway, due to know-how around salmon farming and the existing cold-chain and logistics infrastructure in the region. However, total proposed production volumes are highest in the U.S., followed by China, mainly as a result of the high growth in demand in these regions. According to the Rabobank report, some of the planned projects are at the financing stage, some are working on obtaining the necessary permits, and some are constructing their facilities. Only a few of these projects are harvesting and showing early success. Despite the large volumes of planned production, the current active production volume coming from land-based RAS salmon farming is minor, at around 3,000 mt (or ~0.1% of global production)^{Footnote 7}. Furthermore, according to the same report, none of the projects reviewed had current production that exceeded 1,000 mt.

Domestic drivers

Economic

Aquaculture is a key economic driver for local economies, particularly in coastal, rural and some Indigenous communities. Recent reports have recognized the economic potential of the aquaculture sector and recommended ways to support the responsible growth of the sector. These include the 2016 Standing Senate Committee on Fisheries and Oceans (SCOFO) “An Ocean of Opportunities” report^{Footnote 8} and the 2017 Advisory Council on Economic Growth report^{Footnote 9}, which recognized aquaculture as an industry with growth potential and as a lever for economic development.

Canada has an opportunity to enhance its reputation as a respected food supplier by promoting the development of alternative production systems and technologies. B.C. is well positioned geographically to take advantage of growing global demand, including from one of the world’s largest salmon consuming nations, the U.S. As the low carbon economy increasingly influences the choices consumers make, B.C. and Canada can take advantage of geographic proximity to this major market.

There is currently an opportunity for the B.C. salmon aquaculture industry to increase its global market share using a variety of production systems and technologies. However, while other domestic and international jurisdictions have growth strategies for their aquaculture sectors, B.C. does not. A growth strategy that provides security, including attracting investment for industry development is required for the aquaculture sector in B.C. to meet its potential. A variety of production systems and technologies will help foster trust and growth in the B.C. seafood industry overall and will provide various options for First Nations who will want flexibility in terms of production systems and technologies that align with their social, environmental, and economic goals.

Government commitments

The Minister of Fisheries and Oceans’ mandate letter includes an instruction to develop “[…] a comprehensive blue economy strategy to help guide future government actions and investments that enable Canada to grow its oceans economy to create good middle class jobs and opportunity for coastal communities while advancing our conservation objectives.” The Minister’s mandate letter also includes instructions on aquaculture to “work with the Province of British Columbia and Indigenous communities to create a responsible plan to transition from open net-pen salmon farming in coastal British Columbia waters by 2025 and begin work to introduce Canada’s first-ever Aquaculture Act.” 

Both the Government of Canada and the Province of B.C. are committed to working in partnership with Indigenous communities to create a joint vision of reconciliation based on the recognition of rights, respect, cooperation, and partnership. Moreover, DFO recognizes that fisheries, oceans, aquatic habitat, and marine waterways are of great social, cultural, spiritual and economic importance to many Indigenous peoples. DFO is committed to building renewed Nation-to-Nation and Government-to-Government relationships with First Nations, Inuit, and Métis peoples.

Indigenous participation

Some Indigenous communities are highly engaged in aquaculture as investors, environmental monitors, operating partners, and through a growing share of the aquaculture workforce. The recent Pacific Integrated Commercial Fisheries Initiative (PICFI) report, “Aquaculture Opportunities in the Pacific Region^{Footnote 10},” indicates that while controversy remains around the environmental impact of aquaculture production operations in B.C. – specifically traditional marine-based net-pen salmon farming – many Indigenous communities see the potential for investment in sustainable aquaculture both on-land and in-water to create economic opportunities close to home.

In 2018, the Province of B.C. announced a new policy that obligates traditional marine-based net-pen salmon farms to have agreements with First Nations to operate in their territory by June 30, 2022 before provincial aquaculture tenures will be renewed^Footnote 11. While most of the current production of farmed salmon in B.C. is produced under such agreements, this announcement has provided some clarity around expectations of the aquaculture industry concerning provincial approvals. This policy shift also provides an opportunity for Indigenous groups to play a larger role in the future development of salmon aquaculture in B.C., and a means to ensure future development is aligned with the social, environmental, and economic goals of individual Nations and communities.

Moreover, in 2007, the United Nations General Assembly developed the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP), which includes 46 articles covering all facets of the rights of Indigenous peoples such as culture, identity, religion, language, health, education and community. The UNDRIP emphasizes the Indigenous rights to live in dignity, to maintain and strengthen Indigenous institutions, cultures and traditions and to pursue self- determined development, in keeping with Indigenous needs and aspirations. The UNDRIP has been adopted by 148 countries, including Canada. B.C was the first provincial government in Canada to introduce legislation to implement the UNDRIP; this will form the foundation for the Province’s work towards reconciliation in B.C.^{Footnote 12}  The Minister of Justice and Attorney General of Canada’s mandate letter^{Footnote 13} includes an instruction to introduce co-developed legislation to implement the UNDRIP, with support from the Minister of Crown-Indigenous Relations, by the end of 2020.

Status of alternative production systems

In 2019, DFO, in partnership with Sustainable Development Technology Canada (SDTC) and the Province of B.C., commissioned and funded a study entitled the “State of Salmon Aquaculture Technologies”^{Footnote 14} (the Study) to examine the risks and opportunities of the most promising emerging aquaculture production systems as well as technologies for salmon farming in B.C. The Study explored the financial, environmental, and social elements of these systems and highlighted some of the ways to incent the adoption of them, including how other countries have incented such adoption.

The Study explored four production systems: land-based closed-containment; floating closed-containment; offshore technologies; and hybrid systems, which combine land-based closed-containment or floating semi-closed containment with traditional marine-based net-pen systems through the production of larger smolts that reduce the length of time the salmon spend in the marine environment.

The Study concluded that, overall, land-based closed containment and hybrid systems are the production systems most ready for commercial development in B.C., while floating closed containment and offshore systems still require about five to ten years of further development and evaluation. The Study indicated that land-based closed containment, though less financially viable than hybrid or traditional marine-based net-pen aquaculture, provides the most secure protection for the marine environment and hence is the most socially acceptable system to opponents of traditional marine-based net-pen aquaculture in B.C. The Study also indicated that the hybrid system is likely more profitable and the preferred choice for the majority of the established, traditional marine-based net-pen industry in B.C.

Indigenous and multi-stakeholder advisory body

In this context, on June 4, 2019, the former Minister of Fisheries and Oceans announced a number of initiatives to further enhance aquaculture sustainability in B.C., including the creation of an Indigenous and Multi-stakeholder Advisory Body (IMAB) and three technical working groups (TWG), to develop recommendations related to aquaculture management in B.C.^{Footnote 15} The three TWGs comprise the:

1. Salmonid Alternative Production Technologies TWG;
2. Marine Finfish and Land-based Fish Health TWG; and
3. Area-based Approaches to Aquaculture Management TWG

This report reflects the work of the Salmonid Alternative Production Technologies TWG.

Salmonid alternative production technologies technical working group (TWG)

Purpose and scope

The Salmonid Alternative Production Technologies TWG was created under the auspices of the IMAB to investigate and support the development and adoption of technologies that enhance the sustainability of salmon aquaculture to support the protection and conservation of wild fish in the Pacific Region.

There was consensus among the participants of the TWG that the focus would be on intensive commercial salmonid aquaculture for the production of food. The TWG agreed that it would remain technology-neutral and not evaluate the merits of the different production systems or technologies. While there are a range of technologies that could enhance the sustainability of existing salmon aquaculture in B.C., the TWG primarily focused on alternative production systems, as defined below, to narrow the scope of the discussion.

Definitions

In contrast to traditional production systems (i.e., marine-based net-pens), the term “Alternative Production Systems” in this report refers to the following:

Land-based closed containment (i.e., Recirculating Aquaculture Systems (RAS)):

Land-based RAS involves growing salmon in recirculating tanks in closed production facilities on land. In this system, the fish waste is captured and the water is recirculated using a variety of water treatment technologies. RAS been used for decades in the production of salmon smolts (e.g., 60 to 100 grams). In the last five to ten years, these systems have advanced to successfully produce market-size salmon (e.g., 4 to 6 kg).

Floating semi-closed containment systems:

These systems are marine-based, consist of a walled-barrier, and do not capture all waste. There are different design variations, but all systems involve pumping water from sufficient depths (e.g., 12 metres or deeper) to address temperature regulation and other potential environmental challenges.

Hybrid systems:

The hybrid system involves producing post-smolts weighing from 250 grams to 1 kg in land-based RAS or floating semi-closed containment systems before the salmon are transferred to traditional marine-based net-pens for grow-out to market-size.

Offshore systems:

Offshore production is defined differently across the globe; however, it is primarily defined by a high level of exposure and lack of protection from land masses, rather than a predetermined distance from shore^{Footnote 16}. The variety of designs include open and semi-closed systems, floating and submersible options, as well as fixed and mobile systems. Existing offshore aquaculture operations suggest that the practical boundaries are limited to about 50 kilometres from shore^{Footnote 17}.

More information on the different alternative production systems can be found in the “State of Salmon Aquaculture Technologies” study^{Footnote 18}.

The term “Alternative Production Technologies” in this report refers to technologies that enhance the environmental sustainability of the following production systems:

• Traditional marine-based net-pens;
• Land-based closed containment (i.e., Recirculating Aquaculture Systems (RAS));
• Floating semi-closed containment systems;
• Offshore systems.

Guiding principles

The TWG was guided by the following principles:

• Recommendations are developed and assessed using the best available science and evidence.
• Discussions are informed by a range of policy and technical/scientific expertise in the relevant areas under consideration.
• Recommendations are developed and assessed based on their potential effectiveness to improve the sustainability of aquaculture, recognizing that technologies can and should adapt over time.
• Recommendations should help attract investment to B.C. to grow the aquaculture industry in a sustainable manner.
• The TWG will work in a spirit of collaboration and consensus, but will not be required to reach full consensus around any particular proposal. Should differing viewpoints be expressed, they will be fully reflected in the outcomes of the TWG.

In addition to these principles, there was consensus that the report/recommendations recognize and/or build-in flexibility to allow for modifications as new information becomes available in this rapidly evolving industry.

As there was consensus on the importance of wild Pacific salmon, which has been highlighted by recent and significant declines in stocks, the group viewed that any new and existing production systems and technologies need to be safe and effective. In terms of the TWG’s mandate, it was recognized that all recommendations for facilitating the development of alternative production systems and technologies should be made with due regard to the federal government’s commitment to apply the precautionary approach^{Footnote 19}, particularly with respect to the conservation of wild Pacific salmon. In the recommendations that follow, this approach applies to (i) the granting of longer-term licences for alternative production systems, (ii) the development of streamlined approval processes, and (iii) the creation of financial incentives for innovation.

Process

The TWG comprised representatives and delegates from federal and provincial governments, First Nations, environmental non-governmental organizations (ENGO), industry, as well as academia and subject matter experts (Annex 1). Five meetings were held between August 2019 and March 2020. Select references and technical reports on a range of themes were reviewed and discussed by the group and are included in the bibliography. Notably, the TWG spent a considerable amount of its time identifying hindrances to alternative production systems development and actions to overcome them; these are reflected in a table in Annex 2.

While there was consensus on the importance of the protection and conservation of wild Pacific salmon, this consensus did not extend to the priority consideration that should be given to the conservation of wild Pacific salmon relative to the development of alternative production systems for salmon aquaculture development in B.C. Some felt that the threat of long-term, irreversible losses of wild Pacific salmon populations warranted a high-level of consideration. Others judged the threat posed by current aquaculture practices to be no more than minimal, and hence that the issue did not warrant priority consideration in the group’s deliberations. This lack of consensus is consistent with the views of the members of the Minister of Agriculture’s Advisory Council on Finfish Aquaculture^{Footnote 20} (MAACFA) that provided a final report and recommendations in January 2018. The MAACFA report notes that some of its members viewed the environmental risk, in particular the potential risk of serious harm to wild salmon populations, is such that it makes traditional marine-based net-pen aquaculture unacceptable. Other MAACFA members held the view that properly sited and managed traditional marine-based net-pen salmon farming poses no more than a minimal risk to wild fish stocks, and they emphasize the positive income and employment benefits generated locally and provincially from salmon farming.

Despite these diverging views, it was generally agreed that further research is required to fully understand the environmental impacts of salmon aquaculture and the group acknowledged that the Marine Finfish and Land-Based Fish Health TWG was the most appropriate group to focus on these issues. Expanding both DFO’s internal research capacity and funding opportunities for independent research scientists to quantify the environmental benefits of alternative production systems and technologies would support the work and recommendations of the Salmonid Alternative Production Technologies TWG.

Recommendations

Several themes emerged from TWG discussions on the hindrances and obstacles to the development and adoption of alternative production systems. These themes form the basis of the recommendations which are based on the substance of Annex 2. While the TWG recognized that all of the recommendations are interconnected (e.g., knowledge informs the regulatory framework), it prioritized them as follows:

1. Site Permitting, Licensing and Regulatory Barriers
2. Financial Barriers
3. Knowledge, Human Resource, and Seed Stock Access (Biotechnology) Barriers

Notably, there was consensus that the current regulatory regime is outdated and unclear and is a significant barrier to investment in alternative production systems and technologies in B.C. The development of a modern and clear regulatory/licensing/permitting regime is essential to help to instill confidence, security, and attract investment to facilitate the adoption of alternative production systems and technologies as well as to advance the other main themes explored in this report.

This is echoed in the “State of Salmon Aquaculture Technologies” study which notes that time required for permitting directly impacts capital costs and project risks. It indicates that any complexity and delay of permitting and approvals is a deterrent to the development of land-based RAS (and other alternative production systems) since financial capital is tied up longer and outcomes (timing and costs) are uncertain. It notes that the locations where large projects are going forward (e.g., in the U.S.) took many years to meet all regulatory requirements, noting that this increases the costs to build a facility, increases the risk to investors, and makes it more difficult to achieve a satisfactory risk-return ratio.

Case in point, it has been reported that Cermaq Canada is currently exploring the installation of a semi-closed containment system in one of its existing traditional marine-based net-pen tenures in B.C. This system, still in the R&D stage, costs approximately $5.5 million^{Footnote 21}. Cermaq’s application for installation has been under review since September 2018. As the service standards for applications for alternative production systems are unclear and not guaranteed, this uncertainty and delay is eroding investor confidence among Cermaq senior management and risks cancellation of this project.

Similar challenges exist for the adoption of alternative production technologies. There are a number of commercially-available and developmental technologies designed to enhance traditional marine-based net-pens that have not been adopted due to a need for adaptation to existing Conditions of Licence.

It’s important to note that while licences for aquaculture operations in B.C. are issued by DFO, the provincial government and other federal departments play a role in the licensing process. DFO, Transport Canada, and the Province of B.C. work together in a harmonized application process. All applications for new sites and major technical amendments to existing sites for freshwater/land-based and marine finfish aquaculture operations are submitted through FrontCounterBC^{Footnote 22}.

I. Site permitting, licensing and regulatory framework

According to the “State of Salmon Aquaculture Technologies” study, several things need to be aligned in order to promote innovation in Canada and to position B.C.’s salmon aquaculture sector to meet growing global demand opportunities. The report indicates that national legislation and policy needs to clarify the requirements for aquaculture in terms of environmental and social performance and this will send the appropriate signals for investors to develop the systems and technologies that meet the challenge.

Currently the regulatory and permitting processes for alternative production systems and technologies largely are non-existent (e.g., offshore) or long, unclear and convoluted, and require approvals at multiple government levels. Key permitting issues in B.C. include:

• overlap, gaps, and conflicting requirements in permitting;
• unclear service standards leading to long wait times for licences/permits that may or may not be approved;
• lack of performance standards or inconsistent application of standards;
• ambiguity regarding standards as well as inconsistency between standards for similar industry activities;
• inconsistent classification of aquaculture activities (e.g., agricultural, industrial) impacting such things as taxation, permitting, and waste management.

Notably, the TWG had significant discussion on the issue of dealing with effluent and solid organic waste from land-based facilities. For example, discharge from land-based RAS consists of a more concentrated effluent than the current regulations were designed to regulate. Moreover, the disposal of solid waste from land-based RAS under the existing solid waste regulations in B.C. (i.e., Code of Practice for Agriculture Environmental Management^{Footnote 23} and Organic Matter Recycling Regulation^{Footnote 24}) does not cover fish, therefore the wet solid waste cannot be used as fertilizer on fields like other forms of manure, requiring more costly forms of disposal.

The regulations regarding discharge from processing facilities are also different from land-based RAS facility discharge. Based on the scale of production that is anticipated, onsite processing will likely become the norm, therefore, an alignment of standards is required.

A clear regulatory pathway will provide a consistent and predictable operating environment for industry and is necessary to attract investment in this area. Other jurisdictions, such as Maine, have created and communicated a clear permitting process that has successfully attracted investment in land-based RAS facilities (Annex 3).

Longer licence durations specific to pilot testing of alternative production systems and technologies will increase certainty and increase the likelihood of proponents being able to amortize or recoup costs of investment, which will decrease business risk and potentially facilitate adoption. Licence durations beyond 10-15 years are required for investment due to the high capital and operational costs and risks associated with alternative production systems.

In some other countries, traditional marine-based net pen aquaculture licences are subject to substantial fees, and licences are exchanged between companies at high market prices. For example, Norway instituted fees for licences in 2002 and licences for the standard 780 mt of capacity have recently sold for over $10 million^{Footnote 25}. Moreover, Norway is the global leader in R&D in alternative aquaculture production systems and technologies. This is in part due to its licensing regime and investments in R&D and innovation that encourages innovation in systems and technologies that improve environmental performance.

In 2013 and 2014, the Norwegian Government issued 45 new aquaculture licences for salmon and trout called “green concessions”. These types of licences were allocated to producers who committed to use systems, technologies, or operational methods that reduce the environmental risks from escapees and sea lice on wild salmonid stocks. The green concessions were designed to accelerate the commercialization of more environmentally-friendly methods of production^{Footnote 26}.

To incentivize development of the offshore sector, the Norwegian Directorate of Fisheries launched a new Development Licensing Program in November 2015 that will grant free development concessions for up to 15 years to approved offshore projects. The projects must be large-scale, backed by established teams with operational and development expertise in aquaculture and offshore infrastructure (including deep-water oil and gas), and offer commercially viable technologies to address environmental and health challenges. Successful projects will be able to convert the concessions into ordinary commercial licences at the end of the concession period, at a cost of $1.25 million (well below the $6.5 - 7.5 million needed for conventional coastal licences)^{Footnote 27}.

It is recommended that the concept of developmental licences/tenures be explored so as to further incent innovation in aquaculture production systems in B.C. For example, this is in place in B.C. for issuing Crown land tenures. These “MAP Reserves” have been used for the development of new and emerging aquaculture species in the past.

According to the B.C. Ministry of Forests, Lands, Natural Resource Operations and Rural Development website, “reserves are a particular type of Crown land tenure that grants an agency the right to implement a restriction on the use of crown land. Federal and Provincial government agencies and corporations may apply for the establishment of Land Act Reserves over high value sites required for public purposes, including research and education. Depending on the type of reserve [Order in Council, Map Reserve, Land Act Designation (which can be designated use or prohibitive use) and Notation of Interest] the area is withdrawn from disposition under the Land Act.”^{Footnote 28}

While this could facilitate innovation and research, discussions would be required with the B.C. Ministry of Forests, Lands, Natural Resource Operations and Rural Development, to determine if and how the tenure could be converted to a commercial tenure, once the initial project is complete.

As recognized in the Norwegian Government’s Ocean Strategy^{Footnote 29}, given that technology development in aquaculture is so rapid, flexible rather than prescriptive legislation should be favored to support the development of new solutions. A new Aquaculture Act and the proposed General Aquaculture Regulations could present avenues to address this and other opportunities related to the regulatory framework.

The following recommendation and recommended actions are consistent with recommendation 2 and 6 in the “Scaling Investment into Sustainable Aquaculture in British Columbia: An Indicative Guide for Canadian Policy Makers”^{Footnote 30} which proposes the creation of an advisory committee to streamline regulations and permitting processes specifically for the sustainable technologies listed in their report (i.e., RAS and offshore) as well as the creation of a development licence program.

Strategic recommendation #1

Establish a modern and clear permitting and regulatory framework, with consistent requirements, clear and timely service standards, and licence durations that help provide security to attract investment and facilitate the adoption of alternative production systems and technologies in B.C.

Recommended actions

1. In collaboration with all parties, including various levels of governments (i.e., federal, provincial, municipal, First Nations) and relevant stakeholders, develop a clear permitting pathway, that includes: consistent standards/requirements, clear service standards and clear environmental performance expectations, outlining the various stages and timelines of approval by the relevant government agency and the documentation required at each stage.
   1. Identify a federal champion or single-window process in the statutory permitting process to streamline the process and ensure that service standards are upheld.
   2. Align and/or harmonize regulatory requirements between different government and agencies at the local, provincial and federal level.
   3. The permitting process will need to include how the applicant will manage, or demonstrate potential improved performance over existing production systems and technologies in certain, key environmental sustainability areas. The following key areas may include, but are not limited to: water use and waste/disposal/deposition/management, including organic/inorganic and potential pathogen release; as well as acceptable level/impacts of discharge of waste.
   4. The permitting process should take an iterative approach, with each step as part of a clear gated-application process, and be communicated through a clear flow chart process that captures all steps. The example of what has been created in Maine to attract land-based RAS investment could be used as a model (Annex 3). The example of the flow charts that the U.S. has created for its federal permitting and authorization of offshore aquaculture could also be used as an example^{Footnote 31}.
   5. Taking into consideration existing conditions of licence to avoid duplication, review and update existing federal, provincial and municipal regulations e.g., DFO’s Aquaculture Activity Regulations (AAR), B.C.’s Land-based Finfish Waste Control Regulations^{Footnote 32}to develop regulations that are technology-neutral, outcome-based, based on the best available science and evidence, and flexible rather than prescriptive.
   6. Consider that area-based aquaculture management initiatives explore the pre-approval of sites within certain areas as well as environmental thresholds for the various production systems and technologies.
   7. Consistent classification of aquaculture activities as an agricultural activity.
2. Streamline licence approval times and ensure licence durations are long enough for proponents to have enough time to fully assess the efficacy and financial sustainability of alternative production systems and technologies to warrant their adoption.
   1. Maintain government service standards of up to 1 year to receive licences for alternative production systems and technologies.
   2. Where appropriate in terms of the provisions of the precautionary approach^{Footnote 33} align licence and tenure durations for alternative production systems and technologies and increase them to 10-15 years.

While a 10-15 year licence duration is recommended to incent significant investment in B.C., the current maximum for licences under the Fisheries Act is 9 years. The proposed Aquaculture Act could provide an opportunity to address this issue.

Strategic recommendation #2

Introduce the concept of developmental licences/tenures

Developmental licence definition

In Norway, the development licence system aims at facilitating development of technology for solving either environmental or territorial challenges for the marine-based aquaculture industry (i.e., developmental licences are not aimed at land-based RAS). The system is a temporary arrangement that offers licences to certain marine-based projects based on innovation and resource requirements, and requires sharing of developed technology in order to generate industry-wide improvements.

 Recommended actions

1. Introduce a multi-stakeholder/rights-holder advisory board that has a clear gate system for the evaluation and screening of developmental applications based on clear criteria for validity and priority for improvement of sustainability (reducing wild/farmed interaction, waste management/reduction, sea lice management, pathogen presence and prevalence, offshore, inshore, land-based, etc.). The advisory board could develop a set of outcome-based/performance-based measures/thresholds for evaluating the new production system/technology. The Global Salmon Initiative/Aquaculture Stewardship Council standards could be used as models for developing standards.
2. Allow flexibility or exemption for certain criteria for conditions of licence based on the application. Develop tailored monitoring or inspection requirements based on the design of the alternative production system/technology.
3. The advisory board could develop tailored performance-based measures and evaluate performance for the transfer from Developmental Licence to conventional production licence based on meeting proposed targets.

II. Financial incentives

The commercialization of alternative production systems is hindered by high capital costs estimated at $5 - $40 per kg of production capacity ($5.5 million - $300 million per system). Other hindrances include permitting risks (e.g., uncertain timing and costs due to an unclear process); the lack of a proven track record at commercial scale; and lengthy times to first cash flow. Most producers are either too small to be able to take on such risks or unwilling to adopt unproven techniques and systems in a highly competitive, international environment. Given the risk profile associated with alternative production systems, it is extremely difficult for project proponents to access conventional sources of funding.

While several DFO federal programs [e.g., Fisheries and Aquaculture Clean Technology Adoption Program (FACTAP), Atlantic Fisheries Fund, Quebec Fisheries Fund, B.C. Salmon Restoration and Innovation Fund] currently exist to support or partially-support the adoption of clean technology and innovation by the aquaculture sector, some are focused on the wild capture fisheries sector and their repayable nature may prohibit many smaller- to medium-sized operators from applying given the high capital costs and lengthy, uncertain rates of return associated with developing and commercializing new production systems. While FACTAP has directed about half of its funding towards aquaculture, the program’s scope is restricted to supporting the adoption of “off-the-shelf” technologies thus precluding it from supporting R&D or innovation-related adoption projects. Other limitations of FACTAP include a maximum funding cap of $1.0 million per year, which is too small to support major capital investments, and there is also a requirement for inclusion of provincial financial support. The province of B.C. has supported small-scale RAS projects in the past but has indicated that it does not have the funds to support the scale of projects associated with comprehensive, alternative production systems. There are also differing levels of support provided by regional associations in the Atlantic and Pacific regions.

In order to attract early adopters of alternative production systems to B.C., financial support to share the financial risk associated with adoption of these systems is strongly recommended. One of the greatest financial incentives would be loan guarantees to help offset capital costs (rather than operating costs), given the high capital costs and lengthy, uncertain rates of return for early adopters. The loan guarantees could be limited to, for example, supporting the first 15,000 tonnes of salmon production that is built using alternative production systems that meet the governments’ objectives. However, during TWG discussions, it was noted that many First Nation aquaculture ventures fail due to under-capitalization, and that significant funding would be required to sustain smaller- to medium-sized operators, including First Nations, in the adoption of alternative production systems in the long term.

Capital and operational cost structure

While there have been costs cited in a number of reports such as “State of Salmon Aquaculture Technologies”^{Footnote 34}, the capital and operating costs of the varying alternative production systems are currently under development as the systems are at varying stages of maturity. Capital and operational costs for alternative production systems are largely linked to costs of land, construction, technology (material and labour), energy, and access to operational resources (inputs and labour). In many cases, the cost structure varies from project to project^{Footnote 35} depending on the geographic location and local infrastructure. For example, the cost structures may change dramatically when moving away from larger urban centers.

All new technologies begin with high cost structures. All of the alternative production systems have higher cost structures than traditional marine-based net-pen systems, but through optimization, standardization and scale, the costs of these systems could decrease over time. Furthermore, due to increasing environmental challenges and increasing environmental regulations, the costs for traditional marine-based net-pen systems are increasing.

The following table provides estimated costs between the alternative production systems for illustrative purposes. A range of estimated costs are provided, where possible, as actual data on the capital and operating costs of alternative production systems is limited and/or based on differing assumptions and parameters. Actual data on the cost structures is limited for a number of reasons including:

• Currently, there are no large-scale (>3000 mt) land-based RAS facilities in production^{Footnote 36};
• All large systems are still building their biomass so accurate, steady state costs have not yet been generated;
• Private companies keep operating costs as a closely guarded secret.

Leveling the playing field for aquaculture

Due to categorization of the industry (i.e., not ‘farmers’), fish farmers also do not have access to the suite of financial tools available to terrestrial farmers such as loan guarantees, income stabilization, and business risk insurance. The Canadian Aquaculture Industry Alliance (CAIA) has long advocated for access to these tools available to terrestrial farmers.

These issues are echoed in the 2016 Standing Committee on Fisheries and Oceans (SCOFO) “An Ocean of Opportunities” report which specifically highlighted the need for access to capital for innovation, business risk management programming, and greater variety of animal care products enjoyed by international competitors and other comparable industries in Canada.

The following recommendation and recommended actions are also consistent with recommendations 2 and 4 of the “Scaling Investment into Sustainable Aquaculture in British Columbia: An Indicative Guide for Canadian Policy Makers” which recommends tax grant programs and government loan guarantees to attract capital and reduce risk.

Strategic recommendation

Lower the risk-profile by having various levels of government share the financial risk for early adopters of alternative production systems

Recommended actions

1. DFO to work with federal and provincial government departments and regional associations to address financial incentives such as government loan guarantees, broadening provincial sales tax (PST) exemption, accelerated capital cost allowances, co-shared grants and contributions program, Scientific Research & Experimental Development (SRED) tax credits, etc. to share the financial risks associated with early adoption of alternative production systems.
2. Seed a Community Futures Fund that is specific to the adoption of alternative production systems.
3. Provide access for fish farmers to the suite of financial tools such as loan guarantees, income stabilization, and business risk insurance available to terrestrial farmers.

III. Knowledge, human resource, and seed stock access (biotechnology)

Knowledge

The alternative production systems discussed in this report are, for the most part, nascent with decades of refinement ahead of them. The major traditional marine-based net-pen salmon farming companies are directly plugged into salmon aquaculture technology development in Norway and Chile, which are the center or nucleus of salmon aquaculture production. These companies are focusing their R&D efforts on marine-based aquaculture solutions and are investing in post-smolt RAS facilities to raise fish from 250 g to 1 kg to support hybrid production systems; they are not investing in full grow-out land-based RAS systems. Until projects, like Atlantic Sapphire^{Footnote 48},  prove that large-scale, full grow-out land-based RAS can be achieved profitably, these large, well established companies are not likely going to be early adopters of this system because of the risk involved. Early adopters will, therefore, have to find ways to access research being done elsewhere and will benefit greatly from support that enables them to trial new innovations. Support for R&D and collaboration will help them build a strong, local nucleus of skilled employees and help them gain or maintain their competitive edge as the technology matures. Collaboration with the international community in this area would be important to prevent duplicating existing efforts.

Jurisdictions, such as Norway, Scotland, and the U.S., have programs that support R&D specific to aquaculture. The Conservation Funds’ Freshwater Institute in the U.S. has worked closely with Norway’s Nofima for years and was subsequently invited to join CtrlAQUA – a Norwegian research centre focused on making RAS aquaculture production technology reliable and economically viable. The Scottish Aquaculture Innovation Centre (SAIC), a collaboration of government and industry created in 2014, focuses on areas such as: fish and shellfish health and welfare; feeding, quality and nutrition; breeding and stock improvement; and engineering to contribute towards increased production of clean, safe and sustainable food. It is reported that the SAIC recently secured an investment from government and industry of over $17 M for the next five years to support innovation in aquaculture^{Footnote 49}.

Significant research capacity exists in Canada. The latest biennial Canadian Aquaculture R&D Review^{Footnote 50}, a compendium of the aquaculture research and development projects undertaken by researchers from academia, government labs, or other research organizations, illustrates an array of projects ranging from finfish health, production, husbandry technology, nutrition, and environmental interactions that have been undertaken. Research capacity exists in several universities across Canada and industry-driven research is also being conducted at the Centre for Aquaculture Technologies in Prince Edward Island, the Huntsman Marine Science Centre in New Brunswick, the Centre for Aquatic Health Sciences in B.C., as well as the University of British Columbia’s Initiative for the Study of the Environment and its Aquatic Systems (InSEAS), which was specifically designed to carry out industry-relevant research on RAS.

This research capacity in Canada could be leveraged to improve knowledge of the various aspects of alternative production systems by investing cooperatively with governments, industry, and research institutions as well as by creating a community research body, with shared research resources, either virtual or real, where the innovation and enterprise applications of research elements could be exploited and applied to real world scenarios.

The following recommendation and recommended actions are consistent with recommendation 9 of the “Scaling Investment into Sustainable Aquaculture in British Columbia: An Indicative Guide for Canadian Policy Makers” which recommends the creation of innovation centres to support the development of diverse species and technology that would also provide training to new graduates in the aquaculture field.

Strategic recommendation

Support science and industry-driven R&D and collaboration at the domestic and international level

Recommended actions – immediate

1. Fund the building of a B.C. aquaculture centre of excellence. This would also support aquaculture education and provide or facilitate training in alternative production systems.
2. Support R&D that is focused on addressing the barriers that have been identified in the regulatory section of this report as well as the “State of Salmon Aquaculture Technologies” study (i.e., R&D regarding liquid and solid waste discharge from RAS; identifying pathogen reduction results from different production systems, etc.) in order to guide the development of the new permitting and regulatory standards.
3. Support R&D to address specific challenges or potential improvements. A scientific and social committee consisting of scientists, First Nations, ENGOs and government could learn from the research, which would shape the development of regulatory policy. For example, for RAS systems, do research trials to:
   • reduce/manage off-flavours caused by compounds such as geosmin and 2-methylisoborneol (MIB);
   • better understand fish health and early maturation;
   • increase fish performance;
   • refine harvest processes;
   • improve feed delivery systems and feed conversion rates (FCR);
   • measure pathogen attenuation in effluent; and,
   • measure nutrient discharge.
4. Establish performance criteria and create key performance indicators (KPI) to benchmark various strategies and systems towards reducing the perceived risks or potential environmental impact concerns and to quantify the benefits/effects of alternative production systems.

Recommended actions - mid to long-term

5. Provide government funding/grants to offset cost of production improvements and innovation, as well as applied and innovation research, in partnership with industry (e.g., Aquaculture Innovation and Market Access Program).
6. Provide funding/increase capacity for independent labs (e.g., Centre for Aquatic Health Sciences), learning institutions (e.g., University of Victoria, University of B.C., Dalhousie University, Fisheries and Marine Institute of Memorial University of Newfoundland), and others.
7. Increase access to market research related to the feasibility, practicality, economics, and demographics around the potential to move to alternative production systems.
8. Fund an aquaculture alternative production technologies research chair that sits on educational program boards to stay abreast of alternative production systems and technology development.
9. Expand both DFO’s internal research capacity and funding opportunities for independent research scientists to quantify the environmental benefits of alternative production systems.

Human resources

In its recent report, “Aquaculture Industry Labour Market Forecast to 2025,”^{Footnote 51} the Canadian Agricultural Human Resource Council indicates that it expects that growing market demand for seafood will boost the demand for labour in the aquaculture sector in Canada. The Council also found that the sector faces unique challenges in finding enough workers, which is often compounded by such factors as the remote locations of operations, with rural depopulation and worker transportation issues affecting the industry’s ability to find and retain workers.

At the same time, seasonal employment insurance (EI) for fishers also has a negative impact on the labour pool available to aquaculture operations in remote and coastal regions, as seasonal EI creates a disincentive to enter the labour market.

To compound the issue of lack of labour, alternative production systems necessitate different skills and expertise than those associated with traditional marine-based net-pen production. Globally, a lack of highly qualified personnel for RAS has been identified as one of the major-limiting factors regarding the adoption and growth of this technology. According to The Nature Conservancy and Encourage Capital’s 2019 report^{Footnote 52}, it is estimated that there are less than 100 people worldwide with knowledge to build, maintain, and operate a successful land-based RAS project.

Strategic recommendation

Increase support for education and training in alternative production systems and increased access to foreign workers

Recommended actions

1. Support advanced education/co-op and First Nations aquaculture training programs.
2. Create incentive programs for internships or co-op programs such as Mitacs, a national, not-for-profit research and training organization dedicated to advancing collaborations between industry, academia, and government in Canada, and to fostering international research networks between Canadian universities and the world.
3. Support training in B.C. for highly technical positions.

Seed stock access (biotechnology)

The industry in B.C. does not have access to genetic material (eggs/ova) that has been selected and or developed for optimum performance in RAS. This problem is compounded by the scale of the industry in B.C. which is not large enough to start a genetic stock improvement program exclusive to B.C. Without access to the best genetic material, it will be extremely difficult for the B.C. industry to maintain its competitive position and thrive; this acts as a barrier to new investment in conventional and alternative production systems. Support is needed to develop scientifically and socially-acceptable pathway(s) for the import of high-performance genetic stocks. A critical consideration would be the creation of a domestic or B.C.-based broodstock development/egg production/seed stock facility for the purpose of egg production security and further stock enhancement.

Nonetheless, any proposed genetic or biotechnological innovations must be considered with thorough regard for potential environmental risks, such as, the introduction of genetically modified organisms into the aquatic environment or the importation of eggs or live fish leading to the introduction of pathogens.

Strategic recommendation

Improve access to or development of the best performing genetic material (eggs/ova) for each alternative production system

Recommended actions

1. Create a genetic task force.
2. Streamline the Canadian Food Inspection Agency’s pathway regarding sufficient compartmentalization and quarantine to facilitate the importation of high-performance genetic stocks.
3. Provide funding for a broodstock/selective breeding/seed development facility that is run by a third party. This also solves the problem of the existing industry excluding new entrants due to the shortage of genetic material.

Annex 1 - Salmonid aquaculture production technologies technical working group participants

Annex 2 - Table of hindrances and incentives

Annex 3 - Example of a defined permitting process – Maine’s land-based aquaculture: A guide to successful & timely permitting (separate document)

Maine’s Land-Based Aquaculture: A Guide to Successful & Timely Permitting
(PDF, 1,288 KB)

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