Por: Felipe Irarrázaval y Beatriz Bustos
(Leer noticia en Ciper)
The salmon industry is once again in the spotlight. The National Fishing and Aquaculture Service (Sernapesca) confirmed that during the early hours of Saturday, June 27th, due to a strong storm in the area, around 800,000 fish escaped from 16 cages of the "Caicura" culture center operated by the Blumar company, and it is estimated that this is the largest salmon escape ever recorded in Chile. Although the issue has been in the background due to the emergencies associated with the pandemic, the salmon escape has attracted the attention of the regional press and environmental organizations, due to the potential ecological damage it could mean for the marine ecosystems of the Reloncaví Sound. In the immediate future, Blumar must recapture at least 10% of the escaped fish, as established in the General Law of Fisheries and Aquaculture, while Sernapesca must oversee this process, and then evaluate the corresponding sanctions according to the percentage of recapture and the expert reports on the conditions of the culture center.
While this sounds simple on paper, salmon escapes are one of the dimensions that must be urgently reviewed in terms of the relationship between the industry, the State and the territory in which aquaculture is located. The history of salmon escapes is a constant risk for aquaculture at a global level, and this has had serious consequences for the industry. The most blunt example in this regard, occurred in 2017 with the prohibition of non-native fish farming in the state of Washington, United States, after the escape of about 250,000 Atlantic salmon from a Cooke Aquaculture center. In Chile, regulation has been controversial, generating tensions between different actors, and is far from generating the necessary trust to articulate a sustainable relationship between the industry, the state and the territory.
Escapes have emerged as one of the top three environmental impacts, along with seabed contamination, water eutrophication and mass mortalities.
Despite its importance, the Environmental Regulation for Aquaculture (RAMA) only incorporated indications on escapes in 2007 (in the context of the ISA virus) and the penalty for environmental damage, in case of not recapturing 10%, in the reform of the General Law on Fisheries and Aquaculture in 2010. In view of the urgency of the industry to recapture fish to avoid penalties, it has sought to generate links with artisanal fisheries to comply with the regulations, which has generated tensions. For this reason, at the beginning of 2018, a motion for a law was presented in Congress that addresses the participation of third parties in the recapture, particularly artisanal fishermen. This blind spot draws attention and leads us to reflect on the capacity of existing regulations and institutionality to systematically address the environmental effects of an industry based on natural resources.
En esta columna, planteamos que el presente escape no debe ser revisado como un hecho puntual, sino que dentro de la larga experiencia de escapes que registra la industria en Chile, y sobre todo respecto a la capacidad regulatoria del Estado frente a una industria que ha demostrado recurrentemente su incapacidad de autorregularse
A LONG HISTORY OF ESCAPES
Since the introduction of the exotic salmonid species to Chile, there has been a constant concern to identify and assess the effects of the industry on national ecosystems. Escapes have become one of the three main environmental impacts (together with seabed contamination, water eutrophication and mass mortalities).
These three types of impacts have been at the center of the social conflict associated with the industry (along with union mobilizations). As TERRAM detailed in 2001, the environmental costs of the salmon industry are high, and its ecological footprint requires an institutional and regulatory framework based on objective, traceable and public scientific information, which for various reasons has not occurred.
The fattening stage of salmon farming takes place in an open ecosystem where companies cannot control the entire production process. In other words, companies face moments of uncertainty related to the impacts of environmental conditions on the production cycle and the resulting harvest. This phenomenon, which we have characterized in our research as ecological contradictions of the industry (Bustos & Irarrazaval, 2017, Irarrazaval & Bustos, 2020), implies that salmon production will continue to face events, such as, viruses, algal blooms, or extreme weather events, that will alter the production process and cause consequences in the marine ecosystem in the long term. In this regard, the recent massive escape of fish is evidence of the cyclicality of these phenomena in the salmon production process.
The Chilean salmon farming industry has reported numerous fish escapes. Taking as a reference the report of the Library of the National Congress of May 2019, Sernapesca reported that between 2010 and 2018 there were 87 events, averaging almost 10 per year. According to the data presented, it can be estimated that, between 2010 and 2017, there was an annual average of escapes, close to 410,000 species, which is consistent with figures reported in other works (Niklitschek et al., 2013; Sepúlveda et al., 2013). Generally speaking, the concerns of escapes are related to the feralization of hatchery fish, with their potential predation of native masses, the transmission of pathogens to wild species, and the potential expulsion of endemic native species from their ecosystems, among others (see Glover et al., 2017).
The main causes of salmonid escapes are related to extreme weather events. To contain such escapes, companies must comply with a series of obligations regarding the infrastructure of the centers, which must be reviewed by Sernapesca with a defined periodicity. This generates a scenario in which the scientific information available to the supervisory body plays a central role in order to account for the conditions in which the escape occurred and its magnitude, to evaluate the recapture of the species and, above all, to estimate the environmental damage caused. However, the absence or opacity of the available information has been an arena for disputes between the industry and the State, lengthening the procedures and generating strong distrust towards the industry. This should be understood on the basis that the main institutional reform of the aquaculture sector focused on providing sanitary guarantees to the industry, in the context of diseases affecting production, and only marginally included the strengthening of environmental care (Irarrázaval and Bustos-Gallardo, 2020).
Despite the reforms to the environmental regulations, there has been no major deepening in terms of escapes and the aquaculture institutional framework does not manage to generate guarantees or trust in environmental matters. The escape of the MOWI center in 2018 reflects this point.
MOWI'S ESCAPE
Within the long list of episodes of salmonid escapes, the one that has most marked the recent agenda was the one that occurred at the MOWI center (formerly called Marine Harvest) in Isla Huar, Calbuco commune, in June 2018. The story was similar to what happened in Blumar: a storm damaged the structures and about 690,000 fish escaped. This episode gave rise to a series of controversies between the industry and the State. The first of these was over the number of salmon recaptured after the escape, which should amount to 10% of the total number of fish escaped according to the regulations. While the Marine Harvest report documented 187,000 salmon recaptured, Sernapesca counted 38,209. The difference in the figures was not minor, since non-compliance in the catch percentage defines the environmental damage.
The Environmental Superintendency (SMA) maintained its firm position and issued harsh sanctions against the company for not having appropriate safety conditions at the cultivation center, which was classified on October 31 of the same year as a very serious offense due to the environmental damage that cannot be repaired.
As TERRAM detailed in 2001, the environmental costs of the salmon industry are high, and its ecological footprint requires an institutional and regulatory framework based on objective, traceable and public scientific information, which for various reasons has not occurred.
What appeared to be a categorical stance by the SMA resulted in a slow sanctioning process, which was suspended in June 2019 due to Marine Harvest's (now MOWI) disclaimers regarding the meteorological information. To date, the procedure continues to be paused, but MOWI has submitted several reports. In the last one, dated May 15, 2020, it refutes the SMA's assertion regarding the safety conditions of the center, and is particularly forceful in pointing out that Sernapesca "faked" the recapture process, questioning that this escape has caused effects on the environment. In this sense, MOWI points out that the difference in the number of fish rescued is due to the fact that Sernapesca did not consider the headless and/or eviscerated fish, and in its actions the authority was contradictory at the time of establishing the criteria for the fish.
The set of reports presented by MOWI opened the way to a second controversy. MOWI asserts that the SMA's charges of environmental degradation as a consequence of salmon escapement and less than 10% catch are theoretical and have not been demonstrated. More specifically, MOWI argues that farmed Atlantic salmon have a low capacity to adapt to wild conditions and therefore would have little impact on the ecosystem. Although the SMA has not formally responded to this approach, the Instituto de Fomento Pesquero (IFOP) published a report in which it defends the existence of environmental damage caused by salmon escapes in the short, medium and long term, and refers specifically to the case of the MOWI facility.
These controversies, in which the world's largest salmon producer has made its differences with the Chilean aquaculture institutions known, show that the sanitary regulation on escapes is not properly oiled to deal with critical escape events, and that after two years it has still not been able to sanction the event. Faced with the eventual impact that climate change will have on the frequency of critical meteorological events, in parallel to an industry that continues to project an increase in production, a worrisome scenario is configured. For this reason, it is essential to review the institutional framework surrounding the salmon industry.
AN INDUSTRY WITH MANY DOUBTS
The salmon industry synthesizes many of the contradictions contained in the Chilean economic model. Its successful global insertion and high level of competitiveness is based on processes of environmental degradation and territorial inequality, which have increasingly exploded in social conflicts such as those that occurred in May 2016 in Chiloé or the ISA virus crisis in 2008.
Each of them has forced the industry and the institutional framework to define new rules of the game in terms of regulatory modifications that are reactive rather than proactive. The industry is increasingly aware of the importance of a good environmental and social presentation card in global markets, and has initiated efforts to move in this direction, participating in the Global Salmon Initiative (GSI). (GSI), the ASC, certification system, and, more recently, has shown interest in implementing circular economy models. circular economy.
On the one hand, these initiatives are relevant for the insertion of the industry in the current social and political context of the country, since the social outbreak and, on the other hand, to recover the declining value of Chilean salmon in the foreign market due to its reputation (Irarrázaval and Bustos, 2019). For this reason, the measures taken regarding salmon escapes will mark the seal that both the State and the industry want to give to this path.
In a column in 2016, we argued that based on the territorial disarticulation of the industry lay a deep distrust of the community towards the industry and the State, learned from actions and omissions of both actors in their roles as promoters of local development, oversight and dignified treatment. The escapes and massive mortalities experienced by the industry in recent years, as well as the scandals of alteration of information in the reports of mortalities, reinforce this blindness of both the State and the industry to understand the problem from the perspective of local actors, who demand transparency and traceability of information.
In this sense, a policy that considers the perspective of the communities and is in dialogue with territorial planning instruments is fundamental, for which measures related to timely access to information are essential, as well as promoting the legitimacy of decision-making mechanisms.
The availability of timely information must be both formal and substantive (e.g., an easily accessible, public, independent and standardized registry system). In addition, it is essential to have up-to-date information for anticipating climate events, which is of central importance for making timely decisions during events such as releases, in which the speed of the decision can make the difference between containment or environmental disaster. This implies that both the spaces and the actors making the decisions must be known in advance, and must include the participation of representatives of the local and scientific community, considering mechanisms to compensate for the asymmetry in access and understanding of the information related to the effects of the decisions on ecosystems and affected communities.
In this sense, the availability of scientific information and human capital to establish the environmental and social effects of the industry should be the cornerstone of future regulation. For this reason, an achievable goal for the legislator and the industry should focus on generating planning systems, especially in terms of the aquaculture life cycle, based on the precautionary principle and clarity in legal responsibilities. This should be a consensus of all industry players, who have already shown signs of promoting an aquaculture policy based on sustainability, which now needs to be put into practice.