Gothenburg University Aquaculture Centre West – Subject Aquaculture – 25 Questions and Answers

Gothenburg University Aquaculture Centre West – Subject Aquaculture – 25 Questions and Answers

Gothenburg University Aquaculture Centre West have produced a survey on Aquaculture which Brightwater Fish are using to support their application for an Open Net Fish Farm in The Great Lake – Jamtland County


We have contacted the University professors responsible for this report as it clearly contained errors and misconceptions.  They were very helpful and interested in my views and knowledge inviting me to respond to their report in writing.  What follows is my assessment of the true situation which I have passed on to them and await their comments.

 25 Questions and Answers

The danger of allowing ‘open net’ fish farming to continue

These following observations are not written against or biased to either party (Commercial open net operators or Government Authorities). They are the reality of what happens, taken over a 7 year, 24 hour a day study. Neither party stated has ever observed the effects of open net fish farming in that time frame span.

Question One – ‘What is Aquaculture’

Scientific studies and reports have been ignored since the 80’s that has led this absurd unsustainable polluting commercial business with vast profit making (hence its rapid growth) to the point where it has over exploited and plundered the fish stocks of the Oceans. The word ‘Aquaculture’ and its initial idea of preserving the Oceans fish stocks in the 50’s has been taken and misused by Commerce. This has been completely ignored by the Government. This in itself is ‘self proof’ of the power and control and force, Commerce and Industry have over Governments. Worse still has benefitted Governments ‘exchange trading agreements’ of farmed fish produced.

Well all that is History!

No it is not…because History is being allowed to repeat itself with nothing learnt. Allowing open net Aquaculture to continue.

Now a new source of feed to keep its vast profit making growth machine spiral still further, by the plundering of a huge humanitarian social injustice for third World trading in depleting fish ‘trash stocks’ and land mass that in itself is becoming depleted for food supplies to mankind. Aquaculture feed for ‘open nets fish farming’ is now competing irresponsibly for these feed sources, driving prices higher thereby taking foodstuffs from Third World Countries that cannot compete.  So Aquaculture continues to be irresponsible and unsustainable.

Your report with its well founded facts based on scientific studies and reports, nonetheless is flawed and proven as injustice to Third World exploitation of its continued trash fish food reliance and land mass for its crops. For what! Simply to lower the price of luxury fish further…for the wealthy populations and nations in the most continued unsustainable way.

Open Net fish farming has to be stopped and if any fish farming is to continue, it has to be on land with enclosed tanks with local feed input source and local fish output demand.

Thereby no Environmental/ Habitat damage, no disease, no sludge deposits of P and N and heavy metals with other synthetic chemicals, then the words Responsible and Sustainable can be used in their true context.

Your picture of ‘open nets’ covered in gulls is proof itself of the pollution the open nets cause. They prey on fats, oils, fish faeces and dead fish that float to the surface. Onshore enclosed tanks do not attract gulls. Gulls which spread disease or Crows, Ravens, Cormorants, and other diving birds which suffer casualties in the nets.

All statistics stated in your subheading ‘The Total’, are fiction. The very business of ‘Open Net’ fish farming in Sweden is out of control.

Question Two ‘ What and where grown in Sweden’

Your answer confirms my previous explanation of Government trading with open net farmed fish, its irresponsibility in World resources. Certainly not sustainable.

In using statistics on percentages of open net farmed fish production, is no excuse to feel you have to be responsible in destroying and polluting any more of Sweden.

This is Sweden’s greatest opportunity to Stop existing open net practises, issue all licences as onshore enclosed tank fish farms only. Then Sweden will be looked up to rather than an open ended resource to destroy. Now that Finland and Norway have limited any more fish farms – largely because of the environmental destruction Sweden can be a world leader not one that fails to learn from the mistakes of others.

The Tourism and Angling figures and subsequent employment and money expenditures into the Swedish economy far out way any argument open net fish farming will bring. In fact it has already ‘sown the seed’ which is beginning to destroy existing Leisure, Tourism and Angling Industry.

The well known Worlds depletion of fresh water resources are a further concern to protect rather than lay open to disease and pollution and poor water quality with toxic sludge and plunder one of Swedens most valuable assets for the future, Tourism angling and Nature unharmed by Human greed. Your answers to these questions are severely damaging to the future of Swedens waterways. ‘You don’t know what you’ve got till it’s gone’ is typical of your report supporting commercial exploitation to the suffering of Swedens economy for the present and the future.

Question Three ‘Why should we concern ourselves with Aquaculture’

Your subheading ‘Because fish’ is correct, but that is not what Aquaculture is. That is a comment about sea fish and shellfish, it is irrelevant in its statement. You continue ‘sustainable aquaculture’ yet you are promoting ‘open net’ fish Aquaculture which is a direct contradiction. Until you state onshore enclosed tank fish farming, your statement is not local produced nor sustainable, nor healthy.

Oily fish are not the only main source of Omega 3 in fact the fish in open nets do not produce any omega 3, it is induced by the feed input. The flesh from farmed fish is nothing compared to wild fish. Farmed fish are unhealthy, the grey flesh is not natural or appetising to the consumer so synthetic colouring has to be added. It becomes a chemical fish which the long term effects on human health are as yet unknown except the obvious allergies to synthetic chemicals, 26% of children in Sweden suffer from. The fish simply become what they eat and we become the same as we eat them, unhealthy.

As the feeds for fish farming are consumed in far greater quantity ratios to the fish volume/tonnage output, (and now the oils are coming from land resources) it is common sense to eat the plants and seeds, cut out all the additional burden on the Worlds resources in farmed fish pollution, manage the land in a sustainable manner for human consumption, not unsustainably as is for fodder feeds. Again your answer is irresponsible and biased towards open net fish farming. Misleading and not the ‘true’ facts.

Your sub heading : ‘The state investigation’ is fiction

Again nothing has been learnt, if this is where injustice becomes Law, then Sweden is rapidly set to self destruct. The investigation is simply flawed.  Again nothing has been researched into the effects of open net fish farming. All existing fish farms are flawed together with all the figures, reports and statistics. This leads to an apathy and ignorance and is a golden handshake to open net fish farming continuing in its vast profit making whilst ‘running circles’ around Government Policies.

Facts that the water sampling methods and results are biased and all the relevant government authorities are severely lacking funding, knowledge, awareness, facts on why the open net farms are sited away from any number of residents, facts that all reports on pollution and disease and degradation changes have somehow become mislaid or mysteriously ‘never existed’, facts that Environmental Courts have over ruled statements of degradation to the Environment despite proof by videos and ‘photos. Facts that no operational duty of care plans are in place and no prevention methods have been enforced. No bottom scientific studies have ever taken place before or after fish farms have operated in the Environment around them, before or during any operating permits. No scientific results on any lake surveys on wild fish types, sizes, volumes and local information gathered, nor any reports of ecological changes and degradation and disease reported have been notified and results filed. No pollution reports or disease or wild fish losses or water analysis high P and N results have been passed on to Lansstyrelsen in that Municipality. No communications between municipalities, Environmental Courts, Licensing, Environment Agency nor Agriculture Agency have ever existed between any department controlling open net fish farms. No knowledge of how many tons of fish are actually in the open nets, no interest on inspecting young fish stocks in, their source and condition. No knowledge of witnessing the slaughter of live fish or the volumes removed or where it is going or that the transport out drips blood along the roads. No knowledge whether the fish are GM stock, No Knowledge where the feed comes from at any one time or what is in the feed and where that is sourced from and its effects in polluting the lake water phases or to the lake bed. Refusal to ever take samples or ‘photos. Refusal to witness dead wild fish with skin disease and red eye and white fungus as seen in fish farm bags. The disinfection of transport in and out of fish farms does not happen, the runoff from the blood volumes into the lake water when slaughtering. No interest to call out of office hours to oversee slaughtering, fish movements, no knowledge that slaughter volumes are far beyond licensing requirements, no knowledge what type of fish are in the bags, nor any knowledge of the feed volume input that P and N calculations are based on. If any authority or member of the public has ever confronted the fish farm, they get threats of lawsuits against them or angry intimidating ‘phone conversations by the CEO of the company who overrides any correspondence with each fish farm manager.

Your statement of well founded facts based on scientific studies and reports.  Are far from well founded, further more they are misleading and extremely damaging with regard to allowing open net fish farming to continue. That is why the heading to number three question is indeed ‘why should we concern ourselves!’

All commercial fish farmers are fully aware of onshore enclosed tanks. They were thirty years ago. Some responsible fish farmers now operate onshore enclosed fish farms. But your 25 Q and A are not supporting these fish farmers, on the contrary, they cannot operate competitively or financially by allowing open net fish farming to continue, such as offering your unjustified evidence to support further Environmental destruction in the Great Lake of Sweden and other designated areas. You are destroying your Country by supporting the high profiteering  Commercial Fish Farmers.

Organisations such as Greenpeace, Sea Shepherd and now many others, would not exist if man had evolved without his greedy appetite for more profit with no due care and attention to the Environment or anybody in it.

Today despite the so called Green movement, recycling, Environmental awareness, Sustainability and Responsibility, Certified organisations and Associations, GM free, Organic products   are all twisted and misused to the benefit of powerful Commercial businesses and irresponsible overseeing Government officials.  In effect nothing has changed other than becoming far more wasteful than it ever was. Unawareness of the games they play under the thin veneer of smiles and coffee are easily found when you stand against the Environmental and social crimes they cause. Then you become aware!

Question Four ‘Why is there a need for cultivation of fish and shellfish?’

The words you have used…’should’ and the background’ are self explanatory.  However, to then state Aquaculture is a great addition to fishing is nothing but fiction in its context.

The need of sustainable food for local use Shell fishing has its place but only if it can be controlled and within the public interest. Something to date that has no founding.

The need for onshore enclosed tank fish is required might be acceptable as long as is sustainable and the feed source also sustainable – something I doubt.

Obviously the Bohuslan coast using existing local fisherman in shell fishing are best suited to any development in their local area, those I have spoken to look to the future with concern and want to preserve their area with the habitat and tourism. It is their lively hood. But that does not open the door for ‘open net’ fish farming. Many shellfish areas have been wiped out where this has been allowed in other Countries.

Question Five  ‘Is it easier to raise fish in the Sea than Fresh Water’?

Neither should be raised in open nets in sea or fresh water this has been proven to be Irresponsible and Unsustainable – whatever the circumstances.

Question Six ‘Which fish species can be grown in Sweden’?

This should state no species if in open farms as they are now banned! Onshore cultivation can have a variety of species depending on public survey in different areas of Sweden as to what to grow sustainably for the local market demands. The statement on faster growth is not founded regarding food health and quality. From 350 grms to maturity of 2.5 Kilos in 9 months we have recorded on open net fish farms in Sweden that versus wild healthy fish which if allowed to be sustainable in its fishing controls would take 3 years minimum in an ecologically sustained Ocean.

Question Seven ‘Besides fish what else can be grown’

Providing good repetitive veterinary checking for disease with analysis on toxins such as heavy metals, pathogens and pcb’s are vitally important when producing for consumption. As you quote ‘shellfish filter water of pollutants’, yes they ‘clean’ the water but at what cost to the person consuming the toxins retained by the shellfish, it simply does not go away. If the veterinary and fish sampling in open net fish farms we witness has anything to go by, the type, time and analysis results mean absolutely nothing if overall control is run by biased parties or the fish producers self regulate and dictate when and how the sampling and analysis are taken.

Your report comments on the relatively stagnant market of mussels since the 70’s year on year. It is clearly irrational thinking to operate open net fish farms producing pollutants into the water and then to hope some of those pollutants are taken up by installing mussel farms, when already we know of the stress put on resource to feed open net fish farms is against the need for more mussel farms.

Your sub heading ‘The positive’ is not sustainable in its entirety. You state the marine environment loaded by P and N from land discharges is no way the answer or reason to install shellfish farms. The P and N should be dealt with at source, not after it has polluted. Prevention better than cure. If Agricultural farming was also managed responsibly and sustainably. (Again history where biology and science appear to have ignored, ‘by your very comments’).

Question Eight ‘What are the biggest challenges when growing fish’?

With regard to open net fishing there are none until all the wild fish have interbred in this very short time span the genes weaken and unable to survive in the wild these species will die out.  The beautiful waters are polluted beyond sustaining any farmed fish open nets due to lack of oxygen through the mass of eutrophication and uncontrollable changing climatic conditions.  Solution: Remove all open net fish farms. The biggest challenge? Admit your past mistakes and draw a new Policy of only onshore enclosed tank fish farms with immediate effect.  The irresponsible irrational statement of helping poor nutrient rich lakes is not the answer. Again as I have stated the reasons for the poor nutrient and acidification of the waters are due to the Governments decision some 50 years ago to plant more Spruce forestry in Sweden than anything else. Nutrient depleted Waters are the result of water runoff into the lakes of unnatural monoculture type forests. We have undertaken a study, in an area of such forest over a seven year period to fell most Spruce and naturally allow deciduous roots and seeds to emerge that were starved of light over years. Result: from a 4.6 ph soil analysis to 7.4ph within 5 years and now with broadleaf of a mixed woodland forest the soil has already become nutrient rich. The small sample of forest has turned around for the whole ecosystem to arrive and survive. Eels are now spawning in the original oxygen depleted streams up from the lake nearby. The streams supply the lakes with nutrients rich in biodiversity. Oxygen plants and water lilies with reed are installing naturally where the stream enters the lake.

As for the wild fish stocks, well, they have been depleted by an open net fish farm nearby and year on year the plant life dies due to suffocation by algae from warm oxygen depleted water and edible oil fats that smother the leaf cells of the water plants. Ban that fish farm and all will be a heaven for anglers, tourists, canoeists to visit.

Question 9 ‘What does Aquaculture contribute to the local economy?

You have written fictional unfounded information completely misleading the public and Government authority on this answer.  To quote ‘strengthen the economy’ is untrue – it does exactly the opposite. Example: One such open net fish farm company already well established in another County promised employment of such proportions to get established in ‘open net’ fish farming. But oh dear! What a surprise once established they employ only two persons. Another such open net fish farm company that was well established in other areas, promised some 90 jobs that again once established, automated everything to employ two. So ‘to strengthen the local economy’ actually is not true (the jobs went to men outside that County who travel some 9 miles to work!) Rather than employ a local workforce of which there are many.

The detriment to these areas is also very important it has lowered property prices and tourists/anglers once seen do not return again, the knock on effect to spend their money in shops and so on results in a negative effect on the economy.

As for the farmed fish operators concern for the Environment and local people of Sweden, I will quote you a CEO response to my questioning (at a meeting held in another part of Sweden) where I spoke with a local group of people complaining of the detrimental effect on their Environment so witnessed by me at all times of the seasons.

My questions:

  • What do you think of the effect of the site of this open net fish farm in the Environment. Answer: It does not bother me, I don’t live here.
  • What do you have to say to the comment from local fishermen that wild fish stocks have depleted since your operations here. A: It does not bother me.
  • Why do you refuse to have divers take samples of the sludge beneath the nets. A: There is no sludge. The fish faeces do not exist in the way we feed them.
  • Why are you over producing beyond the licence by almost twice the amount. A: Prove it. Our reply. We have by counting the trucks out and the feed trucks in.
  • What do you say to the analysis of the fish. A. I don’t know that.
  • Are you concerned what you feed your fish and where it comes from and what it contains. A. I grow fish that’s all I’m interested in. If you don’t like it move elsewhere.
  • What do you say about the fats and oils on the surface that now prevent the locals swimming from ancient steps built for that purpose. A. I don’t care.
  • You have 13 nets for a700 ton license yet I have visited another of your fish farms with the same complaints from another action group against open net fish farming on their doorstep that has a license for 300 tons yet you have 16 nets there in production (that’s 3 more than here) of the same size and depth bags, the locals there have witnessed 54tons of fish per net being slaughtered equalling again over twice the production to the license. A. No comment. (With a raised voice).

I believe this again shows the methods of your report that growers have good practise on environmental issues are unfounded.

Question 10 ‘Is there an eco label for farmed fish’?

No, should be your answer here not Yes. ‘Open net’ fish farms can never be eco labelled. The feed input cannot be traceable due to the vast array of suppliers and Countries the feed originates from. I quote an example : A grower of cattle with an eco label sources feed from Germany of Eco labelled seeds all to FAO standards yet on his own concerns of selling his meat found after his analysis the feed input had a percentage of GM crops added. Good for his esteem in his dedication to an eco quality meat product. In open net fish farming,  however my communications with existing farmers are far from even caring. They just will do anything to get the label. The concern here is the MSC having appeared and established itself for good quality Eco labelling and sustainability (that word again!) You query the statement when organised by commercial open net fish farm operators!!

Nothing new, it happens in Forestry as well, making the whole process difficult to trace whether sustainable, responsible or not. It just all sounds good to satisfy those who are easily satisfied.

Traceability is the only way to ensure eco labelling and that demands a system that can be easily spot checked. Similar to waste ‘from cradle to grave’ used in waste reduction and correct disposal (Providing the enforcing authorities are trained in commercial enterprise tactics!).

Question 11 ‘Do farmed fish contain pollutants?

Pollutants in open net farmed fish are not regulated sufficiently in the feed input (similar to question 10). The fish output suffers from that same poor analysis on pollutant resulting in possible heavily polluted fish meat. When you consider farmed fish consume three times their own weight in feed of unknown origin (let us say the Baltic sea fish as it is local to Sweden) to produce one farmed fish, it is irresponsible to say No to question 11. Without the facts and correct controls that so far have been totally unmanaged in all forms of reporting and incidents, the responsible answer to protect the consumers concerns should be Yes. Hence the concerns on the Health authority issuing warnings of eating too salmon much similar to the Government health warnings on cigarettes after so many have died from smoking Aha maybe we should put a warning on the packet of farmed fish!

To add to the absurdity of this statement, the FAO state certain rules on health and safety in eating food types within the EU but Sweden gets an exemption from this WHY! And therefore in goes the fish into fish feed for open net farmed fish to fish operators that don’t care where their feed comes from.

The method used to clean fish oils from pcb’s and dioxins are again open to abuse. Similar to high temperature incineration of waste to rid of certain chemicals prior to scrubbing the incinerators exhaust, except that it cost money to operate in terms of fuel input. I visited as an unnotified inspection of one such plant I noted the temperature was running at 350C instead of 650C and the gasses are escaping with the very pcb’s that everyone thinks are being disposed of correctly! Worse still these are in the atmosphere settling around the plant and contaminating the ground water, farmland and animals and people that coexist breathing the air.

To eradicate this, the feed should be ‘cold call’ inspected and sampled and analysed. I have never ever come across this in Open Net fish farming. Incidentally the fish farm operator switches suppliers regularly to make this even harder to trace the whereabouts of its origin when found in any fish analysed.

These practical real life facts cancel out your response to question 11, you should therefore, state NO.

Question 12 ‘ Are wild fish healthier than farmed’?

I have answered this in previous questions. Your statement again is misleading and biased toward farmed fish. Dare to say Yes not No. It has been proven that wild fish contain omega 3 from wild foraging in the Oceans. Farmed fish get Omega 3 by eating 3 times the amount to make one fish or to eat 3 times the amount made up land and sea fish. The report does not state however, that the omega 3 fed to farmed fish has a 25% loss to the environment by the simple unnatural open net process of feeding these commercially grown fish. That is another human injustice in taking valuable omega 3 and wasting through growing fish than eating wild fish or the land based feeds of omega 3 direct. Flax has a slightly greater omega 3 than fish oil. I believe your statement is again incorrect when it comes to saying No to wild fish being healthier than farmed fish. Do not forget the huge transport costs, energy costs and water pollution costs to the Environmental destruction when it comes to healthier or not. This far outweighs the argument altogether.

Question 13 ‘ Is there much disease in Swedish farmed fish’?

Again you answer NO when it should be YES! The way in which fish farms are vetted for disease has been a massive open hole in the so called management, foresight and control of open net fish farm disease. That is an extreme concern to angling associations and fishery officers as many lake systems are connected through canal systems and rivers where nothing is in place to check disease spread to wild fish stocks or indeed to contain escaped fish from open net fish farms with disease. The simple fact of self reliance in reporting disease and the implication by so doing, do not register the reality in knowing exactly how many and how often fish farms have disease. Apart from the Kidney disease reported in mid Sweden and then the spread found to wild fish stocks there is also the present skin parasite reported slightly south of mid Sweden.  I have witnessed many fish farm diseases that have never been reported. By the time the fish are slaughtered and processed it is very difficult to have known the fish had a disease. For example the feeds can arrive with antibiotic to contain or cure the disease yet the wild fish stocks are never thought of but don’t forget those farmed fish are slaughtered with the antibiotic in them that we consume.  I have seen half the fish of one fish farm with white fungus disease, reported it with photos but no one of any controlling authority has taken the slightest interest. Then I have seen wild fish stocks with red eye and other diseases such as flesh break outs through the skin, slimy mucus on the skin all from an area of a fish farm in summer months of lake water of 23C and then algae forming and drifting into the lake shores.

No one has shown any interest in sampling photographing or even bothering to call when these events are reported, when asked why? They say we have no car available, we go home soon, there is no time available, it is the weekend, I can come Monday and Tuesday but no other day. The polluting has to be at certain time to get any interest or action, and yet when it is they say they are too busy to call – It is a sad state of affairs.  One thing is clear out of this however, you cannot say disease rarely affects open net farms in Sweden, it does.  This is the way the whole so called controlling system operates, it is completely useless and a total failure.

More reason and proof of complete closure of open net fish farms to prevent this diseased water polluting mess. To say a vet visits once a year is totally wrong they should visit twice ‘the same fish stock’. Example young fish introduced into the bags, one month later a vet inspects from a general call from Jordbruk, no other authority knows of this visit, Miljo, fisheries officer, licensing for example. The visit should not have been one month after the introduction (it is obvious the fish operator would not install diseased fish from the start. So the vet’s visit is a waste of resource and the so is the statistic, your statistics would say ‘disease free Sweden’ but the reality is if the vet called prior to slaughter or during say August then the real results would show otherwise – or don’t you want this to be known? Another inadequate incompetent organisation between controlling authorities. Another fact of false figures reported. It is not blaming individuals, it is the system that fails the individuals.

This proves question 13 is worthless in your NO for an answer.

Question 14 ‘Is farmed fish stressed’?

This is misrepresentation of the animal welfare law to the reality of what actually happens and is totally biased towards open net fish farming. The animal welfare act reads well –but it ends there. The resource, funding and efficient bodies to control this bill of rights however falls flat on its face.

Example: I estimate 2% are worthy of employing regarding the calling on animal welfare issues with the knowledge to see and identify if they are stressed or not.

To state the fish are not stressed is wrong.  With regards to the slaughter, it must be 10 times I have reported and filmed live fish lifted from a restricted net during the night and slaughtered live. I am told in Sweden they should be gassed, elsewhere they are stunned. Neither happens to these fish, why? Because nobody has ever bothered to call to witness the slaughter. This was over a period of 6 weeks. The fish are slit from gill to gill but remain alive, and although put on ice when the slaughter trucks leave, they drip blood along the road as they bleed to death they are not frozen on leaving the site and are still suffering.  Another example, the operators state they do not like moving the nets from the lake to the shore for slaughter or to the winter position closer to the shore, as it can stress the fish.  The same operator drags 13 nets 26 kilometers up a lake for slaughter in another municipality, so the locals cannot see the blood in the lake, the fatty deposits nor count the volumes slaughtered against the license volume in their own municipality.  It appears the fish operators had no care for the stress of the fish at this site.

Predators are another stress to the fish, when moving near the vicinity of the bags the fish become stressed, naturally they escape but of course the bags prevent this, you see them jumping out and hitting the bird nets above, because they are so stressed. Any angling boat approaching the bags of an open net fish farm stress the fish, they jump in a frenzy to escape the approaching vibrations and noise. The fish are often ‘split’ and put into more nets/bags when they are of a certain size, the nets are tightened a noisy crane scoops and dumps them into another bag, some escape into the lake but they are considerably stressed during this operation, it takes all day to process one net.  On the coastline seals are another predator, the farm operators shoot them but the seals have had their fish taken in vast numbers to feed open net fish farms, a reason why the seals are hungry enough to attack fish farms.

Wild fish need oxygen rich water in order to survive. Introduce an open net fish farm and this becomes severely depleted affecting wild fish stocks and plant life. Again the report is biased towards open net fish farming without the true facts studied on the welfare of farmed fish.  Farmed fish need moving clean water to survive and thrive – overstocked, stressed and swimming in their own faeces is not a life.

None of this I have stated is surprising when one considers the welfare of pig farming, well managed and controlled on land, so much easier to call and inspect – happy hogs, I don’t think so.  Yet we saw an appalling abuse of the welfare laws in 2009, someone had ‘blown the whistle’ on the horrific conditions pigs were being kept in with photos. Front pages on the newspapers and many, many farms were found to be in the same conditions. But there is the Animal Welfare Act – it cant happen but it did because no one polices the conditions these poor creatures endure.  There is NO excuse – it shows your report on animal welfare concerning open net farmed fish is again flawed.

Question 15 ‘Why is research important for Aquaculture’?

Obviously in all the findings over this lengthy 7 year period of 24 hrs a day shows the results of how research is important but then appears to get forgotten when the next day starts. The last fifty years have shown research results, but most have been totally ignored, as standing in the way of huge profits and restricting Government trading agreements with other Countries. If anybody takes the notice of this report I am writing, then maybe research would be put to better use to protect the future of this Planet for the next generations. Unfortunately the delicate balance of nature is being pushed and pushed with unknown consequences, how far it can be pushed and when it becomes irreversible science cannot say. What can be said is that science is certainly contributing to the demise of Sweden in encouraging the onslaught of further open net fish farming.

Question 16 ‘Are there areas for Aquaculture on the West Coast’?

Simple answer…NO. End of survey.

There are no areas for open net fish farming on any coasts or lakes of Sweden. Your answer stating ‘must be clean water, good oxygen and temperature’ explains what is not polluted soon will be’.

The local skilled workforce promised has never happened, in terms of ratios of existing employment over new jobs, there is actually less employment.

The planning of new facilities simply destroys the Environment and the work where at present people spend fortunes on vacation creating hundreds of seasonal jobs.

Sweden has many lakes so let’s destroy them seems to be the maxim. Who are the names in the County Admin Board, University’s Agricultural Board and Fisheries Board that back the destruction of the areas by allowing a plan that “must include areas for Open net aquaculture”. Their names need to be held accountable, or will it be another mess like the Environment Minister who gave permission for ‘open net’ fish farming on the high coast in a World Heritage area and the following year retired.

Sub heading : The survey

Public Funding and taxes should not have been wasted, there should be No survey for open net Aquaculture because its unnecessary, it doesn’t work – so don’t do it. It seems to be biased towards commercial fish farming, does not take into account action groups against fish farming.  It will become nothing but a social injustice for those living nearby the area and the findings are at the detriment to the Environment.

Your answer to Question 16 is fundamentally flawed. Protect the areas for future generations.

Question 17 ‘Can Aquaculture Grow without an expense to the Environment’?

Your answers to previous questions and this answer to Q17 are contradictory in its written content. It is utter nonsense and is nothing but abuse to the word sustainability, the impact will be an environmental disaster.  Your reasoning for the development of fishing is unfounded and further will destroy the Environment as we know it, it is too biased towards open net fish farming that has long passed its sell buy date.

Raw feeds will be unsustainable creating social injustice in depriving 3rd world Countries of vital food – It will not contribute to better conditions locally, nothing but the opposite.

Question 18 ‘Affects wild fish stocks’?

Your answer is again biased towards open net fish farming, in so far as stating ‘written for you by Commercial fish Farmers’, your written word is misleading in its very content.

Example: ‘can effect wild fish stocks’ should read ‘They do affect wild fish stocks’. ‘Escapes usually occur through wear and tear’, this again is misleading, they do occur through a multitude of mishandling in the very nature of open net fish farms. In introducing young fish stocks into the open nets, sabotage, predators, separating fish into other nets in the growing process and slaughter. All of these do happen with farmed fish escaping to the detriment of Wild fish. Carniverous fish eat other fish and salmon are fish eaters so they will destroy other breeds of smaller fish as well as infecting them with disease. Be honest and face reality, these questions are well founded but with biased, flawed, misleading answers to the reality of open net aquaculture.

Question 19 ‘Who gives permission to fish and who controls the operation’?

The sub heading ‘To raise fish’ reads extremely well, yet in reality is a total failure of any control. There are too many loopholes in the practical reality of ‘open net’ fish farming. There is in this instance too much put on self monitoring and self reports that are a minefield for any authority to manage. On land farming is far easier to control due to its very nature, open net fish farming is difficult to control and wide open to abuse. The very fact that we have discovered that written, telephoned or e-mail complaints on pollution have never been filed, never passed to other departments. ‘Open net’ aquaculture would have been stopped long ago if these reports had been properly logged and filed. Reports of our meetings, documents, videos and samples all ‘brushed under the carpet’ or filed in the bin, this constitutes sheer  environmental neglect and injustice to the people of Sweden in protecting Sweden.

Our experience on monitoring fish farms in Sweden is something to be discussed further. But to mention our experience, a person from authority having no knowledge how commercial powerful business operates, no knowledge about fish farming, would not know pollution if stood in it, is put in control.  If anything is reported it never passes through to the policy makers. When I have investigated every department blames each other, no one takes responsibility. Lansstyrelsen issues a licence, that is all they do then the Fisheries officer gets involved to issue a permit, normally 5 years. He has pressure from the fish farm wanting the permit ‘open’ ended, but the fisheries are over ridden by the Agricultural Board. They also give the vet orders when and where to test the fish.  Water testing is carried out by a third party but completely in the wrong place, unjustified sampling points therefore analysis results misrepresent the true facts of water pollution around the fish farm. Then the Miljo are somewhere amongst all this, with no resource or knowledge of open net fish farms pollution, complaints from the public used to be printed by the local press yet but our local newspaper has had so many they refuse to print any more, why? Nothing was ever done to resolve the complaints. We asked the County Miljo how many complaints do you receive? None they say,  yet the papers say over ten years we give up there are so many, and some locals had files 80cms thick of meetings phone calls, photos but NO they receive no complaints. Again your written report on monitoring and controlling open net fish farming is flawed. I agree with them all ‘they state we have not the knowledge, the experience, the resources, the funding to travel miles to a fish farm that is offshore out in a lake….then when they confront the owner or operator they get abuse and threats. I can understand the stress they are under. With the fact the fish farmers operate outside normal office working hours of 4.5 days a week, there is scope to run circles round the authorities and they do.

Growers are required to notify outbreaks of disease, this in our observation has never happened nor water sampling results of high readings past on. The Industry does not want the reality to be known or the detrimental effects on the Environment. However, when action groups report Worldwide their findings, it summons up the general state of affairs amongst Commercial Fish Farm Operators, their force on Governments.  They override Local authorities sitting with groups against fish farms. After all, the Industry has become extremely threatening and extremely powerful, its pressure on planning authorities (we have reports of this also) and other genuinely caring concerned people in authority that govern fish farms. It is no wonder the answers to these 25 questions are misleading.

Question 20   ‘Can fish be fed plant types rather than fish’?

Open net’ fish farming  has escaped ethical and biological consideration, throughout your answers in this report. You diverse to discuss other cultures not native, but native species are being fed with these diverse feeds as the Oceans have failed by over exploitation. So we now move into a new era destroying the land supplies while continuing to destroy the eco system of the lakes and Oceans to irreversible proportions to further destroy nature, dealing in unknown quantities when feeding carnivorous fish land based products, to the detriment of the fish and human health.

Question 21 ‘Can raw material fish be replaced’?

The industry has plundered the Oceans with no due care and consideration, the need for greed. For over 65years it has gone unchecked. Your answer to Q 21 states ‘ is now working towards sustainability’ is totally misrepresented in its fundamental statement. It should have and did have the opportunity 30 years ago but did not because of greed. Now they are on their knees pleading to continue in the cheapest way possible to plunder the Oceans and Environment further. ‘But we are working towards sustainability’ and your University is backing this type of commercialism despite its destructive methods. No genuine fishermen will be able to start in sustainable Aquaculture of enclosed onshore systems while open net farming exists. It is nothing short of unfair unjust accountability.

Your sub heading ‘Effects on fish health’ and welfare are fiction in its very essence. What about human health and welfare after eating this unsustainable product. Look at all the alternative feeds you are quoting, do you honestly think this is all for the taking. No, it is competing with Third World Countries if not our own for direct human food consumption, it is shear madness and will drive prices higher in competing for such.

Education on open net fish farming is lacking in all sense of the word. Simply you are grasping at articles to sound fantastic yet in reality are completely false. This is nothing but a whitewash allowing open net fish farms to expand in areas to the detriment of existing feed supplies. The end product will become simply cheaper, the market demand will increase and so on when all the time this type of unsustainable resource consuming product is not required. It is shear madness to continue this polluting idea of high in protein vegetable eating carnivorous fish that pollutes the seas and lakes and escapes to affect wild fish stocks already depleted. Messing with nature will have dire consequences.

As previously stated, 25% of oil proteins are wasted in growing the fish, it is far more realistic to consume this fish oil proteins or plant oil proteins direct and not waste such a valuable resource especially with increasing Worldwide demand, is nothing short of wasteful madness. The correct answer should read No it cannot be replaced by other feed products.

Question 22 ‘Why feed farmed fish with fish’?

Sub heading Fish farming reads as an effective way to produce food but this is utter fiction. This is completely unsustainable and starving the Worlds Oceans and humanity in its very idea. It simply has been used by Commercial business as a get rich quick, destroy three times the volume of good fish to grow a luxury fish for the few that can afford it but could afford other products and already were before it was made available. The Environmental pollution in its very process has gone unchecked and still is.

Demand for such fish is likely to grow as populations increase, bringing them under pressure both from aquaculture and direct consumption. In addition, low value fish (inappropriately termed “trash fish”) caught as by-catch and used for fishmeal production is actually an important food source for poorer people in developing countries. Use of “trash fish” in aquaculture inflates prices to such an extent that the rural poor can no longer afford to buy it. With these factors in mind, the UN Food and Agricultural Organization (FAO) has recommended that governments of major aquaculture producing countries prohibit the use of “trash fish” as feed for the culture of high value fish.

Although a trend has emerged in recent years of replacing fishmeal with plant-based proteins in aquaculture feeds, the fraction of fishmeal/oil used for diets of carnivorous species remains high. Moreover, this trend has not been fast enough to offset the growing use of fishmeal, caused simply by an increase in the overall number of farmed carnivorous fish produced. The quantity of wild fish required as feed to produce one unit of farmed salmon reduced by 25% between 1997 and 2001, but the total production of farmed salmon grew by 60.5%, eclipsing much of the improvement in conversion efficiencies.

Question  23 ‘Mussels to purify the sea’?

In your answers you are promoting open net aquaculture as environmentally safe yet you now quote having to use mussel farms that will guarantee to clean up the waste produced from fish farms.  So having absorbed such effluent laced with heavy metals and pcb’s and other toxins from its new food source the mussels are fed back to the fish, or for human consumption (even worse).

The answer should simply read no ‘open net’ fish farms no further mussel farms (you have already stated the stagnant market for these mussels so why increase risks in by creating more polluting fish farms, thereby growing  more polluted mussels for which there is no market. Unsustainable fish feed as an input and unethical polluted fish and shellfish as an output? Apart from the huge profits made in its process, this is nothing but an Environmental and Social Injustice.

Question 24 ‘Can aquaculture clean up its effluent discharge’?

With regard to open net aquaculture your answer should simply read NO.

Land based closed systems are the only way that aquaculture can effectively and safely clean up its effluent discharge.  There simply isn’t an organic organism that can effectively process the amount of faeces produced by an open net fish farm – in theory shellfish do purify the water but only a very small percentage of what passes closely and surrounds them. It a contradiction to reality of practical operations. There has been no environmental impact assessment undertaken within the last 10 years of existing open net fish farms, one of the most obvious subjects to analyse. When biology and science Universities disregard the obvious, it is of interest to see why the fish companies on several fish sites have refused to bottom dive, sample and analyse.

Question 25 ‘Aquaculture pollutes’?

Your first paragraph reports facts avoiding the technical pollution subject of the feeds and effluent contamination to the water phases. Both surface (by floating unnatural colourants fats and oils) the mid phase (soluble fats, oils and dirty effluent and ammonia). We have had samples shown to local newspapers that have remained soluble in the water phase for 4 years! Then the bottom phase which consists of heavy feed pellets (through the open nets) and consequent break down by absorption, festering on the bottom creating a build up of sludge and fish faeces that generates anaerobic gases (mainly hydrogen sulphide) to the Environment, often with consequences to the fish trapped in net bags above, further stress and disease. This pollution continues through the winter months after the bags are placed to a safer environment or for slaughter, but pollutes another area.

Your second paragraph I agree with other than it is not just an excess of nutrients. Considering a previous article from you stating open net aquaculture is good for the nutrient deficient lakes (I answered that previously and will not repeat here) we have seen eutrophication occur due to warm waters created by hot summers. The lake temperatures reaching 20C plus within one meter from the surface, together with very low rainfall, poisonous algae has formed around the fish farm and windblown towards the shore. This has been photographed and is becoming more and more common as weather patterns are changing. The input of nutrient problems are severe in open net fish farms. The Environment problems are not small where the water supply flow through is minimal in the lakes and seas of Sweden. Only surface winds affect surface water flow, or if the bottom is relatively shallow (30metres) the upwelling of bottom deposits to displace the surface windblown water occurs. This is all polluted and if correct water sampling is taken the results would be above restrictions imposed on the culture.

Sub heading ‘The supply of nutrients’ states it is much lower than twenty years ago but this is misleading. The ratio from reduced values in the feed has happened, yet because the increase in open net fish farming has multiplied out of all reason, the actual discharges are vast compared to twenty years ago. Your answer to Q.25 towards open net fish farming will have severe detrimental effects. This is no different to propaganda from Commercial open net fish farm operators stating ‘We are reducing the number of fish farms in Sweden’. Everyone claps their hands with immediate effect but they have doubled the volumes on all other existing fish farms, so out of 14 farms 2 have gone, they were small anyway (200tons) near civilisation and complaints. So 12 farms which had produced 350 tons doubled their licenses to 700 tons. All in Miljo offices think this is good to reduce two of the farms yet in reality the production the same year has increased by 4,200 tons!

My statement concerning the operational practises of authorities with lack of knowledge and the lack to correlate is a total sham. The emission checks are false in their making together with Admin Board and Environmental code are all over ridden by Jordbruk and Environmental Courts with complete disregard to any complaints, samples videos and signed letters of action groups about the operational controls lacking in real practise of fish farming businesses.  I have examples of all operations the authorities do not realise. Despite meetings with filmed imagery.

In conclusion it is criminal to allow open net fish farming to continue with the complete failure in the handing, control, sampling, documentation of open net farms. The long term implications affecting wild fish stocks with access to unnatural fish feeds could be extremely damaging with irreversible affects weakening the wild fish ecosystem of Swedish waterways. The long term human health implications are as yet unknown  consuming farmed fish which have eaten unnatural feedstuffs to produce unnaturally fast grown fatty fish.

Open net fish farming has grown with the same effects as intensive chicken and intensive pig farming. The long term effect on these products are unknown as short life, quick kill methods hide a multitude of genetic abnormalities. We consume them  and as previous tampering with feeds to animals have already shown (BSE) it can become an epidemic of vast proportions. Chickens and pigs are reared in contained environments within their growing farms. Open net fish farming is being allowed to operate directly in the nature. This could lead to water born disease to contaminate Sweden’s vast fresh water stocks apart from the irreversible devastation to wild fish stocks. The writing is already on the wall.

As a meeting could not take place despite my request, having been asked to write I have done so, the above is by no means exhaustive, it is a brief description of the facts of open net fish farming in Sweden. As previously stated the concerns of such observations and assessments are to highlight errors contained within written reports by four University Professors studying in Biology and Science and also to highlight misleading information provided by fish farm operators.

It is clear the way forward has arrived far too late but nonetheless with correct policies (BAT) enforced will open new opportunities for onshore enclosed sustainable feed input and sustainable fish output. This is the only way forward to provide local healthy fish for local demand. Sustainable does not mean transporting unsustainable feeds 100’s of miles switching from different suppliers, or transporting unsustainably produced fish to the other side of the Planet to countries that sell it back to Europe flooding the markets with a product that people do not want to buy.

Colin Shepheard

Solace – Save Our Lakes and Coastal Environment 

13 March 2016









































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