Look Before You Leap

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The Precautionary Principle in Salmon Farming

What is the Precautionary Principle?

The 'Precautionary Principle' is a risk management strategy applied in the face of uncertainty. We already use this in many aspects of our daily lives no matter what we call it: "An ounce of prevention is worth a pound of cure" or "Look before you leap". And consider the Sorcerer's Apprentice in Disney's Fantasia, where the danger of messing with what we do not understand was so graphically illustrated by the mops multiplying out of control. 

Risk management may sound like boring corporate jargon, but most often it is actually just common sense: the less you know about something, it is prudent to proceed more cautiously. And the less room there is for trial and error learning, the smarter it is to proceed more slowly. In general, the precautionary principle is defined as something along the lines of: "When an activity raises threats of harm to human health or the environment, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically. In this context the proponent of an activity, rather than the public, should bear the burden of proof" [1]. 

Three fundamental components of the precautionary principle are that it is pro-active, that is, it aims to prevent rather than fix crises; it is designed for uncertainty, rather than the old less-safe approach of "wait and see if something goes wrong"; and it reverses the burden of proof onto the person wanting to undertake a potentially harmful activity to prove that it is safe, rather than the previously more common approach of charging ahead with an activity and requiring those who are harmed to subsequently prove the harm. One famous example of the non-precautionary approach was portrayed in the film Erin Brockovich, starring Julia Roberts. 


Macquarie Harbour and the Precautionary Principle

The ecological calamity at Macquarie Harbour could have been prevented with the precautionary approach. Many experts flagged potential problems, and even when problems arose, still government and industry charged ahead [2]. It is a textbook example of what can go wrong when arrogance reigns over common sense [3]. When your product depends on a healthy environment, you must look after that environment. Or else your product dies... and indeed it did. 

Macquarie Harbour is a natural inlet along Tasmania's west coast. It is around six times the size of Sydney Harbour. But despite its enormous proportions, it has numerous properties that make it one of the worst conceivable places to industrially farm fish. It has a sill (raised seabottom) at the entrance, which means that it keeps water in and foul water flushes away slowly. It is shallow, which means there's nowhere to get away from poor water quality. And it has a frightening history of heavy metal dumping from decades of mining. Adding more fish poo than the system could process was bound to make it collapse. And indeed it did. 

Prior to 2012, salmon production was on a small scale, up to some 8,000 tonnes. In 2012, incredulously, a production increase of more than triple was approved, up to 29,500 tonnes [4, 5]. Foreseeably, the water quality quickly deteriorated, leading to fish kills and legal battles, reaching a crescendo when more than 1.3 million fish died within six months [6]. The impact on native species was likely even worse. However, most of the native species, as one might imagine, were not even counted. But one, the Maugean Skate, found nowhere else in the world, was driven to the brink of extinction [7]. There's a strong chance it will never recover. Research on it seems to have mysteriously ended, so we don't even know... 


All Bets are Off

Among the biggest current challenges with industry/ecosystem interactions is that things are rapidly changing and extremes are becoming more extreme. Businesses were built on the premise that the past is prologue to the future, and that by understanding how nature has behaved in the past, we could fairly accurately predict future conditions. Inputs and outputs could be planned for. But nowadays all bets are off. The ecological stability of yesteryear is a thing of the past [8].

For the Tasmanian salmon industry, this phenomenon, which may be thought of as shifting instability, is highly relevant. One way to think of it is as if you had a broken leg and were a bit wobbly on crutches, and the ground under your feet was wobbling too, all the while on a moving conveyor belt. The only thing the salmon industry can rely on now is that things will almost inevitably get worse. The climate will warm, and with it, the jellyfish and algae that respond to warming, and the amoebic gill disease, will worsen too. And other pests, like salmon lice, which aren't a problem here yet, likely will become a huge challenge, as they already are overseas. And as the water warms, it will hold less dissolved oxygen, which will make it increasingly difficult for fish to obtain enough oxygen to survive and grow. And all the excrement and uneaten food, which accumulate on the seabed in vast blankets of ooze, will change the sediment chemistry, promoting repeated dead zones, threatening the fish and native species. And the seals, looking for food, will become more aggressive. And the jellyfish will become more numerous and more stingy and more suffocating, because that's just what jellyfish do [9]. 

In the current climate of change, it means that all the technological and efficiency improvements in the world won't fix the biggest threat of all. If the environment tanks, it takes the industry with it. The planned doubling of the industry this decade will need to either stock more fish per pen, or install more pens per lease, or add more leases, and all of these will strongly threaten an already stressed ecosystem. Fish are already dying of oxygen depletion. Costs are already high due to Amoebic Gill Disease and jellyfishDead zones are already smothering native species. It doesn't take a rocket scientist to wonder whether this could go badly. And indeed it will. 


Defining the problem

In our view, the biggest challenge the Tasmanian salmon industry faces is not technological in nature. It is philosophical. A brilliant talk a few years back outlined climate change as an issue of three opposing strategies [10], and we think it provides a good analogy. Firstly, the hierarchical strategy, where scientists and bureacracies tend to see things as a puzzle: you break a problem down into pieces and solve them. In this strategy, nature and the economy can be controlled through good governance; the problem is seen as lack of planning, and the heroes of the story are the scientists, NGOs and enlightened politicians working for the greater good, and the villains are the complacent bureacrats. Secondly, the competitive strategy, where industry tends to believe that their expertise can control resources and responses. In this view, the economy is believed to be fragile and nature is resilient; the problem is seen as insufficient skepticism about the science; the heroes of the story are the technological innovators and venture capitalists who have the vision and guts to solve big problems, and the villains are the panic-prone environmentalists. And thirdly, the egalitarian strategy, which holds that 'better' solutions come about when more stakeholders are brought in to the discussions. In this strategy, nature is seen as fragile and the economy as resilient, the problem is behavioural, the heroes are the activists and offended community, and the villains are the greedy corporations.

The above strategies are all rational approaches, but conflicting. Especially when, as we see in the Tasmanian context, the stakes are high, the uncertainty is high, wrong decisions are being made with public resources squandered, and public trust is broken. The proponents of each strategy disagree on what the questions are and which strategy will best get us where we all want to be, which is where the damn thing is humming along problem-free and we can all just get on with things.

Each of the above strategies is only a partial vision, one corner of a triangle, or one leg of a sturdy three-legged stool, if you will. Neither is entirely right nor entirely wrong. Each strategy may seem an anathema to proponents of the others, but legitimacy and public trust will benefit from the plural partnership of all three in the decision-making process; they all have something beneficial to bring to the table. 

It seems evident that multiple things have faltered in the Tasmanian salmon conflict: the regulator has abdicated responsibility to the industry, the scientists have been largely constrained by the parameters of funding, the industry has progressed too boldly and without caution, even in the face of mounting threats, and the NGOs and activists have been largely relegated to the fringe. Bringing these moving parts back into proper alignment won't be easy. And that's the social part that has nothing to do with managing the declining health of the environment on which healthy food depends. 

The salmon industry as it currently stands and the regulatory framework within which it operates are largely a patchwork that evolved over time. Nobody designed it to be this way. The Marine Farming Planning Act was created in 1995 when the industry was still embryonic compared to today, and the other instruments that control operations were grandfathered in. The unlimited water use arrangements and lack of pollution control for the inland hatcheries are but two good examples. Nobody would have ever agreed to the current framework: there was no master plan that fairly included all stakeholders and it still lacks the legitimacy of checks and balances. We assert that shifting direction to one that is truly sustainable is far more urgent and important than haggling over stocking ratios. Bold and modest growth targets alike are for nought and for nothing if the direction isn't sustainable. The precautionary principle offers a robust framework here. 

The environment and social license are both careening toward collapse. Both are imperative for the long-term viability of the salmon industry. The industry and regulator have some hard choices to make. Pretend like things will be fine and lose valuable time to forestall calamity. Or start building resilience into the system now. Which would you choose? 



[Click here to go to Precautionary Principle References]