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On March 4, 2014, ‘Namgis wrote to Transport Canada, copying DFO, in
regard to aquaculture, citing concerns and seeking accommodations. On March
31, 2014, the day before the 60 day consultation period was to end, ‘Namgis
provided a 15-page response to the five proposed fish farm aquaculture licence
amendments. It stated its concerns, including individual and cumulative effects of
the proposed production increases and restated its previously voiced concerns as
to the potential transmission of parasites and diseases to wild salmon and the
potential for a concentration of infectious diseases. The letter, for the first time,
also raised ‘Namgis’ concern with a lack of methodical, independent disease
testing of farmed salmon with the object of understanding actual and potential
impacts on wild salmon, related to disease transmission, referencing the Cohen
Commission recommendations and an anticipated study by the SSHI. ‘Namgis
sought to be advised on the status of the latter;
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In its response, DFO stated that it was undertaking a comprehensive
review of the five aquaculture licence amendment applications – including
potential fish health considerations – and that, in addition to consultation with
‘Namgis and other First Nations, the results of the reviews would inform the
decision regarding amendments. DFO stated that it remained committed to
meaningful consultation with ‘Namgis, noting its prior offers to meet to discuss
aquaculture related issues and that it remained open to doing so. DFO also stated
that it had reviewed the scientific information available for the Broughton
Archipelago area and considered many of the issues and concerns raised related to
aquaculture. It attached a document containing an overview of the science advice
informing DFO’s management approach as well as consideration of specific
impacts including disease transfer. The attached document mentioned PRV,
stating that there were no indications that PRV was associated with or causative
of HSMI on the west coast of North America, but that as the role PRV plays in
aquatic ecosystem was not well understood, DFO scientists and others were
conducting investigations to better understand the biology of PRV in wild and
farmed salmon. A copy of the December 2013 Integrated Management of
Aquaculture Plan for Marine Finfish (MF-IMAP) was also provided, which was
described as setting out DFO’s current management priorities for aquaculture in
the Pacific Region. DFO also provided a status report on the SSHI study and
offered to meet to provide an overview of this information and answer any
questions ‘Namgis may have had. DFO restated its view that the existing
aquaculture sites posed a low risk to the local fisheries resources and
consequently a low risk on the ability of ‘Namgis to exercise its asserted rights;
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On July 24, DFO advised ‘Namgis that, further to DFO’s ongoing
consultations regarding aquaculture licence applications, DFO had completed a
preliminary environmental and fish health assessment, which it attached. DFO
advised that it was willing to meet to discuss any aspect of this, or aquaculture in
‘Namgis’ claimed territory. On October 28, 2014, DFO advised ‘Namgis that 21
finfish aquaculture licences in the Broughton Archipelago were coming up for
annual renewal. ‘Namgis responded, again indicating its concerns with the prior
consultations, and that there had been no mitigation or accommodation despite the