Cermaq’s contribution to Norwegian Ministry of Industry and Fisheries on growth criteria for salmon farming

The following is a response from Cermaq regarding the Norwegian Parliament's notification about growth in Norwegian salmon and trout farming. Cermaq supports the authorities' desire to facilitate predictable growth in the aquaculture industry, ensuring that growth strengthens the industry's competitiveness while maintaining environmentally sustainable parameters. The aquaculture industry has grown into a significant sector for the country's export earnings and for settlement and employment along the coast, with potential for further increased importance as the oil industry will eventually have to be reduced. It is crucial to establish a robust framework for growth in the industry without compromising national environmental values such as wild salmon. Cermaq agrees that the regulations should not cater to market considerations. This should be the responsibility of the industry and individual actors. Cermaq aligns with key points in FHL's consultation response and would like to highlight the following main points: A parliamentary report on the seafood industry must also include access to areas, market access/trade policy, and organization of management to ensure that regulations and sector authorities contribute to an optimal further development of the industry. Aquaculture, including Norwegian salmon and trout production, is area-, energy- and feed-efficient food production that will become increasingly important in a global climate and environmental context. Production areas as outlined in the consultation document are not a good alternative. It is fundamental for a robust framework that each actor is held accountable for their own results, not for others' results. Growth should be linked to rules of action that apply to each actor and measured at the locality level. The growth rate should be predictable and initially implemented as an increase in MTB. A quantification of specific lice levels does not belong in a parliamentary report. Cermaq would also like to emphasize the following: Only one administrative level. A new, additional administrative level should not be introduced. Any new regional/zone structure will have to take over the management and administration that lies in the current zones, so that there remains one management level. Three production regions. Norway should be divided into three production regions, where the borders at Hustadvika and Bodø are not based on voluntariness. To protect us from the spread of both known and unknown biological challenges, it should not be allowed to move seawater-exposed fish across these borders. Reasonable transition arrangements must be admitted so that the actors have time to build the necessary capacity in the regions. Production areas/zones require investigation. For Cermaq, it is impossible to take a position on the proposal for production zones or areas based on the general basis in the consultation document. Before such a radical restructuring is possibly presented, a thorough impact assessment should be carried out based on different solution proposals. Among other things, it will be crucial how large the zones are, how to ensure a perceived fairness where one actor's growth depends on the neighbor's results, the specific criteria in the rule of action, possible area access, access to moving production, follow-up at the concession or locality level, etc. It is crucial that also active farmers are involved in such an investigation of different solutions, so that both current and possibly new challenges are taken into account. Such an impact assessment will, in our opinion, also be a necessary prerequisite for a proper political treatment in the Parliament. Further requirements for individual actors to be able to increase production. In addition to the rule of action related to salmon lice, Cermaq believes that further requirements should be imposed on the actors who are to increase their MTB: The fish must in the future be traceable so that any escaped fish can unequivocally be traced back to the individual farmer. Satisfactory documentation of escape history. There is currently the possibility to trace the fish based on its DNA with sufficient certainty so that the tracking can be used as a basis in any legal follow-up. It should be required that actors who are to qualify for growth commit to having implemented a type of secure tracking on all releases by e.g. 2018 to be able to increase the production volume. Cermaq is of the opinion that historical results for escape should be one of the criteria for companies that are to be able to increase their MTB. Escape is always strongly unwanted, and is often due to human error, technical error, bad weather or sometimes situations that no one could have predicted or prevented. Good operation and good equipment reduce the risk, and Cermaq believes that a requirement for escape should be set that sends a clear signal that escape is not compatible with increased production. We are happy to provide further background information if desired. Best regards, Cermaq Group AS Cermaq Norway AS Jon Hindar Geir Molvik CEO Managing Director.