Who will pay the cost of salmon farm expansion in Chilean Patagonia?

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By Juan Carlos Cardenas
Translation by Micaela Ross
A day before the expiration of the moratorium on new applications for aquaculture concessions applications in the Los Lagos and Aysén regions, law 20.434 was published in the Diario Oficial of Chile, extending it for five more years. This will allow the government to move forward unimpeded with changes to the aquaculture sanitation regulations and implement the sui generis process of giving replacement concessions to those salmon farms that have acquired high health risk status, or are located in coastal areas that have been declared incompatible with aquaculture. (1)

Of the 1,235 concessions that have been given for industrial salmon and trout farming in the Los Lagos and Aysén regions, 280 (22%) present a risk of creating overcrowding and health and environmental issues. For this reason, it’s estimated that the industry would like to apply for  a “relocation," or compensatory relocation, of 41 percent of its concessions, equivalent to approximately 500 salmon concessions already authorized by the government. (2)
The changes to the intensive industrial aquaculture sector regulations are part of the joint administrative measures that the Ministry of Economy, the Subsecretariat of Fishing and Aquaculture (Subpesca), the National Fisheries Service, along with the Environmental Assessment System and the Environment and Defense ministries, are taking to modify the 2016 health regulations, which aims to reduce costs and increase the international competitiveness and strong transnational presence of this export industry.
The new regulation, extended up to April 8, 2020, suspends concession applications for aquaculture fisheries in the Aysén region, that to the date of publication of the law N° 20.583 of 2012 counted with a favorable environmental qualifications resolution and the requirement of the Subsecretariat of Fishing and Aquaculture for its entry into the Environmental Impact Evaluation System.
In turn, it limited the possibility of dividing and relocating the fractions of the concessions in the Aysén fjord (Aysén Region) or Chaitén (Los Lagos Region). This has caused a harsh response from Salmones Antarctica, a branch of the Japanese transnational company Nippon Suisan Kaisha Ltd. (Nissui), those that see in this government measure a change in the rules of the game, as well as a barrier of entry to the access of new areas and coastal concessions.
Evidenced by the current processes of concentration and transnationalization of the salmon business in Chile, Nissui planned to divide their five salmon farming concessions in Aysén totalling 311 hectares - accounting for half of the marine-coastal surface that it possesses- to later relocate through 50 requests for trading for new territory. It, according to the Japanese transnational, would limit less than a third of its authorized production of 9,6921 tons, only in the Aysén region. (3)
Also the new regulations, through prioritizing the relocation of 19 salmon farming concessions in the waters adjacent to the Alberto Agostini National Park, in the Magallanes and Chilean Antarctic region, gave a final solution to this unfortunate situation which was denounced in 2012 by the civic organizations, artisanal fishermen and regional parliaments, during the discussion of the new fishing and aquaculture law.
Finally, the legislation established deadlines for the companies to request the relocation of their aquaculture concessions, establishing an obligation to implement a plan to close salmon farming concessions that is to be abandoned as a result of this territorial exchange. In turn, the aquaculture concessions that are supposed to be relocated will lose their indefinite status, since they will only have a term of 25 years which may be renewed in time.
Salmon expansion and the destruction of natural banks of hydrobiological resources and fishing grounds
The exponential expansion of monoculture, industrial salmon famring on the open coast and interior waters of the Los Lagos region between 1990 and 2007, meant, among other environmental and social impacts, the massive destruction of valuable natural banks of molluscs, crustaceans and algae, as a product of the active processes of chemical and organic contamination.  
Anticipating that the change of intensive salmon farming sites toward new coastal areas and areas of greatest depth constitute a threat to the valuable merluza austral (Merluccius australis) fishing grounds and congrio dorado (Genypterus blacodes), the artisanal fishermen together with Senator Rabindranath Quinteros, in resistance to the idea of ¨immediate discussion,” which did not allow for informed participation of other productive and social sectors in the parliament debate, were able to put pressure on the Fishing and Aquaculture Commission of the senate that the companies must first obtain a technical report from the fisheries service, which states that in the new areas requested as part of the exchange of concessions, neither fishing grounds nor banks of natural hydrobiological resources currently exist.
Faced with this, the SalmónChile association through its president, the ex-subsecretary of fishing Felipe Sandoval (PDC), immediately warned the government (through Subpesca) that despite the new regulation, there would already be pre-existing agreements between the regulated system, that were linked with the artisanal fishing grounds in the Aysén and Magallanes regions, while in the Los Lagos region, already two comunas  “would have negotiated and resolved the issue with the artisanal fisheries” (4). Until the enactment of this regulation, the artisanal fishing fisheries didn’t have any legal protection, as evidenced by the pro-industry position that has prevailed during the last 25 years both in congress and in the fishing offices of the government. However, despite this step in the right direction, one can’t forget that the artisanal fisheries will continue to be unprotected in the Áreas Aptas para la Acuicultura (AAA) (Areas Suitable for Aquaculture) that existed prior to this new body of law.
Looking after the business of the financial sector and large companies
The legislative text, as per usual, was drafted primarily in order to take care of the interests of the financial sector and the small group of mega-companies that control most of the aquaculture concessions in Chile.
It indicates that the replacement of aquaculture concessions will remain subject to the same system as the original concession, and that only for the ministry of the law, the grave mortaging of the salmon industry’s concession would continue with which would replace it, keeping the date of constitution of the mortgages on their original concessions.
In turn, the holder of 2 or more aquaculture concessions will have the right to merge them, dividing them to merge one or more of his fractions to other concessions of the same ownership. Every one of the fractions that result from a division, may be subject to relocation, requiring the authorization of the mortgage giver.
At the same time, the legal body extended for five years the exemption of the increase of the patent for those concession holders intended for the cultivation of fish that request them to relocate, and that are located within the fringes of the mandatory distance between the macro zones established by Subpesca.
For the Magallanes and Chilean Antarctic region, special regulations are established for the operation of the salmon industry, since it may continue receiving new requests for authorizations. This will enable the delivery of a total of 200 concessions this year, which will support the process of seeking to triple the regional production that is destined for export, from 33.000 tons (2012) to more than 100.000 tons per year by 2016.
Photos ©Patagon JournalPhotos ©Patagon Journal
Right of access to information, hoarding the coastline, and subsidy of the Chilean taxpayers
The background of the exchange of salmon concessions of high health and commercial risk, is the historic delivery of direct and indirect subsidies by the government. For this reason, there will keep on being facilitated for this billion dollar export industry, the transfer of its costs to ecosystems and the local and regional aquatic biodiversity, the public health and the rights of the citizens, workpeople, original peoples and coastal communities. Therefore, it is functional the absence of a informed participation of artisanal fishermen, the local tourism, the coastal communities, and indigenous people in this new phase of expansion of the monoculture industrial salmonids to the regions of Bio-Bio, Araucanía, Los Rios, Aysén and Magallanes, which ensures that these initiatives are discussed in a precautionary, public, and responsible manner. The previously stated concern is joined by two other troubling aspects: The silent and hardly transparent process of corporate hoarding of coastal territory and and expropriation of national property, along with the subsidy delivered to the Chilean taxpayers.
Currently, no more than 35 percent of the total salmon fishing concessions given by the government are used productively. It is surprising that the 755,000 tons of salmon produced in 2013 were obtained using a third of the concessions provided for this purpose. This highlights the privilege of exclusivity on increasingly scarce domestic goods, and thus are more commercially valuable, that have been awarded to a handful of large fishing companies and industrial aquaculture, transnational and familial clans, by means of application and hoarding concessions, especially in the interior sea of  Los Lagos, Aysén y Magallanes regions. According to a report delivered to investors of Multiexport Foods, 75% of the total 1,320 concessions aimed at industrial salmon farming aquaculture are under the control of just 10 companies. Of them, 5 mega companies possess 50 percent of salmon farming concessions. One example, the group created between the transnational Norwegian Marine Harvest and AquaChile, which owns 26% of the total number of salmon farming concessions granted on the Chilean coastline (5).
When Moya is the one who pays
The irony of this process of territorial occupation of the coastal heritage and transnational business clans, which is promoted by the government, is that its funding comes from Chilean tax payers. The former subsecretariat of fishing, Pablo Galilea (RN), confirmed in 2013 that the state delivered  “a historic funding of 5,673 million pesos” across 68 research projects for the socioeconomic evaluation of salmon farming and mitilicultura, zoning, oceanography, health care and pest control, among other items (6).
This would be a vital exercise in transparency since citizens could know the total amount of the billionaire financing using public resources that have been allocated directly and indirectly, to subsidize this inefficient and polluting mega industry that exports 98 percent of its annual production.
It is important to remember the financial bailout of this industry between 2007 and 2009 - which initially meant among several measures, including the delivery of 450 million dollars with with up to 70 percent guaranteed by the government - aimed to offer relief to the companies, and the economic impacts of the mega health, reproductive and social crisis caused by the introduction of the infectious salmon anemia virus (ISA) into the waters of the archipelago in the Chiloé and Aysén region.
This crisis, a direct consequence of the bad practices of the industry and the lack of government control, meant losses of about 5 billion dollars, the elimination of 26,000 regional jobs, especially for women, and the irreversible introduction of this pathogen into the coastal marine ecosystems of the Chiloé and Aysén archipelago.
Subpesca and the National Aquaculture Commission are kidnapped by corporate interests
In October 2013, the National Commission of Aquaculture (CNA) gave a proposal to the Subpesca to develop a proposal for the management of the fishery centers that were members of a Grouping of Aquaculture Concessions. This commission was created in 2012 to address health and environmental regulations, modifications of the General Law of Fishing and Aquaculture, using the coastline and other regulatory issues affecting the marine farming industry.
It is composed of representatives from the Association of the Industry of Salmon in Chile A.G. (SalmonChile), the Association of Industrial Fishing and Marine Growers A.G. (Asipec), and the Association of Mitilicultores of Calbuco. In the aquaculture concessions relocation project, several organizations have participated with Subpesca such as the labor union of Mitilicultores of Chiloé (Amichile), the Regional Commission of Federations of Aquaculture Algueras Organizations of the Los Lagos Region, the Association of Salmon Coho Producers and Trout A.G. (Acotruch), and the Association Producers of Abalones (APROA).
As is evident, in this national committee there are no representatives of artisanal fishing, coastal communities, indigenous peoples and organized citizens who have been historically affected by the processes of territorial and productive expansion of various industrial monocultures for export.
In contrast to the requested areas, the investments and productions associated with large-scale industrial exported monocultures, there is evidence of the successive governments’ lack of political will and that the parliament intended to build a National Aquaculture Policy of integral character, which would incorporate the interests of small-scale producers and the needs associated with the country's food security.
This exemplifies the fact that, despite having spent 12 years establishing aquaculture policy and enacting laws 20.434 of 2010, and the 20.657 2013, a statute for the management of small scale aquaculture hasn’t been established. Despite the existence of 4,000 direct workers and 1,500 temporary workers belonging to 100 aquaculture centers, less than six have been owned by artisanal fishermen dedicated to the production of pelillo, chorito, cholga, choro maltón, Chilean oysters, Japanese oysters, trout, and river shrimp.
This contrasts greatly with the urgency in which legislation has been passed about the topics of interest for big, industrial export companies. We hope that the government makes an announcement during the second half of this year about progress in the establishment of a statute for small-scale aquaculture.
The moratorium on new salmon concessions, or when looks can be deceiving
Behind the government announcement of a five-year extension of the current moratorium on new applications for salmon concessions in the Los Lagos and Aysén regions, is an attempt to give the impression that it would temporarily stop the expansion of these industrial monocultures for the reasons of protecting the health heritage in our inland bodies of water and the marine coastline.
A more in-depth look tells us that the reality is that the government will continue providing concessions to big companies and driving the current process of productive expansion, this time via the indirect route of substituting or exchanging those concessions that present a high health risk or little commercial profitability, which accounts for nearly half of the concessions that have been given by this exporting industry.
Relocating itself outside of public scrutiny and control, along with delivery of new concessions in the regions of Bio-Bio, Araucanía, Los Ríos, and Magallanes, will be the instrument used by the government in the next five years in order to continue driving the territorial restructuring and the expansion of production, associated with the processes of economic concentration and transnationalization of mega-industrial aquaculture in Chilean waters
The fact that there are 70% more concessions than necessary in the hands of 10 companies, in reality means the new government directive will consolidate the strategic interests of these same companies. Especially in the pristine waters of Magallanes and Antarctic Chile, areas that have a strategic role in Chile’s transnational interests, due to their potential to implement in the future massive and fast expansion under the wing of permissive government regulation, together with access to fisheries -particularly, krill - in the waters of the southern ocean, aimed at providing sources of supplementary feed for salmon, which makes this region unique at the global level.
Magellanes: Bread today, hunger tomorrow?
Along with the aforementioned mentioned advantages, one must add the lower sanitary health risks found in the waters of Chilean Patagonia. This translate into lower production costs for the benefited companies. Currently, the average mortality rate in salmon centers in Magallanes is less than 10 per cent, while the average mortality rate nationwide is 16 percent.
However, this factor will be temporary, taking in consideration the traditionally poor health and environmental practices of the industry. To this, they should add the geographical continuity between the salmon fishing regions, the mobility of the pathogens, and the development of mutagenic strains, and the process of bacterial and antiparasitic resistance, among other things
It is likely that attempts by big companies to make their “reserves” of aquaculture concessions in the adjoining regions operational - as a means of rapidly increasing their production amid a climate of high international prices- could be the factor that triggers a second major health crisis, that would end up destroying the health of one of the most vulnerable and pristine regions in the world.
In October 2013, an open letter from 29 Mapuche, Lafkenche, Williche, and Kaweskar indigenous communities, along with civil organizations, warned against the relocation of salmon fishing concessions because of its opacity, lack of informed participation, and failure to consult indigenous communities, as required under Convention 169 of the International Labor Organization (ILO) and ratified by the Chilean government.
The organizations warned against the imposition in the regions of Magallanes, Aysen, Bio-Bio, Araucania, and Los Rios "of the same model and malpractices that meant the destruction of the health and environmental heritage of the archipelago of Chiloé." (7)
The author, Juan Carlos Cardenas, is executive director of Centro Ecoceanos


(1) Ley 20.434 en el archivo: Diario Oficial miércoles 7 de abril de 2015




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