Dear Premier,

As you are aware, the United States Food and Drug Administration (FDA) may announce in the next few days that it will approve genetically engineered (GE) Atlantic salmon safe for human consumption. (If approved, it will be approved as an “animal drug”, not a food.) As you are also aware, the company AquaBounty plans to produce all of its GE salmon eggs, sometimes called “ftankenfish”, in its facility right here in Prince Edward Island.

On September 19 and 20.of this year in Rockville, Maryland, the FDA convened its Veterinmy Medicine Advisory Committee for a public meeting to discuss the possible approval of the “AquAdvantage” GE salmon. Many groups and individuals made presentations to the committee expressing serious concerns regarding environmental and human health risks of the GE salmon. Leo Broderick, representative from the PEl Coalition for a GMO-free province, attended the hearings and made a presentation.

FDA’s own briefing materials for the meeting suggested that the GE Atlantic salmon had significantly lower levels of Omega 3 fatty acids (the healthy fat in salmon) compared to other farmed salmon and may have a greater potential to cause allergic reactions. FDA’s own Advisory Committee raised concerns at the hearings regarding inadequate data from AquaBounty including too-small sample sizes, incomplete data, questionable culling practices, troubling abnormalities, and poor environmental and scientific assessments. In addition, other scientists at the hearings cautioned that there was insufficient study of its impact on human health and the environment. The only scientific research considered by the FDA was from AquaBounty itself.

FDA is required by law to conduct an environmental impact statement for any regulatory action that could negatively affect the human environment. The agency has not done so. Despite Aqua Bounty’s claim to produce only sterile (triploid) salmon, the company admitted that up to 5% of their GE salmon
eggs could be fertile at any given time, prompting the FDA to label the company’s claims ”potentially misleading”.

In short, what AquaBounty presented as evidence to the FDA was sloppy science. Based on what was presented, we believe the FDA should therefore not approve Aqua Bounty’s GE salmon. Since September, opposition to GE salmon has grown, even among US politicians. On Thursday, November 18, Sen. Mark Begich (D-Alaska) introduced legislation that would ban the GE salmon -if the FDA approves it.

Here in Canada, we cannot control what the FDA decides. However, Canada plays a significant role in the growing controversy over the safety of GE salmon, not the least of all because the company has decided that PEl will be the sole source of GE salmon eggs for the world. AquaBounty’s plan is to produce the GE salmon eggs here on PEl, to then export them to Panana where they will be grown out and processed for sale in the United States. AquaBounty’s current environmental assessment to the FDA specifies this production plan and assumes that Environment Canada will permit the commercial scale production of GE Atlantic salmon eggs on PEl.

However, neither the Government of PEl nor residents will be notified by Environment Canada if AquaBounty requests approval for production of GE salmon eggs on the Island. In fact Environment Canada refuses to disclose if this process has begun. Environment Canada will assess the environmental risks of producing the GE salmon eggs in 120 days in a completely secret process. Everything is confidential with Environment Canada. There is no public input, and no notification to the province or public disclosure. This process is flawed.

As premier of Prince Edward Island, the PEl Coalition for a GMO free province, believes you could, and should have a role to play in this issue, a positive proactive role in providing transparency. In the interest of fairness, transparency, and fisheries conservation, we ask that you, as Premier of Prince Edward Island do the following:

First, we request that you insist Environment Canada notify Prince Edward Island when AquaBounty requests approval for commercial production of GE Atlantic salmon eggs, that the province be consulted on environmental risk questions and be notified immediately if approval is granted (or refused);

Second, we request that you and your government hold public consultations on whether or not AquaBounty should be granted permission to produce GE salmon eggs on PEl for export to Panama or anywhere else;

Third, that you call on the Canadian government to ban the sale of genetically engineered animals;

Fourth, that you introduce legislation declaring PEl a GMO-free province.

We look forward to hearing from you with a positive response to our requests.

Sincerely,

Leo Broderick, Council of Canadians
Sharon Labchuk, Earth Action
MaryBoyd, PEl Health Coalition