EcoLur
We, public representatives, think that Environmental Expertise SNCO of Nature Protection Ministry of Armenia should issue a negative opinion to the “Complex Program for Recovery of Trout Reserves and Fish Breeding in Lake Sevan”, as it, first of all, contradicts to RA Law “On Lake Sevan”. The project lays down artificial breeding of trout in Lake Sevan at the expense of the artificial forage containing nitrogen and phosphorus, while these elements accelerate waterlogging process in the lake and deterioration of the water quality.
The preamble of RA Law “On Lake Sevan” says, “This law sets the legal and economic grounds of the state policy on natural development, recovery and reproduction of natural resources, the conservation and use of Lake Sevan as the ecosystem of strategic significance of the Republic of Armenia, having environmental, social, scientific, historical and cultural, esthetic, health, climatic, recreational and spiritual values. LAKE SEVAN IS STRATEGIC TREASURY OF FRESHWATER IN REPUBLIC OF ARMENIA”. Lake Sevan is under the protection of Nature Protection Ministry as represented by “Sevan” National Park. Two applicable laws are available, RA Law “On Lake Sevan” and RA Law “On state complex program on the recovery, preservation, reproduction and natural development and usage of Lake Sevan ecosystem” with an approved management plan.
But the project doesn’t say anything about the compliance of its provisions with either the laws or the management plan. The project doesn’t contain any Environmental Impact Assessment (EIA) at all, which is the subject of consideration of the environmental expertise in line with RA Law “On Environmental Impact Expert Assessment”. Consequently, “Environmental Expertise” SNCO should reject the consideration of the project based on the absence of the EIA either.
The results of the pilot project laid down in this project are extremely insufficient and don’t comply with the ambitious scales of the project. The calculations were conducted with just multiplication of preliminary results, which is not convenient for ecosystem modeling. It should be noted that the pilot project doesn’t contain the data, which will enable computing probable risks and negative effects, no data about accumulation of pollutant substances. Instead of literature review, where both positive and negative experience is described, only several internet links are available with very scarce data. But the accumulated scientific data show that the ecological risks of the cage culture fishery are high especially in wide-scale projects. We outline several excerpts from researches:
1. “Wide-scale increase in artificial fish breeding, including that of the trout and other hydrocole is frequently accompanied with the degradation of water ecosystems, outbreak of mass diseases of indigenous representatives of natural reservoirs, [Maclacova etc,2009; etc, Kazimirchenko, 2006].
2. “Significant changes in the state of water ecosystem take place when increasing the volumes of metabolism products of grown fish and remainders of the forage. Essential, more frequently irreversible changes take place in case of strong impact of the pollution source both in individual organisms and the ecosystem, as whole./“Method of Assessing Impact of Cage Fishery Aquaculture on State of Water Ecosystem (RU 2447435), L. Ryzhkov, Petrozavodsk, 2004/.
3. “Salmon fish breeding and industrial cage fishery lead to the spread of hazardous infectious diseases of the fish. Risk criteria are as follows: generation of new pathogens for fish organisms, as well as increase in the number of existing parasites and pathogenic microorganisms. /Murmansk Marine Biological Institute of Kola Scientific Center of RAS, an institution of the Russian Academy of Sciences, number of governmental contract - 02.515.12.5003 dated on 04 August 2008.
4. “The use of cage salmon fishery increases the risk of cancer diseases more frequently than once a month. The bred salmon contains 10 times as much polychlorinated biphenyl and dioxin as the wild ones. The regular use of cage fishery leads to the problems with vision, as the forage contains canthaxanthin, its increased concentration causes the destruction of the eye iris.
Salmon aquaculture is breeding fish in the fish farms, i.e. in the cages located in the sea. Each cage contain rather a large number of the young fish, thus setting up ideal conditions for various diseases, while farmers use antibiotics and other medicine to prevent these diseases thus leading to serious consequences. People, who eat cage salmon, get a significant amount of these substances. Besides, life in a restricted area promotes not only spread of diseases, but also the reproduction of parasites.” (Dvin-Pechor Territorial Administration of Russia’s Federal Fisheries Agency (Rosrybolovstvo), 2014).
We think that the destruction of the lake ecosystem, water quality deterioration, and probabilities of outbreaks of epidemic in Sevan fish may have irreversible and disastrous consequences for all the country and region, as a whole. The reproduction of the trout and other fish species should take place in the natural processes of Lake Sevan ecosystem, its protection and preservation vest on Sevan National Park and Nature Protection Ministry of Armenia.
January 29, 2014 at 16:00