The following letter was sent to the Newfoundland and Labrador Department of Environment and Conservation.
After thoroughly reviewing the proposal by Grieg Nurseries NL Ltd (Registration Document #1814) to establish a new hatchery facility in the Community of Marystown on the South Coast of N.L., the Atlantic Salmon Federation (ASF) wishes to go on record as being opposed to this project for two reasons:
- this project is part of a larger undertaking that will include activities known to have significant negative impacts on wild Atlantic salmon and the marine environment (i.e., open-net sea cage grow out facilities and introduction of an exotic strain of salmon). However, it appears as though the province will not require those components to be registered for environmental assessment, which is in contravention of provincial legislation and;
- the proposal fails to include any assessment of impacts on wild Atlantic salmon. We outline our concerns below.
The entire undertaking is required to be registered for environmental assessment
We note that the hatchery facility (Reg. 1814) was registered for environmental assessment on October 1. Subsequent to that, a MOU between Grieg and the NL government for a major aquaculture development was signed on October 25. That MOU clearly states that the proposed aquaculture development will consist of:
“A hatchery and nursery in Marystown capable of producing seven million Atlantic salmon smolt annually in order to stock its aquaculture operations in Placentia Bay, including the establishment of 11 sea cage sites for the subsequent grow out, harvesting, and processing of 33,000 metric tonnes of Atlantic salmon.”
The MOU also indicates that Grieg intends to import eggs from Norway or Iceland to stock the hatchery. Furthermore, the MOU indicates that only the hatchery component of the project is required to be registered for environmental assessment.
Requiring only the hatchery component of the undertaking to be registered for environmental assessment is not consistent with the provincial Environmental Assessment Regulations Section 29 which states that aquaculture (including raising fish in salt water) must be registered:
“An undertaking that will be engaged in farm raising fish or shellfish where that undertaking will intervene in the rearing process to enhance production by keeping the animals in captivity, stocking and feeding the animals and protecting the animals from predators including:
- fish or shellfish farming in salt water or fresh water; and
- fish or shellfish breeding and propagating or hatchery services, where the undertaking will include the construction of shore-based facilities other than wharves and storage buildings and
- permanent marine trap or weir fisheries, shall be registered.”
Likewise, the Aquaculture Act prohibits the introduction of exotic strains of fish without an environmental assessment:
“8(3) The minister shall not approve the introduction into or transfer to a body of water or aquaculture facility in the province of a species or strain of aquatic plants or animals not present in that body of water or that aquaculture facility unless the impact of that introduction or transfer has been assessed in accordance with the Part X of the Environmental Protection Act, whether or not that introduction or transfer is an activity of the type otherwise requiring assessment under that Act.”
The N.L. Aquaculture Act (Section 4(7)) prohibits the minister from granting an aquaculture license unless the proposed licensee has complied with other applicable legislation (which in this case would be the Environmental Protection Act and the Environmental Assessment Regulations).
There are no provisions in the Environmental Protection Act, the Environmental Protection Regulations, or the Aquaculture Regulations that permit an undertaking such as the one announced in the October 25 MOU to be split into separate components for the purposes of undergoing or avoiding environmental assessment. Given the significant amount of evidence regarding the negative impacts of sea-cage finfish aquaculture on wild Atlantic salmon, as well as the significant amount of public concern surrounding these impacts, we feel there is no justification (legal or otherwise) for failing to register the entire undertaking as outlined in the October 25 MOU for environmental assessment.
It is our opinion, based on our own research and research conducted globally on the impacts of sea-cage finfish aquaculture on wild Atlantic salmon populations, that the undertaking as outlined in the October 25 MOU will have a serious negative impact on wild Atlantic salmon stocks in this region of the province. Consequently, we believe the current undertaking (Reg. 1814) should be withdrawn from environmental assessment and the entire undertaking as outlined in the October 25 MOU registered. The combined impacts of the proposed hatchery, sea-cage grow out facilities, and importation of European strain salm on wild Atlantic salmon, their habitats, and the people who currently use those (and other) resources should then be assessed through that process.
The proposal fails to consider the impacts on wild Atlantic salmon
Wild Atlantic salmon stocks on the south coast of Newfoundland have been designated as “Threatened” by the Committee on the Status of Endangered Wildlife in Canada (COSEWIC). In response to this designation, the federal government embarked on a listing process to determine if this threatened population of salmon will be formally listed and protected under the federal Species at Risk Act (SARA). As part of this process, the Department of Fisheries and Oceans (DFO) recently prepared a Recovery Potential Assessment on these threatened wild salmon stocks and concluded that under current conditions, there is a 50 per cent chance that the population will drop below its current size (DFO, 2012). DFO recognizes sea-cage salmon aquaculture as a major potential source of habitat degradation and mortality of wild Atlantic salmon on the south coast of Newfoundland.
The DFO Recovery Potential Assessment for Newfoundland south coast salmon concludes “Even small numbers of escaped farmed salmon have the potential to negatively affect resident populations, either through demographic or genetic changes in stock characteristics. There have been many reviews and studies showing that the presence of farmed salmon results in reduced survival and fitness of wild Atlantic salmon, through competition, interbreeding and disease.” (DFO, 2012).
Placentia Bay is part of the south coast salmon population that has been designated as “threatened” by COSEWIC. Nineteen scheduled Atlantic salmon rivers drain into Placentia Bay. In 2014, those rivers had a total of 3,575 rod days of recreational salmon angling effort and a recreational catch of 1,215 salmon. Placentia Bay currently has no salmonid aquaculture; therefore, the planned expansion of sea-cages into this bay will be a new stressor on these threatened populations and the fisheries they support.
Exposing these sensitive wild salmon populations to further threats posed by the construction of this new hatchery and a major expansion of salmonid aquaculture farms into Placentia Bay using an exotic strain of salmon will not only severely hinder these wild stocks from recovering, but in fact will likely result in further reductions and significant socio-economic impacts on the people who currently depend on these fisheries for their social and recreational values.
Despite the widely recognized impacts of finfish aquaculture on wild salmon and the significant concerns expressed by the public about these impacts, the component of the undertaking that has been registered (the hatchery) fails to assess the potential impacts on wild Atlantic salmon.
We note, however, that the proponent does address the potential impacts on other threated species in the area, including freshwater and marine species of fish (banded killifish and wolfish). Given that Atlantic salmon occur in both fresh and salt water near the proposed aquaculture development (including rivers draining into Mortier Bay adjacent to the proposed hatchery site), failure to consider the impacts of the proposed development on threatened Atlantic salmon is a major oversight, and represents a serious flaw in the environmental approval process for this undertaking.
In conclusion, the Atlantic Salmon Federation has significant concerns about the potential impacts of this undertaking and the process through which those impacts are being assessed (or not assessed). We believe that the entire undertaking as outlined in the October 25 MOU should be registered for environmental assessment so that the combined impacts of the proposed activities can be investigated in an open and transparent manner. We are concerned that the government is contravening its own legislation by splitting the undertaking into separate components in order to avoid subjecting the most environmentally damaging components to environmental assessment. As a result, the potentially significant impacts on threatened wild Atlantic salmon and the fisheries they support will not be addressed.
Director, Newfoundland and Labrador Programs
Atlantic Salmon Federation