REASONS for DECISION MINISTERIAL APPROVAL PURSUANT to SECTION 15(1)(A) the ENVIRONMENTAL ASSESSMENT ACT WILD WEST STEELHEAD FISH FARM EXPANSION in KADLA COULEE
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REASONS FOR DECISION MINISTERIAL APPROVAL PURSUANT TO SECTION 15(1)(a) THE ENVIRONMENTAL ASSESSMENT ACT WILD WEST STEELHEAD FISH FARM EXPANSION IN KADLA COULEE Introduction The Environmental Assessment Act (hereinafter called the Act) states that a person shall not proceed with a development (as defined in the Act), until Ministerial Approval has been received. It further sets requirements for a process of environmental impact assessment (EIA) intended to inform the Minister of Environment of the potential impacts of a development prior to making a decision regarding the development. In July 2006, Wild West Steelhead (Wild West) submitted a request to the Ministry of Environment for licences to establish three new cage aquaculture sites on Lake Diefenbaker. In discussions with Wild West it was agreed that the proposed project was a “development” as defined by the Act and that Wild West would have to conduct an EIA and obtain the Minister’s approval in order to obtain licences for the new sites. Wild West subsequently reduced the proposal to just one new site, at Kadla Coulee, and prepared to conduct the EIA with respect to this one location. Project Specific Guidelines, prepared by the Environmental Assessment Branch, were provided to Wild West (hereinafter called “the Proponent”) in March 2008. Wild West subsequently submitted an environmental impact statement (EIS) in March 2010, which underwent both technical and 30-day public reviews. I am therefore satisfied that the Proponent has met the requirements of the Act. Background The proposed fish farm expansion cages are to be located in Kadla Coulee on the west shore of Lake Diefenbaker, approximately 11 km north of the Riverhurst Ferry crossing and 4 km north of the main fish farm in Cactus Bay, near Lucky Lake, Saskatchewan in the Rural Municipality of Maple Bush No. 224. The proposed expansion would produce 300 tonnes of rainbow trout per year and include ten cages altogether, along with anchors and marker buoys. The facility would be contained within a lease area of 200m x 600m, for a total area of 12 hectares. All servicing would take place by water: no shoreland facilities are contemplated. The project is expected to be ongoing, with no specified end date. The Proponent has included a conceptual decommissioning plan in the EIS. Wild West Steelhead Expansion 15(1)(a) – Reasons Page 1 of 7 EAB 2005-190 Lake Diefenbaker supports a wide variety of water based activities, including recreational boating and sailing, fishing, and cottaging, as well as generating hydroelectric power and supplying irrigation and drinking water. There are no cottages or houses visible from the proposed expansion site. The Coteau Hills Rural Water Pipeline Association operates a pumping station in Kadla Coulee, supplying untreated water to a number of users. Environmental Assessment Public notice of the EIA was first given in October 2007, pursuant to Section 10 of the Act. Project Specific Guidelines (PSGs), written to guide Wild West’s preparation of their EIS, were also made available for public comment at that time. There was a considerable amount of public interest in the proposal, mainly by other users of Lake Diefenbaker, and comments were received from eleven individuals or groups. The PSGs were reviewed to ensure that suggested content was included, and where necessary, revised to reflect those comments. In seeking approval for the Kadla Coulee expansion site, Wild West Steelhead, in accordance with the Act, conducted an EIA. The Proponent prepared and submitted an EIS entitled, “Application for New Aquaculture Site at Kadla Coulee, for Wild West Steelhead”, by Sweeney International Management Corp. dated March 16, 2010, to the Ministry of Environment for technical review. The EIS underwent technical review by provincial and federal ministries and agencies. Deficiencies and requests for clarification were identified to the proponent. The proponent subsequently submitted an addendum to the EIS that satisfied the request for additional information. The final EIS (hereinafter called "the Statement") and the technical review comments document written by the Environmental Assessment Branch were then made available March 12, 2011 for a 30 day public review, pursuant to Section 12 of the Act. Having made my decision to issue a Ministerial Approval, the Act requires me, pursuant to subsection 15(2), to state the reasons for the decision. Reasons for Decision Potential Impacts The Statement submitted by the Proponent describes the development and its potentially adverse impacts on the environment. In this regard, the main potential impacts from the project would be deterioration of water quality and impacts on bottom fauna from the addition of nutrients to Lake Diefenbaker. The PSGs identified these as the impacts of greatest concern, along with consideration of escapes, species at risk, air quality, effects on recreation including angling, aesthetics, predator control, and heritage resources. Wild West Steelhead Expansion 15(1)(a) – Reasons Page 2 of 7 EAB 2005-190 Water Quality: Regarding the impacts on water quality, the principal concern is that the feeding of the fish adds nutrients to the lake, which in turn can encourage algae growth. The main substances of concern are phosphorus and nitrogen. The phosphorus is available from the fish feces and from any uneaten feed that passes through the cages, while the nitrogen is mainly from ammonia excreted by the fish. In freshwater systems in general, and according to past research on Lake Diefenbaker, phosphorus is the limiting factor with respect to encouraging algae growth (a phosphorus limited system). Wild West provided nutritional data on their principal fish diets, which showed that the feed formulation contained 1.2% phosphorus, a fairly low level compared to commercial trout feed in the past. As well, the Proponent’s feeding system and schedule is designed to maximize feed utilization and avoid loss of uneaten feed. Wild West has operated their main farm in Cactus Bay for 17 years, and has been required to collect water samples for analysis, and to provide the results to the Ministry of Environment. The water monitoring results from 1998 – 2008 indicate an expected increase in phosphorus and nitrogen directly at the cage site, diminishing rapidly with distance from the cages. Samples taken 300m downstream of the cages show minimal or no measurable increase over control samples from 300m upstream of the fish farm. Since Lake Diefenbaker is a reservoir which ultimately supplies drinking water to the Cities of Saskatoon, Regina, and Moose Jaw, as well as to local users including the subscribers to the Coteau Hills Rural Water Pipeline Association, the potential effects of phosphorus and ammonia on drinking water quality were raised as issues by members of the public. Metabolic wastes from the fish can cause elevated levels of nitrogenous compounds, namely ammonia, nitrates, and nitrites. Canada has established guidelines for nitrates and nitrites in drinking water of 10,000 and 3,200 µg/l respectively. Water testing data provided in the EIS indicated that nitrate and nitrite levels were quite consistent throughout the areas examined, either near the cages or in areas with no fish farming, and only 1/40th (nitrates) to 1/400th (nitrites) of the limits in the Canadian drinking water quality guidelines. Increased phosphorus and nitrogen levels at the cage site may contribute to algae growth, but as indicated above, past sampling has shown that these levels are within the natural range of measurements in Lake Diefenbaker, and that they drop off rapidly with distance from the cages. Based on the data presented, including past records of water quality testing, it is extremely unlikely that the project would affect drinking water quality, or necessitate any additional water treatments. Bottom Fauna: Sediment deposition directly beneath the cages will result in an inhospitable environment for benthic invertebrates. However, research indicates that this dead area is quite localized, and the effect is partially offset by enhanced productivity in the area immediately surrounding the cage site. Overall, due to the relatively small footprint of the cage site, the effect on lake productivity is expected to be negligible. Wild West Steelhead Expansion 15(1)(a) – Reasons Page 3 of 7 EAB 2005-190 Escapes: Wild West Steelhead has experienced several incidents of fish escapes over time, with the most significant occurring in April 2000, when major damage from moving ice resulted in the escape of at least 360,000 rainbow trout. Wild West has implemented various precautionary measures to prevent escapes at the main fish farm, including regular inspection of the cages for holes, positioning the cages deeper in the bay for winter to reduce exposure to moving ice, and increased vigilance during ice out. It is expected that Wild West will implement similar measures at the Kadla Coulee site. Some fish losses from cage operations are always expected, but it is also expected that the Proponent will take all reasonable steps to prevent them, since every fish lost represents lost income. Public input over the course of the EIA process identified escapes as an issue, citing competition with native fish stocks and the potential for spread of fish diseases as concerns. Ministry of Environment experiences on Lake Diefenbaker indicate that effects on native fish, if any, are short term and that anglers respond to news of fish escapes with increased angling activity, reducing the excess rainbow trout from the lake. All fish stocked at the fish farm originate from certified disease-free fish hatcheries, and are unlikely to introduce any new salmonid diseases to the lake. Furthermore, Wild West raises sterile triploid fish, which are incapable of reproduction. Species at risk: There are a number of plant and animal species at risk which may be found in the vicinity of the project, most notably piping plovers, but all are terrestrial and unlikely to be affected by the project.