February 20, 2015

B.C. Ministry of Forests, Lands and Natural Resource Operations Fisheries and Oceans Canada Transport Canada

By email transmission to: [email protected]

Re: Your files no. 1411170 and 1411171 Grieg Seafood o/a 0917228 BC Ltd. Salmon Aquaculture Applications

The following comments are submitted in response to your public consultation regarding the proposal to convert two shellfish tenures/licences to salmon aquaculture. The proposed sites in Clio Channel, Tsa-ya on and Wa-kwa, on West Cracroft Island, are unsuitable for salmon aquaculture and we urge you to reject the applications for the reasons that follow.

1. Proximity to salmonid-bearing streams

The North Island Straits Coastal Plan documents the following: “Unit 9 Clio Channel Salmonid Streams: (3 observed, 2 assumed)”. As Map 1, following, demonstrates, the area is replete with streams which may support salmonids, some of which are within 1 km. of the proposed tenures. Maps filed with the application for the proposed farms fail to indicate the presence of these streams.

The resilience of salmonids on the B.C. coast depends in large part upon the genetic diversity represented by the thousands of discrete stocks spawning in the myriad streams and rivers of the B.C. coast. While we understand that the Department of Fisheries and Oceans may not have the resources to document the presence of salmonids in every one of these streams, it certainly can and should require applicants for aquaculture licences to provide the opinion of a registered professional biologist to the effect that there are no salmonid-bearing streams within 1 km. of the proposed site.

Map 1: Streams on Turnour Island (Bennett Point), Minstrel Island (Tsa-ya) and West Cracroft Island (Wa-kwa)

With respect to the provision of expert evidence regarding the presence of fish-bearing streams, we note that the Applicant has filed the report of a registered professional biologist who, in 2004, undertook field work on Turnour Island in support of the application for Grieg’s Bennett Point salmon farm. The study area is depicted in Map 2, taken from the report. Only 7 streams on Turnour Island were examined at all; only 2 were investigated for the presence of fish habitat. It was observed that most of the streams had a gradient of >30% and were not examined further. In one stream, minnow traps were placed for a single day and even at that small sample size, the presence of cutthroat trout was confirmed.

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Map 2: Excerpted from “Inventory of Streams, Clio Channel”, Monica Stewardson, R.P. Bio, June, 2004

This report is wholly inadequate to support the assertion in the application that there are no salmonid-bearing streams within 1 km. of the sites of the proposed aquaculture operations. The topography of Minstrel and West Crafcroft Islands differs from that of Turnour, with the potential for streams with lower gradient supporting spawning populations.

Further, we believe that additional precaution is required in the case of the present applications—that the “1 kilometer” siting rule may provide inadequate protection for salmonids where it is proposed to place 3 farms in such close proximity. The waters in which the farms are to be placed are rearing habitat for salmonids out-migrating from local streams and identified as a salmon migration route in the North Island Straits Coastal Plan. The cumulative impacts of the three farms, elaborated below, may prove detrimental to salmonid stocks originating in streams more than 1 km removed from the farms.

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2. Proximity to herring spawning areas

Herring spawning in this and other areas are vital to the rich ecosystem and trophic dynamic that is currently supporting large and small predators (whales, marine mammals, birds, fish, etc.) that in turn support significant North Vancouver Island economic activity within the wildlife viewing, kayaking, boating, diving and fishing sectors. While the proposed farm sites are not within 1 kilometer of a designated herring spawn area, there is a designated spawn area nearby and the area surrounding the proposed farm sites is rich in appropriate spawning habitat. As herring spawning areas are well known to vary from year to year within a bay or channel, we believe that it is vital to ensure that access to spawning habitat is not reduced by the siting of a salmon farm. The North Island Straits Coastal Plan identifies this area as having kelp beds and eelgrass throughout Clio Channel and we are accordingly of the view that the proposed location of these farms will reduce spawning habitat.

3. Proximity to intertidal shellfish beds

Map 3 shows the location of intertidal clam beds and the requisite 300-metre buffer, that clearly overlaps the proposed leases.

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The Tsa-ya site has clam beds on both sides and the current and tidal flow may concentrate the contaminants against the shore and therefore into the nearby clam beds. There appears to be greater potential for this impact with the Wa-kwa site.

The cumulative impact of wastes from the three sites in close proximity would likely impact the bivalves in the area and potentially result in faecal coliform-based closures on these clam beds.

These clam beds are important to First Nations and recreational fisheries. We note that Tlowitsis First Nation has approved the proposed location of the farms, but they are only one of several First Nations that have overlapping interests in this area, a fact that would have been apparent to the applicant and regulators from the response to the Bennett Point application. This particular part of the is well known to recreational boaters for prawn, shrimp and shellfish.

The Science Advisory Report 2009/071 states that there is scientific evidence that finfish aquaculture can affect nutrient flow in both pelagic and benthic environments with potential to alter local benthic habitat. In this regard, we note the absence of benthic impacts modeling to support this application: it may have been filed with government agencies but does not appear in materials disclosed to the public.

4. Proximity to all other wild shellfish beds, sensitive fish habitat and areas used extensively by marine mammals

The North Island Straits Coastal Plan identifies this area as having kelp beds and eelgrass throughout, moderate to high invertebrate values, resident Humpback Whales, moderate beach clam and oyster capability and good off bottom scallop capability. It is, in addition, a commercial shrimp trawl fishing area and a holding and rearing area for out-migrating salmon.

We note that the Applicant proposes the use of Aquacannons at both sites. The Science Advisory Report 2009/071 also mentions noise as a local impact of aquaculture operations and this is particularly relevant in an area frequented by Humpback whales. It appears that the effects of Aquacannons are largely unknown and here, the cumulative effect of their use at 3 farms within and enclosed area demands further investigation of potential effects on whales, other marine mammals and fish.

5. Potential impacts on important Aboriginal, commercial and recreational fisheries

As indicated above, several First Nations traditionally use this area and have, in the past, expressed concern for impacts on out-migrating salmon and other fish and shellfish resources.

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The CEAA screening report for the Bennett Point salmon farm application at p. 5 noted concerns:

“DFO sent a follow up letter to the Hamatla Treaty Society, Tlowitsis Tribe, Namgis First Nation, and Musgamagw-Tsawataineuk Tribal Council on September 05, 2005, including a table outlining identified First Nation concerns expressed in the June 21, 2005 meeting with the Namgis and Tlowitsis First Nations”

Commercial fishers have expressed concerns about the disruption of their shrimp trawl fishery. The proposed sites directly conflict with this fishery, which presently trawls within the proposed lease boundaries. The existing Bennett Point site also interferes with this fishery; the combined effect of the 3 farms located as proposed would further endanger this extremely productive portion of the shrimp trawl fishery.

Recreational fisheries for salmon, shrimp and prawn occur at and near the two sites. Crab and clam harvesting will be impacted from fish farm waste close to productive, shallow and intertidal habitat.

6. Proximity to existing finfish aquaculture sites

Both proposed sites are within 3 kilometres of the active Bennett Point finfish site. At the February 10 Grieg Seafood open house in Port McNeill, the DFO representative mentioned that the 3 kilometre criteria had been changed. Unfortunately the public has access only to the Marine Finfish Integrated Management of Aquaculture Plan, December 2013, Version 1.1 on the DFO website; that Plan does not incorporate the change. This siting criterion was developed as an attempt to control for cumulative impacts from salmon farms; even if the criterion has been relaxed, permitting 3 farms within such close proximity of one another (1-2 kilometers) will surely lead to undesirable cumulative impacts. Again, we reference the lack of benthic impacts modelling among the publicly available documents.

7. Consistency with local government by-laws or relevant Coastal and Marine Plans

The North Island Straits Coastal Plan (December 2002) is now over 12 years old. This plan identifies Unit 8 Minstrel Island as having finfish aquaculture potential but also identifies the area’s management emphasis as recreation and the rest of Clio Channel (Unit 9) for conservation. This plan predates the placement of the Bennett Point salmon farm and does not contemplate multiple industrial uses in an area designated for recreation and conservation. We are accordingly of the view that the proposed tenures do not conform with the intent of this Plan.

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The North Vancouver Island Marine Plan has just been completed through the Marine Planning Partnership (MaPP). This collaborative multi-stakeholder plan is currently available in draft form and is expected to be released shortly. Finfish and shellfish sectors participated in the negotiation of the Plan. It identifies all of Clio Channel as a Special Management Zone with an emphasis on shellfish aquaculture, which was of particular interest to First Nations at the table. We are accordingly of the view that the subject applications do not conform with the provisions of the NVI Marine Plan.

8. Transport Canada – navigational issues

The two proposed finfish sites in Clio Channel would be a hazard to navigation as they are situated above and on shrimp habitat that currently supports a significant fishery. Shrimp trawl fishers have been complaining since the establishment of the Bennett Point site that anchors are currently impeding harvest. The extensions proposed to the existing shellfish tenures would further impair the safety and efficacy of that fishery.

Cracroft Inlet and Lagoon Cove are used as anchorages for both commercial and recreational boats. The Wa-kwa site impedes the entrance to Cracroft Inlet for those seeking easy access in poor weather for shelter.

Cracroft Inlet is a First Nations’ recreational and commercial fishing location for bivalves and crab and if the Wa-kwa site were to be approved numerous harvesters would require access through the salmon farm site.

Having three fish farms in this small area will also concentrate the setting of prawn traps increasing the potential conflicts with other users such a log tows and recreational boaters.

Conclusion

All regulators of salmon aquaculture have admitted that there are important knowledge gaps concerning the interaction of salmon farms with wild ecosystems. These gaps have been examined at enormous public expense and resulted in clear recommendations from the Cohen Commission of Inquiry into the Decline of Sockeye Salmon in the Fraser River to adopt a precautionary approach to the industry until such time as those knowledge gaps have been filled.

Those recommendations were a catalyst for some caution: the Provincial government has seen fit to issue no new salmon farm tenures in the Discovery Islands until 2020, a date suggested by the Commissioner by which time he stated that some agency ought to have determined what

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It is self-evident that the same concerns apply to salmon farm interaction with wild stocks of fish and shellfish everywhere; and that the fish and shellfish of the Broughton Archipelago that support northern First Nations and coastal communities are equally vulnerable to the negative impacts of salmon farming.

We submit that the subject applications should fail, not only on the basis of existing siting guidelines as outlined above, but because the cumulative effects of siting 3 farms in such close proximity have not been properly assessed; are poorly understood but have the potential to amplify the documented negative impacts that can result from salmon aquaculture.

Separation of finfish aquaculture from the wild environment through land-based systems, such as the Namgis First Nation’s Kuterra farm, would be a precautionary and risk-averse solution that permits the industry to make a positive economic contribution while protecting the existing economies of North Island First Nations and coastal communities and the marine environment.

Yours truly,

Karen G. Wristen Executive Director

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