Office of the Prime Minister 80 Wellington Street Ottawa, ON K1A 0A2 February 17, 2015 Dear Prime Minister Harper: As business leaders, commercial and recreational fishing associations, scientists, lawyers and environmentalists who care deeply about sustainable jobs, prosperous coastal communities and healthy ecosystems, we are gravely concerned about the Department of Fisheries and Oceans’ proposal to, in essence, exempt the aquaculture industry from the Fisheries Act provisions that prohibit the release of deleterious substances into water frequented by fish. We believe the proposed changes, if enacted, will lead to the discharge of increasingly powerful pesticides and other potentially damaging substances into the ecosystem, significantly reduce government regulatory oversight, and damage Canada’s commercial interests as a provider of untainted seafood. Needless to say, these factors diminish our international reputation for environmental protection. The Fisheries Act has been a mainstay of environmental protection for more than 100 years and the section dealing with deleterious substances is key to ensuring that those of us who use Canada’s aquatic ecosystems, be they marine or freshwater, do so in an environmentally sound and responsible manner. This section of the Act has never been used inappropriately or frivolously. It has however been used to stop activities highly damaging to fish and their habitat. The most recent instance involved an aquaculture operator in New Brunswick who pled guilty to violating the Fisheries Act, in illegally using a pesticide at 15 aquaculture sites, over an extended period of time and despite warnings from Environment Canada. The pesticide is known to be toxic to lobsters and was likely the cause of mortality in hundreds of lobsters found dead in lobster traps during the period of illegal use. We are also concerned that as a consequence of these proposed changes; Environment Canada’s role would be eliminated leaving reliance upon Health Canada and the Department of Fisheries and Oceans (DFO) to ensure environmental protection. Health Canada does not have an undivided environmental protection mandate and DFO does not have the capacity to undertake the surveillance work of Environment Canada. The environmental risk assessments currently performed by Health Canada for pesticide impacts are conducted in a manner that is less than transparent based upon proprietary data sets provided by chemical manufacturers. In the case of drugs, the environmental assessments are negligible and Health Canada does not conduct any subsequent environmental impacts monitoring after these same products are put into commercial usage. In our opinion, under the proposed changes, the environment is less likely to be fully considered much to the detriment of Canada’s fisheries and marine life. We are certainly not opposed to aquaculture activities, nor are we in favour of regulatory overlap or ‘red tape’. We are however, strongly in favour of rules and protocol which protect the natural environment and the interests of all Canadians. In particular we are concerned about sectors like commercial and recreational fisheries and tourism which rely upon government to maintain healthy aquatic ecosystems. We believe, the proposed regulatory changes will give the aquaculture industry special treatment under the Fisheries Act. In our opinion, to exempt one industry from environmental laws that will prejudice others can only increase conflicts among co-users of the aquatic environment. If the aquaculture sector is truly to become sustainable, it will have to deal responsibly with the challenges it faces from parasites, animal health and the unfair international competition from countries with poor environmental protection legislation . There is much the Government of Canada could be doing through research and the negotiation of higher international standards to support the Canadian aquaculture industry in facing these challenges. We therefore respectfully ask you and your Cabinet colleagues to instruct the Department of Fisheries and Oceans to significantly revise the proposed regulatory changes to the Fisheries Act to reflect the substantial concerns expressed herein. Sincerely, Stewart Lamont Maria Recchia Dr. Susanna Fuller Bill Ernst Managing Director Executive Director Ecology Action Research Scientist Tangier Lobster Fundy North Fishermen’s Centre (ret.) Co. Association Environment Canada Additional signatories include: Philippe Archambault, Beatrix Beisner, PhD University of Northern PhD Département des sciences British Columbia, BC Institut des sciences de la biologiques, mer (ISMER) Université du Québec à Jean Boudreault Université du Québec à Montréal (UQAM), QC Président Rimouski, QC Fédération québécoise Cory Bishop, PhD pour le saumon atlantique René Aucoin Department of Biology President St. Francis-Xavier Mark S. Boyce, PhD Nova Scotia Salmon University, NS Dept. Biological Sciences Association, NS University of Alberta, AB Jules Blais, PhD Natalie Ban, PhD President Michael Bradfield, PhD School of Environmental Society for Canadian Professor, Economics Studies Limnologists (ret.) University of Victoria, BC Dalhousie University, NS Annie L. Booth, PhD Julia Baum, PhD Environmental Studies Ralph Brown Department of Biology Ecosystem Science and Lighthouse Lobster Inc. University of Victoria, BC Management Program Welshpool, NB Chair, Dean Bavington, PhD Natural Resources and Christian Brun Department of Geography Environmental Studies Executive Secretary Memorial University, NL Graduate Program Maritime Fishermen’s Union, NB President McMaster University, ON Les Burridge, PhD Eastern Shore Research Scientist (ret.) Fishermen’s Protective Dan Edwards Fisheries and Oceans Association, NS Executive Director Canada, NB Area A Crab Fishermen’s Nicola Craig, PhD Association, BC Silver Donald Cameron, Department of Natural CM, ONS, DCL, DLitt, PhD Resource Sciences David Ferguson Author, filmmaker, McGill University, QC President Executive producer of The Lobster Fishing Area 27 GreenInterview.com Anne C. Dalziel, PhD Management Board NS Biologist Victoria and Cape Breton Université Laval, QC Counties, NS Jack Chan Chief Chemist (ret.) Chris Darimont, PhD Jason T. Fisher, PhD City of Toronto, ON Hakai- School of Environmental Raincoast Conservation Studies Omer Chouinard, PhD Scholar University of Victoria, BC Département de sociologie Department of Geography Université de Moncton, NB University of Victoria, BC Paul Foley, PhD Environmental Policy Ratana Chuenpagdee, Gary Dedrick Institute PhD President Grenfell Campus, Canada Research Chair in Shelburne County Quota Memorial University, NL Natural Resource Group, NS Sustainability and Jessica Forrest, PhD Community Development Sinclair Dewis Département de biologie Department of Geography Biologist (ret.) Université d'Ottawa, ON Memorial University, NL Environment Canada, Halifax, NS Susanna Fuller, PhD Ecology Action Centre, Lawrence M Dill, PhD Halifax, NS Professor Emeritus Jessica Clogg, Department of Biological Herbert Gamberg, PhD Executive Director and Sciences Professor (ret.) Senior Counsel Simon Fraser University, Dalhousie University, NS West Coast Environmental BC Law Association Ruth Gamberg Professor (ret.) Ian C. Colquhoun, PhD Dalhousie University, NS Department of Ken Doe Anthropology Biologist (ret.) Gloria Gilbert Chair, Master's in Environment Canada, Coastal Community Environment and Halifax, NS Advocates, NS Sustainability (MES) Prog. The Centre for Nancy C. Doubleday, Barry Glickman, PhD Environment & PhD Centre for Biomedical Sustainability Director, Peace Studies Research Western University, ON HOPE Chair in Peace and University of Victoria, BC Health Peter Connors Department of Philosophy, Jim Gourlay Past President Tony Hooper Centre for Fisheries Nova Scotia Salmon V.P. Resourcing Ecosystem Research/ Association Connors Brothers, NB Marine Institute NS Memorial University, NL Don Hutchens James Grant, PhD President Martin Krkosek, PhD Professor of Biology Salmonid Council of Sloan Research Fellow Concordia University, QC Newfoundland/Labrador, Department of Ecology NL and Evolutionary Biology Spencer Greenwood, University of Toronto, ON PhD Jeffrey Hutchings, PhD Director-Research Faculty of Science Killam Timothy Lambert Scientist Professor Research Scientist (ret.) AVC Lobster Science Department of Biology Fisheries and Oceans, NS Centre, Dalhousie University, NS Atlantic Veterinary Stewart Lamont College, Jack Imhof Managing Director University of PEI President Tangier Lobster Co., NS Canadian Aquatic Brian Guptill Resources Section Alexander Lautensach, President American Fisheries PhD Grand Manan Fishermen's Society, ON School of Education Association, NS University of Northern Ora Johannsson, PhD British Columbia, BC Sandra Hanson, MBA Emeritus Researcher St. Mary's Bay Coastal Fisheries and Oceans Leonard LeBlanc Alliance Canada President Freeport, NS Adjunct Professor Gulf Nova Scotia University of British Fishermen’s Coalition, NS Ahdia Hassan Columbia Invasive Species R. H. Loucks, PhD Coordinator Jeremy Kerr, PhD Friends of Port Mouton Saskatchewan University Research Chair Bay, NS Conservation Data Centre, in Macroecology and SK Conservation Heike Lotze, PhD Department of Biology Canada Research Chair in Luise Hermanutz, PhD University of Ottawa, ON Marine Renewable Biology Department Resources Memorial University, NL Karen Kohfeld, PhD Department of Biology Associate Professor and Dalhousie University, NS James Higgs Canada