Ms. Madhu Malhotra…

Ms. Madhu Malhotra
Manager
Ministry of the Environment and Climate Change
Climate Change and Environmental Policy Division
Land and Water Policy Branch
135 St. Clair Avenue West
Floor 6
Toronto Ontario
M4V 1P5
Phone: (416) 314-1702 (416) 314-1702

Response to MOECC
EBR Registry Number: 012-7186
Title: Provincial Policy Objectives for Managing Effects of Cage Aquaculture Operations on the Quality of Water and Sediment in Ontario's Waters
Ministry: Ministry of the Environment and Climate Change
Date Proposal loaded to the Registry: March 31, 2016

GEORGIAN BAY FOREVER COMMENTS ON THE MINISTRY OF THE ENVIRONMENT AND CLIMATE CHANGE PROPOSED "PROVINCIAL POLICY OBJECTIVES FOR MANAGING EFFECTS OF CAGE AQUACULTURE OPERATIONS ON THE QUALITY OF WATER AND SEDIMENT IN ONTARIO'S WATERS"

1.Federal Review underway that should be completed prior to any changes to the guidelines.
Fisheries Minister Dominic LeBlanc announces a widespread review of the way natural resource development projects are granted permission to proceed in Canada. DFO will be part of this review and specifically Minister LeBlanc is quoted saying that "his government is launching the review process to fulfil a campaign promise to 'review the regressive changes made by the previous government, and restore lost protections and incorporate modern safeguards in the Fisheries Act.'"
RECOMMENDATION: In light of this review, GBF would urge the ministry and Ontario Government to defer any changes until such review is completed.

2.INTRODUCTION - PURPOSE AND APPLICATION "The provincial environmental policy objectives for cage aquaculture apply to existing operations, as well as proposed expansions and new operations where the proposed annual feed allocation does not exceed 2,500 tonnes (metric) of low phosphorus feed, which is the maximum feed allocation of the largest existing cage aquaculture operation in Ontario."
Low phosphorus does not mean low BOD/COD which can lead to localized anoxia with a variety of impacts. Focussing on the sediments and water quality are only surrogates for the health of the food web. Since this can be assessed by more direct means, any omission of direct ecosystem impairment metrics such as biodiversity, relative abundance of species, stress indicators, invasive species proliferation etc., will overlook important and unanticipated direct and indirect impacts of these open cage aquaculture operations.
For example, our recent research indicates that there may not be a benthic invertebrate pathway for assimilation but rather that the assimilation occurs through uptake by Cisco into the top predator species. These pathways can be traced in the environment as per existing research reported to Georgian Bay Forever.
RECOMMENDATION: Complete research on localized food web energy flows using state of the art techniques to follow nutrients through the food web to characterize the actual assimilation pathways. GBF is in process on this research.
RECOMMENDATION: An exhaustive biodiversity inventory using DNA barcoding techniques be undertaken as part of the approval process. GBF is in process on this inventory collection.

3.Differential approaches to farm practices in the open waters of the Great Lakes vs. land based husbandry effluent requirements amounts to unfair subsidies.
RECOMMENDATION: Water treatment systems be installed by open cage aquaculture operators to diminish the impacts of the operations on the pristine waters of Georgian Bay.
RECOMMENDATION: Suspended mats be installed beneath the cages to catch and hold all overfeed.
RECOMMENDATION: Cultured Fish should be sterilized to eliminate impacts of certain enclosure failures and escapes. While sterilized escaped fish would still directly compete with native populations, at least they will not establish competitive non-native populations in the long term.
RECOMMENDATION: Special levies to properly allocate externalities to this industry that would be used to promote this longer-term objective will ensure that resources that could be focussed on the native fishery are not misallocated.

4.Long term sustainable industry should be focussed on re-establishing a health open water aquatic fishery compatible with and including native fish species.
RECOMMENDATION: Instead of an ongoing monitoring protocol, the Long term, sustainable and overall least costly objective of the Ministry should be to re-establish the substantial native fishery in the waters of Lakes Michigan-Huron-Georgian Bay instead of piece meal approaches like open cage Aquaculture that will only serve as a hindrance to the achievement of that sustainable, long-term focus.

[Original Comment ID: 194052]