1.....It is inappropriate…

1.....It is inappropriate and inadequate that the cage aquaculture operator/applicant is responsible for measuring baseline variables before the facility is allowed to proceed or continue or expand. I t is like wise highly inadvisable that the operator collect/monitor the ongoing effects of the facility on the water and sediment quality. Integrity would be seen with an independent source, or an impartial government agency obtaining the baseline readings and measuring the ongoing effects, or at least a government source whose priority is the protection of the resource, that is, water and sediment quality. It should also be clearer how often the ongoing measurements will be taken. Finally, the MOE/MNR can be 100% transparent with sharing the data collected on the effects of cage aquaculture facilities, but if the data itself is suspect, as it most assuredly is when measured by the operator, it is useless.
2......It is very worrisome that applications for large/expanding operations to and in excess of 2 500 metric tonnes of low phosphorous feed, will be allowed to go ahead without the necessary specific regulations in place. It is very difficult to change things retroactively. The damage will be done before something is done about it. That has been our experience with the facility on our lake started in the 1980's when fish farming was new and there were very few regulations or guidelines. There should be a moratorium on operations at and in excess of 2 500 metric tonnes until due diligence is done by the government agencies tasked with protecting environmental integrity.
3....An additional problem that causes concern is the use of phrases such as "may be required", "should minimize", and "it is recommended that..." These phrases do not inspire confidence as they lack teeth and objectivity. One of many good examples of this is Policy Objective #: Water Quality - Nutrients.

[Original Comment ID: 194053]