Re: Sediment monitoring…

Re: Sediment monitoring requirements for farms with a feed quota greater than 2,500MT.

First ,during years of public consultation there was no indication that the new sediment monitoring guidelines would only apply to farms smaller than a certain size. The parties to the consultation , including industry and the GBA , were led to believe that the new sediment guidelines would be the standards for the industry going forward.

Secondly , MNRF and MOECC have consistently taken many years , often decades to develop aquaculture policy. The consultations for the co-ordinated guide were completed in 1996 and the guide has just been finalized. The sediment policy took at least 10 years to complete.

Third , new license applications are likely to require assurances that they will be able to fully develop a new farm to an economic size. Economic viability is a shifting goal but viable new farms in the future may need to be larger than 2,500MT feed quota particularly if new open water technology is used. The expensive and time consuming application process contributes to the need for new farms to be much larger than established farms.

Lastly , there is no technical justification for the 2,500MT. No modeling or calculations have been used to determine farms larger than 2,500MT are more likely to create environmental problems. 2,500MT is not a large feed quota compared to some farms. A freshwater trout cage farm in Washington State uses more than 22,000MT/year at full production with no adverse environmental impacts.

In consideration of the four points above , I strongly suggest that an interm policy applicable immediately , be adopted for farms larger than 2,500MT and that a clear time frame be developed for finalizing this policy. The interm policy could include some , or all of the following:
- Enhanced sediment monitoring for a number of years , perhaps every 2 years.
- Required reduced depositional loading rates through fallowing , cages that move , reduced densities etc.
- A "laddering" of the available so the quota starts at a lower level then increases at set intervals providing specified environmental criteria are met , i.e. the current sediment and water quality standards.

Finally ; MOECC should be implementing this policy through their own legislation. There is nothing in the FWCA that allows sediment conditions to be put on an aquaculture license. Sediment is not water quality except for the purposes of the act where water quality is defined as including substances that fall out of the water.

[Original Comment ID: 193702]