Comments & Feedback

As Mayor of the Town of Harbour Breton, our town has been fortunate to have the aquaculture industry as a main employer. We have seen so many economic benefits such as: * A significant increase in full-time year-long employment * Over 200 people directly employed in the processing plant and countless others on farms and in service to the industry. *Harbour Breton has seen the creation of 3 new housing development since the expansion of the industry. * There is a zero vacancy rate for house rentals and a wait list for new house being built. * Construction is currently so busy people cannot even get a quote for renovations as the new housing development has everyone too busy. * 100's of driveways were paved in the last 3 years improving the look of our town. * A high percentage of existing houses in Harbour Breton have new siding and decks. Our town has become more colorful and tidy looking. * Local businesses are booming, expanding and new businesses are opening doors. There is much more disposable income in this town. * We enjoy expensive new infrastructure such a the new 5.3 million dollar wharf. * Schools are full of young children and the town is filled with young working families. * This is just the Harbour Breton experience....there are many communities in the Coast of Bays having the same experience. Thank God for aquaculture!!!!

Promotion of open net pen finfish aquaculture has aggressively been pursued by NSDFA, whereas their legislated responsibility to manage and regulate it, so as to protect fish and fish habitat, has all but been ignored, as I have noted in detail in my submission for the panel’s review. Not all aquaculture is alike. Communities are hopeful that this Panel will delve into the considerable number of environmental, economic and social issues facing the communities where these large open-net finfish farms are located. And that your proposed recommendations and regulations for Nova Scotia’s finfish aquaculture industry will truly be forward thinking. Open net pen finfish aquaculture is not in the best long-term environmental, social and economic interests of these communities or the province. It is not in the best interests of the province to pursue and financially support open net pen finfish feedlots. They are NOT sustainable. NS Government could instead take the lead and financially support land based closed containment finfish aquaculture. They should not be continuing to support an unsustainable and outdated industry model. The open net pen finfish aquaculture model/operation today is flawed. The industry applies basically the same techniques/model that it used for a 5000 fish farm of 30 years ago. But things have changed. These finfish feedlots now stock upwards to 1 million fish. ( In the case of St. Mary’s Bay, there are 2 sites of 1 million fish each less than 1250 metres apart.) Even with open net pen ‘best industry practices’ there are dire consequences to the marine environment, traditional fisheries and communities. Why? With the size and intensity of these ‘new’ larger operations come disease, sea lice infestation, and significant degradation to the marine environment. Please consider these facts: • Routinely these operations dump into the bay thousands of tonnes of fish feces and waste feed each production cycle. This causes overnutrification which can, and has, lead to dead-zones on the sea bottom. It can also lead to the spread of algal "blooms" - massive blankets of green slime on the water's surface that precipitate bacteria growth, deplete oxygen, and kill much of the life in the water below. • Sunken feed barges can and have occurred – further adding to overnutrification. • The government ‘regulates’ open net finfish feedlots by ‘monitoring’ only. (But Monitoring is Not regulation. Rather, it is at best a statement of what has already occurred. ) • The operations use therapeutants/pesticides (legal and illegal) to combat disease. These are released into the waters and can be/have been lethal to non-target species (such as lobster). • There are large fish escapes (reported and not reported) often due to weather damaged pens, which put wild salmon at further risk. • Shore residents and communities are plagued by noise, odours, polluted shores, decrease in property values, etc. from this industrial nuisance. • There have been large numbers of fish infected with the ISA virus. This has cost the public monetarily (tax dollars awarded to the company). There is a potential cost to public health. What scientific research shows ISA is not harmful to humans? And... viruses mutate. Diseased fish may be costly to Nova Scotia’s trade - their reputation as a healthy food source could be tainted. (When the CFIA approves sick salmon to be processed and sold –this exemplifies that ‘regulations’ for this open net pen industry mean little.) These are but some of the consequences of these outdated, flawed operations. Can you regulate these consequences out of this flawed model to make it sustainable? No. Is it likely that this type of operation can be regulated to integrate and advance environmental protection, social well-being, and economic opportunity in Nova Scotia, as is stated for this 'regulatory framework'? No. And, even if you have regulations, could they be enforced? There are no means to enforce regulations. It appears the Panel has been given an impossible task if for finfish aquaculture they must regulate the open net finfish aquaculture model. This Panel has been charged with finding the right way to do the wrong thing. But, unfortunately there is NO right way to do the wrong thing. It is past time that finfish feedlot operators bear all of the costs of their operations. For aquaculture operations: Oxic conditions must be maintained in our waters, pesticides must be kept out of our waters, and farmed finfish must not escape into the wild. The finfish farming industry must be forced to abide by strict standards, which must include these components. If the finfish industry is not able to do this in their open net pen operations with the size and density of the sites today , then the government must ‘regulate’ this industry into changing its thinking, strategies and actions, and pursue the development of technological innovations that will allow growth while preserving and protecting Nova Scotia’s natural resources. For finfish aquaculture, this could be accomplished by land based closed containment systems, with the government establishing a time frame in which this conversion to closed containment will occur. Companies already use land- based operations to grow to smolt. Yet to date the open net industry laments that the costs of total land based closed containment systems are too high. But the costs for them NOT to do this are too high for Nova Scotia’s environments and economies – both from marine and community perspectives. Above 50 percent return on investment has been reported for open net finfish operations. These extraordinarily high returns on investment are accomplished by the companies not investing in disposal systems for their operational wastes, instead shifting these costs to the marine environment and communities. We are in an era of having to deal with scarcity. We can ill afford this industry to exploit our resources any longer. Furthermore, there are cost savings from closed systems for finfish aquaculture producers. These would alleviate the costs of disease and fish escapes; produce a healthier product for consumers, in likely a shorter production cycle; and produce other saleable products. I am hopeful that the panel’s work might not just support current policy objectives (to regulate an industry that should not be there in the first place), rather the panel‘s work will look to support and help shape a truly sustainable future for aquaculture in Nova Scotia. Not all aquaculture is alike. Not all aquaculture is sustainable. Our communities want aquaculture, but that aquaculture must maintain a healthy/oxic marine environment, produce healthy products, increase employment, not displace traditional fisheries, not put wild fisheries / wild fish at risk, and not compromise our quality of life. Our futures depend on it. Land based closed containment systems for finfish aquaculture is welcomed, as well as shellfish farming. These can meet the objective to grow aquaculture for the Province, and would be sustainable. The message from fishing communities is:“NO OPEN NET PEN FINFISH AQUACULTURE”.

Dear Professor Doelle, Attached to this e-mail is a somewhat updated version of the handout I gave you when you were in Shelburne on July 18,2013. As I mentioned to you when you were in Shelburne, I have spent the better part of my professional career as a scientist and regulator at both national (USA) and international levels. I have also commented extensively on the regulatory process here in Nova Scotia and this material appears on our website: www.friendsofshelburneharbour.org Thank you for your attention. Sincerely, Herschel Specter Friends of Shelburne Harbour

Numerous reports on the regulation of aquaculture appear on the Friends of Shelburne website, www.friendsofshelburneharbour.org Please look under the heading of Newsletters. This submittal forwards one of these letters and deals with NSDFA's Enforcement Failures. Thank you, Herschel Specter

Letter # 22, Regulating Finfish Aquaculture, from the FriendsofShelburneHarbour website is attached. Thank you, Herschel Specter

Letter # 23, dealing with the Jordan Bay and Blue Island sites, from the friendsofshelburneharbour.org website is attached. Thank you, Herschel Specter

Attached are 12 short letters that deal with different aspects of finfish aquaculture in Nova Scotia. Thank you. Herschel Specter

While this panel is concerned with all aspects of aquaculture I am going to focus my comments on finfish aquaculture and its economic impact on me and my community. The enviromental issues I will leave up to the experts and trust that they will not allow the industry to ruin the environment. Cooke Aquaculture is a finfish producer that has several farms in the Shelburne area and elsewhere in the province. Their intentions are to build a processing plant in the area that will employ in the neighborhood of 360 people. Cooke Aquaculture has been a major boost to the local Shelburne economy and in the future will be a huge player in the future of Shelburne. It has one of the bigger private payrolls in the area and when the plant opens by the end of 2015 it will probally be the largest industry payroll locally. Their payroll and the associated spinoff jobs will mean that the hospital will still be here, the schools will be full, there will be such things as a shoe store, a clothing store, another grocery store. It will mean that a seat in a restraunt will be hard to get as well as a parking space or a motel room. The local economy will boom. The tax base that they will create, the plant and homes of the workers, will allow the local governments to provide more services. The provincial and federal services that are funded by their level of use will be maintained and increased. The other day a couple came into my store that I didn't recognize and in conversation with them I found out that they had bought property around here and had moved from BC. He was orginally from the area and moved back to take a job with Cooke's. What a pleasant surprise that was. West to east migration, a new trend, wouln't that be nice. I hope that the results of this panel will be a set of rules that, at the same time, protects the envirnoment and allows the industry to grow and posper. Thank you.

Antigonish Rivers Association submission to the panel

Dear Professors Doelle and Lahey: I was unable to attend the Sep-09 meeting on aquaculture regulations, and appreciate this opportunity to make inputs by email. As Director of the Sage Environmental Program, a Nova Scotia based funder of environmental projects, I am in a position to stay current environmental issues in the province, including those pertaining to aquaculture. Open-net pen salmon and trout aquaculture has expanded quickly in Nova Scotia in the past few years. In each case there has been been opposition from communities, conservation organizations, commercial fisheries and other concerned citizens. It is my impression that these concerns have not been properly addressed, so I am pleased that your panel has been formed to take a more full assessment of the regulatory requirements. You have heard from the Atlantic Coalition for Aquaculture Reform (ACAR), the Coastal Alliance for Aquaculture Reform (CAAR) and the Ecology Action Centre (EAC). It is a matter of record that open-net pen fish farming has had negative environmental and social impacts in every part in the world where it exists. Nova Scotia is particularly vulnerable, in that our rural economy is highly dependent on a pollution-free marine environment where the commercial lobster fishery, recreational wild salmon fishery, and the tourism industry support thousands of families in coastal communities. These livelihoods in many cases are now threatened by open-net pens. The environmental impacts of open-net pen aquaculture include: pollution of the marine environment through feces, excess feed, anti-foulants, pesticides and farm debris; disease outbreaks and parasites that may be transferred to wild fish; use of chemicals that are harmful to other marine species; impact on the stocks of wild fish used for feed; escapes that threaten already fragile populations of wild Atlantic Salmon; and privatization of coastal areas, displacing traditional fisheries with little to no public benefit. The current regulatory system in Nova Scotia is very weak. It does not adequately monitor environmental impacts, and when thresholds, such as sediment sulphide levels, are reached, there is little to no enforcement that ensures remediation via discontinuation or substantial reduction of operations. We need an improvement in compliance with existing regulations as well as strengthening of regulations and the regulatory process, including proper attention to concerns of affected communities. All monitoring results must be publicly accessible in a timely manner, which has not been the case in recent years. The recommendations of the Cohen Commission are pertinent to Nova Scotia, in particular the need to separate out the competing and conflicting priorities of regulation and promotion both housed federally in the Department of Fisheries and Oceans and provincially in the Department of Fisheries and Aquaculture. At the provincial level we see a strong alignment of the government with industrial interests, with government positions in the Dept. of Fisheries and Aquaculture often filled by people from industry. Federal statutes protecting the environment have been weakened in recent years, partly to facilitate the growth of industries like open net pen aquaculture. I concur also with the results of the Royal Society of Canada panel report on impacts to marine biodiversity, and recommend that Nova Scotia use science as a basis for decision making in all issues related to aquaculture siting and regulation. We need the aquaculture industry to respect and not degrade the ecosystems in which it is located, to work in harmony with the economic, social and cultural activities that use the same resources, to cover their true costs of production including environmental (which are currently externalized), and to retain the opportunity of future generations to use the same natural resources. Many of the requirements that the industry must be required to meet are just common sense, like not using the ocean as a free dump for waste. More specifically, the industry must use technology that eliminates the risks of disease and parasite transfer to wild fish, prevents escapes of farmed fish into the wild, and assures that untreated waste is not released into the ocean. The industry must develop feed for farmed salmonids that does not deplete fish stocks around the world. It must eliminate the use of chemicals, antibiotics, pesticides and genetically modified fish, and stop locating fish farms in areas opposed by local communities. The product should be labelled as "farmed" so that consumers can make informed choices. There is a valid alternative to open-net pens for raising salmon and trout, namely closed-containment systems, which eliminate or mitigate the key environmental impacts. The industry and government are on record saying that the economics of closed-containment are not viable, but evidence is to the contrary. Nova Scotia should be investing in this opportunity area. I am not against aquaculture in general. Shellfish operations have been shown to be sustainable in the right scale. However we need innovations in aquaculture that avoid or greatly mitigate the impacts of open-net pen farming. There needs to be a plan for rural economic development that protects habitats and coastal lands, and respects traditional fisheries, tourism and landowners. Open-net pen farming must conform to it. Your task of developing recommendations for a set of aquaculture regulations that will assure a truly sustainable industry is not an easy one. It is complicated by the strong bias of existing governments to industrial interests, where the regulatory role seems to have been largely abandoned in favour of becoming only a promoter of the open-net pen industry, even at the expense of other rural industries. I have great respect for you and look forward to the months ahead. Graham Smith www.sagegreen.ca

If the clock were turned back and this panel were formed to "regulate" the pollution of Halifax harbour by the huge influx of human feces via sewers, a reasonable person would conclude that the panel was part of the process of stopping the pollution. In the case of open pen aquaculture, the concentrated influx of huge amounts of feces is not from humans but from fish, but it is feces nonetheless with all the destructive, deleterious effects that that entails. So, surely it is reasonable that a panel set up to "regulate" this mess has the aim of removing it, just as in the case of Halifax harbour. Most comments here and elsewhere seem centred on the need for jobs, economic issues and so on. Of course these are considerations, but unless they are achieved without damage to the ecology, they cannot be sustained and are not worth it. Of all the pointers against open net pen aquaculture, the spewing of vast quantities of fecal matter is the one unarguable issue - it is bad and it cannot be justified. The are many other salient arguments against such aquaculture, but the fecal issue is one I personally look to this panel to overcome. The Halifax harbour pollution debacle arose from the ignorance of past generations, understandable in the context of history. What possible justification could there be, on sober consideration, for allowing the current practise of fouling our coastlines? Nova Soctia has been known for it's pristine environment. I have to place that in the past tense, more than anything because of the influx and effects of these fish farms.

Excerpt from a February 2010 National Geograpgic magazine about Patagonia, Chile (minus the pictures): "Salmon companies came to Chile because the fjords were unspoiled. That is no longer the case. Floating pens hold salmon being raised for export to foreign markets. Fish are fed pellets containing fish proteins and antibiotics. Intensive production methods have led to pollution and the spread of infectious salmon anemia. The industry's solution - even as output falters - is to move south to pristine fjords, leaving behind waste, disease, and oxygen-depleted water". How in heaven's name can anyone thing this won't happen here? Do you somehow think our ocean is different? Do you or the companies think you are "smarter" and this scenario won't repeat itself? Please pay attention to what has happened in other countries and try not to repeat the same mistakes. The planet cannot repeatedly recover from our disastrous actions based on short-term thinking.

I live in Shelburne County and I am very concerned with the open pen fish farming in Jordan bay. They haven't been installed for very long and already the other fishing in the bay has been affected. I have strong concerns about the degradation of the water habitat due to fish waste and pesticide use. I strongly disagree with permitting the sale of infected fish.

So far I know of two salmon pens which have been found drifting in the water on the Eastern Shore. They have been towed to land by area locals as they posed a theat to navigation and boating. In one case the company was contacted but have not canme to claim the pen. Just another reason that open pen farming is a bad idea. Let alone where have all the fish gone that were in these pens.

To Whom It May Concern: I am not a scientist nor an expert in the field of aquaculture - I am just a citizen concerned about the enviroment in Nova Scotia. I recognize that economic development is important in Nova Scotia but at what cost to the environment? Based on what I have read, I believe that the best decision long-term is to protect our beautiful coastline and environment. If our coastline becomes contaminated, where does that leave our tourism industry? Where does that leave future generations? I respectfully ask that decision makers seriously consider the environmental impact of fish farms and make the decision that protects our coastline for future generations. Let the environment win over profit. Concerned Citizen

As a local SCUBA dive master I have made many dives around the province and the world. Many people are supprised when I tell them Nova Scotia has some of the best diving around! Several years ago I was asked to dive near a fish farm in Port Mouton Bay NS to see what the bottom would be like around the pens. The area has a beautifull white sand bottom in all areas except near the farm. We dove one quarter mile away from the pens and could not see the bottom as we decended. When we got to the bottom the sludge was as deep as my arm was long! We took a yard stick on our next dive and it was at least 36 inches deep. There was no bottom life to be found just a wasteland. Check out our story on www.friends of portmoutonbay.ca

6032 Charles St, Halifax NS B3K 1L1 October 25, 2012 Re: Public Consultation on regulatory framework for aquaculture industry Dear Panel Members: In mid-July 2013 I attended a public consultation session on aquaculture in Mabou, Cape Breton. At that time I raised a number of points which I thought were relevant to both the information gathering process and the outcome. Please consider this letter a brief summary of some points I raised in that submission. In 1992 I participated in a research project on the salmon aquaculture industry in the Bay of Fundy. The conclusions made then are the same as the conclusions now with the exception that what is now known is more clearly understood. There is no business case for open-pen salmon aquaculture in any measure. The number of direct or indirect jobs promised is never realized. There is a substantial and consequential negative effect on marine environment and wild salmon, that the government has no real capacity to monitor, measure, regulate, prosecute or remediate. There is scientifically proven harm to existing fishery related industries. There are several differences between what was understood in the early 1990s and now. In the early 1990s the Atlantic Salmon Federation supported open pen salmon acquaculture, in part as a way of repopulating the streams, rivers and Bay of Fundy. Presently it no longer supports open-pen farmed aquaculture. Another change is that it is more widely acknowledged that the industry uses large amounts of pesticide and that the quality of the farmed fish, based on scientific research, is harmful to human health when eaten. As well there is an extensive body of scientific evidence demonstrating the fragile state of all oceans and their ecosystems. Dr. R. Myers from Dalhousie clearly and scientifically determined that over 90% of the oceans biomass has been removed in the past 50 years. The remaining species are living in an increasingly precarious environment with the effects of pollution being compounded by changes due to global warming. The scheme of economic salvation promised to communities serves to split and harm the community itself as there is no vehicle for rational debate and resolution. The major corporate aquaculture players, since the late 1980s, have sequentially outmanoeuvred governments in Scotland, Norway, Chile, Peru and Atlantic Canada as jurisdictions began to identify problems and develop regulations, by relocating and recommitting to be the next best thing for coastal communities economic redevelopment. Based on scientific evidence, the Royal Society of Canada 2012 report concludes that the key impact of open pen fish farming are: http://rsc-src.ca/sites/default/files/pdf/RSCMarineBiodiversity2012_ENFINAL.pdf Major Impacts of Open Net Pen Aquaculture on Marine Biodiversity · open net pen aquaculture (e.g., salmon, trout) can affect biological diversity in an area several kilometres from a farm operation, although farther-reaching impacts are possible. · Wild bottom-dwelling organisms and their habitat can be affected by the large volume of organic and dissolved nutrient wastes and chemical inputs, such as antibiotics, anti-foulants, and pesticides that are released from open net pen farms; an open net pen farm producing 500 tonnes of fish will typically release 100 tonnes of waste directly into the environment . · Exchange of fungal, bacterial and viral diseases and parasites such as sea lice between farmed and wild fish can seriously threaten the persistence of wild fish populations. · Interbreeding between wild fish and escapees of the same species threatens the reproductive capability and recovery potential of wild populations of conservation concern. There is no justification for either the provincial or federal government to be permitting or subsidizing open pen farmed fish aquaculture in our coastal waters. I am dismayed that based on what is scientifically known the government is using a public consultation process to determine what clearly should be a unequivocal "No". Yours truly, Peggy Cameron B.Sc., M.E.S.

I'm just curious to know how many millions of dollars Nova Scotia has paid out for fish farms thus far. I would also love to know what the payback's been for the province other than ruining our pristine bays with fish poo sludge, damaged shores, the other affected industries (rock weed harvesting, periwinkles, etc.) and shelling out millions of bucks for the fish farm follies.

I am a retired commercial fisherman and have been Harbour Breten many times and have many fisher friends in Harbour Breten and know many South Coast of Nfld. fishers who live and fish out of Lunenburg couny N.S. I have talked to many of these persons plus merchants in Harbour Breten and they ALL tell me that these clumps of new houses have been buily by young persons working in the oil fields of Alberta or employed inthe Nfld offshore oil industry. They tell me that not one of these new homes have been built by any salmon aquiculture employees.

I am a retired commercial fisherman and have been Harbour Breten many times and have many fisher friends in Harbour Breten and know many South Coast of Nfld. fishers who live and fish out of Lunenburg couny N.S. I have talked to many of these persons plus merchants in Harbour Breten and they ALL tell me that these clumps of new houses have been buily by young persons working in the oil fields of Alberta or employed inthe Nfld offshore oil industry. They tell me that not one of these new homes have been built by any salmon aquiculture employees.

Please consider Wild Coast's submission in your deliberations.

This submission is presented by Wild Coast Conservation Inc. (Wild Coast) to address the issues created by open net pen aquaculture operations raising Atlantic salmon in inshore areas of coastal Nova Scotia. 1. Open pen aquaculture has been found to have negative impacts to the environment and wild native species (including commercial species) by scientific and governmental inquiries in other jurisdictions. These risks are especially significant in Nova Scotia, because the economies of many areas of the province rely on commercial fishing (including lobster). Recommendation: Follow a precautionary approach and adopt recommendations from other formal inquiries. Phase out open net aquaculture in Nova Scotia. 2. Many of the islands and coastal areas of the Eastern Shore have special, rare or unique ecological features. Many of these islands have been selected by the Province for conservation as places of unique ecological habitat. The establishment of large net pen aquaculture operations in the inshore waters around these islands is contrary to the conservation objectives for the area. Recommendation: Phase out and exclude aquaculture operations from inshore areas where lands and islands are designated as conservation and protected places. 3. The Department of Fisheries and Aquaculture serves as both "Regulator" and "Promoter" of the aquaculture industry in Nova Scotia, which is a clear conflict of interest. Other formal inquiries such as the Cohen Commission have recommended the separation of these roles to different departments of the Government. Recommendation: Separate the role of promoting the aquaculture industry from the Department of Fisheries and Aquaculture, whose role should be that of regulation and enforcement. 4. Open net pen aquaculture is an attractive business only because of government subsidies and because the operators bear no cost or responsibility for the waste discharged, the associated damage to the marine environment and the associated risk to the commercial fishery. Recommendation: Promote the development and adoption of closed pen, land-based aquaculture as the sustainable alternative model for Nova Scotia. 5. Open net pen aquaculture was developed for deep water fiords and coastal areas, not the shallow water inshore bays typically selected for sites in Nova Scotia. Shallow water inshore bays have very different oceanographic conditions relating to a site’s ability to naturally attenuate solid waste discharges from aquaculture. Recommendation: Conduct environmental research and public consultations to develop "zones" with conditions suited to finfish aquaculture. It is reasonable to assume that the range of sites suitable to closed pen aquaculture with improved waste treatment processes will be greater than those for open net pen systems. Use this environmental data to support the development of a sustainable aquaculture industry. 6. The aquaculture industry has failed to provide adequate environmental impact assessments (EIAs) in their previous and current applications. Data related to fishing efforts and biota is often missing, or drawn from locations dozens or hundreds of kilometers from the proposed sites. The shallow water inshore bays typically selected for sites in Nova Scotia have oceanographic conditions that vary greatly over very short distances. Recommendation: The Regulator should establish specific criteria for conducting site assessments for any inwater fish pen operations. These criteria should include, but not be limited to, establishing the following requirements: - data provided in EIAs must be specific and proximate to the proposed site - studies to identify seabed flora and fauna at the location and surrounding environment - studies to identify pelagic and demersal species and migration routes for marine and avian species in the area of the site - plans to engage the local community, first nations and fishermen in identifying users and the commercial/social value of sites and surrounding area. - plans and commitment for a solid waste management strategy for each operation - plans and commitment for an economic benefits strategy for local communities. Wild Coast Conservation Inc. appreciates the opportunity to provide this submission to the Panel. The submission provides more detail and discussion on these and other recommendations.

Slow Food in Nova Scotia has developed a position paper on open-net-pen-farmed Atlantic salmon (Salmo salar). The intent of this paper was to examine the issue of farming Atlantic salmon in open-net pens, applying the international Slow Food principles: namely GOOD, CLEAN and FAIR. Having applied these principles as we examined the information available to us about current aquaculture practices and conditions, we express our wish to see them govern all aquaculture regulations, without exception, in Nova Scotia.