18 Fenwick Avenue.
Toronto, ON M4K 3H3
May 26, 2015
David Gonder
LAKE MANAGEMENT SUPERVISOR
Ministry of Natural Resources and Forestry
Provincial Services Division
Fish and Wildlife Services Branch
Upper Great Lakes Management Unit - Lake Huron
1450 Seventh Avenue East
Owen Sound Ontario
N4K 2Z1
EBR Registry Numbers “012-3945, 012-3946. 012-3947, 012-3948, 0123949, 012-3950” – Issuance of aquaculture licences for cage culture.
Reference:
Dear Mr Gonder,
We are responding to all of the above captioned EBR notices in one letter in part because
we feel that all of these licensed aquaculture operations should be evaluated on their
cumulative environmental impact.
The cumulative annual output of phosphorous that the licensees release from their farms
into public waters, based on the previously approved feed quotas, was 46 tonnes (see
Exhibit A). We note that some of the licences that are being renewed have higher feed
quotas. Cumulatively the increase in feed quota is 20%. We believe that this will translate
directly to an increased total phosphorous release of over 55 tonnes per year.
We are concerned with this significant increase in pollution from this industry.
It has been argued that the phosphorous loading from the previously approved licences
has not been shown to have detrimental environmental impact. The pictures taken by
Kelly Amber Hille of a Blue Green Algae bloom adjacent to the Wolsey Lake fish farm
challenge this assumption. The portion of her report that focuses on Lake Wolsey
concludes in part, “even though the aquaculture operation may not be the main impacting
agent on the system, it still plays a part. Every new invasion, every added nutrient and
every physical change to the system adds stress to this already highly disturbed system.”
There is a growing body of evidence worldwide that aquaculture does indeed
significantly impact local aquatic environments. Some of the phosphorous that fish farms
release is readily bio available as it is in a soluble form. The phosphorus that is less
readily available (in uneaten food and feces) sinks to the lake bottom. Recent research
conducted on the algae blooms in Lake Erie has concluded that some of the nutrient
loading that triggered these blooms came from phosphorous that was released from the
sediment at the bottom of the lake. Given this we conclude that we should not take any
comfort in the fact that some of the phosphorous output from the aquaculture industry lies
“dormant” in the lake sediment. It is in fact a ticking time bomb that poses a risk of
release which would result in a spike in nutrient loading.
We have argued in the past that the OMNR&F should change the classification that they apply for
screening of cage licences from a Category A to a Category C. Category C projects are those
considered to have medium to high potential negative environmental effects or public concern. Such
classification would trigger a more detailed review by OMNR&F and a greater opportunity for review
and input by the public and government agencies. We believe that such reclassification is warranted at
this time given the significant increase in feed quota that has been applied for by the industry.
We also note that one of the Licence requests this time includes a request for permission to farm fish
other than Rainbow Trout. We feel that, in order to properly evaluate the potential impact of doing
this, the Province needs to apply more rigorous environmental screening.
Our concerns on environmental screening are shared by the Environmental Commissioner of Ontario,
who has regularly stated his concerns in his annual reports including the following from his 2010
Annual Report,
“The ECO is seriously concerned that MNR continues to classify cage aquaculture licences in the
category of lowest concern, given longstanding public anxiety with cage aquaculture in the Great
Lakes and the potentially damaging impacts to the aquatic environment. By MNR classifying cage
aquaculture projects as Category A, MNR absolves itself of all public consultation requirements
when issuing licences, through its Class EA process and through the EBR. The ECO is
disappointed that – five years later – MNR continues to circumvent the essence of the EBR
without a revision to O. Reg. 681/94 or addressing cage aquaculture approval consultation
weaknesses. The public deserves better public consultation on cage aquaculture licences in the
Great Lakes.”
Yours Sincerely,
Bob Duncanson
Executive Director
Georgian Bay Association
cc Environmental Commissioner of Ontario
Exhibit A
Phosphorous Output from Cage Aquaculture in Ontario
(based on previous round of license applications)
Applicant
Approved
Feed Quota
Phosphorus
Pollution(a)
Equivalent
Human
Population(b)
(tonnes/yr)
(tonnes/yr)
(# humans)
Nutrient
Units (c)
Equivalent
Hog Farm(c)
(# hogs)
Northwind Fisheries
Cold Water - Eagle Rock
Cold Water - Eastern Island
Cold Water - Fisher Habour
Meeker's Aquaculture
Aqua - Cage Fisheries
500
621
650
655
510
1,800
4.9
6.1
6.4
6.4
5.0
17.6
28,500
35,400
37,000
37,300
29,000
102,500
274
340
356
359
279
985
1,640
2,040
2,140
2,150
1,680
5,910
Total
4,736
46
270,000
2,600
15,600
(a) Mass balance assuming 1.3% P in feed, 1.25 FCR, 0.4% P in trout, and no escapes.
(b) Calculated from phosphorus discharge loads and population from 3 largest municipal wastewater treatment
plants on Georgian Bay
(c) From Ontario Regulation 267/03 made under the Nutrient Management Act, 2002.
%P in Feed
FCR
%P in Fish
feed composition an body
1.3 %
1.25
0.4 %
lowest available in feed
typical feed conversion ratio
Ronsholdt, B., 1995. Effect of size/age and
P load per municipal WWT
discharged and
0.1721
composition and phosphorous content of
rainbow trout, oncorynchus
mykiss. Water Science and Technology,
Volume 31, Number 10, 1995,
pp. 175-183(9)
kg/person-yr average of reported phosphorus
Definitation of NU
Hogs per NU
17.9 kg/yr
6 hog/NU
populations in cities around Georgian Bay
O.Reg. 267/03
OMAFRA Nutrient Management Table
The Phosphorous calculation is a mass balance.
Mass of P into the water (from the feed quota) = mass of feed used x fraction that is phosphorus
P in = 4736 tonnes food x 1.3% = 61.6 tonnes
Mass of P out of the water (assuming all the fish is harvested and removed) = mass of fish
removed x fraction that is phosphorus
But first we must estimate: Mass of fish removed = mass of feed used ÷ feed conversion ratio
(each species and farming technique has a generally accepted value, for trout AQ it is 1.25 kg of
feed per 1.0 kg of fish)
And second we must estimate the phosphorus content of rainbow trout, which was determined
and published in the peer reviewed paper that is cited.
P out = (4736 tonnes of feed ÷ 1.25) x 0.4% = 15.1 tonnes.
Mass of P remaining in the aquatic ecosystem = P in – P out = 61.5 tonnes – 15.1 tonnes = 46.4
tonnes
And since this is an annual quota, the P load from this operation is 46.4 tonnes/year. Or, you
could say for every 1000 kg per year of feed, you will release 9.8 kg of P.
Exhibit B
The following two pictures are from a research report published by Kelly Amber Hille in
2008 on the effects of cage aquaculture on epilithic biofilms.
Phytoplankton bloom in the near-shore region of Lake Wolsey adjacent to fish farm.
Photo by K. Hille September 2006
Aquaculture cage and Phytoplankton bloom at Lake Wolsey.
Photo by K. Hille September 2006