GBA Submissions relating to Open Net Cage Aquaculture in Georgian Bay and the North Channel can be found – here
Outline of the Georgian Bay Cage Aquaculture Issue:
- Aquaculture in Ontario originally consisted of many small land-based farms organized under the Ontario Aquaculture Association (OAA).
- In the early/mid 1990s, the Ontario government granted several licenses to operate net-pen (or cage) aquaculture in Georgian Bay.
- Ontario is the only jurisdiction along the entire Great Lakes coastline that allows net-pen aquaculture in public waters. Net-pen aquaculture operations are specifically prohibited in Quebec and in all the US States that border the Great Lakes.
- Aquaculture business owners in Ontario are given free access to public space. They are granted exclusive rights to use a freshwater lot to conduct an industrial operation under the water (high density feed lot), and to use the public trust waters as a dilution sink for the pollution generated (manure, excess feed, antibiotics etc).
- To meet environmental regulations, water lots (referred to by OMNR as Land Use Permits) are sized so that the measurable impact at the water lot boundary is diluted to within standards.
- Environmental standards within the water lot are waived, and the cumulative effect of pollution load is not considered.
- The net-pen business owners do not fully bear their environmental impact:
- The impact is immediately diluted through the water
- It is only measurable slowly through time, after years of operation.
- The net-pen business owner is not responsible for any future environmental remediation.
- This is an aquatic example of ‘tragedy of the commons’, as the environmental cost is not suffered by the business owner, nor even reflected in the cost of the product, but will be borne by the entire public at some point in the future.
- The inevitable environmental damage that net-pen aquaculture can cause has been proven by the irreversible (to date) degradation of the LaCloche Channel site (1) and at Lac Heney (2). The net pen operators in both locations were not required to remediate their damage. Government regulators simply claimed that the operations where sited incorrectly.
- Due to the proven negative consequences of ‘poor site selection’, the precautionary principle should be applied moving forward. However, the principle has been abandoned by government agencies tasked with developing the industry.
- Operational practices such as fallowing and site rotation are purported to be ‘best management practices’ that will ensure ‘environmental sustainability’. This de facto acknowledges the pollution problem of the sites. Aside from the assumption that society has accepted the premise that the assimilative capacity of an aquatic ecosystem should be used to treat an industry’s waste, there is no science to predict the assimilative capacity, and the true damage of net-pen aquaculture will not be known until after the damage occurs. At that point, there is no recourse to restore the aquatic resource to its original clean state.
- By the public subsidy of the freshwater water resources, net-pen fish farmers are given free space, free water, free wastewater treatment, and are waived from environmental standards in their water lots, which gives them a competitive and market advantage over their terrestrial counterparts. As a direct consequence, land-based aquaculture in Ontario has withered as net-pen aquaculture prospered (3). The unfair discrepancy between land-based and net-pen farming caused the industry to split up in 2002. The net-pen farmers formed their own organization called the Northern Ontario Aquaculture Association (NOAA) (4). The land-based component could not compete, and OAA is now struggling as the Ontario Fisheries Enhancement and Aquaculture Association (5).
- NOAA is an industry group representing only four fish farming companies. It receives an unknown, but possibly significant, amount of subsidization funding from Industry Canada’s Fednor program (6), Ontario Ministry of Northern Development (7), Canadian Department of Fisheries and Oceans (DFO) (8), and possibly the Ontario Ministry of Natural Resources (OMNR) (9) and Ontario Ministry of Agriculture and Rural Affairs (OMAFRA) (10). One may reasonably question why a tiny industry with only four primary employers receives such an inordinate amount of resources and promotion from the federal and Ontario Governments.
- In Ontario, net-pen aquaculture is permitted through the Fish and Wildlife Conservation Act (F&WLCA) Section 47 (only 3 lines), and granting of water lots is permitted through the Public Lands Acts. Both acts are managed by the OMNR and treated as Class EA’s. One may reasonably question whether the intent of the Fish and Wildlife Conservation Act and the Public Lands Act was to allow the growth of an agri-food industry inside freshwater lots.
- In Canada, net-pen aquaculture is promoted by the DFO through the National Aquaculture Strategic Action Plan (11). The DFO has an inherent conflict of interest in aquaculture, because it is both a regulator and a promoter of aquaculture – one mandate is to ensure a healthy productive aquatic ecosystem, and the other mandate is to promote the growth of aquaculture. The DFO does not differentiate between ocean (marine) and freshwater aquaculture in regard to the environmental impact. The flushing and assimilative capacity of the ocean is different than freshwater lakes, and therefore requires a different management framework. Freshwater net-pen aquaculture has been proven to have a negative effect on aquatic ecosystems. (12)
- The only government agency raising concerns regarding net-pen aquaculture is the Ontario Ministry of Environment (OMOE) (13).
- In numerous reports to the Ontario Legislature, the Environmental Commissioner of Ontario (ECO) has questioned the claim made by government promoters of the open net-cage systems as legitimate and responsible use of the public waters. Furthermore, the ECO is still calling for a freshwater aquaculture policy to be “prescribed” within the Environmental Bill of Rights (EBR) where it would be properly open for public consideration. (14)
- The Georgian Bay Association (GBA) (15) has been raising awareness of the pollution impact of net-pen aquaculture for over ten years, which may have contributed to the informal moratorium on expansion. However, the DFO has renewed momentum and is well funded to build a large aquaculture industry that they envision inside fresh water net-pens.
- A representative from the GBA Aquaculture committee attended the DFO’s National Aquaculture Strategic Action Plan Initiative on September 24th, 2009 and found she was the only ‘other’ stakeholder in a room full of industry people and government promoters. The purpose of the meeting was for DFO to hold public consultation before finalizing an action plan to be released in draft form in the near future for final comment. The Action Plan purports to enable the industry to grow exponentially. Highlights from the GBA’s summary report (16) reveal:
- A high degree of intimacy between the industry and their regulators.
- A lack of transparency as the DFO adopts an “Ontario freshwater’ plan” authored by NOAA, with no public consultation, and the plan will be released to the public alongside a memorandum of understanding nearing its completion to be signed by Canada and Ontario.
- The so-called “Ontario Plan” is solely net-pen focused. The DFO strategy has abandoned land-based options such as the “Canadian Model Aqua-Farm”, appearing to have been switched from the much-heralded land-based model to a net-pen based model “model Cage Farm” initiative.
- DFO does not differentiate the impact of net-pens on marine or freshwater systems.
- DFO employee Eric Gilbert stated clearly that his focus is economic development for the freshwater net-pen sector, and that various federal initiatives will aggressively invest in freshwater aquaculture; that the Ontario industry partners and government regulators are lucky because there is no public resistance – unlike that on the East and West coasts; and, that more resources will be focused on freshwater due to the lack of socio/political backlash.
(3) Figure 1: www.ontarioaquaculture.com/files/Aquastats_2006-Final.pdf
(12) Can. J. Fish. Aquat. Sci. 66(11): 1936–1948 (2009) | doi:10.1139/F09-121 |
Published by NRC Research Press
(13)Environment commissioner sounds warning on aquaculture:
Sat 05 Nov 2005: Owen Sound Sun Times. See also http://www.ene.gov.on.ca/en/index.php
(16) GBA’s Internal Report on DFO’s Action Plan Initiative 09’09.doc (Can be accessed upon request)
- April 2019 AGM/ Presidents meeting Aquaculture Sub Committee Presentation
- GBA UPDATE article on Lake Wolsey Spring 2018 – here