Net cage fish farming is an on-going issue that the Society continues to monitor. Though the situation has currently improved, in 1997 the issue became a priority with the NCPS as it was learned that effluent from these operations was having an impact on local waters.

These are some samples of correspondance that Society members directed at various levels of Government when the campaign was in progress in the late 1990’s.

Aquaculture in the North Channel

There are now 8 commercial netcage fish farming operations in the North Channel and adjacent waters located on and around Manitoulin Island. The fish are raised in nets which permit their feces and other detritus to fall directly into the water. This direct dumping of sewage is not permitted in any other industry.

The Birch Island Community Association (BICA) first addressed this issue in an August 27, 1997 letter and enclosed petition to the Ministries of Natural Resources and Environment. This letter expressed our concern and recommended action by the MNR and MOE to ensure that water quality in the Bay of Islands would not be permitted to decline as a result of commercial net cage fish farming. BICA received a letter in response, dated October 14, 1997, from Marilyn Fesnak, Acting Director, Northern Region. Ms. Fesnak’s letter noted the Ministries’ intention to improve the monitoring of cage culture facilities.

BICA’s concerns were clearly justified as the MNR was shortly after forced to take prompt action in ordering Cold Water Fisheries to shut down its operation at its La Cloche Channel site. It is of serious concern that such a small operation created serious pollution “covering about 350 hectares around the site”, according to the December 22 issue of the Manitoulin Expositor. (This is an area equivalent to about 1 mile by 1 mile.)

With regard to the incident at the La Cloche Channel site, it is important to note the following:
· based on extensive well documented experience elsewhere, this pollution was inevitable and predictable
· it is likely that provincial law was breached since adequate precautions were not taken to prevent pollution, yet no one is being charged
· those most knowledgeable about the operation at the La Cloche Channel site were not able to foresee that such serious pollution would occur in such a short time; therefore, assurances that water quality is not being impacted at the other sites lack credibility
· the monitoring, and the enforcement of the stipulated monitoring, did not provide advance warning of such serious damage to the environment in the area; therefore, the present sampling programs, at this and at the other sites, are inadequate

Regarding the other sites, some research which we have done leads to the following comments about net cage aquaculture in the North Channel:
· pollution is very likely occurring at the other locations and will inevitably become widespread as a result of algae growth and transport
· it is very difficult to predict when extensive pollution will occur, but the longer that it takes for visual evidence of algae blooms to occur, the worse the problem is likely to be and, of course, the longer for remediation
· the accumulation of biomass, which is occurring at and near the net cage sites, is producing a massive source of nutrients which will result in persisting pollution long after the operations have stopped
· the monitoring of water quality that is currently required by the MNR does not provide an adequate safeguard against significant deterioration of water quality

Furthermore, net cage aquaculture is inappropriate in the North Channel because there is no control of the discharge of pollutants. These operations are polluting. No reasonable person can claim that they are not, particularly after the experience in the La Cloche Channel. The Department of Fisheries and Oceans, who have ultimate responsibility for water in this area, call for a Pollution Prevention approach in their recent publication on sustainable development. This means preventing pollution and excessive waste, rather than reacting to its consequences.

A related reason that net cage aquaculture is not acceptable in the North Channel is that cost effective, pollution prevention technology is available, and is well proven. This is the production of marketable fish in tanks where the outflow water and solid detritus exit through an overflow pipe into a settling tank. The solids settle out and the overflow water is further treated, if necessary. The water can be recycled or discharged to the environment. Normally, the discharge water must meet background quality. The additional costs can be offset by better yield and many more years of operation. Of course, the benefits to the environment are enormous.

Considering all of the above, BICA recommends the following for the North Channel:
· MNR should ban further expansion of the existing net cage operations
· no additional net cage aquaculture sites should be approved
· the existing net cage operations should be required to convert to closed tank systems within 5 years from this date; any discharge to the environment from the tank operations should be no worse than background water quality
· any new fish farming operations, at any time in the future, should be done in tanks, with full treatment of the discharge
· even for tank operations, no additional sites should be approved until a detailed scientific study has determined the capacity of the North Channel to accommodate additional commercial fish farming operations without any degradation to water quality
· as a condition of operation, current net cage operators should be ordered to do more intensive sampling in close proximity to all of their net cages; this should include an annual program similar to that done last fall at the La Cloche Channel site

The damage that has already been done to this world renown recreational area, and very bad experience elsewhere, shows that quick action should be taken on our recommendations.


Correspondence from the Bay of Islands Community Association to the Ontario Government

Honourable John C. Snobolen Minister of Natural Resources

Honourable Norman W. Sterling Minister of Environment

Dear Ministers:

Fish Aquaculture Operations – North Channel of Lake Huron & Adjacent Waters

This letter is further to:
-our August 27, 1997 letter and enclosed petition which expressed our concern about the predictable negative impact of net cage fish farming on water quality, and
-our February 4, 1998 letter which included recommendations for minimizing such impacts

and is in response to the following communications to us:
-the Hon. John C. Snobolen’s letter of March 12, 1998
-the Hon. Norman W. Sterling’s letter of March 26, 1998

We very much appreciate your communications which indicate the sincerity your efforts to prevent pollution from the fish farming in our area. We look forward to reviewing and commenting on the discussion paper which is being prepared by the Ministry of Natural Resources.

Our primary interest is in preventing deterioration of the quality of the water in the Bay of Islands where we live and contribute to the local economy. We are all taxpayers. For these reasons, and because some of our members have relevant technical and professional experience, we believe that we have some salient points to make. Some of these are described in our earlier correspondence. Additional opinions and facts are offered herein, as follows.

We do not agree with the statement by the Hon. Norman W. Sterling that every site has some assimilative capacity. The extensive literature on the subject shows that the vast majority of net cage operations destroys the fish habitat and other life in their immediate vicinity, and in most cases this destruction extends well beyond the close proximity of the cages. Since this occurs shortly after the start up of a net cage, it is clear that there is virtually no assimilative capacity for net cage discharges. Worse, the net cages simply discharge all their sewage onto the lake bed and this pile of detruis just keeps on growing and growing until oxygen depletion and algae growth is so extensive that it is visible to the public. These discharges are substantial; a single operation generates sewage similar in quantity to a town of several thousand people. The nature of the sewage might differ, but its impact on algae growth is the same.

The longer that it takes for the impact to be detected, the worse the problem. In other words, the false optimism that occurs when water quality does not appear to deteriorate during the first several years of operation, simply masks the inevitable, eventual occurrence of a major catastrophe.

The concept of assimilative capacity is only relevant to point source discharges of effluents which have already been treated to reduce pollutants to levels which are thought to be harmless. Such a discharge passes through a mixing zone where the receiving water rapidly dilutes the effluent so there is no perceptible increase in the concentration of the polluting substance in the receiving water. The quality of water in the mixing zone must not be harmful to fish.

The residents of the Bay of Islands are very concerned about the economy of the area. We know that prosperity and employment is in everyone’s interest, and we know that this can only be achieved by sustainable development. Net cage operations are not sustainable, as shown by experience elsewhere. Most have to shut down after a time. Moreover, they are less economical than fish farming in tanks. They require much more extensive monitoring, and have a negative impact on other income activities.

On another point, you are well aware that the Government of Canada has ultimate jurisdiction for water quality in the North Channel. The regulations of the Department of Fisheries and Oceans apply, although we understand that monitoring and enforcement have been delegated to the Government of Ontario. We would like to draw your attention to Sections 35 (1) and 40 (1) of the Federal Fisheries Act.

Section 35 (1) states that “No person shall carry on any work or undertaking that results in the harmful alteration, disruption or destruction of fish habitat.”.

Section 40 (1) states that “Every person who contravenes subsection 35 (1) is guilty of
(a) an offence punishable on summary conviction and liable, for a first offence, to a fine not exceeding three hundred thousand dollars and, for any subsequent offence, to a fine not exceeding three hundred thousand dollars or to imprisonment for a term not exceeding six months, or both; or
(b) an indictable offence and liable, for a first offence, to a fine not exceeding one million dollars or to imprisonment for a term not exceeding three years, or to both.”.

Clearly, these parts of the Fisheries Act are relevant to the destruction of fish habitat in the La Cloche Shipping Channel, as proven by the Ministry of the Environment in 1997. It is our opinion that the other sites in the North Channel and adjacent waters are also subject to this Act, and punishable for the destruction of fish habitat, at least in the immediate vicinity of the net cages.

In summary, we believe that netcage aquaculture poses a serious threat to the quality of water in the North Channel, and directly contravenes the intent of the federal Fisheries Act. We therefore request that the Government of Ontario provide netcage operators the incentive to convert to a sustainable mode of operation- that is, fish farming in tanks with treatment of the effluent.

Weldon Thoburn P.Eng., Ph.D.
Chairman, Water Quality Committee
Director, BICA