The St. Mary’s Bay Coastal Alliance was one of many groups who filed submissions to Transport Canada in what many feel was a flawed screening report filed by multi-national corporation Cook Aquaculture, in their application to install an open net industrial salmon farm in St. Mary’s Bay. (view and download submission here). Other groups filing submission objecting to or commenting on the screening report include:

Some of the elements of the SMBCA submission include:

  • DFO understates importance of lobster fishery

  • DFO acknowledges the lack of evidence and science to support most of its findings and

  • The advice that DFO provided to Transport Canada is not based upon data and facts; instead they had to be largely based upon opinions and conjecture.

  • they were given a short time frame in which to respond

  • existing data sources for St. Mary’s Bay are limited

  • additional research would be required,

  • there is no detailed analyses of water currents in the area

  • local knowledge was not sought

  • DFO says project could impact three populations of endangered salmon

  • DFO says area is salmon migratory route

  • DFO web says growing body of evidence suggests that the rapid decline in numbers of Inner Bay of Fundy Atlantic salmon is due to low marine survival… may be "from commercial salmon farms, which can attract predators, alter habitat, obstruct migration and harbour disease."fishfarmcrowded-nt

  • environmental monitoring not enforceable

  • Environment Canada says, " It is estimated that 40% of the nitrogen contained in fish foods is incorporated into fish biomass, and the rest is released into the aquatic environment as metabolic wastes, faeces and uneaten food fragments.

  • Canadian Guidance Framework for the Management of Nearshore Marine Systems
    (CCME,2007) state that the consequences of nutrient over-enrichment of marine systems
    are numerous and may include changes in species composition, increase in the development of harmful algae blooms, which can be toxic to shellfish, fish, marine mammals, andin some cases become a direct threat to human health. Can also result in increased sedimentation of organic matter, and the bacterial decomposition of this material may result in the depletion of dissolved oxygen (DO) within the water column posing a very serious risk to marine ecosystems.

  • DFO notes Increased  contaminant concentrations can have sub-lethal and lethal effects (This was NOT assessed)

  • Environment Canada says aquaculture operations release lethal chemicals into the environment

  • DFO finds that Altamax (used recently in New Brunswick) is "super-toxic" to crustaceans (including lobster)

  • DFO gives no consideration for far-field or cumulative effects of fecaes and uneaten food

  • 60% of the nitrogen in 10.3 metric tonnes of fish food from 2 million fish proposed will be released into environment

  • solid suspension around aquaculture sites shown to range from two to twenty times that of background levels

  • carbon flux below cages "several orders of magnitude than in adjacent waters

  • according to DFO’s screening tools (MFADSS) sites should have been deemed unacceptable

  • no mitigation measures for fecaes and feed waste

  • species at risk issues include; disturbance and disruption of sensitive species, habitat loss, genetic interactions between escaped farmed salmon and wild salmon, and mortality.

  • new site are ten times existing sitelice-eating

  • no requirement for mitigation measures for odour or noise pollution

  • no modeling for dispersion effects

  • overwhelming local opposition

  • no substantive response to public concerns

  • Panel Review is needed

  • sites are not in the public interest

(view and download submission here)