Re: Request for Federal Environmental Assessment of Proposal from Grieg Newfoundland Seafarms (Provincial Registration #1834 which has been registered for Environmental Assessment with the Provincial Department of Environment and Conservation, in Newfoundland and Labrador. Dear Minister Mckenna,
The Atlantic Salmon Federation (ASF) is the largest and oldest wild Atlantic salmon conservation organization in North America today, and the Salmonid Council of Newfoundland and Labrador (SCNL), who we are closely affiliated with, is the leading Salmonid Conservation Organization in the province of Newfoundland and Labrador. Collectively, we wish to bring to your attention a major aquaculture proposal from Grieg Newfoundland Seafarms, which is currently registered for Environmental Assessment with the Provincial Department of Environment and Conservation in Newfoundland and Labrador (Registration#1834). Based on our review of this proposal and the significant risks associated with it we believe that this proposal should also be subjected to a Federal Environmental Assessment.
This proposal represents a huge undertaking, which will result in current Atlantic salmon aquaculture production levels in the marine environment in NL doubling over the next five years. This proposal, among other things, involves the introduction of foreign strains of farm salmon from Iceland which will be used to raise seven million smolt per year. These smolt will then be transferred to eleven new open net pen farms in the marine environment, which the proponent is planning to establish in Placentia Bay, on the South Coast of Newfoundland. Both ASF and SCNL have thoroughly reviewed this proposal, and contrary to claims made by the proponent that it will have no impacts on wild salmon stocks, we submit that their claim is not supported by evidence in their proposal, and their claim is not supported by existing science. In fact, we feel that this proposal, if allowed to proceed, will have ‘significant negative impacts’ on our wild strains of Atlantic salmon stocks on the South Coast. We have attached copies of our respective responses to this proposal above, which outlines our specific concerns.
Among other things, the significant risks of introducing foreign strains of eggs and fish have been well documented by the scientific literature. Furthermore, the introduction of foreign strains of eggs and fish is against the protocols of the North Atlantic Salmon Conservation Organization (NASCO), which Canada is currently a signatory to. These protocols are outlined by NASCO under the ‘Williamsburg Resolution’ (see attached). It is also our understanding that currently there is an MOU in place between Canada and the USA, regarding the proposed introduction of such foreign strains of fish, and each country must notify the other of any planned introductions of such foreign strains of salmon, before proceeding to do so.
It is worth noting, that currently, all wild stocks of Atlantic salmon on the south coast of NL have been listed by COSEWIC as ‘Threatened’, and these stocks are currently being reviewed for potential listing under the Species at Risk Act (SARA). The Recovery Potential Assessment (RPA) conducted by DFO, as part of this review process for potential listing under SARA, indicates that under contemporary marine and angling mortality rates, there is only a 27% probability of recovery of these wild stocks within 15 years. Since aquaculture has been identified as one of the reasons for the decline of wild salmon stocks on the south coast of NL, we strongly recommend that a review of the potential impacts of the Grieg proposal should be included as part of the current Recovery Potential Assessment, and SARA review process.
While we recognize that many of the ‘triggers’ that would normally require an aquaculture proposal like this one to undergo a Federal Environmental Assessment, were removed from the Environment Act when the former Federal Progressive Conservative Government were in power, we also recognize that your government has committed to conduct a review of such changes with the aim of strengthening legislation to better protect our environment, and this process is currently underway. In the meantime, for the reasons we have outlined above, and since there is currently significant public opposition to this aquaculture proposal in NL, we respectfully ask that you exercise your discretion under Section 14 (2) of the Canadian Environmental Assessment Act, and subject this proposal to a Federal Environmental Assessment. Doing so will insure that the Grieg proposal gets the thorough and proper review it deserves, and that DFO would be required to provide appropriate input, something that they are not required to do under the Provincial Environmental Assessment Process.
Given the many significant environmental impacts associated with this proposal we respectfully ask that you give serious consideration to our joint request, and should you have any questions or comments regarding this important issue please do not hesitate to contact us at anytime.