After reviewing the   Draft Guidelines   released by the Provincial Department of Municipal Affairs and Environment, which Grieg NL must follow when conducting their Environmental Impact Statement (EIS) for their   proposed aquaculture project in Placentia Bay, the following list of issues, deficiencies, and gaps have been identified by NL-CAR.   The deadline to provide public input in response to these guidelines is   .
Submissions should be sent to:   EAProjectComments@gov.nl.ca
Issues from the list below can be cut and pasted into a personalized submission or the entire list down-loaded here:   
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1)   The proponent is only required to hold one public meeting as part of their EIS. This is not nearly enough given the significant level of public concern about this project throughout the province, as demonstrated by some 200 public letters written to the Minister of Environment in response to the Grieg Proposal when it was registered. Therefore, we suggest that additional public meetings should be held in St. John’s, Gander, Grand Falls, and Corner Brook at the very least, with additional meetings in communities where there is interest to do so.

2)   The scope of the EIS is focused only on Placentia Bay. Given the potential for impacts to be felt well outside this area we feel the scope of the EIS should focus on the entire South Coast Designated Unit 4 (DU4) since wild salmon stocks have been assessed by COSEWIC as ‘Threatened’ in this entire area. For example: This is the first time that European strains of fish will be used in this province and as such impacts from the use of these fish could be felt far outside the Placentia Bay area.

3)  The proponent has not been required to describe or characterize the migration patterns of wild Atlantic salmon in Placentia Bay, or along the South coast. Science has documented that open-net-pen aquaculture poses threats to wild salmonids and other species many miles from cage sites. For example: farmed rainbow trout that have escaped from such cages have been confirmed all around the coast of Newfoundland by DFO. Furthermore, all wild salmon stocks on the South Coast (DU4) have been assessed as ‘Threatened’ by COSEWIC and are quite vulnerable to any new threats. Therefore, it is important to describe migration patterns of wild Atlantic salmon (at all stages of their life cycle including post-smolts) to better understand areas where they may be affected. The same applies to pelagics and other fish species that frequent this area.

4)   The proponent is required to provide an update on wild salmon stock status in Placentia Bay only, but as noted above (in item #3) the impacts of open-net-pen aquaculture can be felt many miles from cage sites. Therefore the proponent should be required to provide an updated stock assessment on all wild salmon stocks along the South Coast, particularly since all stocks in this area (DU4) were assessed by COSEWIC as ‘Threatened’ a few years ago. Furthermore, since wild salmon stocks throughout NL (including those in DU4) have experienced significant declines since the COSEWIC assessment was completed, the proponent should be required to include data up to 2017 in their assessment.

5)   The proponent should be required to provide information with respect to escapement levels using open-net-pen technology, both for major escapements and trickle losses, as well as the cumulative impacts of such losses over time. In particular, the proponent should be required to describe current interactions of escaped farm fish with wild Atlantic salmon, since the future prediction is not the same as starting from a pristine environment.

6)   While the proponent is required to describe mitigation measures to prevent escapes, and to describe recapture plans should fish escape from their cages, it should be noted that all attempts to recapture escaped farmed fish in NL to date have completely failed. Therefore, the proponent should be required to describe how they plan to recapture fish that do escape from their farms and what methodologies will be employed (i.e. simply reporting escapes and using failed recapture methods does not resolve the problem). They should also describe if their recapture methods have been tested in NL and if so what efficiency of recapture can be expected. They should also describe what the impacts of using such recapture methods will have on other species of fish, specifically, by-catch and by-catch mortality. The proponent should be required to do modelling on various levels of escapes, and should provide information on trickle losses (i.e. losses of 100 fish or less per day).

7)   The proponent should be required to mark their farm fish for easy identification should they escape, and as such should be required to provide information on the method of marking they will use.

8)   Since the proponent plans to introduce European strains of fish into our waters the proponent should be required to describe the potential impacts of these fish on native stocks of fish in NL. Particularly the potential for the spread of new disease and viruses. They should be required to disclose if these European strains will be subjected to ‘Disease Challenge Tests’ prior to being introduced to cages.

9)   The proponent plans to use all triploid (sterile) fish from European strains that have not been used here before commercially. It is well known that these triploids generally do not perform well, based on information from other jurisdictions where they have been tried. The proponent should be required to provide information on the success and failures of triploids in other jurisdictions where they have been used, as well as, information from jurisdictions where the proposed use of such triploids has been denied, and the rationale why. In addition, the proponent should be required to describe how these triploids perform under different water temperatures, as may be experienced in NL. In addition, they should provide info on the possible introduction of new diseases and viruses associated with this introduction and the impacts on native fish species here. Furthermore, the proponent is should be required to provide information on what the alternative will be if these triploids don’t survive or don’t perform well. If they do not perform well does the proponent then plan to use diploid (fertile) fish, and if so, what will be the impacts of doing so? We suggest that the proponent should be required to address all these issues in their EIS.

10)   The proponent proposes to use Lumpfish to control sea lice infestations but there is not enough information on how this process is going to work. Since this is the first time that lumpfish will be tried in NL on a large commercial scale, the proponent should be required to discuss this whole process in more detail, particularly how using lumpfish will result in less impacts on wild salmon,

other species, and the environment in general. In their discussion they should be required to provide information on: where these lumpfish will come from; what they plan to do with these lumpfish once they are killed after each production cycle is complete; what the impact will be on native lumpfish stocks that currently have been assessed as ‘Threatened’ by COSEWIC (i.e. what are genetic implications if their lumpfish escape and breed with native lumpfish); what are their alternative plans if these lumpfish fail to control sea lice, and what are the potential impacts of alternatives.

11)   Need more information on how they will prevent impacts of diseases, viruses, and other parasites on wild salmon stocks, other fish species, and the environment in general; including how they will control the spread of such diseases, viruses, and parasites. They should be required to discuss thresholds/limits and protocols that are used in other jurisdictions that could help prevent the spread of such diseases, viruses, and parasites here, and whether they are prepared to implement such limits and protocols in NL.

12)  They should also be required to discuss monitoring programs required to document the impacts of their operations on wild salmon, other fish species, and the environment in general. In particular, they should be required to address how they will mitigate for and/or adjust mitigation measures to deal with any observed impacts detected by these monitoring programs. For example: if water quality outside cages is jeopardized how will they deal with such a problem; or, if farm fish escape and enter local rivers and it is discovered that hybridization (cross breeding) has occurred with wild salmon, how do they plan to remove farm fish from these rivers and how do they plan to deal with the hybrids in the river.

13)   The proponent plans to stock cages with densities that far exceed what is currently used in the aquaculture industry in NL now, but they do not provide any information related to the impacts this will have on animal welfare. Neither are they required to discuss what effect these higher stocking densities will have on wild salmon, and other species. Nor do they describe the impacts that such high stocking densities can have on cage failure. They should be required to do so.

14)  While the proponent is asked to discuss alternatives to using open-net-pen technology in the marine environment, they are not specifically asked to discuss closed containment options such as land based operations. Public comments received by the Dept of Environment in response to the registration of Grieg’s original proposal indicate that the public specifically wants land based operations, and other closed containment options addressed, along with any other alternatives. In addition, the proponent should be required to discuss advancements in land based technology, current use of such technology world wide, the potential for growth of such technology, and the benefits associated with the use of such technology (environmentally and economically).

15)   The proponent should be required to address whether the Aqualine Midgard cages that they propose to use were designed to withstand ice conditions such as those experienced in NL. The proponent has indicated that Placentia Bay is ice free but during the winter of 2017 Placentia Bay was full of ice. What are the potential impacts if the cages were not designed to withstand ice as experienced in 2017? The proponent should also describe if these Midguard cages have been tested in NL waters, and if not they should be required to do so before they go to full scale commercial operations.

16)  Based on recent research conducted by DFO’s Kristie Miller-Saunders, it is known that there are many viruses carried by farmed fish in our waters that can negatively impact wild salmon stocks (as well as farmed fish), yet the CFIA only requires testing for a few of these viruses. In light of these new findings the proponent should be required to discuss their plans to test for the presence of these other viruses and mitigation plans they will put in place to prevent the spread of such viruses.

17)  Lamping (ie anti-grilsification lights use on open net pen sites) attracts wild fish at night and significantly increases the opportunity for disease and parasite transfer between wild an open net pen fish, antimicrobial and drug exposure of wild fish, as well as facilitating juvenile wild fish to enter open net pens and get eaten as free food. Lamping is a common practice used by wild fish harvesters due to its effectiveness of attracting wild fish such as mackerel, capelin, herring, squid, etc. It is also used by the aquaculture industry to supplement feed requirements in an un-managed way even from protected wild fish stocks. These super bright lights will also affect sea bird migration and daily navigation. This needs to be monitored or removed from Grieg's ability to use.

18)  Acoustic harassment devices have been used in the recent past by Canadian open net pen operators like Cooke aquaculture but not mentioned or restricted on leases or permits issued by the NL government. DFO has yet to ban them despite that its own review panels recommended it for over a decade. These devices affect sea mammals and sea birds as well as fish.

19)  Predator attracting via mortalities and feed pellets and feed pellet dust has never been monitored and is an issue as sharks and tuna as well as smaller pelagic are attracted. This results in holes in nets, deaths of marine mammals/endangered sharks/tuna/etc, juvenile pelagics entering the netting, and increased disease transfer (eg the shark worm in many wild salmon over the last 2 years and never reported before with a salmon/shark cycle).

20)  Many toxins such as persistent organic pollutants (aka POPs), non-persistent pollutants, heavy metals, ethoxyquin, etc in marketed fish, composted fish, and sea floor sediments are ignored by DFO, Health Canada, and Environment Canada.

21)  Discuss access methods and schedule to sites by an independent panel of stakeholders to check on disease and lice/parasite levels as this has proven effective as a monitoring tool in Ireland and Scotland and should be available in NL.

22)   Discuss timely methods of public reporting of lice, all diseases and parasite issues, and chemical usage on a weekly basis via the web as this has shown to be useful in other regions at reducing environmental issues eg lice counts in Ireland, toxin use in Norway, etc.

23)   An analysis of a full panel of POP and non-POP toxins be done and where possible describe methods for having them removed during feed pellet production. Some of the feed pellet producing companies (even Marine Harvest) do this for some POPs already; but not Grieg, Skretting, EWOS, etc. and as the diet changes so do the POPs and non-POPs so monitoring must remain current.

24)  Require a bacterial and fungal monitoring regiment for feed pellets in storage and prior to release into the environment. Stored feed pellets been shown in numerous studies to be a significant source of pathogen generation. Also a list of antioxidant, antibacterial, and fungicides used in the pellets to increase shelf-life and storage.

25)   Green crab population monitoring downstream of net pen feeding.

26)  Bird netting is often damaged or removed due to icing conditions in NL and this exposes raptors and seabirds to the oil, morts, antibiotics, etc in and around the pens. This has resulted in antimicrobial resistant bacteria being transferred to gulls, eagles being killed due to oil accumulation in the feathers, otters and mink entering the cages stressing the fish and being exposed to an antimicrobial resistant environment and possible diseases.

27)   Bonds should be required for environmental clean-up and restoration.

28)  I would suggest adding requirements for an antimicrobial resistance testing and monitoring of its transfer between species of bacteria/fungi/parasites/etc (hatchery environment, staff, net pen workers and environment, etc) and that the proponent be directed to include such issues when comparing methods of production (land based vs open net pen). This issue is being pursued by CFIA, Health Canada, and other jurisdictions with a fervor due to the results of recent research. A hatchery study in NS found it to be rapidly breeding super-bugs due to dumping antibiotics into the tanks. Chile found aquaculture workers loaded with chronic AMRs. The environment near the cages has serious ARMs issues beyond 8km from a cage site. Studies exist from Chile, Ireland, Scotland, Canada, etc showing serious issues that government and this industry is ignoring.

29)   The following line needs to be removed from the government EIS draft guidelines list of requirements as it is counter to what a guideline document is supposed to do (tell proponent what MUST be done as a minimum):
"It is not intended that the proponent should describe all of the alternatives listed above, but to select those that have greater importance for the environmental assessment of the project. " 

30)   Hazards to marine navigation has been a serious issue in the past and includes a list of people, vessels, and equipment involved in NL. NS, and NB. This should be recorded, made public, and a mitigation strategy developed especially given we have oil tankers and commercial vessels mixing with many miles of floating heavy plastic tubing and miles of super strong ropes that float that will disable props and rudders.

31)   Discuss how the current fees, enforcement, and legislation favour open net pen use over land based RAS use and how this might be changed while including both financial and environmental factors.

32)  Discuss how aquaculture specific fees required by government will be sufficient to cover aquaculture specific costs to government, egs enforcement and monitoring of the project, and offer mitigation strategies for deficiencies.