Deadline for Comment on Aquaculture Activities Regulations is October 22, 2014
On August 22nd draft regulations were announced to remove prohibitions in the Fisheries Act related to the use of pesticides and drugs and the harming of fish habitat by aquaculture. The draft “Aquaculture Activities Regulations” (AAR) will authorize owners and operators of open-net salmon farms to deposit pesticides, drugs and waste into the marine environment; and allow things to be constructed that may harm fish habitat.
Concerned? We are too.
Comment can be provided to firstname.lastname@example.org until October 22nd.
You can access our detailed submission with concerns and recommendations at the link below, a collaboration by the David Suzuki Foundation, the Environmental Law Centre, University of Victoria, the Pacific Salmon Foundation, the Watershed Watch Salmon Society, and the SOS Marine Conservation Foundation.
Our concerns include:
- The draft Aquaculture Activities Regulations (AAR) completely fail to specify conditions under which the use of drugs and pesticides will result in acceptable impacts to fish and aquatic life, relying instead on registration processes when the Minister has been advised by her own science advisors that “There is little in-field environmental evaluation as part of that registration procedure.”
- The Canadian Science Advisory Secretariat identified 15 recommendations on the use of drugs, pesticides and anti-fouling chemicals, none of which are incorporated into the AAR.
- In place of restricting the use of drugs and pesticides the draft regulation offers little more than an after-the-fact submission of an annual report by facility operators/owners documenting their use.
- As currently drafted the AAR inappropriately puts the owners/operators of aquaculture facilities in the driver’s seat by allowing them to decide the economic and other trade-offs of depositing drugs, pesticide and waste and harming habitat.
- Many of the requirements placed on operators are vague and likely unenforceable.
- There is no consideration given to cumulative effects.
- For our full submission with specific recommendations on how these issues can be solved, please see our submission on Aquaculture Activities Regulation.