Call to Action

"Prompt, concerted action is required if the salmon fisheries and aquaculture are to be sustainable."
Commissioner of the Environment and Sustainable Development 2004


The aquaculture industry and both levels of government claim that the industry is science-based, and highly regulated. What we have learned leads us to question these claims, especially in terms of actual protection of the environment.

Responsibility for aquaculture management is shared between federal and provincial governments. The department of Fisheries and Oceans (DFO) is the lead federal regulator of the aquaculture industry. (Other federal departments, such as Canadian Food Inspection Agency (CFIA) and Canadian Environmental Assessment Agency (CEAA) also have a role.) The province issues leases (for the site) and licenses (to operate a fish farm).

The Fisheries Act: A Primer

DFO's key mandate for fish habitat protection and pollution prevention, under the Fisheries Act, are described as:

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

Section 36 deals with the prohibition of deleterious substances into fish-bearing waters

See full text for: Fish Habitat Protection and Pollution Prevention : Fisheries Act

In the review of aquaculture projects, DFO assesses the liklihood that a project will cause a HADD. If a project might cause a HADD, the proponent is required to enter into a “HADD Avoidance, Mitigation, and Monitoring Agreement”.

If a HADD will, or is likely to, result from the project, the proponent must apply for an “Authorization” to create a HADD. An Authorization, if granted, can include specific conditions, and is supposed to follow the principal of “no net loss” of productive capacity. That means the proponent must restore another fish habitat area to compensate for the loss created by the current project. 1

Authorizations are not granted “where adverse effects to fish habitat are judged to be unacceptable.” Cited risks can include loss of critical habitat and low suitability of the site.

See Interim Guide to the Application of Section 35 of the Fisheries Act to Salmonid Cage Aquaculture Developments

We have grave concerns about how DFO and the Province have met their responsibilities in terms of protecting the marine environment. Others share our concerns:

State of Aquaculture Knowledge

Industry and government make repeated claims of a science-based industry.

But: A 2004 report to the House of Commons states "significant gaps in the scientific knowledge about the potential effects of salmon aquaculture." The same report states that DFO "needs to apply more credible, science-based criteria to ensure that approved sites are properly located" and DFO "has to determine how to control the deposit of deleterious substances by salmon aquaculture operations." 2

Federal Department of Fisheries and Oceans, and the Fisheries Act

Fisheries and Oceans Aquaculture Management, under their Aquaculture Policy Framework define "DFO as both a regulator and enabler of aquaculture development". Their focus is: to build public confidence and to increase the global competitiveness of the industry.3

But: There is strong evidence that the enabler role has over-ridden the regulator role. For example:

  • The Standing Committee on Fisheries and Oceans, Aquaculture Minority Report essentially declared that DFO, in its promotion of aquaculture industry, has failed to uphold its mandate to protect fish habitat. 4
  • Fish farms impact the fish habitat under the sea cages. DFO uses sulphide levels as a indicator of when the harm reaches a level to cause a HADD. This measure, sulphide levels, have been set at a level where essentially all sea life beneath the cages has disappeared. How can this be consistent with protection of fish habitat? See notes below.
  • Salmon farmers in New Brunswick were told that DFO was considering recommending that they apply for an "authorization for a HADD" when their sulphide levels reached the threshold of 4500 to 5000µM. By even considering this approach, we question DFO's commitment to protecting fish habitat.5

Provincial Department of Fisheries and Aquaculture

Much like DFO, the provincial department proposes to both promote and regulate aquaculture.

But: We question whether the department can effectively do both. The department only started sampling aquaculture sites in the past few years, noting in its 2004-2005 Accountability Report that they had sampled 60% of all sites (but all sites in full production) 6. The department's 2006-2007 Business plan states they hope to sample ALL sites 7 by 2007-2008.

The goal of the Fisheries and Coastal Resources Act states: "assist the aquaculture industry to increase production;" 8. The department's 2006-2007 Business plan also indicates they are working on an aquaculture development strategy and implementation plan.

How willing is the department to enforce regulations on an industry it wants to grow? Did they take action when the existing fish farm exceeded acceptable standards? See next item.

Environmental Standards - Applied Evenly?

Both provincial and federal levels of government claim that aquaculture is tightly regulated.

But: It appears that the aquaculture industry does not have to meet same environmental standards as other industries. For example, a former employee of Bowater Mersey Paper Co. Ltd., a pulp and paper operation in Brooklyn, Queens County, cites how the company was forced (in order to meet environment regulations) to spend $40 million to treat its effluent before it was released into the water. It was costly, but it was done. Yet salmon farms are not required to manage waste created by their operations. Why is aquaculture not forced to meet similar standards? Read Fred Giffin's full letter (PDF).

Monitoring Aquaculture Sites

Sulphide, Redox Levels and HADD

One of the methods used to determine the impact of fish farm waste on the benthic community (flora and fauna in/on sea bottom sediments) is to measure the level of sulphides in the sediments. The higher the sulphide, the lower the oxygen potential, and then, the fewer forms of marine life that can survive.

The effects of sulphide levels on benthic biodiversity has been extensively studied. As sulphide levels increase, so does harm to the benthic community. Sites classified as “hypoxic” have reduced levels of oxygen supporting much less plant and animal life. “Anoxic” sites are oxygen-deprived where virtually no marine plant or animal life survives.

Sulphide Readings and Environmental Impact
Condition Sulphide Readings (µM) Impact on Macrofauna*
oxic A < 750 losses less than 30%
oxic B 750 to 1500 losses between 40-60%
hypoxic A 1500 to 3000 losses between 60-70%
hypoxic B 3000 to 6000 losses between 70-90%
anoxic > 6000 losses greater than 90%

* macrofauna - small animals such as worms, corals, shrimp, whelk, starfish, shellfish, barnacles, amphipods, and sea urchins.

DFO now considers anoxic sites to be causing a HADD. What scientific grounds support using anoxic sites as the threshold for a HADD? Fish habitat is clearly harmfully altered and disrupted, even destroyed, before an anoxic state is reached. (Previously, DFO considered hypoxic sites as causing a HADD. It has been claimed that DFO changed the standards because a significant number of New Brunswick salmon farms had hypoxic conditions, i.e. already creating HADDs.9)

The table below outlines how Nova Scotia classifies sites based on sulphide and redox levels found in sediment samples. (Redox, or Eh, measures the oxidation-reduction potential. The lower the value, the more harm done to marine life.)

Environmental Quality Definitions for Nova Scotia Marine Aquaculture Monitoring
Condition Sulphide Readings (µM) Redox Readings (mV) Site Classification
norm-oxic < 1300 0 to 300 Type A
sub-oxic (hypoxic) 1300 to 6000 -100 to 0 Type B
anoxic > 6000 < -100 Type C

Aqua Fish Farms Record

The existing fish farm site (#835) monitoring results for years 2004, 2005, and 2006 are available from the Province. As well, the Environmental Impact Assessment document contained 2002 test results for the existing site.

Monitoring results include samples from the existing site, reference sites, and the proposed site. Reference results are test locations outside the fish farm lease area, and are assumed to represent the typical 'natural' values in the area.

Monitoring results for site 835, shown below, clearly show the site as being minimally hypoxic, and often anoxic. Compare those sulphide values with the values for reference and proposed sites.

Aqua Fish Farms Site 835 - Monitoring Results 2002 to 2008 : Sulphides
Year Site 835 (µM) Reference (µM) Proposed Site (µM)
2002 2560, 5935, 6520 n/a 92, 96
2004 484, 613, 4359, 7626 47 to 362 92, 96
2005 624, 823, 592, 4501 162 to 371 600
June 2006 3025, 4253, 6733, 4919, 7771 89 to 193 100, 355
Nov 2006 391, 1920, 7205 164 to 291 n/a
Jul 2007* 8265, 6257, 4006, 3945 371, 382, 473, 368, 429 n/a
Nov 2007* 1002, 10166, 6864 232, 319, 260 n/a
Jun 2008* 2288, 7070, 1193, 5280 198, 248, 322 n/a
Nov 2008* 1932, 8498, 1128 296, 89, 88 n/a

Notes: Hypoxic values shown in green, and anoxic in red

Recent * updated data - note: Site #835 still showing very high sulphide levels as compared to the reference sites

Sulphide and Redox Samples

The two charts below plot mean sulphide and mean redox values at the same four sampling stations, from 2004 to 2006. Stations #AFF 09 and #PTM 14 are in the fish farm lease area. Stations #PTM 17 and #PTM 33 are reference sites.

(Sources: Monitoring Data 2004, 2005, Monitoring Data 2006, Map of Test Locations)

The 2002 monitoring report clearly states the site as being “anoxic”10. It describes the site as follows:

"Evidence of organic loading beneath the cages was identified during the survey. The source of this organic overloading appears to be the combination of waste feed, fecal matter and fouling organisms falling from the cages structures. The accumulation and degradation of this materials has results in widespread sea floor 'souring'".

Subsequent monitoring results through to 2006, as detailed above, show repeated anoxic site conditions.

“Monitoring” at Work

In December 2006, the Province released sulphide test results (2003 to 2005) from finfish and shellfish operations in Nova Scotia. Judging from Aqua Fish Farms' test results for the same time frame, this site was deemed to be the worst site in the Province; the only one to be labeled as Type C.

The report notes: "Only one station was within the ‘C’ range. The Province, in conjunction with its regulatory partner (DFO) and the site operator, has implemented a site remediation plan to improve the sediment conditions within portions of that site." 11

However, June 2006 test results clearly indicate that sulphide levels had actually increased! What about the site remediation plan?

Anoxic sites meet the definition of a HADD. Both levels of government knew about the ongoing anoxic site conditions. Has Aqua Fish Farm applied for and received approval for an Authorization? If not, was not this company in violation of the Fisheries Act? Why, in the spring of 2007, is this farm allowed to continue operations? Why is a second fish farm for Port Mouton even being considered by federal and provincial officials?

‘Friends’ has submitted a document to the review process detailing the monitoring results. Read the full document: Environmental Monitoring Report (PDF)


Despite claims to the contrary, we have real and valid concerns about the effectiveness of environmental monitoring of finfish farm operations and enforcement of all applicable legislation by both levels of government.