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Letter to Hon. John Hamm from Mr. Jim Eldridge
Hon. John Hamm
One Government Place
7th Floor, Granville Street
PO box 726
Halifax, NS B3J 2T3
July 26, 2000
Dear. Mr. Hamm:
I am writing you today as a concerned resident of St. Ann’s Bay in Victoria County. Our family has owned in excess 200 acres of land in this area with substantial water frontage onto St. Ann’s Harbour for several generations. Although I am currently residing in the Truro area, I have built a seasonal home on St Ann’s Harbour, which I enjoy throughout the year.
As you are probably aware, Bounty Bay Shellfish has requested a license to develop an extensive mussel operation in our harbour.I am currently neither for, nor against this proposal in principal, however I so have two major concerns.
First, the review process to date has been seriously flawed. It was undertaken with a minimum of advance notice and many seasonal landowners were unaware of the scheduled hearings. Many of us lobbied your Department of Fisheries and Aquaculture and requested a rescheduling of the hearing so that we could both review the proposal in advance and to allow time for all landowners and other stakeholders to be properly notified. Your department: to postpone it.
Secondly, because of the size of the proposal and the lack of information that could be supplied by either DFA or Bounty Bay, freely acknowledged that they did not have all the answers to the concerns raised. Frequently we were told that there are no appropriate models for a proposed operation of this size. We were also told that little research has been done to date. At the end of the second night, discussion was terminated and we were advised to put any further questions in writing to the Department and they would respond in a timely manner. A committee of local residents did submit a list of questions to the DFA. That was over four months ago and DFA has yet to respond. Needless to say, many of the residents, myself included are very frustrated with the review process and information we have received to date. I firmly believe that the community has been done a great injustice by the lack of “due process” to date. There are still too many unanswered questions and many residents feel that the “deal” was done prior by DFA, and the hearing process was not a serious attempt to listen to the concerns of all the residents.
It is critical that with a proposal of this size, the largest on the eastern seaboard, that a full socio-economic, ecological assessment by undertaken. Precedent for this process has been firmly established in many jurisdictions and it is clearly affirmed in the United Nations GESAMP Report dated 1991. (1)
“Sustainable coastal aquaculture requires adequate consideration of the interactions social, economic and ecological and ecological changes. This can be achieved through an integrated approach to planning and management of coastal aquaculture within the framework of integrated coastal zone management.”
Socio-Economic
During the public hearings the proponents, Bounty Bay Shellfish, emphasized the benefits of job creation. While jobs are badly needed in our community, it is also equally important to put these into the context of the impact on the current sectors of employment in our community. Several residents raised concern as to the potential negative effect this proposal could have on their business. Not all there concerns were answered satisfactorily. This must be further investigated.
Some of the concerns expressed at the hearing included:
1. Will these jobs be sustainable? Can our harbour support an operation of this size over an extended period of time?
2. Will this proposal provide the maximum benefits to our community? What other proposals should the community entertain? Could a co-operative venture by the community be successful and provide great benefit to the community? Your Department acknowledged that if this proposal is approved, then no additional leases would be considered in the future.
3. What impact might this proposal have on existing businesses in the community such as commercial and sporting and tourism.
In addition it is very important that this proposal pass the test of the principal of Sustainable Development. This is defined by the United Nations Food and Agriculture Organization (FAO) as:
“ Sustainable development is the management and conservation of the natural resource base and the orientation of technological and institutional change inn such as to ensure the attainment and continued satisfaction of human needs for present and future generations. Such sustainable development (in the agriculture, forestry and fisheries sectors) conserves land, water, plant and animal genetic resources, is environmentally non-degrading, technically appropriate, economically viable and socially acceptable.”
Ecological
Most of the concern expressed at the public hearings could be categorized as ecological.
These include:
1. What impact will this proposal have on other species of fish? For example the proposal calls for a large tract of mussel beds at the mouth of the North River. This is one of Nova Scotia’s finest salmon rivers.
2. Can the harbour’s food supply support an operation of this size? What is the maximum sustainable carrying capacity of the harbour?
3. What impact will mussel deposits have on the environment?
4. What will the effect be on existing wildlife species? For example it is anticipated that there will be a migration of predatory waterfowl into the area and crab population are likely to dramatically increase. Both will have negative consequences.
5. What effect will this proposal have on the current lobster harvesting?
6. What impact will this proposal have on harbour navigation? Although the lines are to be submerged, many buoys will still be on the surface. In addition the Coast Guard considers these mussel tracts as “non navigational.”
7. Will there be any negative effects on existing beaches and waterlines? I.e. shells and other debris from the operation.
The Department of Fisheries and Aquaculture has openly admitted that they has no estimated on the effect this proposal would have on our harbour. This proposal was touted as the largest of it’s kind, and we were told very little scientific information is currently available. This questions the appropriateness of such a large proposal. Without hard scientific data based on “models” one would expect a more modest proposal. Expansion right might be offered, but only if proven “sustainable.”
Dr. Jamie Smith, a marine biologist, made a presentation at the hearing on behalf of Bounty Bay Shellfish. He assured us that we could consider this proposed mussel operation to have no negative effect on the harbour waters. He used the term “neutral". He explained that mussels do not take anything in but the nutrients that currently exist in the harbour, thus any deposits generated in this process of consumption could also be considered to pose no effect.
Despite his assurances, there is much published information that disputes this claim. Firstly, there is sufficient data that indicate the potential for environmental degradation. Secondly, there are recognized models and guidelines that have been established, as to how to evaluate proposal such as this. From the United Nations GESAMP Report(1991) – Reducing Environmental Impacts of Coastal Aquaculture.
“The large scale, extensive cultivation of bivalves can interact with the marine food web in two ways. Firstly, by the removal of phytoplankton and organic detritus and secondly, by competing with other plank tonic herbivores.”
“In addition culture structures provided a substrate for the crab, the larvae of which also competed with copepods as a plank tonic herbivore..”
“A high level of enrichment leading to what has been termed” souring” of siteshas been reported form a number of fish farms in several countries. For example, it has been estimated that 30% pf oyster and mussel farms in France are periodically abandoned or relocated because of the accumulation of biodeposits (Sourin 1979)”
Protocols for evaluating sites. Again from the GESAMP Report. 1991
“Carrying capacity can be assessed by evaluating historical records of bivalve culture (Heral 1988), measuring the availability of phytoplankton biomass or undertaking more sophisticated studies of carbon flux through the food web (Rodhouse et al, 1985). Furthermore, models have been formulated to predict the carrying capacity of some coastal areas (see for example Heral et al 1989), the general principals of which hold true for any coastal area.”
“Lumb (1989) provides guidelines on the sitting of fish farms which can be used to gain a qualitative assessment of the impact of organic fish farm waste on benthos. However, Hagino (1977) and Gwen et al (1989) present predictive models which have been specifically formulated to predict the dispersal and input to the benthos of organic waste.”
I have used the above quotes to show that information is available and to show the importance of investigating this carefully. I urge you, Mr. Premier, to slow the process down and to support a full and independent socio-economic and ecological review. The process to date has been less than open and impartial. You now have an opportunity to change this.
In closing I again would like to quote from the GESAMP Report.
“The true costs related to the deterioration of coastal water quality are not usually borne by coastal aqua culturists. Such costs are often spread onto other users of coastal waters. The solution to this problem requires policy intervention at national and local level, particularly to address the issues of common property rights and economic incentives and deterrents needed to minimize ecological change. The user of common resources such as water and public land for coastal aquaculture development should take into account traditional use and the potential consequences of over use”
Thank you for your attention and I hope you will give this matter its due consideration.
Yours truly,
Mr. Jim Eldridge
72 Evergreen Drive,
Truro, NS B3B 5T9