Residents question sablefish hatchery effluent changes *
Gulf Islands Driftwood, Wednesday, November 22, 2006
IN DEPTH: By Salt Spring Island Residents
for Responsible Land Use
Salt Spring Island Residents for Responsible Land Use
700 Walker Hook Rd.
Salt Spring Island, BC V8K
November 20, 2006
Regional Manager, Environmental Protection
2080A Labieux Road
Nanaimo, B.C. V9T 6J9
Re: Sablefin Hatcheries,
Ltd.’s Application for a Permit
Amendment under the Provisions of the Environmental
Dear Regional Manager,
We appreciate the opportunity to respond to Sablefin Hatcheries Ltd.’s application
for a major Permit Amendment under the provisions of the Environmental Management
Act. While we regard the proposed action of re-routing the hatchery
effluent out of the archaeological site, sacred burial site, and sensitive
ecosystem of Syuhe’mun (Walker Hook) as a potentially
positive step, we do have questions and concerns.
1. Environmental Impact Assessment
We are concerned the effluent discharged into Trincomali
Channel will impact the marine ecosystem; particularly the eel grass beds,
marine species (e.g., the rare scallop population present in these waters),
the waters of Trincomali Channel, the waterbird
species currently at risk (great blue heron, double crested cormorant, and
surf scoter), and the sensitive foreshore environment. We understand that
DFO usually requires an independent environmental impact assessment when marine
waters are involved. Will that be conducted? We understand that
CRD requires that no net loss of habitat occur with this change. We
are concerned that if no independent environmental impact assessment of the
marine and foreshore environment is conducted, it will be impossible to assess
whether net loss of habitat has occurred. How can changes or losses
be assessed if there are no independent base line studies with which to compare?
On this basis, we request that an independent environmental impact assessment
of the marine and foreshore environment be completed to allow assessment of
the risks and future impacts that may be associated with proposed changes planned by Sablefin
2. Increased production
We note the following statement in Sablefin’s Application
for a Permit Amendment: “Quality and characteristics of the effluent
and treatment works will remain the same as our current permit allows with
the exception that all effluent will be disinfected prior to discharge.”
While reference is made here to quality and characteristics,
there is no reference to quantity. We have concerns about
the quantity of effluent that will be discharged in the new operation.
Sablefin’s original Site Alteration Permit allowed them to
excavate four wells, 10 wells were dug. Four are now used as production wells
and four are used as injection wells. Since the Archaeology Branch of
the Ministry of Tourism, Sports, and the Arts denied Sablefin
Hatcheries, Ltd. an amendment to their Site Alteration permit in January of
2005, no more well drilling and trenching can be done on the tombolo. Will the four
wells currently functioning as injection wells be decommissioned or will they
be converted to production wells? If they are converted to production
wells, how much more effluent will be released in the marine environment than
is currently being discharged into the tombolo?
Will antibiotics and disinfectants be discharged directly into the marine
environment? How will impacts be mitigated?
3. First Nations Consultation
In the November 16 edition of Salt Spring’s local paper, The Driftwood, Sablefin
Hatcheries, Ltd. spokesperson Nancy Dixon is quoted as follows:
Our reasons for proceeding with the outfall revolve around our desire
to continue good relations with First Nations and the Penelakut
Elders and Tribe. It is our hope that our efforts to amend our existing
permit will allow relations to grow and heal with the Penelakut
and the community on Salt Spring.
Despite Sablefin’s past statements about active
consultation, Respected Penelakut Elders have written
affidavits and testified that throughout the history of this development,
they have not been properly consulted. In the case of the new Permit Amendment
application, a Hul’qumi’num Treaty Group representative
confirmed by phone conversation with Salt Spring Island residents on November
16 that neither the Board of Directors of the HTG nor the Penelakut
were consulted. In fact, the Hul’qumi’num Treaty Group (HTG) only received the Permit Amendment
application notice a few days prior to our phone conversation with them on
November 16. We request that Sablefin Hatcheries,
Ltd. sincerely and actively consult with the HTG, particularly the Penelakut, prior to being granted the Permit Amendment or
implementing any new plan.
4. Community Consultation
We are requesting that a Public Information Meeting be held in which members
of the community be allowed to ask and receive answers to these and other questions.
In particular, we would like to see a map showing the route of the proposed
outfall pipe. We would like to see the results of research that Sablefin
Hatcheries, Ltd or consultants have completed that can show the general layperson
how the effluent will be dispersed relative to the complex currents and tidal
flows that are present at Walker Hook. Some neighboring property owners have
expressed concern about their water supply due to changes observed since the
hatchery began operating. Will increased production (if planned) cause
a greater strain on the local water resources? Does Sablefin
have any plans to mitigate these possible effects? Walker Hook beach
is a public beach. With the outfall pipe going above ground, and the
concerns of increased effluent discharge, how will the beach be impacted? In short, we would like Sablefin
Hatcheries, Ltd. to publicly provide information that will help the Salt Spring
community form educated and informed opinions about the proposed Permit Amendment
and ensuing changes. We are requesting that a Public Information Meeting be
held before a decision is made on this permit amendment.
Thank you for your consideration of our comments.
Salt Spring Island Residents for Responsible Land Use:
cc. Geoff Regan, Minister of Fisheries
Robert Morales, Chief Negotiator, Hul’qumi’num Treaty Group
Holman, Capital Regional District, Salt Spring Island
Peter Lamb and George Ehring; Islands Trust, Salt Spring Island
Sablefin Hatcheries, Ltd.
The article in the Driftwood was printed with some information
omitted and slightly altered.
article printed above includes the full text as submitted
to the Driftwood for publication.