Friends Of Baynes Sound Society

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Rezoning to allow rafts in Union Bay – ADVISORY PLANNING COMMISSION meeting on March 24, 2014

Back in August we posted on the blog information on a new application in Union Bay. Application # 1414113 – Aqua 

application #1414113 - Aqua

application #1414113 – Aqua

The AQ-1 zone permits shellfish aquaculture, provided that no structures are
permitted on the site. As this proposal involves structures such as rafts and floats, the AQ-1 zone
does not permit this proposed shellfish aquaculture raft operation. The applicant, therefore, has
requested to rezone the tenure (license of occupation) to a zoning designation that will permit
“aquaculture use” that involves structures above the surface of the Strait of Georgia.

You can have a look at the agenda (link at bottom) for the Advisory Planning Commission meeting to be held in Union Bay March 24, 2014 

To be held in the Bill Woods Room of the Union Bay Hall
Located at 5401 South Island Hwy, Union Bay, BC
Commencing at 7:00 p.m.

*Reminder March 15 deadline for comments on file #1413722 AQUA*

Just a reminder that comments are due by March 15 2014 on file #1413722 AQUA.

Those who have written we Thank You!

Those who haven’t yet please take some time to comment to:

Forests, Lands, and Natural Resource Operations – Email:

The Honourable Gail Shea – MP, Minister of Fisheries and Oceans –

The Honourable Steve Thomson, MLA, Minister of Forests, Lands, and Natural Resource Operations –

The application files have been removed from the MFLNRO website ( so included are links to the two files that we have on file. Please see below:

1413722 Referral Pkg Jan 29 2014

#1413722 Application Revised Dec 2013

For help please writing letter, see original post here:

Urgent comments needed by March 15 2014!

Thanks for your time and please feel free to share this.

Baynes Sound shellfish application smaller due to ‘political resistance’

Sound shellfish application smaller due to ‘political resistance’

By Comox Valley Record
Published: March 10, 2014 07:00 PM
Updated: March 10, 2014 07:57 PM

The application for a 155-hectare shellfish tenure in Baynes Sound has been scaled back to nearly half that size due to “political resistance.”

Now 81 hectares in size, the application for tenure stretches from north of Union Point in Union Bay to the Amber Way area, rather than all the way north to Gartley Road as originally submitted.

“Primarily political resistance,” co-applicant Eric Gant quickly replies when asked why he and co-applicants Bon Thorburn and Dan Bowen changed the size. “We’re always dealing with people trying to interfere with what we’re trying to accomplish, and they’re doing it for reasons that are not valid because they don’t bother to come to us to find out what we’re truly trying to do.”

The sub-tidal aquaculture application has been controversial since it was filed nearly two years ago.

Species now listed on the 81-hectare application include oysters, scallops, cockles and horse clams. On-bottom predator netting and containment structures are included in the plans.

Geoducks (pronounced gooey-duck) and sea cucumbers were listed on the application when it was first filed. Geoducks were removed shortly after filing the application, but sea cucumbers were on the application until about a year ago.

The Department of Fisheries and Oceans will not approve any licences for geoduck or sea cucumber aquaculture until it has management policies in place for these species. Although the applicants tried to get approval to grow sea cucumbers for research, that species was denied on the application more than a year ago.

A group of area residents have voiced a wide variety of concerns since the beginning, some esthetic and many environmental.

Local group the Friends of Baynes Sound Society wants a moratorium on aquaculture expansion in Baynes Sound until more research is completed, such as research on water quality, acidity levels and temperature. For more information, visit

One concern voiced repeatedly throughout this tenure application process was the large size proposed.

Gant, who owns the Gartley Point Hatchery for shellfish, says the idea was always for a low-density aquaculture model rather than a high-density one, hence the desire for a large area to operate on.

“This is just one model that we’re trying to show people how you can raise a multitude of species and fit into the surrounding ecology without trying to impose an intensive approach, just keep it the same density that Mother Nature normally likes,”  says Gant, noting the smaller tenure size, if approved, would be for a smaller operation that is still low-density.

“We don’t want to impose on Mother Nature what we think she should be doing on our behalf; we want to find out what she’s happy with and fit into that ecology. She is massively more powerful than us and we need to respect that a lot more than we do, not try to jam a whole bunch of animals into a small space.”

His blog, (, outlines an example of how sea urchins, geoducks and sea cucumbers could be grown together to create a healthy ecology, noting sea cucumbers, for example, eat rotting organic material, which helps keep the ocean’s ecology healthy.

DFO is working on aquaculture management policies for geoduck and sea cucumber, and aims to have these policies in place this year.

Gant says if the 81-hectare tenure is approved, and if DFO allows geoduck and sea cucumber farming in the future, he will consider applying for a licence for these species on that site at a later date, but he adds the site is not optimal for geoduck growing.

Public feedback will be accepted on the current application until March 15. To comment, visit

Meanwhile, another application for a large aquaculture tenure, which was filed around the same time as Gant’s application, is still listed as ‘under review’ on the Ministry of Forests, Lands, and Natural Resource Operations website. This sub-tidal application is 107 hectares and located between Union Bay and Buckley Bay.

Find this article at:

Integrated Geoduck Management Framework – DFO asking for public consultation

Via DFO -

Integrated Geoduck Management Framework

Fisheries and Oceans Canada is soliciting comments regarding the Integrated Geoduck Management Framework.

Your feedback is welcome as an important input into the development of this framework.

This public consultation period is open from March 6, 2014 to April 19, 2014.

In order to include your advice in the management plan, your input must be received by April 19, 2014.

You may provide input by e-mail to

DRAFT Integrated Geoduck Management Framework

Letters to the Editor and Aquaculture survey

Here are a few letters to the editors appearing in this weeks papers. Please take the time to read them and have a look at the survey that the Comox Valley Echo has on their website.

Survey in Comox Valley Echo

Sustainable or Seastainable?

MARCH 5, 2014

How is increasing the number of shellfish aquaculture tenures and experimenting with wild species in Baynes Sound working with Mother Nature? It certainly isn’t addressing the real problem. Industrializing Baynes Sound by increasing aquaculture tenures may in fact feed into the problem, ultimately creating its own demise.

The problem is C02 emissions. As long as we base our economics on fossil fuels and mass production of products to be shipped to far away markets, C02 will rise.

The answer lies in the first of the three “R’s” – REDUCE! This includes how we market. If food is massed produced and shipped abroad, then the positive loop of C02 emissions is reinforced. It is time to change this model if we hope to survive.

Aquaculture can learn from land-based farming. The industrialization of farming has not only increased greenhouse gas emissions but has also resulted in inferior food. People are returning to small local farms for their chickens, eggs and vegetables as the food tastes better and it has higher health benefits. Although we seem to always have a dollar value for marketing our industries, there is no price tag for health.

Let’s fix the real problem and not add more problems into this complex equation. It is time to stop the expansion of aquaculture and avoid risking Baynes Sound with experiments. Why not let the ocean rest from our human egos, we have yet to prove we can perform better than Mother Nature.

Sue Vince

Seahorses and mermaids

MARCH 5, 2014

In response to Mr. Penner’s story “Experimental Underwater Farm Planned”:

It is amazing to me that after numerous public meetings, several writing campaigns and a petition signed by more than four hundred area residents expressing their strong opposition to the expansion of aquaculture in Baynes Sound that the Ministry of Forest, Lands and Natural Resource Operations (MFLR) is still considering granting an application for an aquaculture tenure in an area of northern Baynes Sound so enjoyed for its natural beauty and recreation.

This application, (MFLR File: number 1413722) which takes in an area of the Sound between the shoreline of Craigdarroch beach and Sandy Island Marine Park, (Tree Island) has gone through several permutations over the past couple of years. Initially it was for farming geoducks, then it was changed to one for “ranching” sea cucumbers now according to the applicant Mr. Eric Gant, he wants to “experiment” with cockles, scallops, oysters and horse clams, what’s next, seahorses and mermaids?

If the dramatic failure of Island Scallops 2010, 2011 and 2012 crop, where an estimated ten million scallops died, tells us anything it is that we must find out much more about what is going on in our oceans before allowing any more aquaculture in the area. Island Scallops has had to lay off thirty percent of its workforce and now CEO Rob Saunders says he is looking for support from the government. Will this be yet another case where the taxpayer is left to foot the bill?

Our Provincial Government is allowing this to happen. Granting Mr. Gant his tenure gives him the opportunity to try his “experiment”. This is a huge area, 81 hectares of some of the prettiest waters around. Mr. Gant boasts of a venture that could generate millions, yet Island Scallops CEO Rob Saunders says they are not sure they can survive. Who is right?

Experiments are best done in the lab under controlled conditions, not in the waters of our Sound and not if there is a chance the taxpayer will have to pick up the tab when things go wrong.

Comments on the application close on March 15, please take the time to write to the ministry of Forest Lands and Natural Resources. Mr. Steve Thomson is the MLA responsible. Let him know your thoughts.

Robert Macdonald

Experimental underwater farm rushes for the last areas in Baynes Sound

March 4, 2014 •

Are we going to risk the last remaining undeveloped foreshore areas of Baynes Sound by rushing to open them up to an experimental “seafarming” project?

Two years ago this same area faced a rushed application for sea cucumber culture, and public concern was correct when DFO denied approval due to no management plan yet existing for the species. Now we are facing a new experimental application for different shellfish species by the same interests – only this time without any public consultation.

This most recent application comes from Seastainable Aquaculture’s Eric Gant, Bon Thorburn and Dan Bowen, the same Dan Bowen who sits on the board of Project Watershed Society and identifies as project manager of the Gartley Point Shellfish Hatchery, and yet claims no conflict of interest.

The average shellfish tenure in BC is less than 5 hectares but this latest application is 81 hectares. In recent years, acquisitions have expanded greatly even though the 2002 Baynes Sound Management Plan said we might have already hit the threshold for more aquaculture – considering all competing uses – without harming the viability of existing industry. In 2010 the Regional Growth Strategy said, “it is uncertain whether any further tenures or farms can be created” and gave the baseline of 470 hectares already tenured. Perhaps polyculture could increase the volume of production without expanding the footprint.

Baynes Sound is not pristine, there is no systems approach to our watersheds and multiple industries appear to be seeking maximum possible land. Yet lost in this battle royale is the fact that Baynes Sound is the second most important wetland for birds in all BC after the Fraser River Delta, only eight estuaries of this significance exist in the whole province, and it already supplies half of BC’s cultured shellfish – which face deteriorating local ocean conditions from acidification and development.

So what about our duty of care to protect this invaluable marine resource?

Already 90% of Baynes Sound foreshore is under aquaculture tenure. Before approving a large experiment with predator netting on or near sensitive habitats, herring spawn areas, the Amber Way Biofiltration Wetland and the Beacon Creek outflow where shellfish harvesting has been prohibited by DFO for over a decade – wouldn’t responsible action require updated science on carrying capacity?

As with sea cucumbers, cockle aquaculture in BC is in its experimental stage. The applicants say they will use on-bottom culture, for oysters too, so the growing method is also experimental. Island Scallops tried “on bottom” culture and it didn’t work for them. No one in BC is currently farming horseclams or producing them in a hatchery. Oyster farmers in BC are already having trouble obtaining enough oyster seed to sustain current levels, let alone this proposed increase in production.

I support shellfish aquaculture when the tenure site is located and operated in accordance with our government’s many sustainable development guidelines. Economic development decisions must balance priorities and contribute to the long-term sustainability of our community and environment. What we should not do is impose unnecessary risks or falsely pit concerned citizens against each other. It’s critical that we not overload Baynes Sound in its most sensitive remaining areas.

S Smith


Experimental underwater farm planned VIA – Comox Valley Echo

Experimental underwater farm planned

 - Where the creek meets the ocean at Amber Way in Union Bay. The proposed aquaculture operation would be located far below the surface off shore. -
Where the creek meets the ocean at Amber Way in Union Bay. The proposed aquaculture operation would be located far below the surface off shore.

FEBRUARY 28, 2014


Shellfish growers behind a revised aquaculture plan covering 81 hectares along northern Union Bay say now is the time to experiment with farming a variety of sea creatures underwater as one scallop producer blames ocean acidity for the loss of $10 million in product.

Eric Gant, one of three people behind a proposal to start growing cockles, scallops, horseclams and oysters at the bottom of the ocean south of Royston, with a company called Seastainable Aquaculture Ltd., said the recent loss of 10 million scallops announced by Rob Saunders, CEO of Island Scallops, highlights the need for shellfish producers to try different farming methods to work with Mother Nature instead of against her.

“The ocean is not static. It’s dynamic entity,” he said. “We have to become more respectful.”

Along with Bon Thorburn and Dan Bowen, Gant would like to farm 54 tonnes of Nuttall’s cockle, 100 tonnes of Pacific oysters, 27 tonnes of Pacific scallops and 80 tonnes of horseclams per year on the site – though he says it’s hard to say what the yield would be right away.

The application was resurrected and downsized slightly from a previous application for a geoduck and sea cucumber farm that had been denied.

“What we’re dealing with here is an extremely complicated and delicate ecosystems,” Gant said. “I think it’s an oversimplification to say it’s a single-cause problem. We’re hoping to resolve it by doing further experimental work with other species.”

Saunders said his company was caught off guard by carbon dioxide levels in the ocean as high as 1,400 parts per million, causing pH levels to drop so low they are hazardous to scallops.

“I have never seen pHs like this,” he said. “That’s beyond anyone’s wildest speculation.”

Brian Kingzett, manager of the Deep Bay Marine Field Station for Vancouver Island University, said while he hasn’t seen research to support a connection between a high mortality rate of mature scallops and ocean acidification, there is a demonstrated effect on the larvee process.

He pointed out it was curious Seastainable Aquaculture would put in an application for species that right now are only wild harvest.

Some residents and members of industry wonder if Gant, who is the president of the geoduck-focused Manatee Holdings Ltd., is trying to circumvent the freeze on applying for geoduck projects as the government works out its policy on harvesting native animals in setting up farming operations.

While Gant acknowledges that geoducks had been included on the previous application, he explained the area is not all that suited to farming the bivalve, which enjoy surges found in more open waters.

“It’s not a particularly good area for geoducks. It’s too sheltered,” he said, adding, “We still believe in a polyculture approach.”

He see the current application in the context of the larger picture of Vancouver Island shellfish farming.

If the industry gets it right there is the potential for a Salish Sea aquaculture industry valued in the billions.

“We can create something that would be very beneficial to the ecology of the Baynes Sound and the economy of the Comox Valley,” he said, noting the proposals from his Salish Seafarms Ltd. venture could generate $50-100 million annually in revenue. “We have to deal with these uncertainties on an ongoing basis whether you’re a wheat farmer, in chickens or aquaculture.”

March Klaver, with the sea farming division of Fisheries and Oceans Canada, said the department will take a look at the application to make sure it fits with their plans for the sustainable operation and development of the shellfish aquaculture sector.

In considering the location of the application, fish habitat, wild populations, at-risk species, fishery activities in the area and First Nations needs for traditional and other purposes are all factors that will come under consideration.

“If a farm is sited appropriately it can dramatically reduce potential impacts to fish and fish habitat,” read a statement sent to the Echo. “Through appropriate siting, and with applicable mitigation measures, the department works with industry to ensure the sector operates with low risks of impact or conflict.”

Though K’ómoks First Nation member Richard Hardy has met with proponents on more than one occasion to discuss the northern Union Bay aquaculture possibilities, the involvement of the band in the project is still something that will be left “to be discussed down the line,” Gant said.

Public comment on the northern Union Bay application will be accepted until March 15. 

Please send your comments to: 

Authorizing Authority

Aquaculture, Ministry of Forests, Lands and Natural Resource Operations
2500 Cliffe Avenue
Courtenay, BC  V9N 5M6
email address:

No Public Notice Needed! Significant Changes (size and species) to Application File #1413722 AQUA

No Public Notice Needed! Significant Changes (size and species) to Application File #1413722 AQUA

 sanitary closures and application 1413722

Do you recall the two  aquaculture applications for Geoduck and Sea Cucumbers? Application #1413722 was applied for in Oct. 2011 and application #1413764 was applied for in Nov. 2011. Where do these applications stand today?

On December 12, 2013 members of board of FOBSS met with Ken Albrecht, who represents Provincial Ministry of Forests, Lands and Natural Resource Operation. We were informed of changes to the applications. File #1413764 (central Baynes Sound) is not going forward at this time. However as of June 24, 2013, File #1413722 (North Baynes Sound) has been revised with a change of species as well as tenure size. The species list now includes Scallops, Oysters and Horseclams. These new species will be bottom cultured and covered with predator netting. The change in size of the tenure was due to the Sanitary Closures in part of the original application. (Refer to map of Area 14 – Pacific Region Sanitary Closures – Closure 14.1 This is seen on the last two pages of the application shown as “Depuration area”.)

The details of this new application were finally uploaded to Front Counters website on Jan 29, 2013, and can be found here: Application File #1413722 AQUA

During our discussions on Dec 12, 2013, MFLNRO (Ministry of Forest, Lands and Natural Resource Operations) informed us that the applicant does NOT have to reapply for this application nor do they have to issue a public notice.

Please contact your local Government involved (contacts below) and challenge the decision to allow the application to proceed with no public notice or consultation regarding these proposed changes to application Application File #1413722 AQUA.

cc: – Mr. K. Albrecht, Crown Land Operations & Aqua

cc: – Mr. Bruce Jolliffe,  Area “A” Regional Director

cc: – The Honourable Don McRae (MLA)

cc: – The Honourable John Duncan (MP)

cc: – Jennifer Mollins, Senior Coordinator, (DFO)

Pictures of Problem Vessels and Floating Structures Requested

Pictures of Problem Vessels and Floating Structures Requested

Jan 8 ,2014

In response to on-going concern regarding problem or ‘derelict’ vessels and floating structures, Transport Canada is looking for additional data in order to develop a long-term strategy.

Transport Canada recognizes the contributions communities have already made for data collection. At this time, in order to develop a strategy and solutions for Vessels of Concern, additional and more specific information is required. Transport Canada is asking that communities complete a “Derelict Vessel Inventory” form for each vessel or structure that your community is able to document. Photographs are also very important to estimate the scope of work needed to create a strategy.

Data must be submitted by March 5, 2014.

Please forward all the information you collect to Russ Tyson. Russ can be contacted by phone if you require a mailing address: 604.461.6664.

If you have any questions or would like more information, please feel free to contact Maria Stanborough or by phone, 604.270.8226, ext.113.

See source here:

Threats to consumers, marine environment – Via – C.V. Echo

Published December 3, 2013

Threats to consumers, marine environment

Like others in the Comox Valley, I support regional economic sustainability and applaud shellfish aquaculture industry values of producing healthy shellfish and preserving and protecting a fragile marine ecosystem. On the surface, then, expanding oyster and geoduck leases in subtidal and intertidal zones can appear to answer the need for economic development in the Baynes Sound.

However, these initiatives that involve expanding oyster tenures and introducing hundreds of hectares of subtidal and intertidal geoduck operations violate two recently published government scientific advisories. These advisories would call an immediate halt due to excessively high Cadmium levels in Baynes Sound and the lack of scientific research to predict long range cumulative effects of either intertidal or subtidal commercial-scale geoduck operations.

Baynes Sound waters are verified as having some of the highest Cadmium levels in the world and oysters grown in the Baynes Sound have Cadmium levels that exceed health levels set by WHO, Eu, New Zealand and China. BC oysters exceeding the Chinese maximum level of 2 ppm have been returned. Recognizing the potential market impact of high Cadmium levels, the Aquaculture Collaborative Research and Development Program (ACRDP) Fact Sheet (Issue 7/May 2010) on Cadmium in Deepwater-Cultured Oysters advises the industry to site leases in waters that are known to be low in Cadmium and to harvest in the summer months when the levels are known to be a little lower. Given Baynes Sound verified high levels, any expansion of oyster leases violates this advisory and puts consumer health at risk.

After the Chinese returned BC oysters, Health Canada issued an advisory to limit consumption of BC oysters to 12 per month, but those at high health risk– individuals with renal failure, smokers, women, children and First Nations individuals–should show extra caution. This advisory can be read in the BC Disease Registry where it is accompanied by the misleading claim that the research linking consumption and health risk is not strong. Some scientists argue the 12 per month limit should be lowered. It is alarming, therefore, to note that one local company is now licenced to harvest oysters in the Union Bay coal beds, an area slated for reclamation as a highly contaminated sites.

Government scientists also warn the industry to be cautions about lifting a moratorium on entering the highly lucrative geoduck market. The Canadian Science Advisory Secretariat, Study No. 2013-001 on environmental impacts of subtidal and intertidal geoduck harvesting and cultivation explicitly states that small scale studies cannot predict long term cumulative effects of commercial-scale subtidal and intertidal operations. This caution would call for maintaining the Precautionary Principle on entering the geoduck market, not putting hundreds of hectares under cultivation.

The fact that government shellfish aquaculture management is ignoring its own scientists is alarming. More alarming is the potential cost to consumer health and to a fragile marine ecostem.

Sharon Small

Denman Island Resident

Commercial diver concerned about geoduck applications – Via Comox Valley Record

Commercial diver concerned about geoduck applications

By Comox Valley Record
Published: December 11, 2013 11:00 AM
Updated: December 11, 2013 11:4011 AM

Dear editor,

Comox council knows about as much about sub-tidal geoduck aquaculture as I do about what’s beyond the event horizon of a black hole.

While I appreciate and admire those people willing to work in Town council, a little due diligence is in order. The fantastic prognostications of the promoters were swallowed hook, line and sinker.

I’ve been involved with the first geoduck aquaculture company, Fan Seafoods, for 18 years as a diver, a major investor and as a member of the board. I planted the first geoduck seed in B.C., which was grown by Island Scallops for Fan Seafoods, into a protected site near Marina Island. I have yet to get back more than a small proportion of my investment.

A litany of the many problems and trials we’ve encountered would take more time and space than your readers would be willing to plow through. In short there are two major problems for any shellfish company.

The production of seed to plant: Try to keep your optimism when you spend several hundreds of thousands of dollars in a hatchery and have a total loss. This has happened to us more than a few times.

There are many ways to lose seed and more are being discovered. When you do get viable seed and you try to plant them in suitable ground, you provide a concentrated source of food to attract the many predators.

This necessitates the placement of various predator exclusion devices, most commonly nets and lengths of piping. Despite the cost, this has only varying degrees of success.

As a commercial seafood diver, I have found that after a storm and diving on the Comox bar, the bottom is disturbed and the sand shifted down to 60 feet. Nets are usually put down from about 25 to 40 feet. Need I say more?

The commercial geoduck dive fishery is one of the best-managed and conservative in Canada and perhaps the world. They harvest only a small percentage of the total biomass and are totally committed to sustainable yield.

The Comox bar and surrounding areas are known to the Department of Fisheries and Oceans as a natural recruiting area, which is self-seeding. These tenure applications are fully exposed to our worst and strongest winds, which — as any local fisherman knows — come from the southeast, and are therefore unsuitable for aquaculture.

To turn this into an aquaculture tenure it would be necessary to alienate it from the wild fishery, which is already being decimated by sea otter predation.

George Dennis,


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