Friends Of Baynes Sound Society

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RE: Public Watching Sea Cucumbers

RE: Public Watching Sea Cucumbers

Residents aren’t alone when it comes to wanting water conservation areas in Baynes Sound. The Nov. 13 letter asking for coastal areas to be set aside and left “untampered by industry” actually echoes a longstanding recommendation from Canada’s lead scientific body, the Canadian Science Advisory Secretariat (CSAS).

In a 2001 baseline review of aquaculture’s environmental impacts on Baynes Sound, the CSAS recommended: An effective network of protected areas in Baynes Sound that exclude shellfish aquaculture should be established. The network should include sensitive habitats and key bird habitat. The coastline of Baynes Sound is already 80-90% tenured by the aquaculture industry – which dramatically drives up the social and ecological value of the last remaining unfragmented areas. These sensitive habitats need to be protected.

If approved, the sea cucumber tenures would become the second and third largest tenures in BC. Whereas the average aquaculture footprint is less than five hectares, the sea cucumber tenures total 270 hectares. Although a native species, sea cucumbers have never been farmed in BC and their impacts haven’t been studied. Because it is a brand new species for ranching, there isn’t yet a policy framework for guiding the development of sea cucumber aquaculture. Wild harvesters of sea cucumbers are concerned. I wonder the position of the commercial fishing associations like the Herring Industry Advisory Board, the BC Seafood Alliance and the Underwater Harvesters Association and if they oppose the proposals as they currently stand.

Raven coal mine opponents might benefit from the creation of a recognized water conservation area in Baynes Sound. Protected areas would also protect existing shellfish aquaculture from the losses caused by unrestrained industry growth. This supports the Comox Valley Regional Growth Strategy, which said in 2010 that, “with little room for additional tenures and shellfish farms, existing farms and tenures should be protected with no net loss.” The Regional District has no goal to expand the footprint of aquaculture in Baynes Sound, but rather to maintain what’s already in production and increase the weight of output. The current 470 hectares is the target that the Regional District wants to maintain until 2030. How could we possibly add another 270 hectares of sea cucumbers? As climate change and acidification ramp up threats, the best way to protect our coastal economies is to protect biodiversity.


The CSAS recommendation for protected areas falls under the DFO (and all conservation groups’) mandate to follow a precautionary approach to ecosystem management. The CSAS explains that “protected areas of an appropriate scale are essential as reference sites for future research studies and as “insurance” areas to ensure that elements of the natural ecosystem are being conserved.”

The sea cucumber proposal is speculation – because the proponents’ statements are based on scientific conjecture, not peer-reviewed independent research. The CSAS report states that the “lack of aquaculture impact studies in Baynes Sound renders opinions on ecological effects of aquaculture speculative.


Cumulative impact assessments, socioeconomic impact assessments, and baseline studies recommended by researchers and government have not been completed in Baynes Sound. The Institute for Coastal Research at VIU says that aquaculture’s “cumulative environmental impacts are not well known nor are the ways the industry affects the resilience of the sound’s social-ecological system or the well-being of the communities within it.” We must know if aquaculture activity adds up to a significant disturbance. Even the sea cucumber management plan, obtained through a Freedom of Information request, states that “these are optimistic plans and there could be many variables that could change these figures.”


Those linked with the project, including a consultant and a biologist, and the Comox Valley Conservation Strategy, have downplayed the public’s concern that these experimental ‘ranches’ might negatively impact the environment. But even a good research project can have a negative impact if it’s in the wrong place. The proposed sea cucumber tenures include sensitive areas, like the top five percent most vital herring spawn habitat, eelgrass beds and an internationally recognized Important Bird Area, which makes these areas ideal candidates for protection.

Intangible quality of life factors – lifestyle, cultural and recreational values – must also be given weight in the assessment process. These proposals haven’t met the criteria for economic, ecological or social sustainability, which requires community consent (social licence) in order to proceed.

Some areas just aren’t right for industry. Let’s support the creation of conservation areas in Baynes Sound for the benefit of everyone and everything.


Phase 0 Review of the Environmental Impacts of Intertidal Aquaculture in Baynes

Sound. 2001. Jamieson et al.

Comox Valley Regional Growth Strategy. 2010. Schedule ‘A’ Comox Valley Regional

Growth Strategy Bylaw No. 120, 2010. Comox Valley Regional District.

Social-Ecological Resilience in Baynes Sound. 2012. Institute for Coastal Research.

Vancouver Island University.


Sue Smith



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