DFO Aqua Enforcement Response Letter to Denman LTC

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From: AQSF / AQSF (DFO/MPO) <ShellfishAquaculture.XPAC@dfo-mpo.gc.ca> 
Sent: Thursday, August 6, 2020 12:09 PM 
To: Wil Cottingham; AQSF / AQSF (DFO/MPO) 
Cc: Denman Island Local Trust Committee; ADIMS info; Lesley.Fettes@gov.bc.ca; 
john.mackie@tc.gc.ca; lawrence.kuan@tc.gc.ca; Roberta.dight@tc.gc.ca; 
Jordan.Wagner@gov.bc.ca; Kosmider, Gabrielle; Marrie, Christopher; Kaatz, 
Robert; Nichole.Prichard@gov.bc.ca 
Subject: RE: Complaint from Denman Island LTC regarding DFO Aquaculture Licence 
Number 119203 
 
Dear Sue and Wil, 
 
Thank you for your email. The letter that you’ve submitted was carefully reviewed by DFO Conservation 
and Protection (C&P) and Transport Canada (TC) and they have both contributed to this response. We 
understand and appreciate your concern with Aquaculture Facility Number 1004, Landfile 1400036 
located on Denman Island. Upon reviewing your concerns it appears that while you mention predator 
netting and debris, the main concern you are raising is pertaining to rafts drifting and being anchored off 
the tenure, which appears to be infrastructure located outside of the public viewable management plan, 
as well as potentially posing a navigational issue. 
 
Responsibility for the regulation and licensing of aquaculture in British Columbia (BC) is shared by 
several provincial and federal agencies. DFO licenses the activity of aquaculture as a fishery, and our 
jurisdiction is limited to topics related to fish and fish habitat (e.g., proposed species for cultivation, 
production rates, rearing methods, fish health and marine habitat concerns).  The DFO Conditions of 
Licence and other regulatory requirements for aquaculture operations, which licence holders must abide 
by, are monitored and enforced by DFO C&P fishery officers.  Here is a link to the DFO Shellfish 
Aquaculture Conditions of Licence: https://www.pac.dfo-mpo.gc.ca/aquaculture/licence-permis/index-
eng.html#ov-conditions.  Land use and concerns related to navigation fall outside of DFO jurisdiction; 
these issues are addressed by the Province of British Columbia, TC, and local governments.  
 
For clarity, as part of the harmonized aquaculture approach, our partner agencies generally deal with 
the following: 
 
Transport Canada  
 Impacts to navigation and placement of navigational markers. 
 
Province of BC  
 Proximity to Provincial Parks and reserve areas. 
 Riparian rights. 
 On and off-tenure activities. 
 
DFO C&P recognizes and acknowledges the potential environmental impacts and compliance issues 
associated with the debris generated by the shellfish aquaculture industry in BC. As such, C&P has been 
engaged with stakeholders, First Nations, NGOs and industry, as part of working groups, attending 
shared forums and participating in annual Beach Clean-up events, prior to COVID-19. C&P was also 
involved in the development of the Shellfish Aquaculture Debris Strategy and executed subsequent 
aquaculture debris focussed inspections in 2018, in conce

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