Letter Minister LeBlanc MP

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200 - 1627 Fort St., Victoria, BC  V8R 1H8 
Telephone  (250) 405-5151    Fax  (250) 405-5155 
Toll Free via Enquiry BC in Vancouver 604.660.2421.  Elsewhere in BC 1.800.663.7867 
Email  information@islandstrust.bc.ca 
Web  www.islandstrust.bc.ca 
 
 
Bowen  Denman  Hornby  Gabriola Galiano  Gambier  Lasqueti  Mayne  North Pender  Salt Spring  Saturna  South Pender  Thetis 
January 2, 2018 
 
via e-mail: min@dfo-mpo.gc.ca 
 
File Number: 5450-30 
 
The Honourable Dominic LeBlanc, MP 
Minister of Fisheries and Oceans Canada 
200 Kent Street, Station 15N100 
Ottawa ON K1A 0E6 
 
Dear Minister LeBlanc: 
 
Re: Request for ecosystem-based study of potential impacts of the Integrated Geoduck Management Framework 
2017 on the health of the Salish Sea 
 
On behalf of the Islands Trust Council I am writing to request that Fisheries and Oceans Canada undertake, as a 
priority, an ecosystem-based study of potential and cumulative impacts of the Integrated Geoduck Management 
Framework 2017 on the health of the Salish Sea. 
 
There are concerns in our island communities that DFO did not sufficiently consider ecosystem and cumulative 
impacts before approving the 2017 Integrated Geoduck Management Framework. It is my understanding that when 
creating the Framework, DFO chose to focus analysis of geoduck aquaculture impacts to “conservation and long-term 
sustainability of wild geoduck stocks” rather than impacts to the broader environment. No mention is made in the 
Framework of protection of the marine environment, fish habitat, biodiversity or human health. DFO staff advises that 
broader ecological impacts will be assessed at the licence application level. This raises concern for us and community 
members that assessment at the individual licence level will result in insufficient consideration of cumulative impacts 
regionally, and at the ecosystem level.  
Concerns  about the  adequacy  of  the  science  that  informs geoduck  aquaculture regulations are  not  new.  In  2007, 
the BC Legislature’s Special Committee on Sustainable Aquaculture recommended that: “No new species are to be 
approved  for  commercial  aquaculture  without  a  consensus  of  independent  peer-reviewed  science  demonstrating 
that the potential impact on the marine environment is minimal”. (7.5)  
Islands Trust staff has reviewed the available research and did not get an impression that there is yet scientific 
consensus about the potential impacts of intensive geoduck aquaculture in the Salish Sea. Staff noted that many 
articles conclude with calls for additional research. It seems prudent for DFO to study and understand the potential 
and cumulative impacts of future geoduck clam aquaculture installations.  
The Framework states that the objective of supporting economically, environmentally and socially sustainable wild 
and aquaculture fisheries will support the integrated management of wild and aquaculture fisheries for geoduck. With 
this in mind, we respectfully suggest th

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