Potential Geoduck Farm In Waters Off Kye Bay

Thanks to our neighbour Sandy Stewart, in mid-November 2013 the Kye Bay Ratepayers’ Association (KBRA) learned that Salish Sea Farms Ltd has applied to government for permits to farm geoducks in the waters off Kye Bay.  Their application is at:


The application includes a map which shows the proposed 94 hectare farm extending from a point in deep water off the end of the Kye Bay spit, parallel to the coastline to a point north of Air Force Beach. I understand that Salish Sea Farms is owned and/or operated by K’omoks First Nation.

KBRA directors have been examining the application. What is the local impact of a geoduck farm?  While the marine ecology is of course of interest, so is any impact on the amenity value of Kye Bay as a residential area and as a recreation destination for the Comox Valley.  What sights and sounds would Kye Bayers experience during the farm operations?

The farm would be in waters some 10 metres deep.   Seeding and harvesting the crop would be by boat.  Divers would seed the sea floor with hatchery stock, covering the area with netting against predators such as starfish and crabs.  The netting would be kept in place for the first two years, then removed.  After a total of some 8 years, divers would harvest the mature geoducks by injecting sea water into the sea bed.

The government has invited comments on Salish Sea Farms’ application  with a deadline of Thursday, November 28th. Written comments should be emailed to the Manager, Aquaculture, Ministry of Forests, Lands and Natural Resource Operations at AuthorizingAgency.Nanaimo@gov.bc.ca

Following an approach by the KBRA, Salish Sea Farms has kindly agreed to meet with Kye Bayers for a question and answer session.  All  are invited:

• 7:30 pm on Wednesday November 27 • at the Band Hall, 3320 Comox Road, Courtenay (adjacent to the Queneesh gift shop).

Mr Tom Broadley, Agent for Salish Sea Farms, will be attending.

Please use “Leave a reply” below if you would like to comment on this issue.

2 thoughts on “Potential Geoduck Farm In Waters Off Kye Bay

  1. Here are a few additional questions and concerns:

    1) Impact on Kelp and Other Species Restoration

    I have witnessed a dramatic reduction in the diversity and density of life in the bay and around the reef since 1970 when I began to visit Kye Bay on a regular basis. My discussions with Fisheries Canada suggest that no one knows the cause of this negative trend. My personal theory is that the loss of the kelp beds near the reef may be an important factor because kelp provides habitat in a manner analogous to forests on land.

    Kelp is in decline on most of the coast. There are several kelp restoration projects underway in the region including at Point Holmes and Hornby Island. If these projects prove successful I think we should attempt to re-establish kelp around the Kye Bay reef.

    My question is, have any studies been done to compare the location of historic wild kelp beds with the planned location of the geoduck farm? I think any areas that previously grew wild kelp should be avoided since the geoduck farm equipment and operations will prevent kelp restoration.

    A related additional concern I have is that one possible solution to kelp restoration is restoration of sea otters since they are a predator of sea urchins which in turn feed on kelp. Sea otters are also a predator of geoducks and thus I see another possible future conflict between kelp restoration and geoduck aquaculture.

    2) Responsibility and Funding for Business Wind-Up

    Most people are probably aware that the US has been expanding its money supply at an unprecedented rate to stave off an economic depression. Specifically, the US is printing about $1 trillion dollars per year or about $3 billion per day. What most people may not realize is that China has been expanding its money supply at over 3 times this rate at about $10 billion per day. I do not know when or how this will end but I do know that mathematics and history guarantees a very bad ending. I think it highly probable that the China bubble will burst within the next 10 years. This means that the major market (China) for geoduck may significantly decline before the first harvest of farmed geoduck. This in turn means a high probability of business failure for new geoduck aquaculture companies.

    My question is, what financial and legal guarantees have been made for deconstruction of farm infrastructure and seabed restoration in the event of business failure? I think the government should require the company to put sufficient funds in a trust account for an environmentally responsible wind-up before the operation is approved.

    3) Responsibility for Ongoing Cleanup of Human Mistakes and Acts of God

    What provisions have been made for cleanup of equipment failures caused by human error and/or Acts of God? If, for example, a predator net becomes detached from the seabed due to a storm or pleasure boat anchor, and is washed onto the Kye Bay shoreline in an area inaccessible to equipment (as is the case for the majority of the Kye Bay shoreline) what responsibility does the company have for cleanup and what method is planned to implement the cleanup?

    4) Impact on Wild Geoducks

    What percentage of the natural habitat for geoduck will remain for wild geoduck stocks in the proposed farming area?

    What is the source of brood stock? If the brood stock is not obtained from local wild stocks, how do the genetics differ?

    Will the geoducks be harvested before they reach sexual maturity? How do you know the answer to this question given that the literature does not seem to agree on the age of sexual maturation?

    How will the density of farmed geoducks compare to the density of wild geoducks that previously occupied the site?

    5) Precautionary Principle Should Apply

    My brief survey of the literature on geoduck aquaculture suggests that environmental impacts are not yet understood due to a lack of research and the infancy of the industry. We know from the history of salmon aquaculture in B.C. that once an industry is established it is almost impossible to stop it regardless of negative impacts on the environment that later come to light. It is therefore wise to follow the precautionary principle.

    My question is, what studies are currently underway on existing geoduck aquaculture sites in B.C. and when are results expected? I think approval of the farming license should be withheld until credible science confirms that the impacts are acceptable.

  2. I copy here the opinions and questions on this issue that I have received in emails from Kye Bayers over the past few days, up until noon on November 29. Not included are the names of the authors because I’ve not had the opportunity to obtain their permission to show their names. The breaks (======) between indicate the start of a new author.
    I oppose the application for License of Occupation for Aquaculture  (Geoduck on bottom) for the following reasons:
    1.    The onshore properties which face on the proposed license areas are currently residential and the creation of industrial operations in the foreshore areas are highly inappropriate due to the predictable degradation of the quality of tenure for the residents there.
    2.    The presence of industrial operations in the foreshore areas will drastically affect the property values within the existing residential areas.
    3.    The harvesting techniques, hydraulic plowing of the sea bottom, will have a seriously negative effect on the marine environment, and collateral damage to all of the other organisms within the license areas.
    4.    There has not been a good scientific environmental review of Geoduck aquaculture.  Geoduck aquaculture is fairly new and there are potential issues as in any aquaculture with both the control of pathogens and the potential for reduced genetic diversity leading to widespread disease susceptibility.
    5.    The areas of the licenses are spawning grounds for herring and the use of hydraulic harvesting will, at best, degrade, and at worst destroy, those spawning areas along with the marine plant life necessary to the spawn.  The permit application also includes reference to Sea Cucumber nursery bags in .05% of the license area.  Sea Cucumbers are a major predator of the roe of Plainfin Midshipman also known as Bullheads (Porichthys notatus).  Bullheads are a source of food for the Bald Eagles living in the area.
    6.    Kye Bay is also a critical spawning habitat for Sand Lance (Ammonodytes hexapter) that we used to call Needlefish.  This species along with the herring already mentioned together are the most important forage fish for recovering salmon stocks.  Pacific Salmon Foundation and others are putting large efforts and resources into salmonid restoration in this region.  Healthy forage fish stocks are also key to the recovery of many at risk marine species and are the “protein” base of the complex food webs that support iconic species like Killer Whales (Orcinus orca) and Marbled Murrelets (Brachyramphus marmoratus).
    7.    The locations of the licenses are within recreational fishing and crab trap areas and the proposed industrial use will interfere with that recreational use.
    8.    These areas are already home to a sizeable population of wild/natural geoducks and there will be no way of differentiating wild from farmed geoducks – they will all go.  Since it will take 8 to 12 years for the farmed geoducks to become harvestable, in the meantime the wild geoducks will solely be what is taken.
    9.    The actual planting technique; inserting short lengths of pvc piping into the sand and then covering with predator netting is also questionable from a number perspectives. Its effectiveness has not been proven in some of the BC areas where it has been tried and there is no requirement to remove the pipe after insertion. This will result in more plastic pollution in the water and will have unknown impacts on critical fish habitat such as eelgrass beds. In Washington State there have been habitat destruction issues with the removal of pipes and nets as well so either way there are issues. Our beaches are already littered with industrial waste and the proximate location of the proposed licenses will only increase the pollution of those beaches, rendering them less attractive for their primary designation as residential and recreational areas.  It is important to stress that the area is far more than residential and that perhaps the most compelling argument against the licenses is the potential for ruining an excellent recreational beach whereon thousands of people enjoy the sandy summer low tides of Kye Bay.  It is a public beach that is well loved and well used.  Imagine the impact of running barefoot through sand mixed with broken pvc piping. 
    10.The adjacent municipal zoning for the Kye Bay and Point Holmes license areas is as follows:
    401.1 Permitted Uses:
    In the M1.1 zone, the following uses are permitted and all other uses are prohibited:
    (1) Accessory structures and uses, excluding buildings and outside storage
    (2) Breakwaters
    (3) Navigation of boats
    (4) Parks                                      [Municipal Bylaw, Town of Comox]
    Industrial use clearly does not fit within or adjacent to this zoning.
    Please do not support nor approve the applications.
    Obviously, I am opposed to any aquaculture in the vicinity of Kye Bay or Cape Lazo.  I have written a brief letter as requested in the e-mail but a response from the Association would, I think be a good thing.  I didn’t think to put it in my letter but last summer for the first time in many years, at least 15, there were significant patches of herring off of Lazo and very significant numbers of coho jumping out in the gulf by the buoys off of Cape Lazo  It would be tragedy to invite other industry in and once again wipe out these fish.  I’m willing to review help, write and support any document the executive or members of the Association want to pursue.  I understand there is a Nov. 28 deadline which is why I put in a quick response today.
    I am opposed to any aquaculture in the Kye Bay and Cape Lazo areas and would support as a director of the KBRA taking a position of opposition against this application for a geoduck license. We will be forwarding two letters of opposition from our properties at Kye Bay.
    It is my understanding that there is very little research on the impact of the nets on the sea bed, not to mention the impact on other animals when the goeducks are blown out ….what else gets blown out along with the goeducks? It is my understanding that residents of Denman Island spend hundreds of volunteer hours cleaning up the mess on their beaches from industrial aquaculture: nets, buoys etc,…… what assurances will we have that Kye Bay will not be similarly filled with detritus?
    1. Has an environmental assessment been completed for this project?
    2. If yes for (1), is it available to review?
    3. Is this a one-time harvest after 8 years, or will operations
    continue after the harvest?
    4. Are there other geoduck farming operations similar to this in
    Georgia Strait?. If so where are they located?
    5. How much marine traffic will this generate? What type of vessel(s)?
    6. Will the area be off limits for recreation, or fishing?
    7. What is the anticipated start date, if approved?
    8. We would like additional info on the aquaculture methods:
    – how will the site be prepared?
    – how will predators be removed initially?
    – are there any protected species in the area?
    9. Why was there no consultation or info provided until almost the
    end of the period for comments?
    I have already filed an objection with
    the minister and the department involved , support opposition to the project
    but will not be able to attend the meeting.
    The biggest issue I see is the reduction in a valuable PUBLIC resource, the
    easily accessible beach and foreshore due the industrial nature of the
    harvesting, which after the first lengthy period of growth one would assume
    would be at least an annual process, if not more often.
    Is there any danger posed to recreational users of the bay? I am thinking
    the kite boarders, wind surfers, etc.
    …though this perhaps is not a really destructive project, surely there are
    better locations.
    Please add me to those who are opposed to this type of development so close to the shore here or elsewhere at our coastline. I thought that we have posted warnings about our shellfish being contaminated in this area for a reason.
    You know they have been harvesting Geoducks in those areas for a long time. (Wild)They have always used divers with air tubes (You cant get them without the air blast) to harvest. It is very hard work. I used to commercial dive for Swimming scollops when I was a little younger. The area that would concern me is the 1414127. That is where the sewer outfall is located. I am very familiar with what is underwater out there as I have dove the whole area from the yellow bellboy all the way over to the out fall. It is some of the best diving I have done. Thank god it is not fish or oysters they want to farm in front of our beach houses. Denman Island is not looking very good as all the coast on both side are seafood industrial lands. Its ugly. I have one question. How will this farm affect the #1 Abalone(they are trying to make a come back) #2 purple hinge rock scallops that are abundant but on the decline. 1414127 is the area with those other shellfish?
    1. What risk assessment did the applicant perform with regards to
    disruption of mud and sand, destruction of the biological sea bed soil.
    2. Ask the applicant to describe in detail how the process works,
    disruption of sea bed soils. Would we accept the same kind of disruption
    on the land and allow it to flow into the ocean?
    3. What pre-inspection and post inspection of the harvest sight will be
    done to demonstrate no harm to the environment.
    4. When measuring benefit and risk, who is to gain? Who is to lose? The
    risk to public waters for private gain has not been identified.

    Several decades ago permits were granted for harvesting at Kyebay. The
    harvesters took advantage of the permit which did not describe in detail
    limitations in harvesting including methods and means to acquire the
    bounty. Sadly, Kyebay reef, mud flats and surrounding areas were stripped
    of almost all shellfish life for decades to follow. With that change came
    decrease in needle fish and hearing spawning clearly visible in tidal pools
    years prior.

    The new application has no measured limitation to the harvesting process, no
    accountability in risk identification or management, no acceptance to the
    liability of silt transfer via tidal water or currents. The applicant
    wants approval to hydro- blast under water, unseen by public eyes. The
    potential consequential damage to other marine life resulting from large
    scale hydro-blasting is certain.

    The applicant must provide specific method, have constraints on current and
    tidal flows prohibiting harvest times. And because harvesters have not
    proven trustworthy, require independent inspection should be required at the
    time of harvesting.

    Geo-duck harvesting is not an essential need of the public.

    The applicant must prove why this is good for public when applying to use
    public land.

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