The Department of Environmental Protection will conduct a Public Meeting on October 28, 2021 from 5:00 PM – 8:00 PM via Zoom to provide an opportunity to comment on the applications for Waste Discharge Licenses filed by American Aquafarms. The particulars of the applications plus the Zoom meeting info are listed in the notice sent out by the DEP and included at the end of this letter.
We are encouraging any and all who can provide testimony at this meeting against granting the licenses to do so. It’s important to have lots of public show up. You can testify either in person or in a written letter. Testifying is important firstly to just show the DEP that there is wide interest in the application and that lots of people from all walks of life care about this issue. The DEP should hold apublic in person hearing (not just the Zoom public meeting)because the people have things to say.
If you want to submit testimony in the October 28 Zoom meeting, here are some ideas that you could have in your paper or be ready to speak to. You will likely be limited to three minutes in person (about a page full of words). Your written submission can be longer.
1. Be polite, and don’t bring up things that are not relevant to the application. Remember this is a waste discharge issue and DEP could care less what the fish farm looks like visually, or what it does to other boats, like in the lobster fishery. Items which relate to your general objections to the location like visual issues or even noise are not in the department’s criteria, and therefore not something they even look at.
2. Tell the DEP a bit about who you are and how you relate to Frenchman Bay; why it’s important to keep it as clean as possible.
3. Pick one or two points that you object to and ask for a Public Hearing on the application to address your concerns.
Here are three bigger themes you could bring up. You don’t need to be an expert; the purpose is to demonstrate that the people commenting understand the criteria (at least a little bit), and can relate their comments to the application. You are giving examples of weak points which should be further explored.
A. Consolidation of permits. Air pollution is a big deal for this area of Maine. Request that the DEP examine both the air and water pollution permits at the same time because one cannot function without the other. For example: Generators are included in the waste discharge application, but there’s no information on the air pollution that will result from running them 24/7.
B. Discuss why the Cormix model that is being used to depict water flow is not appropriate for Frenchman Bay. According to definitions, it should not be applied in tidal-only cases because it assumes steady state flow (like a river) where the pollution is carried away from the source on a regular basis. Frenchman Bay doesn’t have a river flowing through it. Therefore pollution is likely to concentrate upstream (you may remember seeing Lauren Ross’s calculations, where the particles in the bay slosh back and forth in the bay instead of going in and out). Better modeling is needed to determine just how the bay flows because pollution from this project directly threatens public health in the area (you can bring up clamming and the mussels being cultured and harvested in the bay).
You don’t have to be an expert to include these points in your testimony. Bringing up things the experts are going to discuss lets the DEP know that we are citizen scientists who understand how pollution will affect the bay and the various livelihoods dependent upon it.
C. Discuss the fact that the DEP chose to exclude from its Net Pen Aquaculture General Permit For Waste Discharge the area north of a line from Schoodic Point in Winter Harbor to Baker Island in Cranberry Isles, then west to Naskeag Point in Brooklin, Maine which includes Frenchman Bay. Reference https://www.maine.gov/dep/water/wd/net-pen-aquaculture/MEG130000-2014fact-sheet.pdf which states “The Department has chosen to exclude from the area of coverage the Blue Hill Bay and Frenchman’s Bay regions, since these areas have less tidal flushing and nutrient loadings are a relatively greater concern.” Exclusion from General Permit coverage does not categorically make these areas unsuitable for finfish aquaculture, and individual permits may still be issued. But ”The direct discharge of pollutants to Class SA waters is prohibited by Standards for classification of estuarine and marine waters, 38 M.R.S.A. § 465-B(1)(c).”You could point out that nearby waters ARE classified SA (near Schoodic Point, and off Otter Cliffs). These two areas could potentially be affected by increased nitrogen pollution being released in the bay which then has to flow south to the Gulf of Maine, and further into the greater Atlantic Ocean.
You could point out that the increased nitrogen load could potentially affect Bar Harbor’s ability to expand its sewage treatment facilities in the near future.
4) Finally, while this is just a public information meeting, it could lead to an in person public hearing. At the end of your letter you should request that the DEP hold a public hearing.
We will be having a Friday zoom meeting on October 22nd so people can discuss issues or points to include at the hearing. Stay tuned for that zoom invitation.
NOTICE FROM THE DEP:
Public Meeting on DEP review of proposed American Aquafarms net pen sites in Gouldsboro
The Department of Environmental Protection (Department) will conduct a Public Meeting on October 28, 2021 from 5:00
PM – 8:00 PM via Zoom (https://us06web.zoom.us/j/6928501126?pwd=blBEMDBlUTFKb3ZIbFN0NFVEaTl0dz09
Meeting ID: 692 850 1126 Passcode: 4gWhZz or via CALL IN # 1-929-205-6099 Meeting ID: 692 850 1126 Passcode:
110856), pursuant to Organization and Powers M.R.S. 38 §345-A (5), 06-096 C.M.R. ch. 2, § 8 (2018). The purpose of the meeting is to provide an opportunity to comment on the applications filed with the Department by American Aquafarms of 68 Commercial St., Portland, Maine 04101, (207) 405-7451. The Department’s review of and decision on
these applications will also provide the basis for determination of the project’s consistency with applicable enforceable polices of the Maine Coastal Program (MCP) pursuant to Section 307 of the Coastal Zone Management Act (CZMA).
The applications are for two net pen arrays for the rearing of Atlantic salmon. The net pen arrays are proposed to be located off of Long Porcupine and Bald Rock islands in Frenchman’s Bay. Each net pen array is proposed to consist of 15 individual net pens along with a treatment and feeding barge. The combined primary-treated discharge from one array is proposed to be 2.05 billion gallons per day. The treated discharge from one array (treatment barge discharge) is proposed to be 0.18 million gallons per day.
The applications and other current project documentation are available for review at the Maine Department of Environmental Protection’s website https://www.maine.gov/dep/projects/americanaquafarms/index.html. A copy of the
applications and supporting documentation may also be seen at the municipal office in Gouldsboro, Maine.
Information regarding the MCP and CZMA consistency review is available at:
https://www.maine.gov/dmr/mcp/index.htm. Comments on this project may also be sent to [email protected].