Research & Helpful Information
Demonstration that mercury could be recovered quantitatively from Penobscot Bay sediment was critical to having any confidence in the Nordic Aquafarms data but seems not to have been so recognized and carried out.
Chart from the HoltraChem case that shows the distribution of mercury in the Bay.
It would be appropriate for the new leadership at the DEP to reconsider a public hearing; and I recommend Northport and Islesboro be allowed and encouraged to become more fully engaged in the process.
A major concern with this application is the lack of assurances that there is a complete understanding of all the pollutants from the NAF discharge.
Nordic has failed to meet its TRI burden, and Nordic cannot meet its TRI burden. Here is why.
Our comments to DACF/BLM regarding NAF's attempt to correct their lack of evidence of Title, Right or Interest
Nordic has known for months that the Eckrotes did not own the intertidal land on which their lot fronts and, as a result, Nordic lacks and could never acquire any interest in the intertidal land sufficient to constitute the TRI required to file an application for a submerged lands lease. However, Nordic intentionally withheld this information (and the surveys demonstrating this fact) from the State and the public.
Three important factors exist for evaluating the discharge into the local environment: local physical oceanographic conditions, local background water quality and waste-water composition. Based on my understanding of the currently available data, these parameters have not been well enough described to make a confident risk assessment for water quality near the project site.
The applicant should be asked to determine and demonstrate what variation in percent removal of treatment can be expected and under what circumstances? As an example, if phosphorous removal is reduced by just one percent, from 99% to 98%, the amount of phosphorous in the effluent would double. The applicant should be asked how that will be managed to prevent additional pollution. Same for a reduction to 95% or 75%, variability is not uncommon in large scale manufacturing operations.
Since the location of the proposed wastewater discharge is planned at 11.5 m, and also very near to the bottom, this discharge is likely to occur in very slow mean flow and the flushing time could be much greater than suggested by RANSOM. In addition, the local circulation will be altered by the strong pumping of discharge and intake. I suggest that the best method of understanding the potential effects of Nordic Aquafarms' proposal would be a year-long oceanographic experiment at the discharge and intake locations and a high quality 3D numerical ocean model with horizontal mesh scales of 25 m or smaller.
In consideration of the condition of the dams and the potential hazards posed to Nordic by their failure, we believe that any permit issued by the State of Maine be conditioned by a definitive commitment to repair or remove the dams prior to Nordic operating at the site. It is recommended that no permit be issued until the potential adverse environmental effects from the groundwater extraction and the resulting saltwater intrusion be fully addressed by the applicant.
Fish disease is a serious problem for the aquaculture industry and some estimates suggest that facilities at Maine latitudes can lose up to 34% of their stock to disease over the whole life cycle1. There are measures that can be taken to mitigate the effect of disease, but the installation of a facility which grows salmon through both their fresh and salt water life phases would have difficulty implementing some of those measures and thus could potentially become a point source for fish diseases from their outflow pipes.
Our calculation estimates have revealed that the applicant’s GHG contribution of between 0.55 and 0.76 MMTCO2e represents 4.6 – 6.4 percent of the 2030 total state GHG target, and between 12.8 and 17.6 percent of the 2050 target. To approve these new large sources of carbon emissions, while making commitments to reduce GHG, violates the intent of PL 237, §576-A. This large-scale aquaculture facility proposed by Nordic Aquafarms (NAF) in Belfast, Maine would also make it difficult to “achieve carbon neutrality by 2045” as mandated by the Executive Order No. 10FY 19/20, signed by Governor Mills on September 23, 2019.
PLEASE NOTE: More recent data has revealed significantly higher carbon impact.
If Best Managing Practices had been considered, the facility would have acknowledged its odor potential, estimated its potential emissions, truly explored not only the enclosure, but minimum ventilation requirement, conveyance methods, performed an odor control technology assessment, provided design plans that actually locate the required odor control systems, and finally completed an odor dispersion assessment so it could demonstrate compliance with the city and Site law requirements.
Nordic proposes to construct a power plant, a wastewater treatment plant, a water treatment plant, a food processing plant, millions of gallons of process tanks, hundreds if not thousands of miles of utility piping, ducting, wiring, etc., millions of cubic feet of soil excavation, countless cement trucks, supply delivers, equipment delivers, and a major road diversion and construction project and a significant pump station and outfall project. Each one of these could cause an adverse impact, and suggesting in their report that the site is large and that there is plenty of space for sound to dissipate is simply not a mitigation strategy. It provides no solace when the entire site is essentially earmarked to be developed.
If Best Managing Practices were being used then the applicant would have provided a site plan of the exact areas they were proposing to have blasting occur, a schedule of the number of expected blast days, and the number of blasts per day. There are no calculations of how many cubic yards would have to be blasted, and it cannot be determined from the inconsistent submittals.
These inconsistencies and the lack of information provided in the Blasting Plant is again an example of how the application is lacking in viable information and that the information provided has continued to change throughout the application process.
Nor did the proponent offer an analysis of an aquifer water only based design using it's existing technology. Nor did the proponent offer to use only local salmon genetics that have tested virus free and develop a less risky broodstock and eggs source as per the Williamsburg Treaty. These are viable solutions and mitigation plans to the many risks associated with the current flow through design and its myriad of issues shown by the history of other projects in other jurisdictions.
Direct, biological field surveys for virtually all of the non-wetland vertebrate and invertebrate species to be found in uplands, intertidal, subtidal, and in the offshore water column were not conducted resulting in data gaps that make it difficult to fully assess the project’s ecological/biological impacts. The temperature and possibly chemical plume anomaly were not considered in the discussion of the distribution, abundance and behavior of both benthos and fisheries. Rarely, have I seen such a client-centric disposition and approach to a Natural Resource Report. These deficiencies are particularly concerning given the fact that the project will have profound and permanent impacts to uplands, wetlands, inter and subtidal and water column habitats and to the biological food chains upon which so many species, including human livelihoods, depend.
Fisheries & Marine Resources Comments
Nordic's Violated Permits
Nordic Aquafarms is a corporation that has violated their permits in Norway.
This statement does not evaluate the DMR’s comments to the DEP concerning “Fisheries and Industry Impact”, nor does it take into account the comments from local fishermen who have experienced dredging and other disturbances in the bay for decades.
Nordic Power Requirements
Nordic Aquafarms has increased the energy usage for their proposed project in Belfast to 28 megawatts (MW). According to CMP’s consultant, with this demand the area’s existing grid resiliency calculations would immediately fail.