CCA Maryland and a coalition of recreational fishing clubs STRONGLY opposes this proposed permit and facility due to the probable negative impacts to important and already imperiled habitats and fish populations in the region in question.  This letter was sent to MDE on October 14th outlining the issue. 

Overall, the Chesapeake Bay and many of its tributaries continues to be plagued by numerous failed wastewater treatment operations and other point sources of harmful nutrients that fuel algae blooms.  Adding another negative water quality impact that is likely to arise from this proposed project poses a unacceptable risk at this time.

Maryland has a rich fishing focused heritage and culture.  While that culture may continue to change as our Bay changes, CCA Maryland strongly believes that Atlantic Salmon farming should have no place in Maryland, especially when current technology cannot mitigate the nutrient loading that will occur when growing such a massive quantity of fish.

Beyond the environmental impacts of discharges, the proposed facility will also increase impervious surface run-off which can increase temperatures in the nearby waterways, further adding to an existing problem with changing climate and temperatures in the regions.

More specifically, the permit should be denied for the following reasons:

• The proposed nutrient laden discharge of 2.3 million gallons per day will negatively impact the water quality and habitat of Marshyhope Creek and the Nanticoke watershed.
• The Nanticoke watershed includes important spawning areas for striped bass, a species facing continued reproduction issues in the Chesapeake Bay, and which is currently deemed overfished, or below it’s population goals set by fishery managers.
• Marshyhope Creek is known as a prime spawning ground for the endangered Atlantic sturgeon.
• Salmon farming relies on wild caught forage/bait fish species, further impacting the balance of regional ecosystems and existing fisheries.  Efforts to feed farmed salmon soy or other plant based products are not proven or practical at this time.
• Similar salmon farming facilities in operation continue to have problems with diseased fish, mass die offs and additional challenges with the proposed or not yet used filtration and nutrient management systems.

The Maryland Department of the Environment should deny any permits for this proposed facility.  It is the wrong project, in the wrong location and at the wrong time.