Fish Processing Permit Amendment Project

The Ministry of Environment and Climate Change Strategy (ENV) has launched a project to review, and where necessary, amend, all 30 effluent (for example liquid waste and/or sewage) discharge permits issued under the Environmental Management Act (EMA) for fish processing facilities. It does not include aquaculture operations such as hatcheries or fish farms. 

Objective

The objective of the project is to ensure effluent discharge permits in the fish processing sector contain adequate provisions to protect the environment. This project was developed as a follow-up to recommendations made in the compliance verification audit of effluent discharge permits within the fish processing sector. You can find the audit report and additional background materials on the Fish Processing Plant Audit page.

Facility InformationClick to see the distribution of fish permits in B.C.

The 30 EMA discharge permits for fish processing facilities include plants that process both wild and/or farmed fish and shellfish. Detailed information about the types of fish processed and the production volumes is provided in the Fish Processing Plant Sector Compliance Audit Report (PDF)

Locations of the fish processing facilities with EMA discharge permits are shown on this map and are identified by authorization (permit) number. Click on the map to view a larger version.

How are permit amendment decisions made?

Statutory decision makers (under s.16 of EMA) have the authority to amend waste discharge permits. Permits are site-specific documents, and therefore, requirements within permits are also site-specific. For the fish processing permit amendment project, issues are being considered on a sector-wide scale. At the same time, decisions about what is reasonable and appropriate for the protection of the environment, and resulting permit requirements, are made one at a time, considering the unique situation of each individual facility. Consultation with Indigenous groups is being conducted for each permit amendment. 

How are the amendments being prioritized?

The Ministry is conducting permit reviews and amendments in batches, based on a three-tier priority categorization. The permits were grouped based on fish processing production volume and operating status. Also, permit reviews and amendments will be grouped based on other characteristics such as permit holder, location, similarity or sensitivity of the receiving environment, and/or Indigenous group territory. This will enable efficiencies in the technical assessment and consultation processes. 

  • Facilities processing the highest volume of fish have been categorized as high-priority to be addressed first (Tier 1). Three permits are categorized as Tier 1, and account for more than 80 percent of the total production (based on 2017 production data) from all 30 authorized facilities.
  • Facilities with a production volume less than 10,000 tonnes per year, are categorized as Tier 2. Fifteen facilities are categorized as Tier 2.
  • Facilities that are not currently operating are categorized at Tier 3. Twelve permits are categorized as Tier 3.
  • Facilities categorized as Tier 2 and Tier 3 may change depending on their 2019 operating plans.

Gathering Information from Permittees

Input from permittees and Indigenous groups is important to the permit amendment process and is being used to inform decision making. 

A generic Information Requirements Table (IRT) was sent to all permittees on August 17, 2018 and was updated on September 28, 2018. The IRT was intended to collect current information about each discharge and the receiving environment to inform site specific amendments to each permit. To explain the amendment process and the information requirements, the Ministry gave a presentation to permittees through a series of webinars in September 2018.

In reviewing the information received from permittees in the fall of 2018, it was identified that limited effluent and receiving environment information exists, for the majority of Tier 2 facilities. The Ministry determined it was necessary to postpone the requirement for discharge limits for these facilities to allow for the collection of monitoring data during the 2019 operating season. As a result, the Tier 2 permits will be amended in two separate stages.

In December 2018, the Tier 2 facility permittees were informed of the new staged approach and received an updated list of information requirements, narrower in scope than the original IRT, that the ministry will use to inform stage 1 amendments.

The first stage will take place over the spring and summer of 2019 and will involve updates to all permit conditions with the exception of discharge limits. The second stage will occur in 2020 to set discharge limits based on the monitoring data collected in 2019. 

Project Phases

Permit reviews for the Tier 1 facilities began in July 2018. The process for these permits was initiated in the fall of 2018 and concluded with the issuance of amended discharge permits for each of the Tier 1 fish processing facilities in April 2019. To view the amended permits for these facilities, please see ‘Search for Status and Documents’ below.

The Ministry is using a staged approach to amending the Tier 2 facility permits as outlined above. The first stage amendments for these permits are currently in phase 4 and 5 (see phase descriptions on the right side of this page), with a completion target of September 30, 2019.

The amendment process for each of the Tier 3 permits is anticipated to occur over the summer of 2019.

A general schedule is provided below. This schedule is subject to change as the project proceeds. However, the Ministry is committed to completing the project in a timely manner.

Permit Review and Amendment timeline
*This schedule does not include Stage 2 of the amendment process for the medium priority Tier 2 permits, anticipated to occur in Spring 2020.

Search for Status and Documents

Once the amendment process has been started for a permit, it will be entered into the Ministry’s E-Licensing system. Before you do your search, download the guide to E-Licensing search functions (PDF), specific to the Fish Processing Permit Amendment Project. To search for the status of an authorization in the amendment process or obtain a copy of an amended permit, visit:


Other Actions Taken

In addition to this permitting project, the Province has undertaken the following actions:

Compliance Audit

ENV’s Compliance Team conducted a province-wide compliance verification audit to assess compliance against the existing requirements in fish processing effluent discharge authorizations, as well as the general provisions of EMA to not cause pollution. Detailed information about the audit is provided at the following resources:

Piscean Orthoreovirus (PRV) Science review

In response to concerns related to recent detection of Piscean Orthoreovirus (PRV) in seawater near a salmon processing plant, ENV retained local scientists to examine the state of science on PRV in B.C. waters. Specifically, the Ministry requested a literature review to: 

  • Assess the risk to wild salmon that may come into contact with PRV when present in fish processing plant wastewater,
  • Provide clarity on the issue of Pacific salmon contracting Heart and Skeletal Muscle Inflammatory disease (HSMI) as a result of infection from PRV that could be present in wastewater, and
  • Develop guidance to identify mitigation procedures and knowledge gaps for further research.

The full report is provided here: