The likelihood of fish encountering an MHK device, and therefore the risk posed to fish, depends largely on the natural distribution of fish at tidal energy development sites. In temperate locations, such as the Bay of Fundy, seasonal changes in the environment and fish assemblage may alter the likelihood of fish encounters with MHK devices. We examined two one-month hydroacoustic datasets collected in winter 2015 and summer 2016 by an upward-facing echosounder deployed at the Fundy Ocean Research Center for Energy test site in the Minas Passage. Fish density was higher and less variable in winter than in summer, likely due to the presence of migratory vs. overwintering fish. The vertical distribution of fish varied with sample period, diel stage, and tidal stage. The proportion of fish at MHK device depth was greater, but more variable, in summer than in winter. Encounter probability, or potential for spatial overlap of fish with an MHK device, was < 0.002 for winter and summer vertical distributions. More information on the distribution of fish (horizontal and vertical), species present, fish sensory and locomotory abilities, and nearfield behaviours in response to MHK devices is needed to improve our understanding of likely device effects on fish.