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Fish farming is now being promoted by several state and federal regulatory agencies and is slated for expansion into the U.S. Exclusive Economic Zone (EEZ) when the National Marine Fisheries Service is expected to launch major legislation this year to promote ocean aquaculture. Despite the hype about growing fish to feed the world, what’s being proposed is the raising of high value fish to satisfy wealthy developed-world consumer tastes. Potential impacts on the commercial fishing industry seems to matter little to these agencies, even to those in them who have made their careers forecasting and writing about wild fisheries.
All this was readily evident at a November conference in Seattle where aquaculture proponents from Canada, Europe and the United States described how new technologies, fewer regulations and larger government subsidies would result in production of different kinds of fish and at the same time reduce our trade deficit: a Homeland Security Plan to warm the heart of Tom Ridge while further imperiling small, family owned fishing businesses.
The three-day conference, held just before FISH EXPO, was hosted by the Pacific States Marine Fisheries Commission and featured a heavy lineup of aquaculture cheerleaders and a bevy of NMFS bureaucrats boosting aquaculture as the “wave of the future.” Although the conference was billed as “Marine Aquaculture: Effects on the West Coast and Alaska Fishing Industry,” few of the speakers addressed environmental or economic harm caused by fish farming. Most came to this “fish-farm love-fest” to discuss divvying up the 3.4 million square miles of the EEZ that NMFS plans to soon offer up for private usage by industrial fish farm operations. NMFS’ “Matrix Manager” Conrad Mahnken, in response to a question from the audience, acknowledged that such facilities may be exempted from the Magnuson-Stevens Fishery Conservation & Management Act and that foreign corporations would not be excluded from owning fish farms in our waters. Nobody was asking the fundamental question about whether this is even a good idea, or whether we should do it at all.
Despite encouragement for providing a balanced perspective, there was a heavy undercurrent of a “this is the future and fishermen had better get out of the way” attitude at this conference. Commercial fishing was characterized by some invited speakers as just another dying industry that couldn't compete in the marketplace, and fishermen were variously compared to buggy whip makers and buffalo hunters. One PR type, who apparently has both processor and aquaculture accounts, shrilly told fishermen not to ally with environmental groups. The fish farmers rightly understand that coalitions forming between harvesters and environmentalists will boost wild fish sales and prices as an increasingly informed media touts the health benefits of wild fish and the risks of fish produced in floating feedlots.
Several scientists and fishing industry representatives spoke on the second and third day, with the time slot of 0730 hours allocated to Environmental Defense’s Dr. Rebecca Goldburg who flew in from New York to discuss “Ecological and Human Health Issues.” Canadian researcher Dr. John Volpe, who has documented hundreds of escaped Atlantic salmon in BC streams, was also relegated to the last morning. In probably the low moment of the event he was called a “racist” by an executive of “Salmon of the Americas” (SOTA) (the international trade organization for salmon farmers) for suggesting that after money is spent developing technologies in the northern hemisphere, fish farms of the future will go south where labor costs are cheaper. It appears the recent bad press and plummeting prices of farmed fish have made their hacks a bit nasty.
Although the SOTA representative was not on the agenda, he was slipped into the schedule the second day and consequently speakers who would have provided valuable counter information, such as Gordon Ennis of the Pacific Fisheries Resource Conservation Council of Canada and Jim Seeb of the Alaska Department of Fish & Game, had their time substantially reduced.
Then there were the folks from NMFS, who apparently have never found an aquaculture operation they didn’t like, and their willingness to throw our tax dollars at these ventures was alarming.
At issue is whether fishermen and conservation groups are going to roll over for aquaculture, as aqua-culturists and NMFS would like, leaving fishing men and women as little more than their hand maidens to catch the wild fish aquaculture needs to feed its stock and provide the “color” for their advertising campaigns.
Aquaculture itself is not all that new: the Chinese have been growing carp for 3,000 years, the Bretons have been cultivating oysters for hundreds of years, and we’ve been using aquaculture techniques here on the west coast for over 100 years with our salmon hatcheries to supplement production or mitigate habitat losses from dam construction. Nevertheless, some forms of aquaculture, just as certain fishing methods such as dynamiting or using cyanide on reefs, cannot be tolerated. Salmon and shrimp farming, at least the way they are practiced now, are not sustainable plus allow escaped fish, disease and pollution into the marine environment. Moreover, some other forms of aquaculture, such as oyster cultivation where pesticides are widely used in fragile estuaries, definitely need cleaning up.
Our response should be neither a knee-jerk reaction opposing aquaculture, nor silent acquiescence. Over the past decade, the fishing industry has come under considerable scrutiny for many of its practices. Most are working hard now to eliminate overfishing where it has occurred, to reduce bycatch and prevent harm to ocean habitats. We are also working to make sure our hatchery operations producing native stocks for release are conducted in such a manner that they are compatible with wild spawning populations. As we work to make our practices environmentally and fish friendly, should we allow others, including some of the more rapacious aquaculture operations, to undercut the conservation we’ve been striving for? Shouldn’t the two industries to be held to the same standards?
In addressing aquaculture and its compatibility with fishing and the environment, three issues need consideration: 1) whether the operation is environmentally sustainable; 2) whether the product being produced can meet the same health and nutrition standards we are demanding for wild fish; and 3) whether the operation makes economic sense absent subsidies – direct or indirect – and with its costs internalized. In the aquaculture debate a final issue that needs to be looked at is the government’s role, and that of NMFS is particular, which apparently is applying the Precautionary Principle to capture fisheries while abandoning all caution when it comes to promoting aquaculture.
Unlike the Marine Stewardship Council (MSC) certification program for sustainable wild fisheries, there is currently no U.S. certification scheme for aquaculture (See December 2003 Fishermen’s News: ”Defining and Achieving Sustainability” at: www.pcffa.org/fn-dec03.htm) Furthermore, the aquaculture certification systems that exist in Europe and elsewhere are suspect at best. Absent a credible certification system, there are at least five factors that should be looked at in judging whether a given type of aquaculture is sustainable.
Containment. The first factor to be examined is if the operation is contained in such a manner as to prevent escape into the wild of the fish or shellfish being cultured. This is critical since farmed salmon frequently escape their netpens. The escaped fish can prey on native stocks, including species of concern, compete for forage or habitat, or in some cases interbreed with native fish populations. Heightening this concern, of course, are proposals for using genetically engineered (GE) or “transgenic” organisms in aquaculture operations, such as Aqua Bounty’s fast growing GE Atlantic salmon now awaiting U.S. Food & Drug Administration (FDA) approval.
At a time when many fisheries are being constrained and billions of public dollars being spent to recover and rebuild wild stocks, why should these stocks again be put at risk because aquaculture operators refuse to pay for secure facilities to prevent escapes? Facilities that cannot assure against escape should not be permitted, period, which probably means most forms of ocean netpen salmon farming should be banned.
The only exceptions to requiring contained and secure facilities may be: 1) where fish are being raised as part of an approved program for supplementing wild stocks; or 2) where fish may be captured and held alive, tuna or halibut for example, prior to being marketed. The other exception would be for certain forms of molluscan culture, such as oysters, where the animal is not likely to move location on its own.
Pollution. The second factor to be considered is whether the given form of aquaculture is polluting or not. Pollution from aquaculture facilities, which are in essence “aquatic feedlots,” comes from a variety of sources, including fecal matter, uneaten feed, antibiotics and fungicides. Marine aquaculture operations diminish water quality, spread disease and create dead zones around their operations unless strict discharge requirements are imposed.
The problem is not just salmon and shrimp farming. Even some of the more benign forms of shellfish mariculture can still create problems. The widespread spraying of the pesticide carbryl on oyster beds in Willapa Bay and Grays Harbor to kill burrowing shrimp, for instance, was not environmentally sustainable and no help either to organic oyster growers in those same areas.
Then too, cumulative impacts have to be considered. One or two shellfish operations, for example, in a bay or inlet may be perfectly fine, but too many can cause water quality problems. Even contained facilities located on land need to have water treatment facilities in place to assure that discharges into rivers, bays or the ocean do not pollute. Simply put, aquaculture operations of any sort that pollute should not be allowed.
Disease. The third factor that has to be considered is the transmission of disease. Aquaculture operations, particularly since these animals are raised in close confines, can harbor diseases that may be spread to the wild with the potential to devastate native fish populations. While most attention has been on the spread of diseases from salmon net pen operations, such as the outbreaks this past year in the farms in the Maritimes and Maine, there are other instances of disease spread from aquaculture operations to the wild. One of the most egregious instances occurred some years back off southern California when an outplanting of farmed abalone spread the withering foot disease to wild populations, wiping most of the state’s wild abalone out. Aquaculture operations cannot be allowed unless they are incapable of spreading of diseases into the wild.
Feed. Aquaculture proponents have been claiming that this form of food production is needed to meet the demand of a growing world population for fish. The truth is, many types of aquaculture actually result in a net loss of protein. Although salmon are relatively efficient in converting feed to pounds of flesh for food (ratios generally cited are between four pounds of feed to one pound of flesh, though others cite a 3:1 ratio) there is still a net loss of protein if those farmed fish have to be fed feed made from wild stocks, such as herring, anchovy, sardine or krill. Fish that could serve as an excellent protein source for people in developing (as well as developed) nations is instead being ground up to produce fewer pounds of fish for sale in the markets of the wealthiest nations.
Other Inputs. A final factor to weigh as to whether a type of aquaculture is sustainable or not are the inputs (other than feed mentioned above) that go into production; that is, whether other natural resources are being depleted in the production of farmed fish or shellfish. One such example is desert shrimp farms which might otherwise seem like a good idea: mangroves are not being destroyed and the wastewater from the shrimp farms is used to irrigate agricultural crops, with the nutrients from the shrimp waste acting as fertilizer for the plants. Furthermore, such an operation is not displacing any traditional fisheries, as has happened in Southeast Asia and Central America. The only problem is, where is the water coming from? If the operation is not drying up a stream or lake or overdrafting an aquifer, there may be no problem, but in most desert settings that is probably not the situation and such operations are not likely to be sustainable.
Aquaculture products are lumped into the category of fishes and shellfishes we call seafood and mostly are sold alongside wild products. Fish generally has a good reputation and is regarded as a nutritious source of protein, mostly low in fat and rich in omega 3 fatty acids. State and federal health regulations prevent wild fish from being sold that is tainted or from contaminated sites. There are printed advisories for fish containing higher levels of mercury, warning certain members of the public to avoid them and the rest of us to eat them in moderation, much the same as the warning labels on wine bottles. There are bans on the sale of shellfish taken from contaminated beds and on fish caught in places such as the Hudson River that are contaminated with PCBs.
Unlike aquacultured fish, however, wild fish are not raised in feedlots where they may be ingesting excrement, fed antibiotics and dyes, or treated with fungicides. To maintain the reputation of fish as a wholesome food source and assure wild fish’s good name is not sullied by aquaculture products, fishermen and the public should insist on a ban on the use of antibiotics, dyes, fungicides, pesticides and herbicides in the production of any aquaculture product. Aquaculture operations whose products cannot meet the health and safety standards achieved by wild fish in the market should be banned from sale.
Finally, there needs to be labeling so consumers can clearly distinguish between wild and farmed fish. Labeling is to be required in 2004 under the provisions of the 2003 Farm Bill; however, lobbyists for the major grocery outlets and the National Fisheries Institute are working to undermine this important piece of consumer legislation.
The last issue to be considered in judging whether a type of aquaculture should be supported or opposed is whether it can stand on its own economically. By this we mean, can it make it in the marketplace without government subsidies, without externalizing its costs, and while complying with environmental and labor laws and paying fair wages to its employees? Additionally, will it compete fairly in the marketplace without resort to dumping or other anti-competitive practices designed to drive competing fish and shellfish products, wild or cultured, from the marketplace?
Banning Subsidies. As governments throughout the world reduce or eliminate subsidies to the fishing industry for boat building and other forms of support, the question to be asked is whether aquaculture will be treated the same way. Governments have subsidized aquaculture in a variety of ways, most notably in research and development, and fish farmers are now being promised money to market their products in ways that directly compete with wild fish harvested by the commercial fishing industry. If the subsidies to fishing are to be reduced or eliminated (in the U.S. they never amounted to much anyway), will the same be true for aquaculture? This is important since fishermen have to compete in the marketplace with aquacultured products, as Alaskan salmon fishermen and Gulf shrimpers know all too well, and it is critical that there be a level playing field in order that competition be fair.
There is growing pressure in the world for the U.S. and Europe to drop many of their subsidies for agriculture so developing nation’s farmers can survive and compete in a world market. At a time when fishery subsidies are being dropped and there is pressure to drop agricultural subsidies, aquaculture too must learn to stand on its own instead of feeding at the government trough.
Externalizing Costs. Aquaculture in much of the world survives only by externalizing its costs. That is, the true costs associated with aquaculture production are often borne by the public at large, not the company. Examples of aquaculture’s externalization of its costs include pollution, the destruction of mangroves for shrimp farms, the displacement of traditional artisanal fisheries by multi-national shrimp and salmon farming operations, losses of native fish stocks and the fisheries and communities they supported, and public and private costs of efforts to capture and kill farmed fish that escaped into the wild. If an aquaculture operation is worthy of support then it must internalize all the costs of its production, not foist them off on the public taxpayer to gain a price advantage in the marketplace.
Compliance With Applicable Laws and Paying a Fair Wage. Aquaculture operations must be required to fully comply with applicable environmental and labor laws. Aquaculture products coming from facilities that do not comply with environmental and labor laws, either by flaunting such laws or bribing government officials to look the other way, should be banned. Why should fishermen care? The concern here for the fishing industry is that the evasion of laws is a way to externalize production, labor and cleanup costs, plus it puts other aquaculture operators who are complying with the law (as well as commercial fishermen) at a competitive disadvantage in the marketplace.
Finally, fishermen should also insist that aquaculture operators pay their employees a living wage. Fishermen, particularly in North America, Europe, Australia and New Zealand are paid higher wages, as are processing plant workers in those nations. It is not too much to ask, in the spirit of fair competition, that workers employed in aquaculture facilities are also paid at least a living wage.
No Dumping or Anti-Competitive Practices. Despite the Mom-and-Pop image aquaculturists try to portray for themselves, the trend in this industry is for increasing consolidation that will likely mean the industry, already heavily dominated by a few large multi-national companies, will soon be controlled by just a few huge corporations. These will be entities with sufficient capital to engage in dumping and other non-competitive practices to drive out their competition, including commercial fishermen. Every effort, therefore, should be made to block further consolidation of aquaculture operations, in order to foster competition. Where the industry ownership is concentrated, fishermen must be willing to speak out and be vigilant to protect themselves against conglomerates’ natural tendency to engage in monopolistic behavior.
An examination of aquaculture’s compatibility with traditional fishing operations would not be complete without a look at our own fishery agency – the National Marine Fisheries Service (aka NOAA Fisheries) and its role in all of this.
Fishing groups, as well as consumer and conservation organizations, should continue to call for aquaculture practices that are environmentally sustainable, and for fish/shellfish production that is healthful and produced in such a manner that it can get to market without subsidies, externalization of costs or the thwarting environmental, labor and fair trade laws. At the same time NMFS and other federal agencies, such as the Department of Agriculture, must stop pimping for the fish farm industry.
It has been embarrassing of late to see some NMFS employees, who apparently have forgotten they still work for a public agency, in their pandering to the aquaculture industry. In 1977, some of these same folks were out there promoting the construction of large trawlers and longliners to exploit the “endless fishery resources” of the U.S. Fishery Conservation Zone (now called the EEZ). These large boats, including catcher processors, were to be the “wave of the future” (familiar ring?). They said, essentially, get out of way you New England lobstermen. Get out of the way you salmon trollers and halibut longliners. This was Americanization. Yet with all their enthusiasm, until it waned in the late 1980’s and early 1990’s, the agency never assessed how much resource was out there or how much effort it could actually support. Since then, of course, a number of the fisheries they avidly promoted back then have collapsed and we’ve just finished a sad chapter here on the west coast buying back and scuttling 92 trawlers that proved too many to maintain an environmentally and economically sustainable groundfish fishery.
But now they’re back, many of them the same folks (although with a few more wrinkles and a lot more girth) and now they’re pushing aquaculture as “the wave of the future.” It’s as if the disaster set in motion by similar blind boosterism 25 years ago never happened.
NMFS for its part is now actively pushing for caged aquaculture in the Exclusive Economic Zone (see the December 2002 Fishermen’s News: “Aquaculture’s Next Wave Threatens To Swamp Commercial Fisheries: Moving Offshore, Out of Sight and Free of Scrutiny,” by Natasha Benjamin, www.pcffa.org/fn-dec02.htm). NMFS has developed strategies with SeaGrant and fish farmers and is now actively lobbying members of Congress to pass legislation that will open up the EEZ for private venture aquaculture operations. Before they go too far, it’s time that NMFS, the Trustee agency for our nation’s fisheries, was reminded of its past mistakes and its current responsibilities. It’s also time that the agency, which loves to give lip service to the “Precautionary Principle” when considering wild fisheries, remember that a precautionary approach is needed as well for aquaculture, particularly because the unknowns are far greater than with our traditional fisheries. NMFS may have surfed its last wave.
There is little agreement to the question posed at the Seattle conference on whether traditional fisheries and aquaculture can work together. Some would say “conditionally yes,” but that is certainly not the blind affirmation fish farmers or government hacks who are trying to bully fishing men and women into a silent acquiescence are seeking.
Others say certain minimum standards must first be met by aquaculture, the same standards many fishing, conservation and consumer groups are insisting upon. Fishermen are already working to ensure their operations are environmentally sustainable. Why shouldn’t we demand the same from aquaculture?
Fishing men and women proudly supply health-enhancing and nutritious seafood for their markets. Fish farmers marketing inferior products have benefited from the “halo effect” of wild fish, and now must ensure the quality and wholesomeness of their product. We pay our own way and most fishermen do not externalize their costs, avoid laws or dump product to gain market advantage. We’re already holding ourselves to high standards, and it only makes sense to expect the same from aquaculture.
Pietro Parrravano is a commercial fisherman from Half Moon Bay, California, President of the Pacific Coast Federation of Fishermen’s Associations (PCFFA) the Institute for Fisheries Resources and former member of the Pew Oceans Commission. Anne Mosness of Bellingham, Washington fished Copper River and Bristol Bay, Alaska and Puget Sound for many years. She is a former Food and Society Policy Fellow with the W.K. Kellogg Foundation and currently directs the “Go Wild Campaign” with the Institute for Agriculture & Trade Policy. Zeke Grader is Executive Director of the Pacific Coast Federation of Fishermen’s Associations. PCFFA can be reached at: Southwest Regional Office: PO Box 29370, SF, CA USA 94129-0370, (415)561-5080; Northwest Regional Office: PO Box 11170, Eugene, OR USA 97440-3370, (541)689-2000; or by email to: fish1ifr@aol.com. PCFFA’s web site is at: www.pcffa.org.
December 18, 2003
William T. Hogarth, Ph.D.
Assistant
Administrator for Fisheries
NOAA Fisheries
14555 Silver Spring Metro
Center 3
1315 East-West Highway
Silver Spring, MD 20910-3282
Re: Legislative Environmental Impact Statement for Aquaculture Legislation
Dear Dr. Hogarth:
The undersigned groups, on behalf of their hundreds of thousands of members and constituents, are concerned about the aquaculture legislation that NOAA has drafted and intends to propose to Congress next session. This legislation, as you know, would create – for the first time – a system for permitting aquaculture in federal waters in the Exclusive Economic Zone. Due to the precedent setting nature of this action, along with the potentially significant environmental impacts caused by offshore aquaculture, we are writing to formally request that your agency prepare a Legislative Environmental Impact Statement (LEIS) to accompany this legislation as required by the law.
Under the National Environmental Policy Act (NEPA), all recommendations “on proposals for legislation and other major Federal actions significantly affecting the quality of the human environment” must include a detailed statement on the environmental impact of the proposed action. 42 U.S.C. §§ 4332(C). Legislation includes “a bill or legislative proposal to Congress developed by or with the significant cooperation and support of Federal agency.” 40 C.F.R. § 1508.17. “Only the agency which has the primary responsibility for the subject matter involved will prepare a legislative environmental impact statement.” Id. Given that NOAA has primarily drafted the offshore legislation, NOAA Fisheries should be the agency responsible for preparing a LEIS.
The NEPA regulations provide that a LEIS is “a detailed statement required by law to be included in a recommendation or report on a legislative proposal to Congress.” Id. § 1506.8(a). As mandated by NEPA, public comment must be part of this process. Id. § 1506.8(c). In order to provide a complete and accurate environmental impact statement that will be used for substantive public and Congressional debate, the LEIS process should be started immediately. Before submitting proposed offshore legislation, NOAA should note that NEPA requires that the LEIS must be submitted to Congress within 30 days of transmitting the legislative proposal and in time for Congressional hearings and deliberations. 40 C.F.R. § 1506.8(a).
The National Environmental Policy Act has two overarching goals. First, it seeks to have a decision-maker who is informed about the environmental impacts of the decision. Here, it is essential that the agency and Congress fully understand the environmental impacts of opening up a new type of aquaculture under the auspices of one federal agency in federal waters. Second, NEPA seeks to have an informed public. This can be accomplished here by having full public notice and comment on the LEIS. These comments must then be forwarded, along with NOAA Fisheries’ responses, to the Congressional committees with jurisdiction over the aquaculture legislation.
We welcome the opportunity to discuss this issue with you further. Thank you for your cooperation and we look forward to providing comments to the LEIS.
Sincerely,
Ellen Athas
Tracie Letterman
Ocean Conservancy Center for Food Safety
Zeke Grader, Executive Director
Pacific Coast Federation of
Fishermen’s Associations
Pietro Parravano, President
Institute for Fisheries Resources