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7/31/2019 Factory-Fed Fish: How the Soy Industry Is Expanding Into the Sea
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Factory-Fed
Fish
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About Food & Water Europe
Food & Water Europe is the European programof Food & Water Watch, a nonprofit consumer
organization based in the United States that
works to ensure the food, water and fish we
consume is safe, accessible and sustainable.
So we can all enjoy and trust in what we eat
and drink, we help people take charge of where
their food comes from, keep clean, affordable,
public tap water flowing freely to our homes,
protect the environmental quality of oceans,
force government to do its job protecting citizens,and educate about the importance of keeping
shared resources under public control.
Food & Water Europe
Rue dEdimbourg, 26
1050 Bruxelles
Belgium
www.foodandwatereurope.org
Copyright June 2012 by Food & Water Europe.
All rights reserved.
This report can be viewed or downloaded at
www.foodandwatereurope.org.
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Factory-Fed FishHow the Soy Industry Is Expanding Into the Sea
Executive Summary 2
Findings 3
Introduction 3
Why Should We Be Concerned? 4
Fishy raditions 5
State o the Soy Industry 6
Who is lobbying or the soy industry? 6
How much soy is genetically modifed 6
How much soy is in our ood now? 6
What Does Soy Have to Do With Fish Feed? 7
Te soy industrys championing o soy diets or actory armed fsh 7
Cargill and Monsanto: Corporate interest in soy or armed fsh 8
Impacts o a Soy Diet on Fish and Teir Environment 8
Issues o indigestibility and nutrient defciency 8
Potential impacts on the marine environment 9
Impacts on Consumers 10
Missing omega-3s 10
General impacts o soy consumption 10
Environmental and Human Rights Inringements in Soy Consumption 11
Other Alternatives 12
Conclusion 13
Recommendations 14
Endnotes 14
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2 Food & Water Europe www.foodandwatereurope.org
Executive SummaryIn 2010, the CEO o the American Soy Association
reported that the organization has been closely
monitoring progress in the development o oshore
sh arming legislation and meeting with congres-sional sta on the topic1 In March 2011, it endorsed
a controversial plan that would allow such sh
arming or aquaculture in the Gul o Mexico2
In September 2011, a press release was issued
announcing a new marine sh arm project that
would revolutionize sustainable agriculture3 Te
source o the release? Te Illinois Soybean Associa-
tion4
Why are trade associations or an agricultural
commodity that is grown on land involved in poli-
cies and marketing that aect the use and steward-
ship o our oceans?
Seaood is one o our last wild ood sources Fish
are a vital part o many peoples diets because
o potential health benets, resh taste and the
connection that sh give us to our oceans and
coasts Around hal o the worlds seaood, however,
now comes rom arms rather than rom the wild5
In some o these arms, sh are grown in crowded,polluting cages and may be attened on commer-
cially prepared diets6
Feed has been one o the aquaculture industrys
greatest challenges Many o the species grown
by the ocean nsh industry are highly valued
carnivorous sh,7 which have typically been ed
diets consisting o shmeal and oil made rom
smaller, wild sh8 Te excessive use o wild sh to
grow armed sh can make aquaculture inecient9
Further, aquaculture has been accused o spurring
the depletion o these small sh, which is problem-
atic not only or their own populations, but also to
the other animals that rely on them or ood10
With little public scrutiny, soy has been hailed by
some as a sustainable alternative to eed based on
wild sh, thus supposedly solving some o the sh
arming industrys sustainability problems11
In this report, the rst to address the relationship
between the soy and actory sh arming indus-
tries, Food & Water Watch reveals that, while the
soy industry stands to make large prots rom
the expansion o actory sh arming,12 there is
no guarantee that soy-based aquaculture eed
can consistently produce healthy sh or promote
ecological responsibility In act, by causing sh toproduce excess waste,13 soy could lead to an even
more polluting sh arming industry
By supporting actory sh arming, the soy industry
could not only help to expand an industry that
degrades marine environments, threatens wild sh
populations and damages coastal communities, it
could also extend its own negative impacts Already,
industrial soy production has led to the prevalence
o genetically modied crops on US armland14
and in consumer ood products,15 caused massive
deorestation in South America16 and displaced
indigenous communities living in areas now used to
grow soy17
Rather than actually promoting sustainability in a
developing industry, the involvement o soy associ-
ations in aquaculture could spur the growth o two
industries that have extremely negative impacts
on our land, our oceans and the communities that
depend on them
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Factory-Fed Fish: How the Soy Industry Is Expanding Into the Sea 3
Findings I the soy industry succeeds in helping the
aquaculture industry meet the annual produc-
tion goals or marine nsh set by the ederal
government, and in getting a substantial portion
o soybean meal included in the diets o these
armed sh, it could net an additional $201million each year; this doesnt include revenue
it may earn rom supplying soy as a eed
ingredient or other types o sh arming in the
United States or abroad
Although the soy industry claims that soy is an
environmentally riendly alternative or sh
eed, sh that are ed soy have been shown to
produce more waste; thus, an increase in the
amount o soy ed to sh in sh arms could
increase the pollution load on the environment
surrounding these arms
In open ocean sh arming, uneaten eed fows
directly rom the cage into the environment
Because 94 percent o the soy grown in the
United States and much o the soy grown inter-
nationally is genetically modied, eeding soy
to armed sh means that genetically modied
ood will enter the environment and diets o
other marine organisms
Te rising use o soy in sh arming industries
will mean that notorious agribusinesses like
Monsanto, which has sponsored eed trials
with genetically modied soy and salmon, and
Cargill, which has an aquaculture eed division,
will play a hand in seaood production
Deorestation to clear land or soy arms, which
is already a problem in South America, could
increase given the large quantity o soy thataquaculture would require to meet US targets
or nsh production
A growing number o researchers has noted
that the potentially negative impacts o the
increasing amount o soy in our diets are under-
researched, and it is even less apparent what
the long-term human health impacts could be
o consuming soy secondarily, through sh and
meat raised on soy
IntroductionAs you take your rst bite o a reshly grilled sh
llet, you may be imagining the weathered boat that
reeled it in or the seaside town where it was brought
to shore Perhaps you are contemplating the lie it
led in the seas and eeling content that you chose a
healthier, resher alternative to the mass-producedhamburger you considered ordering But what you,
along with most people, are probably not picturing
is a deorested plantation in Argentina, the dead
zone growing in the Gul o Mexico or a US soy
industry executive signing o on a press release to
promote actory sh arming
Around hal o the seaood consumed in the world
is now produced through aquaculture, or sh
arming18 Tere are various types o sh arming,
including production in coastal ponds, near-shorecages, or cages placed arther o the coast Open
ocean actory sh arming, also known as oshore
aquaculture, is the practice o growing nsh in
huge, oten overcrowded cages miles o the coast-
line Tis method o arming can be problematic or
both the environment and the economy
Te waste ecal matter, uneaten ood and the
chemicals or drugs used in these operations
fows directly into the ocean, where it has thepotential to damage ecological equilibrium19 Fish
tend to escape rom cages, and once in the wild
they can interbreed with or outcompete wild sh,
leading to decreased genetic viability and access
to resources20 Even beore escape, sh can spread
diseases and parasites which may be prevalent on
some arms due to crowded conditions to nearby
wild sh21 I arms damage wild populations, shing
communities and local coastal economies could be
seriously threatened
A variety o concerns also come into play with
regard to eed or armed sh Farmed sh have
generally been raised on eed that is ormulated
with shmeal or oil made rom small, wild sh22
But now, both ecological and nancial obstacles to
this practice are arising23 As a result, the industry is
seeking out potential alternative ingredients to eed
armed sh, and the soy industry has positioned
itsel as a viable option Te American soy industryis powerul It has been able to und many studies
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4 Food & Water Europe www.foodandwatereurope.org
on using soy or sh eed24; it has built relationships
in the aquaculture industry25; and it has publicly
supported ederal policies in avor o oshore
aquaculture26
Supporters o the soy-aquaculture alliance claim
that using soy or sh eed could allow or a new,
more environmentally riendly type o aquacul-
ture27 Soy does not have the ull array o nutrients
demanded by sh, however28; nor is it a natural sh
ood or substance in the marine environment In
act, using soy may cause some sh arms to pollute
more by producing extra waste29
Further, the negative ramications o the soy
industry on the environment and potentially on
our health are reasons to resist the allure o soy as
a savior o the aquaculture industry Te cultiva-
tion o soy is associated with agricultural runothat is contributing to the dead zones in the Gul o
Mexico,30 with deorestation in Latin America31 and
with the displacement o many indigenous peoples
rom their homes and work32
As soy becomes increasingly ubiquitous in our diets
in processed oods and the meat rom animals
that have been raised on it33 we must ask what
health impacts this high level o soy consump-
tion may have on us Scientists are beginning toquestion claims about the benets o eating soy
and to suggest that the plant-based estrogens that
occur naturally in soy, many o which are endo-
crine disruptors, could potentially have adverse
impacts34 In light o these concerns and unan-
swered questions, it is troubling to know that much
o our sh one o our last wild oods could be
attened on this crop
Why Should We Be Concerned?People who are looking to sh or a lighter,
healthier or more sustainable ood option may have
no idea that mega-industries rom both land and
sea are wielding infuence on the types o seaood
that we can consume35
US policy and much o the research and develop-
ment on aquaculture, however, is currently ocused
on the development o actory-style oshore sh
arms and on soy as an ingredient in sh eed36
In 1999, the US Department o Commerce (DOC)
released a policy calling or a quintupling o the total
value o the nations annual aquaculture production
by the year 2025 rom $900 million a year to $5
billion37 Te policy listed DOC objectives including
osetting the seaood trade decit, creating more
jobs and bringing more high-quality seaood to US
consumers38
o completely oset the seaood trade decit
through open ocean aquaculture would require
producing an almost unimaginable 200 million sh
in oshore cages each year39 But the seaood decit
is more complicated than simply producing more
sh Te United States exports 74 percent o the
seaood caught or grown domestically and, in turn,
imports 85 percent o the seaood available in the
United States, primarily rom Asian countries40 Tis
problem could be better met by increasing import
inspections in order to keep cheaper, lower-quality
seaood out, and keeping more US-produced
seaood in the country41
Te likelihood that open ocean aquaculture
would produce a signicant number o jobs is also
dubious i Kona Blue Water Farms, a prototypical
open ocean arm in Hawaii, is taken as a potential
indicator o what an expanded US industry might
look like Although the company once employed 49
people, it projected in 2009 that it would eventuallyemploy only 14 Te company said that sta reduc-
tion would be necessary to achieve protability42
Further, a large-scale oshore sh arming industry
could cause major environmental damage Placing
sh arms in the open ocean has been pitched as a
way to minimize pollution by diluting or dispersing
waste43 Tere is not enough inormation available
yet to know what the long-term eects o these
arms will be,44
and research rom Italy indicatesthat pollution rom oshore arms may aect the
marine ecosystem well beyond the local scale45
Te ecosystems around arms could also be
disrupted by chemicals and drugs used on arms,
potentially leading to negative health consequences
or people One study ound that the use o antimi-
crobials on sh arms can lead to the development
o drug-resistant genes in sh pathogens genes
that could be transerred to bacteria that inect
humans Tis could make human illnesses moredicult to treat46
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Factory-Fed Fish: How the Soy Industry Is Expanding Into the Sea 5
Despite indications that oshore sh arms are
economically uneasible, environmentally unsound
and unlikely to provide major benets to US
consumers or the regional economies that could
most benet rom a revitalized seaood industry,
the National Oceanic and Atmospheric Administra-
tion (NOAA) has hung on to it as a pet project and
continued pushing or it47
Various environmental, consumer-interest and
shing groups, as well as many individual citizens,
have raised concerns about NOAAs aquaculture
policy48 But the agency has held on to allies in the
soy industry, who are interested in new markets
Fishy TraditionsFeeding sh is one o the central challenges in
the sh arming industry o grow and producemarketable quantities or seaood, sh must be ed
a sucient diet On arms, carnivorous nsh are
typically ed commercial diets containing shmeal
and/or oil, which can be produced rom smaller
sh species or, in some cases, rom shermens
unwanted catch49
Te use o shmeal and oil in sh arming began in
Europe and North America in the early 19th century
as a way to utilize excess herring catch50 Unor-
tunately, what started as a creative way to utilize
extra catch has now become a motivation to exploit
small, orage sh populations and a burden on
marine ood webs On average, it takes one to two
pounds o wild sh processed into shmeal or oil
and included in commercial eed to produce one
pound o armed sh (rates vary between species;
or some it takes much more)51 Tereore, as aqua-
culture production increases, so does the demand
or shmeal and oil Between 1995 and 2010, the
aquaculture industrys use o shmeal increased75 percent, and its use o sh oil has risen by 62
percent52
Te growing demand or shmeal and oil does not
appear to be without consequence Some species
o the small sh used to create these products are
considered to be ully exploited or overexploited,
which, according to the Food and Agriculture
Organization o the United Nations, means that no
sustainable increases in catches rom these species
can be expected53 Exploitation o these species can
threaten not only their own populations, but also
those o the predatory nsh,54 marine birds and
mammals that depend on them or survival55
In addition to these ecological problems rom using
increasing amounts o shmeal and oil in the sh
arming sector, nancial impediments have arisen
As demand has gone up and supply has been
squeezed, the price o shmeal has risen sharply It
doubled between 1995 and 2010, and now consti-tutes the sh arming industrys largest production
expense56
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6 Food & Water Europe www.foodandwatereurope.org
State of the Soy IndustryIn light o the burden that actory sh arming
places on the marine ood web, any alternative
plant-based sh eed may seem like a welcome
alternative But beore soy is accepted as the savior
o the sh arming industrys sustainability, the state
o the soy industry and soy productions impacts onthe environment and our diet must be analyzed
Who is lobbying for the soy industry?
Te soy industry is well organized and represented
in Washington, DC and other parts o the world57
Te American Soybean Association (ASA) repre-
sents 32,000 soybean producers and is primarily
concerned with policy development and infuencing
the legislative process in avor o soy growers58 In
addition to the national association, 26 aliated
Soybean Associations represent various states or
regions o the United States,59 and the US Soybean
Export Council has nine international oces60
Te ASA states in a policy resolution that it
supports expansion o the domestic aquaculture
industry, including oshore aquaculture, and
encourages ederal unding or research that
would optimize the use o soybean protein and oil
in aquaculture eed61 It even has included a resolu-
tion that it supports the recommendation o theGul Coast Fishery Management Council to allow
oshore sh arms in the Gul o Mexico,62 reer-
ring to a controversial actory sh arming plan that
was challenged in ederal courts63
How much soy is genetically modified?
According to the 2007 Census o Agriculture, the
number o soy arms in the United States, at 279,110,
was second only to the number o corn arms64 In
the 2008 Organic Survey, only 1,336 soybean armswere reported as certied organic65 Te standards
or certied organic ood do not allow the use o
genetically engineered crops
I arms arent producing or the organic market,
there is a good chance that they are using geneti-
cally modied seeds, and that they are whether
intentionally or not looped into the major transna-
tional companies that control large portions o our
current ood system While the seed industry oncerelied on universities or most o its research and
development, a ew major chemical and pharma-
ceutical giants now dominate66
Between 1996 and 2007, Monsanto acquired more
than a dozen smaller companies67 Te company
controlled approximately 625 percent o soybean
seeds and seed trait licenses in the United States
by 201068 By 2009, because o this dominance,
93 to 94 percent o the soybeans produced in the
United States are genetically modied according
to Monsanto patents69 Te increase in geneti-
cally engineered soybeans, which are resistant
to Monsantos herbicide Roundup, has led to an
increase in herbicide use70
How much soy is in our food now?
From 1996 to 2009, the sales o oods containing
soy increased rom approximately $1 billion to
almost $45 billion71 Soybeans are a key ingredient
in many oods that Americans eat every day, even
though they may not know they are eating them
Soybeans are a key eed ingredient or cattle, hogs
and chickens, and products known as textured
soy protein and soy protein isolate are used in a
wide variety o processed oods including hot dogs,
hamburgers, baked goods, cereal, pasta and snack
oods72 Soybean oil is also commonly used to ry
rench ries at ast ood restaurants73 According to
various estimates, soy is ound in 60 to 70 percent o
our processed oods74
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Beyond the soy that we consume directly, large
amounts o soy are entering our ood chain indi-
rectly, through our consumption o meat rom
animals that have been raised on soy An estimated
47 percent o the soy produced in the United States
is consumed by livestock75
What Does Soy Haveto Do With Fish Feed?Te US soy industry is powerul and successul at
expanding its markets Te American Soy Associa-
tion testies beore and lobbies Congress,76 and
counts many successes in encouraging Congress
and ederal agencies to enact policies in its avor77
The soy industrys championingof soy diets for factory farmed fish
In 2002, the United Soybean Board and the Illinois,
Indiana and Ohio State Boards unded the Soy in
Aquaculture Initiative, with the goals o increasing
the use o soy in sh eed and developing a program
or international marketing o soy-based aquacul-
ture eed78 Under this initiative, the industry has
unded many research projects to investigate the
inclusion o soybeans in diets or salmon, marine
shrimp and marine nsh Tese studies have
been carried out by researchers at numerous US
universities, and with commercial armers in Latin
America, Asia and the Mediterranean79 In China
alone, where the ASA began work in 1989,80 the
industry has successully increased the volume o
soy used annually in aquaculture eed rom close to
zero to approximately 6 million metric tons81
Although the industry has also given some support
to the inclusion o soy in the diets in more sustain-
able means o sh production, such as re-circu-
lating land-based aquaculture, it has ocused mucheort on oshore cage-based aquaculture82 In
2004, the Soy in Aquaculture Initiative began an
Ocean Cage echnology Project to experiment with
eeding soy to sh raised in oshore cage proto-
types For the next two years, trials were completed
o the coast o Hainan, China Although the study
ound that these sh, which were kept at densities
o 9,600 sh per cage, perormed as well on soy-
based diets as on the sh meal-based control, the
author concluded that growth rates were at leastpartially caused by the eects o antibiotics that the
sh were given ater contracting a parasitic inec-
tion83
Te industry appears eager to bring this type o
oshore arming to the United States as well Te
ASA gives support to policies that will encourage
the development o a US oshore aquaculture
industry, and it has stated not merely that it
applauds the release o a national aquaculture
policy that includes the controversial plan or
oshore aquaculture in the Gul o Mexico, but also
that it will work toward [the policys] implementa-
tion84
Further, both the Illinois Soybean Association (ISA)
and Indiana Soybean Alliance are members o the
Ocean Stewards Institute, a trade organization that
advocates or the open ocean sh arming industry
and provides testimony and public comments toCongress and ederal agencies on policies regarding
oshore aquaculture85 Te Director o the ISA has
been vocal in the organizations support o NOAAs
aquaculture plans, stating: We want to see aqua-
culture grow and fourish Economic activity within
the industry would be the best driver or economic
opportunity or soybean armers, too, and we hope to
see that86
Te ISA has also worked closely with KampachiFarms, ormerly known as Kona Blue Water Farms,
in Hawaii In August 2011, the ISA recognized
Kampachis Neil Sims with an Excellence in Market
Development award or research on soy inclusion
in the diets o the companys sh87 Te ollowing
month, a press release listing the ISA as a source
announced Kampachis new project to test oshore
cage technologies in which sh would be ed a
diet with signicant portions o shmeal and oil
replaced by soy and other agricultural proteins88
In the past, the Kona Blue Water Farms has also
listed the United Soy Board, Nebraska Soy Board
and mega-agribusiness Monsanto as partners in its
research89
Te soy industrys enthusiasm or expanding open
ocean aquaculture is not surprising given the
potential market it oers soybean producers Te
ederal government has estimated that marine
nsh production could be raised to 590,000 tons
annually by 202590 Te ISA has said that soy may
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8 Food & Water Europe www.foodandwatereurope.org
be able to comprise 35 percent o shes diets91 I
the ederal governments goal is reached, and each
o these sh is ed on a 35 percent soy diet, the
soy industry could stand to net an additional $201
million each year by supplying eed or marine
nsh armed in the United States92 Tis does not
include additional revenue that could be made
supplying soy-based eed or reshwater sh, likecatsh, or anadromous sh like salmon and trout
Nor does it include earnings made by supplying
soy-based eed to rapidly expanding aquaculture
industries in other countries93
Cargill and Monsanto:Corporate interest in soy for farmed fish
It isnt only soybean trade associations that have a
stake in supporting the development o open ocean
sh arming Other large corporate soy interestshave a role to play, too For instance, Monsanto
supported a study on incorporating soy into sh
diets by providing both genetically modied and
non-genetically modied soy or the researchers to
give salmon in eed trials94
Cargill, the worlds largest trader in agricultural
commodities and the third largest soybean-
crushing rm,95 is also extending its role in the sh
eed business Cargill created a team dedicated to
aquaculture eed products in the 1990s96 In April
2001, Cargill acquired Agribrands International,
Inc97 Combined, the two companies control 178
animal nutrition acilities/ actories98 Agribrands
Purina, owned by Cargill, is now producing several
lines o sh eed,99 and in May 2004 Cargill acquired
another sh eed production company, Burris
Mill100 According to the vice president o Cargill
Animal Nutrition, Aquaculture is the primary ocus
o Burris Mill, and Cargill intends to increase its
presence in this industry101
Impacts of a Soy Dieton Fish and Their EnvironmentDespite the industrys best eorts, there are still
serious limitations and challenges to eeding soy
to armed sh which is not entirely surprising
considering that it is not a ood that sh would ever
encounter naturally Even the America SoybeanAssociation has stated that, despite years o
research unded both by government and industry,
there are still unidentied actors in plant eedstus
that limit its use in diets or carnivorous species,
including most marine species o commercial
importance, as well as salmon and trout102
Issues of indigestibility and nutrient defi-ciency
Various inherent qualities o soybeans make thema less-than-ideal ood source or sh Although,
as the ASA and researchers have said, there are
unidentied soybean meal components limiting its
use, there are also many diculties that have been
identied A review article o studies on plant-based
eeds or sh indicates that soy is not easily digest-
ible or sh, a problem that can lead to reduced
growth rates and inecient eed use103
Soybeans contain lower levels o some o thenutrients that sh need, and excessive concentra-
tions o others Tey are lower than shmeal in nine
o the 10 essential amino acids, crude at and ash104
Crude at and ash can be made up or through
supplementation, and amino acid concentrations
could be increased by processing soybeans into soy
protein concentrate or isolate, but these products
are relatively expensive compared to shmeal105
On the surplus side, soybeans contain high levels o
carbohydrates, including two types that are indi-
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Factory-Fed Fish: How the Soy Industry Is Expanding Into the Sea 9
gestible or sh106 One o these types, non-starch
polysaccharides (NSPs), intereres with the ability
o sh to digest eed, thus making it dicult or the
sh to obtain the energy they need107
Additionally, soybeans contain protease inhibitors,
natural components that help make the bean more
resistant to pests but that damage the enzyme
balance in sh digestive tracts, also impeding their
ability to digest and utilize soy108
o make things worse, when the raction o
soybeans in sh eed is too high, sh may develop
an infammation o the lower intestine called
enteritis109 Tis infammation may be sparked by
immunological ood intolerance essentially, like
some people, sh may be allergic to soy110 rout and
salmon that are ed soy, or example, sometimes
mimic the human allergic reaction, suering skinlesions, alterations o the digestive tract and exces-
sive mucus in the eces111
Potential impacts on the marine environment
Because certain characteristics o soy make it
dicult or sh to digest, eeding sh soy and other
plant-based eeds causes them to produce higher
levels o excrement112 Even without unusually high
waste production, waste fowing directly through
sh arms into the ocean can damage the ecologicalequilibrium o the sea foor and cause habitat
destruction or disrupt the ecology in the area113
In addition, soybeans contain phytoestrogen, an
estrogen-like chemical produced by plants Tere
is inadequate research on what the impacts are o
introducing phytoestrogen to the marine environ-
ments around arms Various research has conrmed
the [o]estrogenic activity o soybeans in sh114 In
other words, the phytoestrogens in soybeans havebeen shown to produce physical eects on sh that
are ed soy or injected with phytoestrogens in clinical
settings
Tere is insucient evidence to understand how
severe these eects can be, but one study ound
that when eels were ed one type o phytoestrogen
present in soy, 11 times more eels became emales
than in the control group115 Tere is inadequate
research to know whether levels o soy eed being
released into the aquatic environment are harmul
to the reproduction o native sh species in the
surrounding areas But this lack o understanding
should give regulators and the open ocean aquacul-
ture industry pause beore the wholesale adoption
o soy diets or armed sh
Dj vu?Fish are certainly not the first animal to
be fed an unnatural diet on factory farms.
Ninety-eight percent of soybean meal in the
United States goes to livestock feed,116 and
either corn, soybeans or a combination is
the main ingredient of most feed mixtures
for factory farmed cows, chickens and pigs.117
Soy and corn became cheap feed options for
livestock operations after a series of policy
changes culminating with the 1996 Farm Bill,
which marked the end of policies designed to
stabilize farm prices.118 Change in farm policy
eliminated requirements that some land be
kept fallow and resulted in large increases in
the amounts of soy and corn produced, thus
leading to price decreases for these crops.119
Rather than addressing the root cause of
this problem in the 1996 Farm Bill, Congress
issued emergency payments for farmers to
offset their losses.120 These subsidies have
continued to encourage overproduction,
and livestock producers can often buy corn
and soy feed below the cost of production.121
Unfortunately, these farm animals arent
naturally suited to corn and soy diets. Cows,
for instance, are ruminants their four-part
stomachs are made specifically to digest
grass. When they eat other foods, their gut
health may be impaired. Studies show that
artificial diets increase the amount of time
that E. coli strains live on in the manure of
cows, which can be passed on to the meat
itself.122 Increased antibiotic use to counter
E. coli contributes to the development
antibiotic-resistant bacteria strains.123
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10 Food & Water Europe www.foodandwatereurope.org
Impacts on ConsumersEvidence indicates that soy-based aquaculture
eeds may not be the best option or the sh that eat
them or the marine environment into which they
are released But what about the people who eat the
sh?
Unortunately, there are lots o unanswered ques-tions about both eating soy in general, and eating
sh raised on soy However, several potential health
problems associated with soy consumption, as well
as concerns about the nutrient prole o sh that
are ed soy, indicate that we should proceed with
caution
Missing omega-3s
Consumers increasingly preer ood products that
are high in omega-3 atty acids124 Omega-3 attyacids are thought to promote human health and
lessen the likelihood o various diseases, including
coronary heart disease125 Tere are three types o
omega-3 atty acids, which all into two general
categories One, -linolenic acid (ALA), is a plant-
based atty acid, and the other two, eicosapentae-
noic acid (EPA) and docosahexaenoic acid (DHA),
are marine atty acids We get these by consuming
sh, which become enriched with them by eating
algae126 Te American Heart Association recom-mends that adults eat sh at least twice a week in
order to gain the positive benets o EPA and DHA,
which it says are more potent than ALA127
Unortunately, substituting the sh oil used in
eed or armed sh with terrestrial plant oils, like
soybean, reduces the concentration o these omega-
3s in eed128 I sh armers do not want to produce
a nal product low in omega-3s, they must switch
their sh o o a soy diet and on to a high-sh oildiet shortly beore harvest129 Doing so, however,
means that the industry will continue to consume
small, wild sh the very problem that soy use was
intended to avoid Researchers have also explored
genetically engineering soy and other plants to
increase the amount o omega-3s in them130 Tis
would be a troubling proposition, however, or
those who turn to sh or a more natural, sustain-
able ood product, and it may bring other unin-
tended consequences
General impacts of soy consumption
Perhaps more complicated is the issue o increasing
soy in human diets Although eating sh that are ed
soy is a less direct way to consume soybeans than
eating soy products or snacks made with soybean
oil, it needs to be questioned whether some compo-
nents o soy such as the phytoestrogens could
also be passed on to human consumers through
their consumption o sh
Soy is oten associated with healthy eating131 A
central component in some Asian diets, such as the
Japanese cuisine, soy has been associated with the
historically lower rates o cardiovascular disease,
menopausal symptoms, breast cancer, diabetes and
obesity in these populations than in Western popu-
lations132 However, some researchers are calling
this linkage into question,133 or suggesting that theselow rates may be caused by dierent actors134
Moreover, the soy in these diets may not be equiva-
lent to the soy now present in the American diet
due to diering levels o isofavones organic
compounds that have been associated with some
o the potentially negative impacts o soy135 New
Zealand-based toxicologist Dr Mike Fitzpatrick
has pointed out that the soy in traditional Asian
diets is typically ermented, a process that lowersits levels o isofavones136 Additionally, the strains
o soybeans grown in Asia are lower in isofavones
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Factory-Fed Fish: How the Soy Industry Is Expanding Into the Sea 11
even beore ermentation than those grown in
North America, which have been bred to be higher
in isofavones to make them more pest resistant137
Te debate over soys impacts on human health
has been contentious and complicated Although
researchers have connected consumption o the
phytoestrogens in soy to potential lowered risk
o osteoporosis, heart disease and breast cancer,
scientists Heather Patisaul and Wendy Jeerson
have pointed out that phytoestrogens are also
endocrine disruptors with a range o potential
negative impacts that likely depend on a persons
age and health status138 Tey state: While the
potentially benecial eects o phytoestrogen
consumption have been eagerly pursued, and
requently overstated, the potentially adverse
eects o these compounds are likely underappreci-
ated139
In addition, the jury is still out on whether the
phytoestrogens in soy are helpul or harmul in
protecting against breast cancer Although many
studies have been conducted in both humans and
animals, the results have been conficting140 For
instance, a meta-analysis supported by the Susan
G Komen Breast Cancer Foundation ound that the
risk o developing breast cancer decreased as soy
intake increased among Asian women, but that soyintake was unrelated to breast cancer risk in studies
conducted in Western populations141
Another study that looked at the eects o soy
consumption on pre-existing cancers suggested
that highly processed soy, like the sort commonly
consumed in the United States, may be harmul
to post-menopausal women with breast cancer
Te study ound that mice that were ed minimally
processed soy four, like that typically consumed inAsian diets, had no tumor growth, whereas tumors
in mice that were ed more processed orms o
soy grew Te study concluded that the benecial
impacts o soy may be eliminated during certain
types o processing, and cautioned against the
common practice o natural hormone replacement
therapy via increased soy intake or menopausal
women, particularly those with breast cancer142
Tere is also evidence that phytoestrogens could
potentially be harmul or males A study geared
at determining the negative impacts o eeding
soy ormula to male human inants ound that
eeding soy ormula to monkeys reduced the
typical neonatal rise in testosterone expected at a
certain age, an eect that they expected would be
equal, or perhaps more marked, in human inants
under the same conditions Although researchers
are not sure what the impacts o suppressing thisneonatal rise in testosterone are, they write that
it would seem prudent to avoid eeding inants
with SFM [soy ormula milk] whenever alternatives
are possible143 Another researcher has suggested
that the isofavones present in soy reduce sperms
mobility, thus having a great impact on male
ertility144
While the potential health impacts o soy consump-
tion are yet to be ully understood, it appears that,
as Patisaul and Jeerson state, moderation is likely
key145
Environmental and Human RightsInfringements in Soy ProductionRather than provide a sustainable eed or armed
sh, soy-based eed simply shits the burden and
potential risks onto other ecosystems Ninety-our
percent o soy grown in the United States is geneti-
cally modied,146 as is the majority grown in Argen-tina and Brazil147 Monsanto introduced genetically
engineered soy in the mid 1990s Te companys
Roundup Ready soy plants are designed to be
resistant to Roundup, a herbicide that the company
also sells, so that armers can chemically control
weeds without damaging crops148 Increased use
o herbicide has been shown to lead to herbicide-
resistant weeds, which can in turn lead to even
heavier herbicide use in a vicious cycle Tis intense
chemical application raises concerns about poten-tial environmental and human health impacts149
As the soy industry has expanded into South
America, most notably in Argentina and Brazil,
but also in Paraguay, Uruguay and Bolivia,150 it has
led to deorestation and corresponding reduc-
tion o tropical biodiversity and soil erosion151 An
estimated 10,000 hectares (24,711 acres) o orest
is lost in Argentina each year to expanded soy
production152 Tis is damaging not only to plantsand animals,153 but also to human populations
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12 Food & Water Europe www.foodandwatereurope.org
As soy arms take over, indigenous people have
been pushed rom their homeland154 An estimated
300,000 peasant and indigenous amilies have
been displaced in the last decade as a result o soy
expansion in Argentina, and our out o ve previ-
ously existing arming jobs have been lost
In response, groups o small armers and peas-
ants, such as La Via Campesina and the National
Indigenous Campesino Movement o Argentina,
have organized against the monoculture-based soy
industry155 Even more shocking, there have been
documented instances o orced labor on soy plan-
tations in Brazil In 2004, the government created
a registry o agricultural rms ound to have used
slavery156 According to an October 2011 search o
the governments database, six soy operations have
been cited or enslaving a total o 241 workers157
I the US governments estimation that the country
can increase marine nsh production to 590,000
tons a year by 2025 is achieved, and an average o
35 percent o soy is included in the shs diets, as
the Illinois Soy Association says is possible,158 then
the industry would need to utilize an entire 456,292
tons o harvested soy a year to eed these sh It
would take approximately 172,838 hectares o land,
or around 427,000 ootball elds, to produce this
much additional soy each year159 Tis is over twotimes the size o greater New York City,160 and is 173
times the amount o orest already lost to soybean
cultivation in Argentina each year161 It is unclear
what land would be used to meet this growing
need will it be ound through additional tropical
deorestation?
Soy production in South America can also be
problematic or national ood security Even the
Argentine government has blamed the soybeaneconomy or diverting agricultural capacity toward
soy exports, which have orced the country to
import crops that it used to produce domestically162
Te environmental eects o soybean production
are by no means exclusive to South America In Illi-
nois, Iowa, Ohio and southwest Minnesota, under-
ground drainage pipes are used to make the land
dry enough to plant corn and soybeans Te water
that these pipes collect rom arms, which is mixed
with nitrogen ertilizers, drains into tributaries that
eventually eed into the Gul o Mexico163
Te nitrogen ertilizer rom these pipes is possibly
the largest source o nutrient pollution in the Gul164
Tese pollutants eed harmul algae blooms that
take oxygen out o the water, and can cause sh,
shrimp, crabs and other marine lie to suocate i
they cannot swim quickly enough to a more oxygen-
rich area o the water Tese oxygen-depleted
areas are known as dead zones, and in 2011 the
dead zone in the Gul o Mexico equaled and likely
exceeded the size o New Jersey165 I aquaculture
were to create a demand or much more soy, it could
potentially lead to more harmul runo rom soyarms, and more destruction o wild sh
Other AlternativesTere are other options or working toward seaood
sustainability On the most basic level, consumers
can restrict their consumption to wild seaood rom
well-managed sheries or sustainable arming
operations Research, government unding and
private entrepreneurial eorts can be shited away
rom open ocean actory sh arming and toward
other alternatives, such as land-based recirculating
sh arms Because conditions in these closed-loop
systems can be careully controlled, growth rates
can be higher in closed-containment sh arms
than in others166 Plus, sh convert eed eciently
when the water they are in is at the optimum
temperature,167 so the ability to control temperature
in recirculating systems could potentially lead to
lower overall eed requirements Instead o being
ed wild sh or soy, these sh could be ed alterna-
tive ingredients such as algae
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Factory-Fed Fish: How the Soy Industry Is Expanding Into the Sea 13
Because algae are rich in omega-3s and oils168 and
are produced in marine environments, they seem
likely to be a better option or sh eed than soy
Whereas soybeans contain only 18 percent oil, algae
contain as much as 70 percent by weight169 Tey
can also be ecient to grow, with some species
able to double their population in only 24 hours170
Several researchers around the world, includinga team at the University o Maryland, which also
houses a demonstration closed-loop recirculating
sh arm, have been studying possibilities or using
algae as sh eed171 For algae to be a good option,
however, water use will need to be monitored and
genetically engineered varieties avoided
ConclusionTe soy industrys involvement in aquaculture is
a tale o how ar-reaching the infuence o a large,powerul, well-organized agribusiness can be
Although soy is an unexpected and unnatural ood
or sh to eat, the research and outreach unded by
the soy industry has propelled it to the oreront
o alternative eed research in the aquaculture
industry Because o the widespread concern about
sh armings reliance on small, wild sh or eed,
the industry has been able to position soybeans as
an answer to aquacultures sustainability problems
Unortunately, however, eeding soy to sh is ar
rom sustainable Increasing the global demand or
soy through the aquaculture industry could exac-
erbate the negative ramications that already exist,
including pollution to the Gul o Mexico, deoresta-
tion in South America, displacement o indigenous
peoples, and an increase in genetically modied
crops It also raises questions about the rising ubiq-
uity o soy in the ood chain and concerns about
potential human health impacts
Even i soy alleviates the eed problem in aquacul-
ture, open ocean actory sh arming would still be
plagued with the burden o potentially spreading
disease to wild sh, threatening many types o
marine mammals, birds and sh, and disrupting
coastal shing communities Even worse, soy eed
could increase some o the pollution impacts o
ocean sh arming by increasing the amount o
waste that sh produce
Rather than a partnership or innovation, therelationship between the soy and aquaculture
industries is one that could spread damage on both
land and sea
RecommendationsConsumers:
Choose local or domestic seaood that is rom
sustainable, wild sheries or rom conscientious
land-based arms Tis helps you get better sh,protects the environment rom the damage
caused by sh arming and supports economies
in coastal communities
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14 Food & Water Europe www.foodandwatereurope.org
Look beyond the label Not all sustainable
schemes are as helpul as you might think See
De-Coding Seaood Eco-Labels: How the Euro-
pean Commission Can Help Consumers AccessSustainable Seaood or more
Oppose expansion o commercial sh arming
operations Tey promise clean, green jobs, but
they dont deliver See No Jobs Hereor more
Policymakers:
Support research and eorts to sustainably
manage wild sh stocks, and explore other
methods o aquaculture, such as land-basedrecirculating systems
Shit research unding away rom soy into
investigating alternative sh eeds like algae
Support communities eorts to prohibit expan-
sion o commercial sh arming operations in
avor o jobs and industries with a genuinely
sustainable uture
Shit arming policies toward research intoalternative breeds and eeds to help break
Europes dependence on imported soy that
enables industrial meat and sh production and
exports our environmental damage to other
countries
Support moves or the European Union to with-
draw its soybean commitments under the Blair
House Agreement and the current WO Agree-
ment on Agriculture Te EU should be able to
reassess and reestablish arm programs without
the limitations posed by agreements designed
to suit industrial armers in other countries
See Te Perils o the Global Soy rade: Economic,
Environmental and Social Impacts or more
Endnotes1 AmericanSoybeanAssociaon.CEOReporttotheBoardandStates.
March2010.
2 AmericanSoybeanAssociaon.ASAPolicyResoluons.March5,2011at
2.23.09.
3 IllinoisSoybeanAssociaon.[PressRelease].VelellaResearchProject
PromisestoRevoluonizeSustainableAquaculture.September14,2011.
As reprinted in The Sacramento Bee.
4 Ibid.
5 FoodandAgricultureOrganizaonoftheUnitedNaons(FAO).TheState
oftheWorldsFisheriesandAquaculture2010.2010atForeword.
6 Weber,MichaelL.SeawebAquacultureClearinghouse.WhatPriceFarmed
Fish:Areviewoftheenvironmentalandsocialcostsoffarmingcarnivo -
roussh.2003at18and43;Rana,KrishenandMohammedHasan.FAO.
ImpactofRisingFeedIngredientPricesonAquafeedandAquaculture
Producon.(FisheriesandAquacultureTechnicalPaper541.)2009ativ.
7 Naylor,RosamondandMarshallBurke.AquacultureandOceanResources:
Raisinggersofthesea.Annual Review of Environmental Resources,vol.
31.2005at185to218.
8 Shamshak,GinaandJamesAnderson.FutureAquacultureFeedsandFeed
Costs:TheRoleofFishMealandFishOil.InNaonalOceanicandAtmo -
sphericAdministraon(NOAA).Oshore Aquaculture in the United States:
Economic Consideraons, Implicaons and Opportunies.2008at73to96.
9 Inthatitresultsinanetlossofproteinifitrequiresmorethanoneunitof
wildshtoproduceoneunitoffarmedsh.SeeWeber(2003)at24.
10 Sles,Margotetal.Oceana.HungryOceans:Whathappenswhentheprey
isgone?Undatedat2,4,9and18;Cury,Philippeetal.GlobalSeabird
ResponsetoForageFishDepleonOne-thirdfortheBirds.Science,vol.
334,iss.6063.December2011at1703to1706.
11 Forexample,theMarineAquacultureTaskforcerecommendedin2007thataenontoalternavefeeds,suchassoy,wouldbeadvisablefortheaqua -
7/31/2019 Factory-Fed Fish: How the Soy Industry Is Expanding Into the Sea
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Factory-Fed Fish: How the Soy Industry Is Expanding Into the Sea 15
cultureindustry.See:MarineAquacultureTaskforce.SustainableMarine
Aquaculture:FulllingthePromise;ManagingtheRisks.January2007at
95and99.
12 Basedon2011pricesforsoyofapproximately$12abushel,anaverage
feedconversionrateof1.75andstascalconversionsoftheSoybean
ExportCouncil,weesmatethatthesoyindustrycouldpotenallynet
$201millionannuallybysupplyingsoyasaningredientforthefeedofthe
590,000tonsofmarinenshthatNOAAhasesmatedcouldbeproduced
annuallyby2025.MethodologyonlewithFood&WaterWatch.
13 Gatlin,Delbertetal.Expandingtheulizaonofsustainableplantproducts
inaquafeeds:Areview.Aquaculture Research,vol.38.2007at557,558and
566.
14 Duetothefactthat94percentofsoygrownintheUnitedStatesisgene-
callymodied.See:UnitedStatesDepartmentofAgriculture(USDA),
EconomicResearchService.AdoponofGenecallyEngineeredCropsin
theU.S.:SoybeanVariees.July1,2011.
15 Barne,Anthony.TheyHailedItasaWonderfood.The Guardian(Lon-
don).November7,2004.
16 Ibid.
17 Wallace,Sco.LastoftheAmazon.Naonal Geographic,vol.211,iss.1.
January2007at40to71.
18 FAO(2010)atForeword.
19 Alston,DallasE.etal.EnvironmentalandSocialImpactsofSustainable
OshoreCageCultureProduconinPuertoRicanWaters.FinalReport
SubmiedforNOAAFederalContractNumber:NA16RG1611.April2004at
12.
20 NaylorandBurke(2005)at202.
21 Upton,HaroldandEugeneBuck.OpenOceanAquaculture.Congressional
ResearchService.August9,2010at12to13;NaylorandBurke(2005)at
203.
22 UptonandBuck(2010)at11.
23 Tacon,AlbertandMarcMean.Globaloverviewontheuseofshmeal
andshoilinindustriallycompoundedaquafeeds:Trendsandfuture
prospects.Aquaculture,vol.285.2008at154;FAO.Fishmeal.Globesh.
March2010;Slesetal.(undated)at2,4,9and18;Curyetal.(2011)at
1703to1706.
24 U.S.SoybeanExportCouncil,UnitedSoybeanBoardandAmericanSoybean
AssociaonInternaonalMarkeng.SoyProteinConcentrateforAqua -
cultureTechnicalBullen.2008at8;AmericanSoybeanAssociaon.Com-
mentsSubmiedtotheUnitedStatesDepartmentofAgricultureinregards
totheResearchEducaonandEconomicsOceRoadmap.May2009;Hart,
Steven.SoyAquacultureAlliance.PresentaonatAquacultureCoalion
Meeng.March2012.
25 Forinstance,asillustratedbytheIllinoisSoybeanAssociaonworkingwith
andcommemorangtheworkofKonaBlueWaterFarms:KonaBlueWa-
terFarmsCo-founderWinsAward.Pacic Business News.August2,2011;
alsobythesameorganizaonspartnershipwithaquaculturistsinIllinois:
IllinoisSoybeanAssociaon.[PressRelease].IllinoisAquacultureSurfaces
asNewSoybeanPartner.September9,2010;andbytheU.S.SoyExport
CouncilandtheIndianaSoybeanAlliancesmembershipintheGlobalAqua -
cultureAlliance:GlobalAquacultureAlliance.AssociaonMembers.2011.
26 AmericanSoybeanAssociaon.ASAPolicyResoluons.March5,2011at
2.23.09.
27 AmericanSoybeanAssociaon.[PressRelease].ASAOutlinesPotenalofOshoreAquacultureforSenateCommiee.April6,2006.
28 Gatlinetal.(2007)at553to554.
29 Naylor,RosamondL.etal.Feedingaquacultureinaneraofnitere-
sources.Proceedings of the Naonal Academy of Sciences,vol.106,iss.36.
September8,2009at15106.
30 Marder,Jenny.FarmRunoinMississippiRiverFloodwaterFuelsDead
ZoneintheGulf.PBS.May18,2011.
31 Barne(2004).
32 Wallace(2007)at40to71.
33 Pasaul,HeatherB.andWendyJeerson.Theprosandconsofphytoes-
trogens.Froners in Neuroendocrinology,vol.31.March2010at402;
Barne(2004);InstuteforAgricultureandTradePolicy.Below-CostFeed
Crops:AnIndirectSubsidyforIndustrialAnimalFactories.June2006.
34 PasaulandJeerson(2010)at400.
35 See,forexample,Food&WaterWatch.WhosBenengfromFactory
FishFarming.September2011.Availableatwww.fwwatch.org
36 Asevidencedbythevariousbillsregardingoshoreaquacultureintroduced
inthepast15years,theGulfFisheryManagementPlanforOshoreAqua -
culture,andthediscussionofsoyintheNOAA/USDAFutureofAquafeeds
report,whichstatesthattheexpertpanelconvenedtodiscussalternave
feedingredientsforaquacultureendorsesthestrategicresearchplanlaid
outbythePlantProductsinAquafeedsWorkingGroupwithsponsorship
fromtheUnitedSoybeanBoard.See:S.1192,104thCong.(1995);S.1195,
109thCong.(2005);S.1609,110thCong.(2007);H.R.2010,110thCongress
(2007);H.R.4363,111thCongress(2009);H.R.2373,112thCongress
(2011);GulfofMexicoFisheryManagementCouncil.FisheryManagement
PlanforRegulangOshoreMarineAquacultureintheGulfofMexico.
January2009at18to19;Rust,Michaeletal.TheFutureofAquafeeds,
NOAA/USDAAlternaveFeedsIniave.November2010at45;Plant
ProductsinAquafeedWorkingGroup.StrategicResearchPlan.November
2005at2;UptonandBuck(2010).
37 U.S.DepartmentofCommerce.AquaculturePolicy.1999.
38 Ibid.
39 CalculaonsconductedbyandonlewithFood&WaterWatch.Formore
informaon,seeFood&WaterWatch.FishyFarms:TheGovernments
PushforFactoryFishFarmsinOurOceans.October2011.
40 NaonalMarineFisheriesService.FisheriesoftheUnitedStates.NOAA.
2010at50and63.
41 Forfurtheranalysisandinformaon,seeFood&WaterWatch.Import
Alert.May2007;Food&WaterWatch.LaboratoryError.December
2008.
42 KonaBlueWaterFarms,LLC.FinalSupplementalEnvironmentalAssess-mentforaModicaontoNetPenDesignsWithintheExisngProducon
CapacityandFarmLeaseAreaforKonaBluesOshoreOpenOceanFish
FarmoUnualohaPoint,Kona,Hawaii.April21,2009at10,22and23.
43 Forinstance,anarcleinScienc Americanwrites:Atoshoresitessuch
asKonaBlueWaterFarms,polluonisnotanissue,Sims[companypresi -
dent]explains.Thesevensubmergedpaddocks,eachoneasbigasahigh
schoolgymnasium,areanchoredwithinrapidcurrentsthatsweepawaythe
waste,whichisquicklydilutedtoharmlesslevelsintheopenwaters.See
Simpson,Sarah.TheBlueFoodRevoluon:Makingaquacultureasustain -
ablefoodsource.Scienc American.February7,2011.
44 MarineAquacultureTaskForce.SustainableMarineAquaculture:Fullling
thePromise;ManagingtheRisks.January2007at6.
45 Sar,G.etal.Impactsofmarineaquacultureatlargespaalscales:
evidencesfromnandpcatchmentloadingandphytoplanktonbiomass.
Marine Environmental Research.AcceptedFebruary24,2011.
46 Heuer,Ole.E.etal.HumanHealthConsequencesofUseofAnmicrobial
AgentsinAquaculture.Clinical Infecous Diseases,vol.49,iss.8.2009at
1248to1253.
47 Formoreinformaonsee,forexample,Food&WaterWatch(2011).
48 Asdemonstratedbypubliccommentssubmiedin2011inregardto
NOAAsDraAquaculturePolicyincluding:Commentssubmiedby2,325
individualsandbySarahAlexanderonbehalfofFood&WaterWatch
supporters;Raney,Dave.SierraClub.SierraClubCommentsonNOAA
andDepartmentofCommerceDraAquaculturePolicies.April11,2011;
Keever,MarcieandEricHoman.FriendsoftheEarth.NOAAsDraAqua-
culturePolicy.April11,2011;Witkowski,JillM.SanDiegoCoastkeeper.
CommentsonNOAAsDraAquaculturePolicy.April11,2011;Coastal
ConservaonAssociaon.CommentsontheNOAADraAquaculturePol -
icy.April11,2011;Vinsel,Mark.UnitedFishermenofAlaska.Comments
onNOAADraAquaculturePolicy.April11,2011;Kelley,Dale.Alaska
TrollersAssociaon.DOCandNOAADraAquaculturePolicies.April10,
2011;Kimbrell,Andrew.TheCenterforFoodSafety.CommentstoDepart-
mentofCommerceandNOAADraNaonalAquaculturePoliciesonthe
NeedforaProgrammacEnvironmentalImpactStatement.April11,2011;
Mitchell,JamesandMarianneCufone.Food&WaterWatch.Comments
ontheFebruary2011NaonalOceanicandAtmosphericAdministraon
DraAquaculturePolicyandtheDepartmentofCommercesDraNaonal
AquaculturePolicy.April11,2011.
49 NaylorandBurke(2005)at194.
50 FAO.Theproduconofshmealandoil.(FAOFisheriesTechnicalPaper
142.)1986at1.
51 UptonandBuck(2010)at14.
52 TaconandMean(2008)at146to158.
53 FAO.Reviewofthestateofworldmarinesheryresources.(FAOFisheries
TechnicalPaper457.)2005at6to7.
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16 Food & Water Europe www.foodandwatereurope.org
54 Upho,J.H.Jr.Predator-preyanalysisofstripedbassandAtlancmenha-
deninupperChesapeakeBay.Fisheries Management Ecology,vol.10,iss.
3.2003at313to322.
55 Cury(2011)at1703to1706;Bearzi,Giovannietal.Ecology,statusand
conservaonofshort-beakedcommondolphinsDelphinus delphisinthe
MediterraneanSea.Mammal Review,vol.33,iss.3.2003at236.
56 U.S.DepartmentofCommerce,NOAA,NaonalMarineFisheriesService.
BudgetAcvity:NaonalMarineFisheriesService.FiscalYear2012at117
and118.
57 TheAmericanSoybeanAssociaonisrepresentedinWashington,D.C.by
thermGordleyAssociates.See:DelaneyMovestoAmericanSoybean
Associaon.The Hagstrom Report,December19,2011;CenterforRespon -
sivePolics.OpenSecrets.AmericanSoybeanAssociaon.Availableat
www.opensecrets.org.AccessedFebruary2012.
58 AmericanSoybeanAssociaon.StatementtotheUnitedStatesDepartment
ofAgricultureResearch&PromoonProgramsJointTaskForce.Wash-
ington,D.C.March9,1999;AmericanSoybeanAssociaon.ASASoybean
Success.2008.
59 AmericanSoybeanAssociaon.FirmlyRootedinSuccess:2011Soybean
SuccessReport.AnnualReport.2011at11.
60 U.S.SoybeanExportCouncil.AnnualReport.2009.
61 AmericanSoybeanAssociaon.ASAPolicyResoluons.March5,2011at
2.23.07
62 Ibid.at2.23.09.
63 GulfRestoraonNetwork,Inc.etal.v.NaonalMarineFisheriesServiceetal.730F.Supp.2d157(D.D.C.2010).
64 USDA.FarmNumbers,Demographics,Economics.2007CensusofAgricul-
ture.2007.
65 USDA.2008OrganicSurvey.2008atTable7,OrganicFieldCropsHar-
vestedfromCeredandExemptOrganicFarms.
66 Howard,Phil.MichiganStateUniversity,AssistantProfessor.SeedIndustry
Structure,1996-2008.2009.OnleatFood&WaterWatch;Fernandez-
Cornejo,Jorge.TheSeedIndustryinAgriculture.USDAEconomic
ResearchService,AIB-786.January2004at25to26and36(Table18).
67 Fernandez-Cornejo(2004)at33to34.
68 See:Moss,DianaL.TheAmericanAntrustInstute.TransgenicSeedPlat-
forms:CompeonBetweenaRockandaHardPlace?Addendum.April
5,2010at5;Moss,DianaL.TheAmericanAntrustInstute.Transgenic
SeedPlaorms:CompeonBetweenaRockandaHardPlace?October23,2009at13to14.
69 AdoponofGenecallyEngineeredCropsintheU.S.:SoybeanVariees.
DataSet,EconomicResearchService,USDA;Whoriskey,Peter.Monsantos
dominancedrawsantrustinquiry.Washington Post.November29,2009.
70 Benbrook,Charles.GenecallyEngineeredCropsandPescideUseinthe
UnitedStates:TheFirstNineYears.BioTechInfoNet,Paper7.October2004
at2,4,22and34.
71 Soyatech,LLCandSPINS.SoyfoodsAssociaonofNorthAmerica.TheU.S.
Market2010.OnlewithFood&WaterWatch.
72 PasaulandJeerson(2010)at402.
73 Jahren,A.HopeandRebeccaA.Kra.Carbonandnitrogenstableisotopes
infastfood:Signaturesofcornandconnement.Proceedings of the Na-
onal Academy of Sciences,vol.105,iss.46.2008at17859.
74 PasaulandJeerson(2010)at402;Barne(2004).75 InstuteforAgricultureandTradePolicy(2006).
76 See:AmericanSoybeanAssociaon.ASASoybeanSuccess.2008;Censky,
Stephen.AmericanSoyAssociaon.CEOReporttotheBoardandStates.
July2011.
77 AmericanSoybeanAssociaon.FirmlyRootedinSuccess:2011Soybean
SuccessReport.AnnualReport.2011at4.
78 Hart,Stevenetal.Soybeanannutrionalfactorsandtheirrelave
importanceinlimingtheuseofsoybeanmealinsalmoniddiets.Funded
byIndianaSoybeanAlliance,IllinoisSoybeanAssociaon,IowaSoybeanAs -
sociaon,OhioSoybeanCouncilandtheUnitedSoybeanBoard.Undated.
79 Hart,Steven.SoyAquacultureAlliance.PresentaonatAquacultureCoali-
onMeeng.March2012.
80 AmericanSoybeanAssociaon.StatementtotheUnitedStatesDepartment
ofAgricultureResearch&PromoonProgramsJoinTaskForce.Washing-
ton,D.C.March9,1999.
81 AmericanSoybeanAssociaon.Aquaculture.PosionPapers.Onleat
Food&WaterWatch;Gatlinetal.(2007)at552.
82 See,forexample:VirginiaCobiaFarms.IndustryExperienceinGood
PracceRecirculaonSystems.PresentedattheWWFsSeriolaandCobia
AquacultureDialogues(SCAD)II,Veracruz,Mexico.September25,2009at
31;BellAquacultureandIndianaSoybeanAlliance.[PressRelease].Bell
AquacultureTeamswithIndianaSoybeanAlliance,VirginiaCobiaFarmsand
theConservaonFundsFreshwaterInstute.January25,2012.
83 Hsiang,PinLan.GrowthPerformanceofPompano(Trachinotus blochii)
FedFishmealandSoyBasedDietsinOshoreOCATOceanCages.Results
of2007OCATCageFeedingTrialinHainan,China.
84 AmericanSoybeanAssociaon.Aquaculture.Undated.
85 Sims,Neil.OceanStewardsInstute.TesmonytotheHouseSubcom-
mieeonInsularAairs,OversightHearingonOshoreAquaculture.
September9,2009;OceanStewardsInstute.Commentssubmiedduring
publiccommentperiodondrapolicy.CommentsontheNaonalDra
DOCNaonalAquaculturePolicy.NOAA,DepartmentofCommerce,2011.
86 IllinoisSoybeanAssociaon.[PressRelease].ISAEncouragesU.S.Aquacul-
tureIndustrytoMoveForward.June6,2011.
87 KonaBlueWaterFarmsCo-founderWinsAward.Pacic Business News.
August2,2011.
88 IllinoisSoybeanAssociaon(September14,2011).
89 Sims,Neil.KonaBlue,andtheFutureofFish.PresentaonattheAmeri-
canSoybeanAssociaonAquacultureInvestmentSeminar,Miami,Florida,
August24,2010.
90 NOAA,U.S.DepartmentofCommerce.NOAA10-YearPlanforMarine
Aquaculture.October2007at12.
91 IllinoisSoybeanAssociaon(June6,2011).
92 Basedon2011pricesforsoyofapproximately$12abushel,anaverage
feedconversionrateof1.75forthisproduced,andstascalconversions
oftheSoybeanExportCouncil.MethodologyonlewithFood&Water
Watch.
93 AccordingtotheFAO,aquacultureisdeveloping,expandingandintensify-
inginalmostallregionsoftheworld,exceptinSub-SaharanAfrica:FAO.
StateofWorldAquaculture2006.(FisheriesTechnicalPaperNo.500.)
2006.
94 Sissener,N.H.etal.AlongtermtrialwithAtlancsalmon(Salmo salar
L.)fedgenecallymodiedsoy;focusinggeneralhealthandperformance
before,duringandaerparr-smolttransformaon.Aquaculture,vol.294,
iss.12,September2009at108to115;Sissener,N.H.etal.AnAssessment
oforganandintesnalhistomorphologyandcellularstressresponsein
Atlancsalmon(Salmo salar L.)fedgenecallymodiedRoundupReady
soy.Aquaculture,vol.298,iss.12,December2009at101to110.
95 Blas,Javier.CargillBuysAgriumsGrainTradeUnit.The Financial Times
(London).December15,2010;Hendrickson,MaryandHeernan,William.
ConcentraonofAgriculturalMarkets.UniversityofMissouri.April2007.
96 Whiy,Gerry.SmallPondsServeaBigFish.Feed & Grain.June/July2007.
97 AgribrandsShareholdersApproveMergerwithCargill.PR Newswire.April
26,2001.
98 Grainnet.CargilltoAcquireAgribrands.December8,2000.
99 Cargill.AgribrandsPurina(JiaXing)FeedmillCo.,Ltd.AccessedonJune10,
2011.OnlewithFood&WaterWatch;CargillBuysStakeinPurina.Food
Navigator.May22,2001.
100 CargilltoacquireBurrisMills&FeedInc.TheFishSite.
101 Ibid.
102 AmericanSoybeanAssociaon.[PressRelease].ASAOutlinesPotenalof
OshoreAquacultureforSenateCommiee.April6,2006.
103 Gatlinetal.(2007)at557,558and566.
104 Ibid.at553.
105 Ibid.
106 Chou,R.L.etal.Substungshmealwithsoybeanmealindietsofjuve-
nilecobiaRachycentron canadum,Aquaculture,vol.229,iss.14.2004at
325to333.
107 Gatlinetal.(2007)at557and558.
108 Ibid.at559.
109 Ibid.110 Bakke-McKellop,etal.Changesinimmuneandenzymehistochemical
phenotypesincellsintheintesnalmucosaofAtlancsalmon, Salmo salar
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Factory-Fed Fish: How the Soy Industry Is Expanding Into the Sea 17
L.,withsoybeanmeal-inducedenteris.Journal of Fish Diseases,vol.23.
2000at115to127;Gatlinetal.(2007)at559.
111 Gatlinetal.(2007)at559.
112 Nayloretal.(2009)at15106.
113 Alston,DallasE.etal.EnvironmentalandSocialImpactofSustainable
OshoreCageCultureProduconinPuertoRicanWaters.FinalReport
SubmiedforNOAAFederalContractNumber:NA16RG1611.April2004at
12.
114 Gatlinetal.(2007)at560to561.
115 Ibid.at561.
116 Ash,Mark.SoybeansandOilCrops:Background.USDA,EconomicRe-
searchService.May7,2010.
117 Starmer,E.,andT.A.Wise.FeedingattheTrough:IndustrialLivestock
FirmsSaved$35BillionfromLowFeedPrices.GDAEPolicyBriefNo.07-03.
GlobalDevelopmentandEnvironmentInstuteofTusUniversity.Decem -
ber2007.
118 Eand,AnneB.W.USDA,EconomicResearchService.U.S.FarmPolicy:
TheFirst200Years.AgriculturalOutlook.March2000at25.
119 Beitel,Karl.U.S.FarmSubsidiesandtheFarmEconomy:Myths,Realies,
Alternaves.FoodFirst/InstuteforFoodandDevelopmentPolicy.Sum-
mer2005.
120 Ray,Darrelletal.AgriculturalPolicyAnalysisCenter,UniversityofTennes-
see.RethinkingUSAgriculturalPolicy:ChangingCoursetoSecureFarmer
LivelihoodsWorldwide.September2003at9.
121 Ibid. at13.;StarmerandWise(2007).
122 Franz,Eelcoetal.EectsofCaleFeedingRegimenandSoilManage-
mentTypeontheFateofEscherichiacoliO157:H7andSalmonellaenterica
SerovarTyphimuriuminManure,Manure-AmendedSoil,andLeuce.
Applied and Environmental Microbiology,vol.71,iss.10.October2005at
6165and6172;Callaway,T.R.etal.Foragefeedingtoreducepreharvest
Escherichiacolipopulaonsincale,areview.Journal of Dairy Science,
vol.86,iss.3.2003at858.
123 Schroeder,CarlM.etal.AnmicrobialResistanceofEscherichiacoliO157
IsolatedfromHumans,Cale,Swine,andFood.Applied and Environmental
Microbiology,vol.68,iss.2.February2002.
124 Nayloretal.(2009)at15103.
125 Li,MengheH.etal. EectsofDriedAlgaeSchizochytriumsp.,aRichSource
ofDocosahexaenoicAcidonGrowth,FayAcidComposion,andSensory
QualityofChannelCaishIctalurusPunctatus.Aquaculture,vol.292.2009at232.
126 Jenkins,DavidandAndreaJosse.Fishoilandomega-3fayacids.Cana-
dian Medical Associaon,vol.178,iss.2.January2008at150.
127 Kris-Etherton,PennyM.etal.AmericanHeartAssociaon.Omega-3Fay
AcidsandCardiovascularDisease:NewRecommendaonsfromtheAmeri -
canHeartAssociaon.Arteriosclerosis, Thrombosis and Vascular Biology,
vol.23.2003at151to152.
128 Nayloretal.(2009)at15107.
129 Ibid.
130 Ibid.
131 Lawrence,Felicity.ShouldWeWorryAboutSoyainOurFood?The Guard-
ian(London).July25,2006.
132 PasaulandJeerson.2010at400.133 Ibid.
134 Lawrence(2006).
135 Ibid.;Barne(2004).
136 Lawrence(2006).
137 Ibid.
138 PasaulandJeerson(2010)at400.
139 Ibid.at413.
140 Ibid.at406to407.
141 Wu,A.H.etal.Epidemiologyofsoyexposuresandbreastcancerrisk.Brit-
ish Journal of Cancer,vol.98iss.98.2008at9to14.
142 Allred,ClintonD.etal.Soyprocessinginuencesgrowthofestrogen-
dependentbreastcancertumors.Carcinogenesis, vol.25,iss.9.2004at
1649to1657.
143 Sharpe,RichardM.etal.Infantfeedingwithsoyformulamilk:eectson
thetessandonbloodtestosteronelevelsinmarmosetmonkeysduring
theperiodofneonataltescularacvity.Human Reproducon,vol.17,iss.
7.2001at1692,1699and1701.
144 Barne(2004).
145 PasaulandJeerson(2010)at414.
146 AdoponofGenecallyEngineeredCropsintheU.S.:SoybeanVariees.
DataSet,EconomicResearchService,USDA.
147 AlmostallofArgennassoybeancropisnowfrombiotechnologyseeds:
Mergen,DavidandAndreaYankelevich.USDA,ForeignAgriculturalService.
ArgennaAgriculturalBiotechnologyAnnual.July15,2011at2;In
2007/08anesmated5261percentofBrazilssoycropwasgenecally
modied:EuropeanCommission,Health&ConsumersDirectorate-General,FinalreportofamissioncarriedoutinBrazilfrom22Aprilto30April2009
inordertoevaluateocialcontrolsystemsforfood,feedandseedconsist-
ingoforproducedfromgenecallymodiedorganisms(GMOs)intended
forexporttotheEU.(DG(SANCO)/2009-8301-MRFINAL.)2009at4.
148 Paarlberg,Robert.Food Polics: What Everyone Needs to Know.Oxford:
OxfordUniversityPress.2010at163.
149 Binimelis,Rosaetal.Transgenictreadmill:Responsestotheemergency
andspreadofglyphosate-resistantjohnsongrassinArgenna.Geoforum,
vol.40,iss.4.July2009at623to633.
150 AmericanSoybeanAssociaon.SoyStats,AReferenceGuidetoImpor-
tantSoybeanFacts&Figures.2011at30;Garca-Lpez,GustavaA.and
ArizpeNancy.ParcipatoryprocessesinthesoyconictsinParaguayand
Argenna.Ecological Economics,vol.70,iss.2.December2010at196to
206.
151 Nepstad,Danieletal.TheEndofDeforestaonintheBrazilianAmazon.
Science,vol.326.December2009at1350to1351;Grau,H.Ricardoand
MitchellAide.GlobalizaonandLand-UseTransionsinLanAmerica.
Ecology and Society,vol.13,iss.2.2008atarcle16(onlinepublicaon).
152 Barne(2004).
153 vanSolinge,TimBoekhout.DeforestaoncrimesandconictsintheAma-
zon.Crical Criminology,vol.18,iss.4.December2010at263to277.
154Wallace(2007)at40to71.
155 Garca-LpezandArizpe(2010)at196to206.
156 ReporterBrasil.SlaveLabourLaundryList.AccessedOctober23,2011.
157 InternaonalLabourOrganizaon,EthosInstuteandReprterBrasil.Slave
LabourLaundryList.AccessedOctober23,2001.
158 IllinoisSoybeanAssociaon.(June6,2011).
159 CalculaonsconductedbyandonlewithFood&WaterWatchbasedon
averagefeedconversionraosof1.75.
160 CalculaonsconductedbyandonlewithFood&WaterWatch.
161 Anesmated10,000hectaresoflandarelostinArgennaeachyear,and
weesmate172,838hectaresoflandwillbeneeded.172,838/10,000=
1.73.Barne(2004).
162 Lewis,Steven.SouthAmericansoybeanboomposeslogiscalchallenges.
Food Chemical News.March1,2010.
163 Marder(2011);David,MarkB.,etal. SourcesofNitrateYieldsintheMis-
sissippiRiverBasin.Journal of Environmental Quality,vol.39.September
October2010.
164 Ibid.
165 Ibid.
166 Timmons,M.B.andJ.M.Ebeling.RecirculangAquaculture.CayugaAquaVentures.2007at7.
167 Masser,Michaeletal.SouthernRegionalAquacultureCenter.Recirculat-
ingAquacultureTankProduconSystems:ManagementofRecirculang
Systems.No.452.March1999.
168 Li,MengheH.,etal.EectsofDriedAlgaeSchizochytriumsp., aRich
SourceofDocosahexaenoicAcidonGrowth,FayAcidComposion,and
SensoryQualityofChannelCaishIctalurusPunctatus.Aquaculture,vol.
292.2009at232to236;Mata,Teresaetal.Microalgaeforbiodiesel
produconandotherapplicaons:Areview.Renewable and Sustainable
Energy Reviews,vol.14.Spring2010at221.
169Mata(2010)at221.
170 Chis,Yusef.Biodieselfrommicroalgae.Biotechnology Advances,vol.25.
February2007at126.
171 Block,Ben.WorldwatchInstute.NewFishFarmsMovefromOceantoWarehouse.May2008.
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