Fishy Farms: The Government’s Push for Factory Farming in Our Oceans

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Fishy Farms:The Governments Push forFactory Farming in Our Oceans


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About Food & Water Watch

Food & Water Watch works to ensure the food, waterand sh 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 owing

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 Watch

1616 P St. NW, Suite 300

Washington, DC 20036tel: (202) 683-2500

fax: (202) 683-2501

[email protected]

www.foodandwaterwatch.org

Copyright October 2011 by Food & Water Watch.

All rights reserved.

Cover images courtesy of NOAA.

This report can be viewed or downloaded at

www.foodandwaterwatch.org.

California Ofce

25 Stillman Street, Suite 200

San Francisco, CA 94107tel: (415) 293-9900

fax: (415) 293-8394

[email protected]


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Fih F The Governments Push for Factory Farming in Our Oceans 1

Executive Summary 2

Key Findings 3

Introduction 4

Feedlots o the Sea: Factory Fish Farms and the United States 5

Why Factory Fish Farming Is Not Environmentally Sound or Sustainable 7

Pollution 7

Disease 7

Escaped Fish 8

Sidebox: Genetically Engineered Fish 8Pressure on Wild Fish 9

Sidebox: Fish to Pellets to Fish Again 9

Sidebox: Vegetarian Carnivores? 10

Impacts on Marine Animals 11

Why Factory Fish Farming Wont Fix Our Economy 11

Logistical Diiculties 11

No Jobs Here 11

Not or Small-scale Entrepreneurs 11What It Would Take to Oset the Seaood Decit Through Factory Fish Farming 12

Why Factory Fish Farming Wont Benet Consumers 13

Health Concerns 13

A Costly Product 14

Contributing to Global Food Insecurity? 14

Lie on Factory Fish Farms 14

Atlantic Marine Aquaculture Center 14

Snapperarm and Ocean Blue Sea Farms 15Kona Blue Water Farms 16

Hukilau Foods, Formerly Known as Cates International 17

Other Farms 18

Conclusions 19

Recommendations to Policymakers 19

Recommendations to Consumers 19

Fishy Farms:The Governments Push forFactory Farming in Our Oceans


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2 Fd & W Wh www.foodandwaterwatch.org

Execuve Summary

Over the past decade, people have become increas-

ingly conscious about the environmental, cultural

and economic repercussions o their ood choices, and

a movement has emerged to support more diverse,

sustainable options This movement has extended to

choices about seaood, as people take note o issues

such as overshing and the environmental ramica-

tions o dierent types o sh arming

Despite this, the US government continues to

subsidize the development o open ocean aquaculture,

a type o actory arming that threatens the healtho our oceans, coastal communities and consumers

Factory sh arming involves the production o as

many as tens o thousands o sh in cages o the

coastline

This report revisits the our US taxpayer-supported

actory sh arming experiments in Hawaii, New

Hampshire and Puerto Rico that are described

in Food & Water Watchs previous reports, Seas of

Doubt and the rst edition oFishy Farms. Because

all o these research and demonstration projects havepreviously received government unding to advance

the industry, we have traced the operations histories

or lessons that can be drawn about the easibility o

ocean sh arming

The results are bleak This newest update nds that

despite having as many as 13 years to overcome

setbacks,1 the arms have been largely unsuccessul,

acing some combination o technical, economic or

environmental setbacks They have experienced sh

escapes, equipment ailure and community opposition

In some cases, the problems have caused the opera-

tions to relocate, scale-back, sell out to other compa-

nies or even stop production altogether Operations

that have since been proposed have had diiculty

securing permits and community support

Even as new inormation about these acilities contin-

ues to demonstrate that their easibility is uncertain,

the data is becoming clearer about their potential

impacts A leading argument used to promote actory

sh arming is that we need it to oset the US sea-

ood trade decit that is, to import less seaood and

produce more seaood or local consumption A Food

& Water Watch analysis nds that to do this through

actory sh arming, however, would require an almost

unimaginable 200 million sh to be produced in oceancages each year This would call or approximately 41

percent o the entire global production o shmeal to

be used as eed, could produce as much nitrogenous

waste as the untreated sewage rom a city nearly nine

times more populous than the city o Los Angeles and

could lead to the escapement o as many as 348 mil-

lion sh (i conditions are unavorable) or 12 million

sh (i conditions are ideal) into our oceans in one

year alone2

Despite years o opposition rom consumers, envi-

ronmentalists and coastal communities, as well as

increasing evidence that this type o arming is inea-

sible and irresponsible, the ederal government, under

the National Oceanic and Atmospheric Administration

(NOAA), has continued to sink resources to support

this industry and develop a policy or it The govern-

ment already has spent over $44 million in support o

the troubled industry3 During a time when people are

pushing to trim the ederal budget, NOAA continues to

request money to support ocean sh arming moneythat could be more wisely spent supporting job cre-

ation and economic growth in other areas

Ater more than a decade o setbacks, it is time or

the US government to recognize that actory sh

arming is not the solution or increasing seaood

saety and availability NOAA must stop taking

money away rom improving the sustainability o our

Image courtesy oF Noaa

SeaStaon 3000 with feeding tube approximately 40 feet below

the surface oshore of Honolulu, Hawaii, with divers on side.


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wild sheries Congress should act to prevent ederal

agencies rom ast-tracking the development o the

industry The international community already has

learned that large-scale, industrial, land-based ag-

riculture cannot solve all economic and ood security

problems When it comes to seaood and our oceans,

we should take a lesson and avoid repeating the same

mistakes

Key Findings

The actory sh arming industry has ailed to

demonstrate that it is environmentally sustain-

able or nancially or technically viable on a com-

mercial scale None o the US taxpayer-supported

actory sh arming experiments have succeeded

in proving that the industry is nancially easible

or environmentally sustainable

Open ocean aquaculture is not a solution to the

US seaood trade decit According to Food & Wa-

ter Watch analysis, based on examples rom cobia,

a type o sh currently in production, the United

States would need to produce 200 million sh each

year to oset the $10 billion seaood trade decit

Our estimates conclude that:

It would take more than 12 million tons o

shmeal or 41 percent o the current estimat-

ed global supply to eed this many sh

Assuming that these sh produce a similaramount o waste as armed salmon, this volume

o production would lead to as much nitrogenous

waste as the raw sewage rom a city o over 34

million people nearly nine times the city o

Los Angeles

I as many sh escaped rom these arms as

escaped on average over the course o three

unavorable years o salmon production in Wash-

ington state, 348 million sh could be released

into our oceans, where they could compete andinterbreed with wild sh This is over 17 times

as many sh as are estimated to escape rom

salmon arms in the Atlantic Ocean each year

Even i the industry avoided the unavorable

conditions o storms or equipment ailure, we

could still expect 12 million sh to be released

into our waters annually, comparable to the

quantity o salmon escapes in the Atlantic that

some scientists believe has contributed to the

extinction o wild Atlantic salmon

Ocean actory sh arms will not reduce pressure

on wild sh populations The aquaculture industry

already is the worlds largest user o shmeal and

sh oil, consuming 80 percent o the worlds sh

oil and hal the shmeal each year Rather than contributing to domestic and global

ood supplies, open ocean aquaculture acilities

will likely produce an expensive product that is

out o reach or many US consumers and may, in

act, contribute to ood insecurity in populations

that are dependent on the small sh species used

in shmeal and oil or protein

Like other actory-style industries with the goal

o outputting as much as possible or the smallest

cost, oshore sh arms will employ relatively ew

people, and the jobs may not be desirable or sae

or workers

Despite spending many resources and sta time,

neither NOAA nor Congress have successully

drated a policy that could responsibly regulate

actory sh arming


Juvenile cobia responding to a feeding pipe in an oshore cage

o of the island of Culebra, Puerto Rico.


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For example, all o these operations have received

government subsidies, and they have not demonstrat-

ed that they can be protable or even nancially

sel-sustaining without government assistance4

In one notorious example, each pound o sh sold in a

year by the Atlantic Marine Aquaculture Center, an

experimental acility in New Hampshire, cost about

$3,000 in US taxpayer dollars to produce5 Kona Blue

Water Farms, operating in Hawaii, is currently not on

the market but has previously supplied a product that

cost $17 a pound or a llet6

Further, all o these operations claim that waste rom

the submerged cages is causing little or no harm to

water quality, sea lie or ecosystems in general7 But

with a maximum o our operating at any one time in

the United States (and the closest o the two on sepa-

rate Hawaiian Islands), the arms represent a tiny

raction o the thousands o cages that the industry

and its government backers envision building along

US coasts in the upcoming years Looking at the

impacts o a ew arms alone does not reveal the ull

potential impact o opening the waters to an entire

industry o actory sh arming

All our o the operations discussed in this report have

made claims o sustainability,8 and the president o

one has strongly encouraged the National Organic

Standards Board (NOSB) to create organic standards

or net pen aquaculture9 But ocean actory armed

sh cannot credibly be considered organic due to themassive amount o water pollution they can cause

and the amount o non-organic eed made rom wild

sh (some that are already depleted) and non-organic

agricultural eed constituents like soy that they can

consume This large-scale industry runs counter to

the spirit o organics and the local and sustainable

ood movements

Introducon

Currently located in Hawaii, and previously located or operating in New Hampshire and

Puerto Rico, none o the US taxpayer-supported actory sh arming experiments have

succeeded Each has been plagued by an assortment o diiculties From shark encounters

and sh escapes to nancial troubles and lawsuits, these operations have not demonstrated

that they can sustainably meet soaring demand or seaood and ease pressure on over-

harvested wild sh populations


View of an oshore cage in the Gulf of Mexico near an oil rig.


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The government hopes that oshore sh arms can

help reduce the countrys $10 billion seaood trade

decit10 Some claim that the industry could help

US consumers eat more domestic seaood and ewer

tainted imports Others even boast that it could boost

worldwide ood supplies and global ood security

But existing and proposed operations in the United

States have ocused mainly on expensive boutique sh

destined or high-end restaurants and sushi bars, not

on varieties with widespread accessibility11 In act,

by eeding on smaller sh species, called orage sh,

high-end armed sh could actually reduce ood secu-

rity in communities across the world, many o which

depend on smaller sh like anchovy or sardines (see

box on page 10)

In sum, despite receiving more than $44 million in

US taxpayer unding, millions more dollars in pri-

vate investment12 and extensive political support romagencies within the ederal government, the open

ocean aquaculture industry has ailed to demonstrate

that it is environmentally sustainable or nancially or

technically viable on a commercial scale

Feedlots of the Sea: Factory FishFarms and the United States

Fish arming itsel is nothing new Four thousand

years ago, beore written records, the Chinese were

said to have begun arming carp

13

And sh ponds inHawaii, called loko i`a, may have been in operation

as early as 1200 AD These arms were constructed

along the shore with seawalls and grates to keep in

mature, typically herbivorous sh that were raised in

a complex ecosystem Hawaiian organizations are now

working to restore the arms to provide local ood or

their communities14

Many types o sh arming exist around the world and

in the United States to this day some sustainable,

some not But the type o aquaculture designed or theopen marine waters most closely resembles salmon

net pens, while replicating the large-scale livestock

production model on land that grows thousands o

animals in a conned environment Marine sh are

grown in cages or net pens that allow uneaten sh

eed, sh waste and any antibiotics used in the opera-

tion to fow through the cages directly into the ocean15

The rst experimental oshore cages used in the

United States were deployed o the coast o Washing-

ton state in 1989, and the rst commercial operation

opened in 200116 Both acilities were in state waters,

within three miles o the coast

In 1999, the National Oceanic and Atmospheric Ad-

ministration (NOAA) called or a quintupling o the

nations annual aquaculture production by the year2025 rom $900 million a year to $5 billion The

stated goal was to oset the seaood trade decit, cre-

ate more jobs and bring more high-quality seaood to

US customers17

This has spurred the governments seemingly re-

lentless push or the development o more oshore

aquaculture, no matter its human and environmen-

tal costs, specically pushing or the industry to be

allowed in ederal marine waters (typically between

three and 200 miles o the coast), where it is out o

reach o state environmental laws and ar rom other

coastal activities:

In early 2004, the Gul o Mexico Regional Fishery

Management Council, the body charged with ad-

vising the ederal government on how to manage

wild sheries in the Gul o Mexico, announced in-

tentions to create a plan or developing sh arms

in ederal waters o the Gul coast18 The council

developed this plan with input rom a recentlyappointed member with a background in oshore

aquaculture19

In 2005, pressed by NOAA, Congress introduced

legislation in the US Senate that would speci-

cally authorize aquaculture in ederal waters

It ailed to pass20 Both the Senate and the US

House o Representatives introduced similar bills

in 200721 Members o Congress introduced these

bills as a courtesy to the Bush administration, and

the measures were opposed by a wide array o shing, environmental and consumer groups None o

the bills passed out o committee22

Foiled by Congress, NOAA turned back to the

regional development o the industry and hired

consultants to help the Gul Council develop its

plan23


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Meanwhile, the Bush administration sought alter-

native ways to launch these arms in our oceans,

including a 2008 proposal to allow the ederal

agency that regulates oshore oil and gas develop-

ment, the Minerals Management Service under

the Department o Interior, to grant permits or

oshore aquaculture acilities attached to oil

and gas structures24 Ater stark opposition rom

organizations and individuals, the proposal was

dropped25

In 2009, ater years o debate and opposition, the

Gul o Mexico Regional Fishery Management

Council nalized its regional plan or oshore

sh arming It was passed on to the newly ap-

pointed Secretary o Commerce under the Obama

administration, but when the Secretary ailed to

veto it, it went into eect26 The agency said that

it would neither approve nor disapprove the plan,but that it would instead develop a national policy

on aquaculture by which to assess aquaculture27

The Gul o Mexico plan was challenged in court,

but the judge ruled that the lawsuit could not go

orward until the agency nalized rules to imple-

ment it28

In response to concerns about NOAAs aggressive

push or the development o a sh arming indus-

try, the National Sustainable Oshore Aquacul-

ture Act was introduced in 200929

The bill would

have authorized sh arming in ederal waters but

with some environmental standards It did not

pass out o committee30

In 2010, the Research in Aquaculture Opportunity

and Responsibility Act was introduced to put

the brakes on open ocean sh arming until

urther studies could be conducted The bill also

contained measures to supplement wild seaoodwith sustainable methods o sh arming31

The bill was unable to move orward beore the

legislative year ended32

In June 2011, NOAA announced its nal National

Aquaculture Policy The broad policy strongly

promotes actory sh arming, while remaining

vague on how the non-binding policy document

would protect the marine environment and sh-

ing communities The document states that NOAA

supports sustainable aquaculture developmentthat provides domestic jobs, products, and services

and that is in harmony with healthy, productive,

and resilient marine ecosystems, compatible with

other uses o the marine environment, and con-

sistent with [its] National Oceans Policy33

However, as demonstrated in this report, ocean

sh arming may be inherently unsustainable,

both environmentally and economically

The same day that it announced its National

Aquaculture Policy, NOAA announced that itwould issue rules to implement the Gul o Mexico

Fishery Management Councils very controversial

aquaculture plan34

Foreseeing that this was a possibility, in February

2011 US Representative Don Young rom Alaska

introduced a bill that would block the Department

o the Interior or Secretary o Commerce rom

allowing these operations in ederal waters with-

out specic Congressional approval Rep Young

introduced the bill out o concern that oshore sharming would damage Alaskan wild sheries35

As can be seen, our nation is currently at a cross-

roads NOAA can either heed the advice o congres-

sional members, shing and conservation groups and

others and halt development o the actory sh arm-

ing industry, or it can continue to pursue the same

tired oshore policies o the past to the detriment


View from inside a Hawaii oshore aquaculture cage with Moi

swimming near the surface


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o the ederal budget, the environment and coastal

communities

Why Factory Fish Farming Is NotEnvironmentally Sound or Sustainable

Polluon

Untreated sh waste, excess eed and dead sh empty

directly rom cages into the ocean This waste has been

shown to alter ragile marine habitats36 It is unknown

how the oceans, which have already been damaged by

industrial and agricultural pollution, and more recent-

ly by the catastrophic oil spill in the Gul o Mexico,will respond to yet another source o pollution

Little is known about the assimilative capacity o the

marine environment or these pollutants, concludes a

2007 report commissioned by the Woods Hole Oceano-

graphic Institution Pollution rom a greatly expand-

ed industry could have signicant eects locally and

regionally37 The most recent edition o the Congres-

sional Research Services report on open ocean aqua-

culture makes a similar point, noting that The pres-

ent lack o knowledge owing to limited experience,

lack o research unding, and ew studies ocusing

specically on open ocean aquaculture limits under-

standing o potential environmental concerns38

Although we do not know the ull extent o the dam-

age that can be caused by oshore aquaculture

acilities, what we do know does not present a pretty

picture A 2011 study accepted to the journalMarine

Environmental Researchanalyzed the impacts o ma-

rine aquaculture on a large scale Researchers ound

that aquaculture acilities were responsible or an

increase o nutrients (or pollutants) in a gul o the

Italian Coast and wrote that o-shore aquaculture

may aect the marine ecosystem well beyond the

local scale39

Antibiotics, pesticides and the other drugs or chemi-

cals used in these operations can also be damaging40

As with waste, little is known about how these drugs

might aect the oshore marine environment, because

the drugs that might be allowed on actory sh arms

have not been tested in open ocean marine arming

situations41 Evidence does indicate several seri-

ous concerns associated with the use o aquaculture

drugs

For example, Maine lobsters have been harmed by

pesticides used to control sea lice in salmon arms

along the Maine and Canadian coasts42 Further, anti-

biotics can kill benecial seafoor bacteria and spawn

antibiotic-resistant organisms One study ound that

the use o antimicrobials on sh arms can lead to

the creation o reservoirs o drug-resistant bacteria

According to the study, the genes responsible or this

resistance may ultimately aect the human popula-

tion through transer to human pathogens43

Disease

The drugs mentioned above are used to overcome the

increased risk o disease that exists when sh are

packed densely together in operations, are exposed to

pathogens in the marine environment and are subject

to a number o other environmental stressors44

Sea lice is perhaps the most notorious o aquaculture

inestations, thriving in the presence o new hosts,

such as with the expansion or addition o a sh armAccording to a 2011 article, exposure to salmon arms

with lice inestations may result in a sharp decline

in wild pink salmon populations in British Colum-

bias Broughton Archipelago45 In addition to sea lice,

Inectious Salmon Anemia (ISA) has been a major

problem or salmon arms The disease was reported

rst in Norway, and later spread to Canada, Scotland,


Photo of the dewatering table as sh are taken from the

oshore cage in Hawaii.


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the Faroe Islands and the United States46 Around

2007, the virus wreaked havoc on the salmon industry

in Chile devastating production and putting more

than 7,000 people out o work47

Disease has also been a problem or open ocean aqua-

culture acilities in the United States In Hawaii, or

example, Kona Blue Water Farms has encountered

problems with skin fukes, a parasite that does notharm human health but must be controlled due to its

negative impact on the sh48 The company also has

dealt with streptococcus inections, which it treated

with the antibiotic forenicol, a drug that has not

been tested specically or aquatic use in Hawaiis

unique marine environment49

Escaped Fish

Fish escapes are a major problem on open water sh

arms They can be caused by equipment ailure, staerror and adverse weather conditions Fish raised in

aquaculture acilities are bred to thrive in armed,

rather than wild, environments When escaped sh

interbreed with wild sh, their ospring may have

diminished survival skills, resulting in a genetically

less t wild sh population

The recovery o wild salmon populations has been

jeopardized by armed salmon escapes These es-

capees can interbreed with wild salmon and mayharmully alter the genetics o the wild stocks50 The

international list o escape disasters is extensive:

About 2 million armed salmon escape into the North

Atlantic each year, an amount equal to the number

o wild salmon in the region51 In six months o 2007

alone, more than 100,000 Atlantic salmon escaped

rom our acilities on the west coast o Scotland52 On

December 31, 2008, storms caused 700,000 salmon

and trout to escape rom various arms in Chile,

prompting the leader o the Chilean Senates Envi-ronmental Committee to proclaim the incidents an

Genecally Engineered Fish?

s f h nl pvil p-

ing opn ocan s farms av said tat t

will not us gncall modid s.59 If h

ind w h l h Noaa hp,

owvr, t industr will likl connusarcing for nw was to mass-produc s.

th ln fin ind, whih i h

n-h nl f h pn n ind-

tr, is ampng to do so troug gncall

modid s. A compan calld AquaBount

thnli h d n f n p

(a l-lik s) to crat a gncall ngi-

nd ln h ppdl w wi

as fast as rgular salmon. Tis ma sound lik

ln f d, b ge ln will

nd b fd l vl f fd d

from wild s, and t could av xtrml

ngav impacts on wild s populaons if

t scap.60

Wild salmon spawning at Hood Canal.


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environmental disaster53 In October 2009, 40,000

salmon escaped rom a arm in British Columbia54

One year later, 70,000 salmon escaped rom a arm

in Norway55

And not all instances o escape occur so ar rom

home In 2010, an article revealed that a research

project in the Bahamas, headed by University o Mi-

ami researchers, experienced a loss o approximately90 percent o its sh56 Kona Blue Water Farms in

Hawaii also has encountered ongoing instances o

escapes57

The negative impacts o escaped armed sh can be

even more serious i the sh are non-native or have

been genetically modied Caliornia, Maryland and

Washington have addressed this by banning arm-

ing o genetically modied sh in their state marine

waters58

Pressure on Wild Fish

Although one might assume that arming sh could

take the pressure o wild stocks, this is not actually

true Farmed sh oten are ed large amounts o eed

made rom shmeal and oil These ingredients are

derived almost exclusively rom small ocean sh such

as sardines, anchovies and herring, caught in mass

quantities in the Northeast Atlantic and o North and

South Americas Pacic coast61 The aquaculture in-

dustry is the largest user o shmeal and oil, and the

amount demanded continues to increase62 In 2006, an

estimated 372 million metric tons o shmeal were

consumed, representing 682 percent o worldwide

production and 084 million metric tons o sh oil, or

885 percent o production63 Many species o small

sh being converted to aquaculture eed are being

harvested beyond sustainable levels, not only leading

to their depletion but also jeopardizing the predatory

nsh that depend on them or survival, such as tuna,

salmon, grouper and snapper64

Impacts on Marine Animals

Fish to Pellets to Fish Again

Ar small wild s ar procssd into smal and oil, s fd procssors mix in vitamins, minrals,

cllulos, lipids and otr ingrdints. T mixtur is moldd into pllts, wic aquacultur opra-

tors latr fd to farmd s.

So ow man wild s dos it tak to grow on farmd s? T answr dpnds on t tp of sbing farmd. To dtrmin t s-in-s-out rao w must look at ow man pounds of fd a

farmd s is fd ovr its lifm, calculat ow muc of t fd is mad up of smal or oil and

tn look at t amount of wild s it took to crat tat mal or oil.

Tpicall, it taks four to v pounds of wild

s to produc on pound of dr smal or

0.22 pounds of oil, wic in turn constuts

wh nd 40 pn f in

ns fd.65 On avrag, marin ns gain

n pnd f v w pnd f fd ht at.66 Tus, for vr pound of farmd s

tat is producd for uman consumpon, it can

tak btwn two and six pounds of wild s

to produc. T following tabl lists convrsion

raos for svral spcis tat av bn grown

in or proposd for opn ocan s farms.

The Wild Fish to Farmed Fish Conversion

Fish

cbi67

rd p68

rd d69

Atlanc alibut70

Atlanc cod71

Pounds of wild sh used to

produce one pound of farmed sh

3.276.72

4.64

3.715.56

2.743.17

2.813.07


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Vegetarian Carnivores?

Rcognizing t irrconcilabl tnsion btwn dclining s stocks and aquaculturs projctd

dmand for smal, as wll as t industrs costs of spnding incrasing amounts of mon on

smal-ric fd, bot indpndnt and industr scinsts av trid to rplac t smal in fdwit otr protins, suc as sobans, canola, wat glutn and pas.72 s h l hv

focusd on t potnal of using alga as a fd ingrdint. 73

Scinsts ar facing diculs aciving dsirabl rsults fding land-basd vgtabl protins to

carnivorous s spcis tat could b raisd in osor cags. Ts farmd s rquir ig-qualit

protin. T rsults of a numbr of xprimnts av sown tat as t rao of land-basd fds to

smal and oil in fd incrass, s can b mor pron to rducd growt and vn dat, largl

du to t dicult of digsng ts altrnav protins.74 mn f h di hv fd n

rplacing smal in fd wit so.

T livstock industr alrad as bn cricizd for its rlianc on so in fd, so it is troubling tat

t aquacultur industr ma b rpang t sam mistaks. In t Unitd Stats, 93 prcnt of t

so producd is gncall modid,75 and worldwid 77 prcnt of so producon is from gncall

modid crops.76 Furtr, xtnsiv so producon as ld to soil rosion, dforstaon and rducon

of tropical biodivrsit in Lan Amrican countris.77 Kona Blu Watr Farms as conductd fd trials

wit so tat as not bn crd GMO-fr.78

In opn ocan aquacultur, unatn s fd ows dirctl into t surrounding watr. Altoug so

is also bing xtnsivl addd to fd, lil is known about t impacts to wild s psiolog and

rproducon from tis trrstrial plant ntring t marin nvironmnt in larg quans. 79

Bcaus alga ar ric in omga-3 fa acids and ar producd in a ss own marin nvironmnt,

t ar an obvious opon for an altrnav fd ingrdint and would appar to b dsirabl ovr

land-basd crops. On rsarc facilit in Balmor, Marland, wic osts a dmonstraon land-

basd rcirculang aquacultur facilit, as xprimntd wit fding alga to s.80 Potnal for

alga in aquacultur, owvr, ma b drownd out b lobbing and markng orts b powrful

so industr groups.81


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Open ocean aquaculture acilities could negatively

aect the marine animals that requent these sites,

including whales, seals, dolphins, turtles and sharks

Dolphins have requented the site at Kona Blue Water

Farms (see page 16), and the animals have appar-

ently begun to exhibit unnatural behaviors, which

may constitute conditioning I the animals have

become conditioned to respond to eeding opportuni-

ties at the site, they may experience reduced survival

skills82 An investigation o sharks and ocean-arming

cages in Hawaii has ound that sandbar sharks tend

to aggregate around the cages, and that tiger sharks

occasionally visited Although the study concluded

that the sharks were not aecting public saety at

beaches adjacent to the cages, the researchers noted

that the ecological eects o aggregating sharks are

unknown83

Why Factory Fish FarmingWont Fix Our Economy

Due to the challenges o oshore sh arming, devel-

opment o the industry could sacrice environmental

stewardship with little in return

Logiscal Dicules

As discussed in the ollowing proles o sh arms,

actory sh arming technology comes with a host o

economic and easibility challenges To date, no US

operation has shown that it can be used to consistent-ly raise healthy crops o sh and generate income

The our acilities proled in the originalFishy Farms

report (2007) have aced major setbacks The Atlan-

tic Marine Aquaculture Center has lost unding and

halted its open ocean sh arming demonstration The

owner o Snapperarm shut down operations in Puerto

Rico ater nding that it could not expand, which the

company blamed partly on US regulations Kona

Blue Water Farms, ailing to secure permission to

expand, was orced to cut sta and has sold its cages

in Hawaii to another company, although it continues

to be heavily involved in the operation It recently lost

two cages that it was testing or production in ederal

waters And nally, Hukilau Foods, once known as

Cates International, has led or bankruptcy

An article in an industry publication discussing the

diiculties aced by two operations in Hawaii ound

that Hawaii and the US government have been

generous with support nancial and otherwise or

both o these fedgling oshore operations So youve

got to ask yoursel: I oshore cant make it there, can

it make it anywhere in the United States?84

The international community also has noted the di-

culties o oshore aquaculture A report by the Foodand Agriculture Organization o the United Nations

noted that oshore aquaculture means higher risk o

sh escapes; higher transportation costs; diiculty in

approaching cages during severe weather conditions;

deeper [and more dangerous] operational routines or

divers; and more expensive cages, mooring systems

and nets85

No Jobs Here

In our current economy, job creation is a priority Yetoshore sh arms are unlikely to create many jobs In

2009, the two open ocean sh arms operating in Ha-

waii employed a total o 44 people At that time, both

companies were planning modications to their busi-

ness models Combined, these modications would

result in an approximate overall 173 percent increase

in production, rom 22 million pounds o sh to 6

million pounds, but would lose ve employees an 11

percent decrease in employment86 According to Kona

Blue Water Farms, the company needed to reduce thenumber o divers on sta in order to achieve prot-

ability87

Furthermore, it seems that the ew jobs that are o-

ered may not be sae Four ormer employees have

led lawsuits against Kona Blue Water Farms, alleg-

ing various ailures to provide a sae working environ-

ment and claiming various physical and emotional

repercussions88 A much greater loss occurred when a

diver was killed at Hukilau Farms in 201189

Not for Small-scale Entrepreneurs

As demonstrated in the proles below, setting up an

open ocean sh arm is a diicult and costly endeavor,

oten requiring government subsidies and private

investment Even with AOLs Steve Case as an owner

and inusing $45 million into the operation in 2007,90

Hukilau Farms in Hawaii led or bankruptcy in


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201091 Clearly, this industry will not be the domain o

small businesses with limited resources, and i it were

to restrict access to shing grounds or damage wild

sh populations, it could damage the small businesses

o many shermen

Many commercial shermen are suering rom

competition with cheap seaood imported rom other

countries, as well as by disasters such as HurricaneKatrina and the BP Deepwater Horizon explosion

They ear that the advent o actory sh arming in

the ocean will urther damage their livelihoods92

The state o Alaska banned open ocean aquaculture

in its state waters in 1990 as shermen experienced

sti competition rom cheaper, mass-produced

armed salmon grown in Canada and other coun-

tries93 The rise o salmon arms was dealing a hard

blow to shermen acing competition rom mass-

produced armed salmon

What It Would Take to Oset the Seafood

Decit Through Factory Fish Farms

Proponents o oshore aquaculture claim that it could

be used to oset the nearly $10 billion US seaood

trade decit, which is the amount o sh imported

compared to the amount exported94 According to

Food & Water Watch calculations, the United States

would need to produce an astounding 200 million sh

per year to close the decit, based on data rom openocean cobia arms This volume o production would

require an unrealistic amount o small wild sh to be

converted to sh eed and could lead to a rightening

volume o escapes and pollution95

To eed this many armed fsh would take ap-

proximately 1.2 million tons o fshmeal, or 41

percent o the estimated global production.96 In

act, this is a conservative estimate, and the require-

ments could actually be much higher i the operations

cannot achieve a eed-conversion ratio o 175 orlower, or i a eed consisting o more than 50 percent

sh-based protein is used

Fishmeal is already demanded elsewhere, and produc-

tion is currently decreasing,97 so it is unlikely that this

need or shmeal could be met

But i this limitation were somehow overcome, the

production o 200 million sh on oshore actory

arms could produce an astounding amount o envi-

ronmental damage This many fsh arms would

result in approximately the same amount o

nitrogen pollution as the untreated sewage

produced by a city that is nearly nine times the

population o Los Angeles.98

Further, as discussed earlier, escapement is a common

problem on sh arms For instance, over the course othree years in Washington state, the salmon industry

lost approximately 174 percent o its sh annually99

I the arms averaged this same rate o escapes, 348

million sh could be released into our oceans each

year This is roughly 17 times the amount o salmon

that escape rom arms in the Atlantic Ocean per year

an amount that some scientists ear is leading to

extinction o the wild species

Granted, those three years, which are the only three or

which we could obtain records, were considered to be

the product o catastrophic events In the unlikely sce-

narios that the new ocean sh arming industry consis-

tently avoided adverse weather conditions or technical

ailures and lost only the minimum amount o sh that

sh arms should expect, the industry could still be ex-

pected to release 1 to 2 million sh into the ocean every

single year, approximately the same number o salmon

Sacks of anchovy shmeal at Los Ferroles shmeal plant in Peru

PhOTO By JOSe CORT/NOAA, 1999.


15/28


that escape each year in the Atlantic100

I this is what it would look like to oset the seaood

trade decit through oshore sh arming, it is clear

that we must pursue other options, such as limiting

imports and producing sustainable, healthy, aord-

able seaood domestically or US consumers

Why Factory Fish FarmingWont Benet Consumers

Health Concerns

Perhaps the worst news or the oshore aquaculture

industry is that its operations may produce hazards to

human health A serious public health concern with

actory sh arms is the use o antibiotics Antibiotics,

which can be applied by way o medicated baths and

medicated ood,101 can enter the environment around

cages, where they may alter the composition o marine

bacteria102 Evidence suggests that these antibiotic-

resistant bacteria can, in turn, pass on their antibiotic

resistance genes to other bacteria, including human

and animal pathogens103

An increasing number o studies have documented

elevated levels o bacterial antibiotic resistance in

and around aquaculture sites For example, beore

1990 in the United Kingdom, the disease-causing

bacteriaAeromonas salmonicida were sensitive to

amoxicillin But ater the antibiotic was introduced

to sh arms, amoxicillin-resistant strains began to

appear104 Evidence o antibiotic resistant bacteria

also has been reported in the Mediterranean,where

a study ound a high percentage o resistant strains,

indicating a widespread antibiotic resistance in the

bacterial populations surrounding sh arms105

At a time when more and more consumers are mov-ing toward organic meat and milk in order to avoid

ood products rom animals that have been excessively

exposed to antibiotics,106 it is unclear why we would

develop a new, antibiotic-dependent ood industry

Additionally, there is cause or concern that actory

sh arms could lead to higher incidence o ciguatera

in both armed sh and surrounding wild sh popu-

lations Ciguatera poisoning is the largest cause o

nsh-related ood-borne illness in the United States,

and possibly globally It causes an array o gastroin-

testinal, cardiological and neurological symptoms

Poisoning is contracted by consumption o a sh

that has accumulated toxins living in microalgae107

A study examining the impacts o oshore rigs has

parallels to oshore sh arms, as they both provide

havens or toxins to accumulate The study ound that

use o these platorms or sheries enhancement

structures could have unintended consequences or

human health, and that these concerns also extend

to proposals or o-shore mariculture [marine aqua-

culture] operations108

In addition, there is the possibility that armed

sh could contain higher levels o certain contami-

nants such as PCBs, dioxins, fame retardants

and pesticides than wild sh Although this

has not been critically examined or all types o

aquacultured sh, one study o salmon ound that

13 out o 14 organocholorine contaminants are more

common in armed salmon than wild109

Anotherstudy has suggested that exposure to sh arms may

increase mercury contamination in nearby wild sh

Rocksh around a salmon arm in British Colom-

bia were ound to have increased levels o mercury

contamination ater being exposed to arm waste and

uneaten eed110

A Costly Product

Closeup of netpen in the waters oshore of Catalina Island.



16/28


Further, products produced on oshore arms are

likely to be out o reach or many US consumers The

most commonly consumed seaood items in the United

States are those that have become more widely and

cheaply available at grocery stores and inexpensive

restaurants: shrimp, canned tuna, salmon, pollock

(used in sh sandwiches and sh sticks), tilapia and

catsh111 The majority o seaood that US consumers

eat is imported, oten rom countries with less strin-

gent regulations on the chemicals and conditions that

seaood can be armed in, leading to concerns about

the quality and saety o these sh112

In order to benet the majority o US seaood con-

sumers, we need aordable seaood that is locally

available and locally produced However, open ocean

aquaculture operators are primarily interested in

growing premium products that can be sold or a

high value Kona Kampachi, the brand nameo Kona Blue Water Farms sh, have been sold or

$17 a llet113 The newest sh arm on the horizon

in Hawaii hopes to grow bigeye tuna, a popular

species or sushi114 Not only are these products

out o reach or many consumers, they are also

likely to be exported to Japan or countries in the

European Union, where high-quality seaood can

etch a higher price

Contribung to Global Food Insecurity?

As discussed earlier, it can take many pounds o small

wild sh in order to grow the carnivorous marine

nsh armed in open ocean aquaculture operations

These small sh, such as anchovies and sardines, may

not be in high demand or human consumption in the

United States, but they are a healthy ood source that

low-resource populations in many parts o the world

rely on or a component o their protein intake A 2009

article pointed out the dire consequences o malnutri-

tion around the globe, and the growing competition

or small pelagic sh or direct consumption, or or

reduction into shmeal115 I these small sh species

are shed out to create ood or large species o armed

sh, we may be trading many peoples access to a

nutrient-rich ood source or ewer peoples access to

more high-value, sushi-grade sh

Life in Factory Fish Farms

Since the originalFishy Farms was published,

the our arms proled have not ared well Atlantic

Marine Aquaculture Center has stopped production

Snapperarm, in Puerto Rico, has ceased production,

and its owner has moved production outside

o the United States Kona Blue Water Farms has

sold its grow-out operations and has not had sh

on the market in the past year And nally, Hukilau

Farms (ormerly known as Cates International) has

ceased production in the open waters in order to

ocus on its land-based hatchery Three new opera-

tions have proposed development in Hawaii but

have yet to make it to the operational stage Another

arm was proposed o the coast o Caliornia but

mysteriously stopped, while complaining about thepermitting process

Atlanc Marine Aquaculture Center

In 2006, Richard Langan, director o the University

o New Hampshires Open Ocean Aquaculture Project

told Congress that one o his centers goals was to

explore the economic viability o arming nsh116

In early 2007, Langan observed: At the University o

New Hampshire, eight years o research and technol-

ogy development have led us to conclude that a com-mercially viable and environmentally sound oshore

aquaculture industry is an option or the US117

Between 1997 and 2007, NOAA gave $19 million in

support to the Atlantic Marine Aquaculture Center

But since 2007, when AMAC and its various opera-

tional and technological setbacks were eatured in

the originalFishy Farms report, the center does not


17/28


appear to have ared well All o the programs prog-

ress reports on nsh aquaculture, updated regularly

rom 2000 onward, cease ater 2007118 A call placed to

AMACs ormer spokesperson, Dolores Leonard, in Au-

gust 2009, revealed that the project had lost some o

its unding in 2007, leading to a reduction in sta, and

research activities were thereore greatly curtailed119

In 2008, however, the center did receive $474,999 romNOAA to support the advancement and improve the

economic viability o oshore sh arming,120 as well

as $355,000 or research on oshore cage technology

to nd ways to optimize eeding processes, reduce sh

stress and promote sh growth121 These hety grants

did not result in new public inormation on the topics

they were intended to explore The centers website

has not even been updated since 2007 Although

Langan once said that his operation had made

tremendous strides toward bringing oshore aqua-culture closer to commercial reality,122 in the end, it

could not exist without research unding

Snapperfarm and Open Blue Sea Farms

In 2003, Brian OHanlon, a young entrepreneur, put

the rst trial cages o cobia o the coast o the Puerto

Rican island o Culebra123 The company, Snapper-

arm, aced some initial growing pains A 2010 paper

that lists OHanlon as the second author details open

ocean sh arm trials that occurred during a previousbut unspecied year in Puerto Rico124

Between 2007 and 2009, the company ramped up

operations, increasing production and experimenting

with new production technologies, such as the sel-

propelled Aquapod, an enormous geodesic cage that

can roam the ocean untethered125

By 2009, the company was growing 50 tons o cobia126

OHanlon had hoped to grow his acility up to 750 tons

1,500 percent its current size127

Ater strugglingthrough disease outbreaks in Puerto Rico and the

loss o his ngerling supplier in Miami, Florida, he

eventually gave up and moved to Panama, where he

launched Open Blue Seaarms in conjunction with his

investor, Aquacopia128 There he ound the permitting

system to be easier; as he explained to a reporter in

2010, Panama has a very small government Lower

labor costs and the ability to build larger acilities was

also another draw129

OHanlon has acquired another operation, Pristine

Oceans,130 and developed what he describes as the

largest oshore sh arm in the world, where he grows

cobia nine miles o the coast within a 2,500 acre

site131 Currently, the company appears to be the most

successul o the open ocean arms discussed in terms

o production and scale, but it is unclear whether

the arm could ever reach the same success in any

conditions o the US coastline, or while subjected to

suiciently environmentally and culturally protectiveregulations

The company compares its product to ree-range

bee, poultry and eggs,132 appearing to try to capture

interest rom environmentally conscious consumers

It claims that its approach lessens environmental im-

pact, providing a guilt ree, high quality, sae, healthy

and sustainably cultivated seaood133 Numbers on

the company eed-conversion ratios, waste dispersal

and incidence o escape are unavailable to the public,

however And considering that the arm hopes to net

$20 million in revenue annually using eight aquapods

and has a permit to arm 10,000 tons o sh on its

35 square-mile arm,134 it is hard to believe that this

enormous arm is the type o operation that consum-

ers o ree-range eggs have in mind when they seek

out seaood, clearly demonstrating that to be prot-

able actory sh arms must be large and capital

Sta prepare to send cobia juveniles through pipe to oshore

cage at Culebra Island, Puerto Rico



18/28


intensive

Kona Blue Water Farms

Located o the western coast o the Island o Hawaii,

Hawaii, Kona Blue Water Farms (KBWF) has possibly

the most storied history o the open ocean operations

When Food & Water Watch proled KBWF in 2007,

the company already had experienced its share o

tribulations, including killing a tiger shark in 2005

that requented the site;135 contamination o eed with

melamine rom China in 2007;136 and over 1,000 sh

escaped that same year when a diver let a zippered

entrance to the cage open137

Since then, the troubles have continued In 2009, a

Galapagos shark attack released hundreds o the

companys armed sh into the wild138 The year be-

ore, a public oicial raised concerns about the arms

potential or causing impacts to benthic (seafoor)organisms and its ailure to adequately address these

issues during the permitting process to recongure

the cage site139 Additionally, concerns were raised

about unnatural behaviors in dolphins that had begun

requenting the arm site The oicial was concerned

that interaction with the arm could be causing dol-

phin conditioning, which can be detrimental to the

animals survival due to altered eeding and social

behaviors140

In 2008, the company applied or a modication to its

permits in order to double the capacity o its opera-

tion141 However, the arm aced opposition rom the

community Two challenges were led against the ap-

plication, and KBWF withdrew its request142 In 2009,

the company submitted another application and re-

ceived approval or modiying its net pen designs This

modication didnt enable KBWF to scale up, but it did

allow it to experiment with new cage types143 KBWF

claimed in its application that changes were necessary

to achieve economic eiciency The changes would alsoallow the operation to minimize its need or divers,

shrinking its already small sta In its application, the

company wrote: We believe that the only way or Kona

Blue to achieve protability or our Kona operation is

by reducing our reliance on SCUBA divers144

Meanwhile, KBWF has expanded into Mexico with an

operation in the Sea o Cortez145 Presumably, KBWF,

like Snapperarm, was looking to avoid the regulatory

hurdles it aced in the United States Following these

various attempts to overcome nancial diiculty and

achieve protability, Kona Blue sold its operation and

received approval on January 8, 2010 to transer it to

Keahole Point Fish LLC, a company registered just

months prior in Delaware146

In November 2009, KBWF said that it would tem-

porarily halt production in Hawaii as it continued

to develop a hatchery in Hawaii and move its opera-

tions in Mexico Reportedly, sh would be back on themarket by the end o 2010147 However, as o June 2011

Kona Kampachi was still not on the market, and

any availability o the product appears to have been

ragmented since November 2009148

In January 2011, the company was charged or coral

damage ater it had parked an experimental pen

that it was no longer using in the Kawaihae Small

Boat Harbor on the western side o the Island o

Hawaii Twenty-eight instances o coral damage were

cited The $13,500 ne was cut in hal and eventu-

ally waived, allowing the company to use the monies

instead to support coral conservation eorts149

In November 2010, KBWF applied to the National

Marine Fisheries Service or a Special Coral Ree

Ecosystem Fishing Permit in order to conduct an

open ocean aquaculture operation in ederal waters,

A diver swimming toward the oshore cage in Hawaii with

equipment.



19/28


where it will attempt to raise sh in a cage towed by

a boat largely foating with natural eddies150 In June

2011, KBWF received the permit, the rst o its kind,

setting a dangerous precedent or uture operations

In March 2011, prior to the issuance o its permit, the

company took empty cages out into the ocean or test-

ing They quickly lost one and had to sink the other151

The permit has been legally challenged by both Food

& Water Watch and KAHEA: The Hawaiian-Environ-

mental Alliance152

Hukilau Farms, Formerly Known

as Cates Internaonal

Cates International, the rst commercial sh arm

in the United States, rst secured its lease in 2001153

The company took over operations rom a demonstra-

tion acility led by University o Hawaii researcher

Charles Helsley Like the other acilities discussed

in this report, Cates International has aced a di-

cult path in its quest or viability One year into the

experiment, Helsley wrote in a report that 30 percent

o the sh had died rom inections, lack o oxygen and

other problems when they were transerred into sh

cages He wrote that the experiment was operating at

sub-economic levels, and yet he optimistically wrote

that moi, the species being cultured, could be raised

in an economically viable way154

From site sampling between 2001 and 2004, re-

searchers reported that the arm had grossly pol-

luted the seafoor and severely depressed some

types o sea lie Despite the open ocean location

and alongshore currents, the eects o sh eed and

waste on the [seafoor] community were evident

The ecosystem had been drastically changed, they

ound, and the eects had spread beyond the areabeneath the cages155

That same year, the company entered into agreement

with Visionary LLC, a company owned by Steve Case

o AOL-Time Warner, to orm a company called Grove

Farm Fish & Poi, LLC In 2007, Cates Internationals

lease was transerred to this company, and the arm

was renamed Hukilau Foods156 The company hoped

that this merger would enable it to expand its opera-

tion and build a large land-based hatchery

In 2008, a concerned government oicial commented

that studies conducted at the arm had ound a large

cyanobacterial mat growing beneath cages, which

raises concern because the sandy bottom underneath

cage sites is a home or sea grasses that provide a

meadow-like grazing habitat or a wide variety o ma-

rine organisms157 Despite these ndings, in 2009 the

company was granted approval to expand operation

rom 12 million pounds a year to 5 million 158

However, the arm has not actually been able to scale

up to this size In June 2010, Randy Cates, ounder o

Cates International, sued Visionary LLC or what he

alleged was mismanagement o the company159 Then,

in November o that same year, according to an article

in theHonolulu Star-Advertiser, the company led or

bankruptcy with only $5 million in assets compared to

$86 million in debts160 The company estimated in JulyView of seacage with anchor being deployed o Hawaii



20/28


2011 that it would take two-and-a-hal years to raise

the $98 million that would return it to protability

Cates has cited mismanagement and low survival

rates o the sh as contributors to the bankruptcy Ac-

cording to Cates, the survival rate or its sh dropped

by more than 50 percent since 2009 The company has

not had any sh on the market since February 2011,

and with none currently being raised in its oshore

cages, the sh will not likely be back in distribution

until next year161 The cages themselves are currently

out o compliance with state regulations, since the

company ailed to obtain approval rom state agencies

beore deploying new equipment162

Hukilau has been nanced in part by American tax-

payers through a $38 million secured loan that the

company received rom the National Marine Fisheries

Service and another, unsecured loan o $64,450 rom

the US Department o Commerce163

Other Farms

Over the past several years, additional arms have

attempted to set up shop in marine waters around

the country Hubbs-SeaWorld Research Institute in

San Diego, under the leadership o Don Kent, de-

veloped a plan to grow 1,000 metric tons o striped

sea bass ve miles o the coast o San Diego, and

to eventually scale up to produce 3,000 metric tonsannually164 The project was pitched as a demonstra-

tion project, a somewhat dubious claim considering

that it was planning to produce more sh than any

commercial arm operating in US waters is permit-

ted to165 In 2009, Don Kent submitted a letter asking

that his permit applications or the operation be put

on hold Ater complaining about diiculties securing

approval, he indicated that he would wait until the

Obama administrations national aquaculture policy

was nalized166

In 2009, a company called Indigo Seaood discussed

opening a acility in an area hal a mile o the west-

ern coast o the Island o Hawaii,167 and another

company in Hawaii, Maui Fresh Fish, LLC, is moving

orward in the permitting process to establish a arm

o o the Island o Lanai 168

Most troubling, however, are developments with a

company called Hawaii Oceanic Technology, Inc In Oc-

tober 2010, the company received a 35-year lease romthe Hawaiian Board o Land and Natural Resources

or a 247-acre ocean arm site 26 nautical miles o the

western coast o the Island o Hawaii169 The company

plans to arm 12 million pounds o either bigeye or yel-

lown tuna in its enormous, patent-pending Oceans-

pheres170 The company boasts that its operations

are environmentally sustainable and will represent a

more eicient source o ood than land agriculture or

wild sh171 And yet it also says itsel that it takes up

to 42 pounds o wild sh to create 10 pounds o marine

armed sh172 Wasting 32 pounds o wild sh that

could be consumed by other marine sh, animals or

people hardly seems like an eicient source o produc-

tion, especially considering the high cost that is gener-

ally associated with sushi-grade resh tuna

The company plans to deploy its rst ull-scale oceans-

phere in 2012173

Moi inside an oshore cage in Hawaii.



21/28


Conclusions

As the United States emerges rom recession, we

must continue to prioritize the development o local

economies, create steady job opportunities and spend

ederal money wisely Meanwhile, eorts to support

local businesses and buy local, while promoting

environmentally sustainable, community-supportive

businesses, have grown The local oods movement has

gained support rom diverse sources as people have

recognized potential economic and environmental

benets In light o these trends, the ederal govern-

ments support o oshore actory sh arming seems

woeully wasteul and out o place

Ater over a decade o exorbitant nancial support

rom the ederal government and labor wasted by gov-

ernment oicials and university scientists, the open

ocean sh arming industry still has not provided any

clear indication that it can create a signicant num-

ber o jobs or an aordable source o quality sh prod-

ucts The fedgling industry is not yet large enough to

draw conclusions about the environmental ramica-tions o a ull-scale industry, but evidence indicates

that oshore sh arms, especially at the scale imag-

ined by NOAA, will threaten the marine environment

in a variety o ways

I we want to achieve the goals o strengthening the

economy, making more sae domestic seaood avail-

able, protecting our beautiul marine environments

and ostering a diverse array o businesses that rely

on it, we must stop sinking money into this troubled

industry Instead, we must ocus on managing our

wild sh resources responsibly, developing alternative

methods o sustainable sh arming, reducing seaood

exports and limiting imports by turning away more

contaminated seaood at the border

Recommendaons to Policymakers

Support bills to prohibit ederal agencies rom

authorizing commercial nsh aquaculture opera-

tions in ederal waters

Support eorts to increase seaood inspections, so

that US consumers will not be exposed to unsae,

contaminated seaood imports

Support research and eorts to sustainably man-

age wild sh stocks, and explore other methods

o aquaculture, such as land-based recirculating

systems

Recommendaons to Consumers

Let your Senators and Representatives know thatyou are concerned about oshore actory sh arm-

ing and its impacts

Make sae, sustainable choices about seaood

Show restaurants, vendors and others that you

care about the type o seaood you eat For tips,

see Food & Water Watchs Smart Seafood Guide.


22/28


1 T hawaii Opn Ocan Aquacultur Dmonstraon Projct, wic b-

cam Cats Intrnaonal and tn hukilau Foods, was startd in 1998.

S hlsl, Carls. hawaii Opn Ocan Aquacultur Dmonstraon

Projct. UJNR Tcnical Rport No. 28, 1999 at 15-22.

2 Calculaons conductd basd on t following sourcs: Bn, Danil

D. t al. Growt rats of cobia (Raccntron canadum) culturd in

opn ocan submrgd cags in t Caribban.Aquaculture, vol. 302,April 2010 at 195-201; Bianci, Alssandra. T nxt safood fronr:

T ocan. CNNMon.com, April 28, 2009; Amos, Kvin and Andrw

Applb Atlanc Salmon in Wasington Stat: A s managmnt

prspcv. Wasington Dpartmnt of Fis and Wildlif, Sptmbr

1999; Frazr, Nil. Opn ocan aquacultur can b dstrucv. Ho-

nolulu Star Adverser. Novmbr 28, 2010. Mtodolog on l wit

Food & Watr Watc.

3 Tis numbr includs grants tat t Naonal Ocanic and Atmospr-

ic Administraon and Naonal Marin Fisris Srvic av givn for

osor/opn ocan aquacultur, and mon tv spnt in support

for t Gulf of Mxico aquacultur sr managmnt plan. Informa-

on is on l wit Food & Watr Watc.

4 Fdral funding rcivd b t hawaii Osor Aquacultur Dmon-

straon Projct, wic bcam Cats Intrnaonal and tn hukilauFoods; b Kona Blu Watr Farms; b t Atlanc Marin Aquacultur

Cntr for osor aquacultur; and Snapprfarm and t Univrsit

of Miami. Informaon is on l wit Food & Watr Watc.

5 Btwn 1997 and 2007, Atlanc Marin Aquacultur Cntr (AMAC)

rcivd $19.5 million in nancial support from t Naonal Ocanic

and Atmospric Administraon, according to Univrsit of Nw

Hphi bd dn bind b Fd & W Wh

troug a public rcords rqust. yt during tis m, AMAC sold onl

$23,710 wort of s and no sals wr mad unl 2005. Docu-

mnts sow tat it mad 12 sals of cod to v Nortastrn compa-

nis, totaling 6,500 pounds. Tis mans ac pound of s sold cost

about $3,000 in U.S. taxpar dollars to produc.

6 Kona Blu Watr Farms. Ordr Now. www.Kona-blu.com/ordr.pp.

Jul 22, 2011.

7 Statmnt of Ricard Langan (April 6, 2006); Rivra, Jos A. Snappr-

farm exprinc in Purto Rico wit Comparison. Worksop for Dvl-

opmnt of Sustainabl Praccs for Marin Cag Cultur Opraons

in t U.S. Caribban. NOAA Aquacultur Program, el San Juan hotl

and Casino. Novmbr 2-3, 2010; Kona Blu Watr Farms. Powrpoint

Prsntaon originall dlivrd to: Kawaia harbor Communit

Managmnt Commi. Octobr 14, 2007; Davidson, Osa Gra.

T farmr gos to sa. Popular Science, Marc 2006.

8 Ricardson, Wit. Fising for a futur: A Sarsmont ntrprnurs

aquacultur innovaon is wlcomd in forign watrs wil t U.S.

plas catc up. Mainbiz, Jan 25, 2010; Atlanc Marin Aquacultur

Cntr. [Prss Rlas]. Sn. Judd Grgg Clbrats First Commr-

cial Osor Aquacultur Farm. Octobr 11, 2007; Kona Blu WatrFarms. [Prss Rlas]. Kona Blus Kona Kampaci Back in t

Markt Jul 18. Ma 20, 2010; Aquacultur Planning & Advocac LLC.

Dra environmntal Assssmnt for Proposd expansion of hukilau

Foods Osor Fis Farm, Mamala Ba, Oau, hawaii. Prpard for:

Oc of Consrvaon and Coastal Lands, hawaii Dpartmnt of Land

and Natural Rsourcs, Marc 5, 2009 at 26, 42, and 48.

9 Clut, Mitcll. NOSB dbats organic safood. Natural Foods Mer-

chandiser, vol. 28, no. 5, April 24, 2008.

10 Costa-Pirc, Barr. NOAA Aquacultur Listning Sssion exprt Pr-

sntaon. April 14, 2010.

11 As mnond, Kona Kampaci as sold for $17 pr pound. hawaii

Ocanic Tcnolog intnds to rais big and/or llown tuna, a

s tat is popular for susi rolls and sasimi. See McAvo, Audr.

hawaii rgulators approv honolulu compans plan for rst US opn

ocan tuna farm.Associated Press, Octobr 26, 2009.

12 For instanc, Stv Cas of AOL as invstd $4.5 million troug is

Viin LLc in h pn gv Fih & Pi, whih wn HkilFoods. See hao, San. Nt Gains for hawaii. Honolulu Adverser,

April 15, 2007.

13 Rabanal, hrminio R. histor of Aquacultur. ASeAN/UNDeP/FAO R-

gional Small-Scal Coastal Fisris Dvlopmnt Projct, April 1988.

14 Bond, Stanl and Ricard Gmirkin. Rstoring a Part of hawaiis Past:

Kaloko Fis Pond Rstoraon. Ecological Restoraon, vol. 21, no.

4, Dcmbr 2003 at 284.; U.S. environmntal Protcon Agnc.

Projct Loko I`a: Rstoring hawaiis Tradional Fisponds. Pacic

Soutwst Rgion 9.

15 Upton, harold F. and eugn h. Buck. CRS Rport for Congrss: Opn

Ocan Aquacultur. Congrssional Rsarc Srvic, August 9, 2010

at 1-2.; Cabllo, Fllp C. hav us of proplacc anbiocs in

aquacultur: a growing problm for uman and animal alt and for

t nvironmnt. Environmental Microbiology, vol. 8, iss. 7 at 1138.

16 Borga, Racl and eugn h. Buck. CRS Rport for Congrss: Opn

Ocan Aquacultur. Congrssional Rsarc Srvic. Dcmbr 13,

2004 at 16 and 17; Davidson (Marc 2006).

17 U.S. Dpartmnt of Commrc. Aquacultur Polic. 1999.

18 Gulf of Mxico Fisr Managmnt Council. [Prss Rlas]. Scoping

mngs scduld on potnal amndmnt for liming accss in t

commrcial rf s and king mackrl sris and on a potnal

gnric amndmnt for managmnt of osor marin aquacultur.

Naonal Ocanic and Atmospric Administraon. Januar 26, 2004.

19 Gulf of Mxico Fisr Managmnt Council. [Prss Rlas]. Com-

mrc Scrtar evans Announcs 2002 Ocan Fisr Council Ap-

pointmnts. Naonal Ocanic and Atmospric Administraon, Jun

23, 2002.

20 Gulf of Mxico Fisr Managmnt Council. Fisr Manag-

mnt Plan for Rgulang Osor Marin Aquacultur in t Gulf of

Mxico. Januar 2009 at 18-19.

21 Upton and Buck at 16.

22 Ibid.

23 Documnts rgarding pamnts mad to consultants to undrtak a

socioconomic analsis of osor aquacultur in fdral watrs in t

Gulf of Mxico and to rvis t altrnavs to b prsntd to t

Council for t prmit condions tat would b rquird of aquacul-

tur opraons in fdral watrs wr obtaind via FOIA rqust and

ar on l at Food & Watr Watc.


25 74 Fd. Rg. 19638-19871 (April 29, 2009).

26 Upton and Buck at summar.

27 Balsigr P.D, Jams W. Lr to Dr. Robrt Sipp, Cairman, Gulf of

Mxico Fisr Managmnt Council. Naonal Ocanic and Atmo-

spric Administraon, Unitd Stats Dpartmnt of Commrc,

Sptmbr 3, 2009 at 2.

28 Food & Watr Watc. [Prss Rlas]. Fdral Court Ruls Lawsuit to

Stop First U.S. Fis Farm Program Cannot Procd Unl Rgulaons ar

Dvlopd. August 12, 2010.

Endnotes


23/28


29 Oc of Rprsntav Capps. [Prss Rlas] Capps Introducs

Comprnsiv, Sustainabl Osor Aquacultur Lgislaon. Dcm-

br 18, 2009.


31 Oc of Snator David Vir. [Prss Rlas]. Vir Introducs Aqua-

cultur Bill to Provid Rlif to Struggling Gulf Fisris. Ma 25, 2010.

32 T Librar of Congrss ThOMAS. Bill Summar and Status 111t

Congrss: S. 3417. Availabl at p://tomas.loc.gov. Accssd Jul

24, 2011.

33 Naonal Ocanic and Atmospric Administraon. Marin Aquacul-tur Polic. Jun 2011 at 1.

34 Naonal Ocanic and Atmospric Administraon. [Prss Rlas].

Commrc and NOAA rlas naonal aquacultur policis to

incras domsc safood producon, crat sustainabl jobs, and

rstor marin abitats. Jun 9, 2011.

35 Oc of Rp. Don young. [Prss Rlas]. Rp. young introducs

aquacultur lgislaon, Fbruar 9, 2011.

36 Prz, Marta, t al. Psiological rsponss of t sagrass Posidonia

oceanica as indicators of s farm impact. Marine Polluon Bullen,

vol. 56, iss. 5, 2008 at 869-879; holmr, Mariann, t al. ects of s

f w n Posidonia oceanica madows: sntsis and provision of

monitoring and managmnt tools. Marine Polluon Bullen, vol. 56,

iss. 9, 2008 at 1618-1629.37 Marin Aquacultur Task Forc. Sustainabl Marin Aquacultur:

Fullling t Promis; Managing t Risks. Januar 2007 at 69.


39 Sar, G. t al. Impacts of marin aquacultur at larg spaal scals:

vidn f n nd p hn ldin nd phplnkn bi-

mass. Marine Environmental Research, Fbruar 24, 2011.

40 Marin Aquacultur Task Forc, at 74-76.

41 Tis is bcaus tr ar no drugs spcicall tstd and approvd for

us on s in opn watr cags. Currntl, if opn ocan farms nd

to us drugs, t must gt approval to us tm in an xtra-labl

mannr (bond wat t ar spcicall approvd for) or parcipat

in an xprimntal trial. Tis mans tat t cological rprcussions

of using ts drugs in opn ocan farms as not bn full xamind.For mor informaon, s Food & Watr Watc. harmful Aquacultur

Cmicals Slip Troug Rgulator Cracks. Wasington, DC, Novmbr

2009.

42 Tror, Bill. Parasits, Pscids, Sick Salmon Dad Lobstrs. Ban-

gor Daily News, Main, Januar 10, 2011.

43 hur, Ol. e. et al. human halt Consquncs of Us of Anmicro-

bial Agnts in Aquacultur, Clinical Infecous Diseases, vol. 49, no. 8,

2009 at 1248-53.

44 Gardnr, Julia P.D and David L. Ptrson. Making Sns of t

Salmon Aquacultur Dbat: Analsis of issus rlatd to ntcag

salmon farming and wild salmon in Bris Columbia. Pacic Fisris

Rsourc Consrvaon Council. Januar 2003 at 4.; Cabllo, at 1138,

op. cit.

45 Krosk, Marn and Ra hilborn. Sa lic (Lepeophtheirus salmo-

nis) infstaons and t producvit of pink salmon (Oncorncus

gorbusca) in t Brougton Arciplago, Bris Columbia, Canada.

Canadian Journal of Fisheries and Aquac Sciences, vol. 68, 2001 at 17-

29.

46 Dvold, M. t al. Strain variaon, basd on t magglunin gn, in

Norwgian ISA virus isolats collctd from 1987 to 2001: indicaons

of rcombinaon. Disease of Aquac organisms, vol. 47, Novmbr 8,

2011 at 119-128.

47 Anotr 500 Jobs Lost to Cils ISA Crisis. T Fis Sit, Marc 6,

2009.

48 Kona Blu Watr Farms, LLC. Final Supplmntal environmntal As-

sssmnt for a Modicaon to Nt Pn Dsigns witin t exisng Pro-

ducon Capacit and Farm Las Ara for Kona Blus Osor Opn

Ocan Fis Farm o Unualoa Point, Kona, hawaii. April 21, 2009 at

39.

49 Pratr, Donald and Jnnifr Matsczak. [e-mail]. Novmbr 2, 2007. On

l wit Food & Watr Watc.

50 Marin Aquacultur Task Forc, at 3.

51 Stud to invsgat wild/farmd salmon brding implicaons. T

Fis Sit, August 15, 2007.

52 Rid, Mlani. Grat salmon scap could turn wild s into couc

potatos. The Times (Unitd Kingdom), Sptmbr 18, 2007.

53 Wi, Bnjamin. Tousands of salmon and trout scap in soutrn

Cil. The Patagonia Times (Cil), Januar 19, 2009.

54 Lavoi, Judit. 40,000 s scap farm. The Times Colonist, cnd,

Octobr 24, 2009.

55 Grindim, Joar. Costl salmon scap. IntraFish Media, ob 15,

2010.

56 Bn t al. at 196.

57 As indicatd b a supplmntal nvironmntal assssmnt. Kona BluWatr Farms, LLC (April 21, 2009) at 27, 42 and 43.

58 Cal. Fis & Gam Cod 15007 (2003); Md. Natural Rsourcs Cod

Ann. 4-11A-02 (2003); Was. Admin. Cod 220-76-100 (2003).

59 Ttratc, Inc. Final environmntal Impact Statmnt for t Ai

Aquacultur Projct, Koala Coast, hawaii. Prpard for hawaii Oc-

anic Tcnolog, Inc. Ma 25, 2009 at xvi; Kona Blu Watr Farms, LLC

(April 21, 2009) at 90.

60 For mor informaon s Food & Watr Watc. Ge Salmon Will Not

Fd t World, Novmbr 2010.

61 Food and Agricultur Organizaon of t Unitd Naons. 5. Us of

wild s in aquacultur. FAO Technical Guidelines for Responsible

Fisheries. no. 5, suppl. 5. Rom, FAO 2011 at 13.


63 Tacon, Albrt G.J. and Marc Man. Global ovrviw on t us of s

mal and s oil in industriall compoundd aquafds: Trnds and

futur prospcts.Aquaculture, vol. 285, Dcmbr 2008 at 149.


65 Tacon and Man (Dcmbr 2008) at 148, Convrtd from kilograms

to pounds.

66 Ibid.

67 Lungr, Angla N. t al. T cts of organic protin supplmnta-

on upon growt, fd convrsion and txtur qualit paramtrs of

juvnil cobia (Rachycentron canadum).Aquaculture, vol. 264, April

2007, at 342-352, 2007; Cou, R.L. t al. at 325-333.

68 Kalinowski, C.T. t al. ect of dirnt carotnoid sourcs and tir

di lvl n d p (Pagrus Pagrus) growt and skin color.

Aquaculture, vol. 244, Fbruar 2005 at 223-231.

69 Moon, ha young L and Gaitlin, Dlbrt M. III. ects of animal

protins on growt and bod composion of t rd drum (Sciaenops

ocellatus).Aquaculture, vol. 120, Marc 1994 at 327340; Rig,

Robrt C. and ellis, Simon C. ects of ditar soban and s-

protin raos on growt and bod composion of rd drum (Scianops

ocllatus) fd isonitrognous dits. Aquacultur vol. 104, Jun 1992 at

279-292.


24/28


70 hlland, Stl J. and Grisdal-hlland, Barbara. Rplacmnt of

s mal wit wat glutn in dits for Atlanc alibut (Hippoglos-

sus hippoglossus): ect on wol-bod amino acid concntraons.

Aquaculture, vol. 261, Dcmbr 2006 at 1363-1370; Brg, G. M. t

al. So protin concntrat in dits for Atlanc alibut (Hippoglossus

hippoglossus).Aquaculture, vol. 178, Jul 1999 at 139-148.

71 Rfs, Stl. t al. Fd intak, growt, and ulisaon of macronutri-

nts and amino acids b 1- and 2-ar old Atlanc cod (Gadus morhua)

fd standard or bioprocssd soban mal.Aquaculture, vol. 255,

Ma 2006 at 279-29; Topp, Jogir t al. Inclusion of s bon and

crab b-products in dits for Atlanc cod, Gadus morhua. Aquaculture,vol. 253, Marc 2006 at 636-645.

72 Tibbs, S.M. t al. Apparnt Protin and enrg Digsbilit of Com-

mon and Altrnav Fd Ingrdints b Atlanc Cod, Gadus morhua

(Linnaus, 1758). Aquaculture, vol. 261, Dcmbr 2006 at 1314-1327;

Lungr, A.N. t al. at 342-352; Cou, R.L. t al. Substung Fis Mal

wit Soban Mal in Dits of Juvnil Cobia Rachycentron canadum.

Aquaculture, vol. 229, Januar 2004 at 325-333; Albrktsn, Sissl t

al. Growt, Fd ecinc, Digsbilit and Nutrint Distribuon in

Atlanc Cod (Gadus morhua) Fd Two Dirnt Fis Mal Qualis at

Tr Ditar Lvls of Vgtabl Protin Sourcs.Aquaculture, vol.

261, Novmbr 2006 at 626-640; Rfs, Stl t al. at 279-291.

73 harl, Mo t al. Advancd DhA, ePA and ArA nricmnt matrials

for marin aquacultur using singl cll trotrops.Aquaculture, vl

213. Octobr 2002 at 347-367.

74 Tibbs t al. at 1314-1327; Lungr t al. at 342-352; Cou t al. at

325-333; Albrktsn t al. at 626-640; Rfs t al. at 279-291.

75 Adopon of Gncall enginrd Crops in t U.S.: Soban Varit-

is. Data St, economic Rsarc Srvic, Unitd Stats Dpartmnt

of Agricultur.

76 GMO Compass. Gncall Modid Plants: Global Culvaon Ara,

Soban Availabl at p://www.gmo-compass.org/ng/agri_bio-

tcnolog/gmo_planng/342.gncall_modid_soban_global_

ara_undr_culvaon.tml. Accssd Januar 20, 2011.

77 T Dutc So Coalion. Stratgis for rducing t ngav impacts

of so producon. Factst 1. 2010.

78 Prsonal Communicaon. Kll Colman, Vic Prsidnt of Markng,

Kona Blu Watr Farms, Jul 28, 2009.

79 Frnandz-Jovr, Damian t al. Wast fd from coastal s farms: A

tropic subsid wit composional sid-cts of wild gadoids. Estua-

rine, Coastal and Shelf Science, vol. 91, iss. 4. Marc 2011.

80 Agnda for t Mini-smposium on Algal Biotcnolog and Bionrg.

T Cntr of Marin Biotcnolog, Univrsit of Marland Biotc-

nolog Instut, Dcmbr 12, 2008.

81 Soban farmrs incras support for aquacultur. The Times and

Democrat(Sout Carolina), Jun 9, 2011; Amrican Soban Associa-

on. CeO Rport to t Board & Stats. Marc 2010.

82 Mmorandum. Dan Polmus, Administrator, Division of Aquac

Rsourcs and J Waltrs, Co-managr of hawaiì humpback Wal

Naonal Marin Sanctuar to Sam Lmmo, Oc of Coastal and Con-srvaon Lands, Dpartmnt of Land and Natural Rsourcs. Subjct:

Kona Blu Watr Farms opn ocan s farm, concrns rgarding

dolpin intracons. Fbruar 20, 2008.

83 Papastamaou, yannis P. t al. Sit dlit and movmnt of sarks

associatd wit ocan-farming cags in hawaii. Marine and Freshwa-

ter Research, vol. 61, no. 12, Dcmbr 2010 at 1366-1375.

84 Fiorillo, Jon. Is U.S. osor farming DOA? IntraFish, spb 15,

2010.

85 Cardia, Fracsco and Alssandro Lavatlli. A Rviw of Cag Aqua-

cultur: Mditrranan Sa. In halwart, Maias, Doris Sota and J.

Ricard Artur (eds.). Fisris Tcnical Papr, Food and Agricultur

Organizaon of t Unitd Naons. Cag Cultur: Rgional Rviws

and Global Ovrviw. (498) 2007 at 186.

86 Calculaon prformd b Food & Watr Watc. Combind total pro-

ducon and jobs projctd b companis in tir Final environmntal

Assssmnts ar approvd modicaons from Aquacultur Planning

& Advocac LLC. Final environmntal Assssmnt Proposd expan-

sion of hukilau Foods Osor Fis Farm, Mamala Ba, Oau, hawaiì.

Prpard for t Oc of Consrvaon and Coastal Lands, hawaiì

Dpartmnt of Land and Natural Rsourcs b Jul 24, 2009 at 8 and

22 and Kona Blu Watr Farms, LLC (April 21, 2009) at 22-23.87 Kona Blu Watr Farms, LLC (April 21, 2009) at 10.

88 Michael Larson vs. Kona Blue Water Farms LLC., Unitd Stats District

Court for t District of hawaiì. CV 08 00428. Fild Sptmbr 23,

2008 (voluntaril dismissd, Dcmbr 2008); Labossir v. Kona

Blu Watr Farms, LLC., Unitd Stats District Court for t District

of hawaiì No CV 07 00540 BMK Fild Octobr 29, 2007 (sld and

dismissd Marc 2009); Karlsson v. Kona Blue Water Farms, unid

Stats District Court for t District of hawaiì No CV07 00242BMK

Fild Ma 10, 2007 (dismissd Dcmbr 2008); Wagner v Kona Blue

Water Farms LLC. Unitd Stats District Court for t District of hawaiì

No CVO9 00600 Fild Dcmbr 16, 2009.

89 Sikina, Rob. honolulu rgtr did in diving accidnt. Honolulu

Star Adverser. Ma 24, 2011.

90 hao (April 15, 2007).

91

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