OFFSHORE AQUACULTURE

Food fish aquaculture in the United States is currently limited to inland closed-system facilities and a few open water operations located in coastal waters under State jurisdiction. The National Offshore Aquaculture Act of 2007, H.R. 2010, crafted by the National Oceanic and Atmospheric Administration (NOAA) and endorsed by President Bush seeks to expedite expansion of aquaculture into federal waters from three to 200 nautical miles off the coast in order to capitalize on the burgeoning market in farmed seafood. However, requests from fishing and environmental groups to conduct a thorough assessment of the economic, social and ecological impacts of industrial-scale open ocean aquaculture and to incorporate adequate safeguards into the bill went unheeded. Touted as a solution to supplement fully exploited fish stocks, a poorly designed and regulated offshore aquaculture program can increase pressure on wild fish and devastate the marine ecosystems on which they depend through escapements of farmed fish, disease transmission, pollution, destruction of essential habitat and by relying heavily on wild forage fish for aquaculture feed.

NOAA justifies the need for offshore aquaculture by citing the $9 billion trade deficit in seafood and has called for a five-fold increase in the worth of domestic aquaculture by 2025. While examples in developing countries may lead many to believe that offshore aquaculture holds promise for the economy, the Congressional Research Service admits in its 2004 Report to Congress, "little evidence has been provided for the economic benefits of open ocean aquaculture development beyond the general acknowledgment that marine aquaculture has proven profitable elsewhere, especially in areas with little or no environmental regulation and/or enforcement… The present lack of knowledge, owing to limited experience and few studies focusing specifically on open ocean aquaculture, limits our understanding of potential environmental concerns."

Because the effects of offshore aquaculture on fishing communities, fishery resources and marine ecosystems are largely unknown, NOAA consulted a diverse group of stakeholders to create A Code of Conduct for Responsible Aquaculture Development in the U.S. Exclusive Economic Zone, which was published in 2002. The Code pledges "to temper progress with responsibility, and encourage good stewardship of all living and non-living marine resources found offshore. Aquaculture development in the EEZ will adopt the guiding principle of a precautionary approach combined with adaptive management to achieve sustainable development in offshore waters." Disappointingly, the National Offshore Aquaculture Act of 2007 does not take a precautionary approach and instead emphasizes promoting offshore aquaculture over protecting natural resources. Environmental requirements are omitted from the bill, leaving those to be worked out later through a rulemaking process.

NCMC maintains that national legislation for marine aquaculture must explicitly outline a strategy that, above all, values the health of marine ecosystems and resources. Risks from offshore aquaculture must be eliminated or minimized through the creation of specific environmental requirements. A policy for sustainable marine aquaculture must include the following principles:

• Permits to conduct offshore aquaculture should be withheld until:
  
  1. Studies are conducted to fully analyze the environmental costs and benefits of such a program;
  
  2. A balanced administrative framework is in place to ensure that aquaculture develops in an unbiased, sustainable and transparent manner that does not compromise the health or conservation of natural resources or the interests of other resource users;
  
  3. Enforceable standards are instituted that minimize or eliminate risk and impact to wild fish stocks, the environment, and the public . The standards should address the critical concerns about aquaculture identified by the Marine Aquaculture Task Force (see summary of the Task Force report below). These include escapes, loss of genetic diversity, disease and parasites, water pollution and the use of wild caught fish in aquafeed.
  

• Regulations should require that farmed species and their diets be selected to minimize, to the extent practicable, the use of wild fish in feed. Although aquaculture is sometimes promoted as a way to reduce pressure on wild stocks, farming carnivorous fish that are high on the food chain uses considerable quantities of wild-caught forage species (e.g., menhaden, sardines and anchovies) as feed, resulting in a net loss to the ocean food web. The Alaska Marine Conservation Council reports, "In the case of salmon farming in British Columbia, farms use between 2.7 and 3.5 tons of wild fish to make enough dry feed to raise one ton of salmon." An evaluation of tuna farming produced more alarming statistics. Researchers found that up to 20 tons of forage fish are required to raise a single ton of tuna.1 Operators should strive for a Feed Conversion Efficiency (FCE) or wild fish to farmed fish ratio of 1.0 or less.
  
  
• Wild forage fish used for aquafeed should be sourced from ecologically-sustainable fisheries. Chain of custody measures should be applied to aquafeed in order to track the origin of fishmeal and fish oil so that sustainably produced feeds can be identified. Most forage fish stocks around the world are fully exploited, and many scientists believe these fisheries could be overfished in an ecological sense. Ecosystem-based fishery management should be employed to protect the vital ecological role of forage fish in the food web. A domestic aquaculture program poses an imminent threat to forage fish, as operators will logically look to local sources to supply feed. The aquaculture industry already consumes more than half of the global supply of fishmeal and oil, and demand is projected to double in the next decade, outstripping global supplies.
  
  
• Conservation measures and sound fisheries management must remain in place to rebuild depleted stocks. Aquaculture is not a solution for depleted fisheries. Experience with salmon indicates that aquaculture does not reduce pressure on wild stocks. In fact, to stay competitive, fishermen are pressured to increase their catch and lower prices.
  
  
• Siting, construction and operation of offshore aquaculture facilities should not overlap or otherwise impact Essential Fish Habitat (EFH), Habitat Areas of Particular Concern (HAPC) or other protected marine areas. Nor should they interfere with other spatial management measures employed by NOAA and the Regional Fishery Management Councils to protect fishery resources.
  
  
• Aquaculture should not include species for which wild stocks are robust, fished sustainably and yielding high economic value.
  
  
• Aquaculture in the U.S. EEZ should not include non-native species, and native species farmed should be of the genotype native to the geographic region.
  
  
• Offshore aquaculture legislation should prohibit the practice of "ocean ranching", where undersized wild finfish are caught and held for extended periods in ocean pens to be grown out to legal size before being sold to markets. This practice undermines fishery management and promotes Illegal, Unregulated and Unreported (IUU) fishing.

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1Weber, Michael L. 2003. What price farmed fish: A review of the environmental and social costs of farming carnivorous fish. SeaWeb.

Links to Offshore Aquaculture Reports and Legislation:

National Offshore Aquaculture Act of 2007

Sustainable Marine Aquaculture: Fulfilling the Promise; Managing the Risks
Report of the Marine Aquaculture Task Force

National Stock Conservation Act of 2007

Sustainable Oceans Act - California Bill S.B. 201

Magnuson-Stevens Fishery Conservation and Management Reauthorization Act of 2006

Read more about NCMC's latest efforts on aquaculture.