The following is an excerpt from a letter to the editor and was originally published in the April 2019 Yearbook issue.
We represent U.S.-based aquaculture producers and related businesses that are committed to supplying American consumers with safe, high-quality, nutritious and sustainable fish and seafood. We are writing to challenge the “facts” cited in the March issue letter to the editor, “Finfish aquaculture has no place in U.S. waters.”
Our members sympathize with U.S. commercial fishermen who have seen stocks dwindle because of loss of fish habitat, ocean acidification, climate change, industrial pollution, IUU fishing by rogue nations, and competition from the recreational fishing sector. We share their concerns that, despite conservation efforts, ocean water quality is changing and that soon there may not be enough fish in the sea to support a strong commercial sector.
Such devastating events, however, have nothing to do with aquaculture, and we need the support of the trade press to advocate working together to find solutions that affect us all. We care about the ocean because our livelihood, like the commercial sector, depends on it.
We therefore suggest that the time has come for trade publications to take a stand to support the idea of cooperation and collaborative efforts to foster both a healthy, prosperous wild harvest, and successful sea farming. Aquaculture trade publications do not publish stories bashing the commercial sector.
We welcome the opportunity to challenge the assumptions made in the anti-aquaculture letter and we are grateful for the chance to set the record straight:
Without Congressional authorization for aquaculture in federal waters, it is unlikely that any significant American marine aquaculture production will emerge any time soon. As a result, we will continue to buy our salmon, trout, and other popular species from other countries such as Canada, Chile and Norway; and those foreign countries will continue to reap the benefits of family-wage jobs, tax revenues, and the advancement of aquaculture knowledge and experience.
We all need healthy ocean environments whether we harvest wild fish or raise farmed fish. Neither wild fisheries nor aquaculture are without some level of impact to the environment. The key is controlling, reducing, and mitigating such impacts wherever reasonable to do so, while understanding that the need for animal protein production will continue to increase as the world’s human population increases. It’s easy to read between the lines in the letter and see what lies beneath: A desire to keep wild fish prices high, which means most fish products will be of limited availability and beyond the reach of those with modest means.
It’s time to stop using sensationalist terms such as “factory farms” to describe marine aquaculture. As to the charge that marine aquaculture is incompatible with commercial fishing, we respectfully suggest that the letter-writers look at the federal and state regulations that are in place today to ensure that wild fisheries and aquaculture are producing sustainable seafood products for the consumer. Over the past 20 years, aquaculture has evolved into a highly regulated industry, and most producers today are making continuous improvements to meet the demands of the marketplace. Food safety and traceability are paramount.
In the United States, since the 1970s, the U.S. Environmental Protection Agency has held authority to regulate discharges from fish farms (e.g., nutrients, chemicals and solid waste) under several iterations of the Clean Water Act. More recently, environmental groups sought EPA re-evaluation of the Clean Water Act standards applied to aquaculture.
Between 2000 and 2004, the agency completed a detailed technical review of its then-current standards and modern aquaculture methods, including those used for marine aquaculture. Formal rulemaking was conducted to ensure that Clean Water Act regulations for aquaculture met all standards of environmental protection mandated by Congress. In that process, the EPA determined, contrary to the position of environmental groups, that the proposed and adopted revised regulations assured environmental protection.
Existing laws applicable to aquaculture operations include, but are not limited to, the Animal Health Protection Act; Animal Medicinal Use Drug Clarification Act; Coastal Zone Management Act; Endangered Species Act; Federal Food Drug and Cosmetic Act; Federal Insecticide, Fungicide, and Rodenticide Act; Federal Water Pollution Control Act (Clean Water Act); the Lacey Act; Magnuson-Stevens Fishery Conservation and Management Act; Marine Mammal Protection Act; Migratory Bird Protection Act; National Environmental Policy Act; Outer Continental Shelf Lands Act; and Rivers and Harbors Act.
Through rulemaking, judicial rulings and an opportunity to comment on significant federal permitting by other federal agencies, the U.S. EPA, NOAA, Department of Agriculture, Army Corps of Engineers, Coast Guard, Department of Defense, Federal Aviation Administration, Fish and Wildlife Service, Bureau of Ocean and Energy Management, and state agencies (agriculture, natural resources, and environmental protection) have an important regulatory role relative to offshore aquaculture and, in particular, the coastal states are provided an opportunity to comment on proposed federal permits and leases associated with offshore marine aquaculture.
Current regulatory authority exists to protect marine water quality and benthic environmental systems, manage fish escapes, require responsible drug and chemical use, ensure safe navigation, and assure consumers that they will have access to safe foods. Indeed, it has been argued, and we agree, that:
The regulatory environment in the United States has become increasingly stringent in recent years in terms of both the number and complexity of regulations that affect U.S. aquaculture.
Especially difficult is the lack of a lead agency at federal and state levels to effectively coordinate and streamline regulatory and permitting processes. The cumulative effect has been continued increases in the regulatory costs and risk faced by U.S. aquaculture growers.
Offshore farms that have operated in Hawaii and Puerto Rico were welcomed by commercial fishermen and operated in a manner that benefited both farmer and fisherman. In fact, Hawaiian commercial fishermen encouraged the operators of the first offshore farm in their waters to establish a second location so that during adverse weather they could fish in proximity to either farm. A commercial fishing cooperative in Puerto Rico invited a sea cage farm to establish a farm in their waters and use their working waterfront to land production, store equipment, and perform maintenance of farm gear.
Fishing and farming can coexist in the United States. We believe fear of the unknown driven by extremist agendas making false claims has triggered the sensationalist opposition letter.
In a prior letter to National Fisherman, we reported farm-gate fish values which were hardly cheap as claimed in the letter, and we are disappointed that the letter’s authors consider U.S. farm-raised fish to be low-quality. The U.S. domestic aquaculture industry is committed to supplying consumers with consistent, high-quality, safe products produced in an environmentally sound manner.
The marketplace success of U.S. farmed fish is consumer confirmation that we are meeting that commitment. The U.S. Food and Drug Administration works with state departments of agriculture, the Association of Food and Drug Officials, and the American Association of Feed Control Officials to regulate aquaculture food handling and processing and the manufacture of feeds to ensure that they are safe and do not contain contaminants or illegal substances.
Furthermore, the Interstate Shellfish Sanitation Conference in cooperation with the FDA and state agencies administers a certification program requiring all shellfish dealers to handle, process, and ship shellfish under sanitary conditions and maintain records that the shellfish were harvested from approved waters. State agencies establish standards for shellfish growing areas and monitor water quality.
Fish and shellfish packers, warehouses, and processors must comply with the requirements of the Hazard Analysis Critical Control Point Program administered by the FDA. The program identifies potential food safety hazards and develops strategies to prevent them.
New rules by the FDA authorized by the Food Safety Modernization Act have added regulations for the processing, handling and transportation of animal feeds and human food.
As U.S. farmers, we are at a very real price disadvantage and recognize import product prices as being one of our greatest challenges. In response, rather than a protectionist approach, we have been working to develop markets that appreciate locally grown and high-quality fish, shellfish and seaweed products. And we are working to educate the U.S. consumer of our sustainable production practices, environmental stewardship and the nutritional benefits and value of buying U.S.-grown foods.
We are farming during a period in history that the human population is rapidly increasing, and the health benefits associated with consuming seafood are being recognized and promoted like never before. Whether we are fish farmers or fishermen, we all are part of the working waterfront seeking to feed our country healthy food.
The truth is that both sectors have our work cut out for us to communicate product value, respond to expanding regulations when necessary, and to share with the next generation our hard-won knowledge, skills and experience.
We should be united in encouraging Americans to eat more seafood, both wild and farmed. Bashing farmed fish only confuses the consumer, and sends them to the chicken, beef, and pork counters at the supermarket.
National Aquaculture Association
Northwest Aquaculture Alliance