NCMC POSITION ON OFFSHORE AQUACULTURE

updated February 19, 2010

With the global catch from wild fisheries stabilized at around 90 million tons a year and most of these fisheries fully exploited, aquacultured fish is becoming an increasingly important food source for a booming world population. Worldwide, marine fish aquaculture is expanding at a rapid pace of 9% annually. Within the United States, around 50% of the seafood we consume is from aquaculture farms, and most all of this is imported.

Food fish aquaculture in the U.S. is currently limited to inland closed-system facilities and a few open water operations located in coastal waters under state jurisdiction. Citing the $9 billion trade deficit in seafood, NOAA has been aggressively promoting the development of industrial-scale ocean fish farming in our federal waters. In 2005 and 2007, legislation crafted by NOAA to establish a national regulatory framework for offshore aquaculture was introduced in Congress. Both bills were widely criticized for their lack of environmental safeguards and did not pass. Touted as a solution to supplement wild 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 feed.

Reaching a roadblock with national legislation, NOAA began to pursue its aquaculture agenda through the regional fishery management councils. In September 2009, the Gulf of Mexico Fishery Management Council’s Fishery Management Plan for Regulating Offshore Marine Aquaculture in the Gulf of Mexico (Gulf Aquaculture Plan) took effect, enraging many members of Congress who urged disapproval of the plan because of NOAA’s clear lack of authority to regulate offshore aquaculture through the regional councils and the risks associated with such a piecemeal approach to aquaculture development.

To put an end to piecemeal aquaculture regulations, Congresswoman Lois Capps (D-CA) is spearheading the first national offshore aquaculture legislation to include explicit standards to protect wild fish, ocean habitats, and the people that depend on them. Her bill, the National Sustainable Offshore Aquaculture Act of 2009 (H.R. 4363), was introduced in the House of Representatives in December 2009. Modeled after her own state’s legislation, California’s Sustainable Oceans Act, the bill strives to balance environmental, social, and economic concerns. The bill takes a precautionary approach by withholding all permits until regional environmental impact assessments are completed, prioritizing research, and establishing clear environmental safeguards. NCMC is currently working with its allies in the fishing and conservation communities to provide feedback on the legislation in order to strengthen protections for marine ecosystems and fisheries, consistent with the bill’s intent.

NCMC’s Position on National Offshore Aquaculture Legislation

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 costs and benefits of such a program;
     
     
  2.  A balanced administrative framework is in place to ensure that aquaculture develops sustainably and in a transparent manner that does not compromise the health of or management plans for natural resources or the rights of other user groups;
     
     
  3. Enforceable standards that minimize or eliminate risk and impact to wild fish stocks, the environment, and the public are instituted. The standards should address the critical areas for sustainable aquaculture identified by the Marine Aquaculture Task Force (see summary of the Task Force report below). These include escapes, disease and parasites, water pollution and the use of wild caught fish in aquafeed.
     
     
• Siting, construction, operation and demolition 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 hinder other area measures employed by NOAA and the Regional Fishery Management Councils to protect fishery resources.
  
  
• Regulations should require that farmed species and their diets be selected to minimize, to the extent practicable, the use of wild fish in feed. Operators should strive for a Feed Conversion Efficiency (FCE) or wild fish to farmed fish ratio of 1.0 or less. 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 enormous quantities of wild-caught forage species (e.g., menhaden, sardines and anchovies) as feed, resulting in a net loss to the ocean food web. An evaluation of tuna farming found that up to 20 tons of forage fish are required to raise a single ton of tuna.1
  
  
• 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 outstrip global supplies in just a few years.
  
  
• 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.
  
  
• 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 Referenced Offshore Aquaculture Documents:

Fishery Management Plan for Regulating Offshore Marine Aquaculture in the Gulf of Mexico

National Sustainable Offshore Aquaculture Act of 2009 (H.R. 4363)

Sustainable Oceans Act