Net pen aquaculture is unsustainable

March 3, 2017

Cedar Bouta, Project Coordinator
Re: Recommendations for Managing Sustainable Net Pen Aquaculture

Dear Cedar Bouta,

On behalf of PCC Natural Markets, please accept the following comments on recommendations for managing commercial marine net pen aquaculture in the Straits of Georgia and Juan de Fuca, Puget Sound, Willapa Bay and Grays Harbor.

PCC long has advocated for sustainable fisheries and healthy oceans and waterways. As the first full retail partner of the Monterey Bay Aquarium’s Seafood Watch program, we only sell sustainable seafood from well-managed fisheries. Our 56,000 member-owners and the shoppers at our 11 Seattle-area stores expect us to defend an ecologically and socially sound food system, which is why we strongly urge the Department of Ecology not to condone expansion of net pen aquaculture in local waters.

Guidelines for net pen aquaculture siting and operations in Washington have not been updated since 1990, when the Final Programmatic Environmental Impact Statement: Fish Culture in Floating Net Pens was complete. During the past 27 years, Wild Fish Conservancy reports that many of those guidelines have not been followed, including exceeding maximum fish production limits, siting of salmon net pens in endangered species habitat and near wildlife refuges, failing to conduct recommended environmental surveys, and using antibiotics not approved by the U.S. Food and Drug Administration.

The significant ecological risks associated with net pen aquaculture should deter the development of commercial net pen aquaculture in our state waters. If the State of Washington is interested in expanding aquaculture production, it should instead explore truly sustainable alternatives such as land-based recirculating aquaculture systems.

Ecological Risks

Ecological risks associated with marine net pen aquaculture include fish escapes, sedimentation and pollution beneath net pens, chemical and antibiotic inputs, phytoplankton blooms, introduction of exotic pathogens, and interactions with marine predators.

Fish Escapes

Escapes of farmed, non-native species are of particular concern as they can expose wild populations to parasites and pathogens, and increase competition for food, habitat and spawning areas. A 2014 study in British Columbia, where salmon net pen aquaculture is well established, found that farmed, non-native Atlantic salmon were present in 97 percent of rivers and streams occupied by native Pacific salmon. In 2012, an outbreak of Infection hematopoietic necrosis virus (IHNV) was reported in three Atlantic salmon net pens on the coast of Bainbridge Island, Washington. Five months passed before officials from the Washington Department of Fish and Wildlife were notified by the industry, during which wild fish may have contracted the disease.

The commercial net pen industry uses a chemical compound called emamectin benzoate as a feed additive to control sea lice. However, the FDA lists emamectin benzoate as an unapproved drug that should not be used on fish destined for consumption in the U.S. The build-up of this toxin inside and outside net pens could have very harmful effects on other marine wildlife and human health.

Fish Feed

Most farmed marine finfish are carnivorous and consume large amounts of fish meal and fish oil. Three pounds or more of wild fish are required to produce one pound of farmed salmon or other carnivorous fish. The ecological footprint to produce one ton of industrial farmed Atlantic salmon is approximately twice that of commercially captured sockeye, chum or pink salmon.
The marine area needed to produce the feed consumed in a salmon farm is 40,000-50,000 times greater than the area of the farm itself. Many industry experts expect that within a decade, the global aquaculture industry will use two-thirds of world fish meal production, and there already may be a serious fish oil shortage.

Fish Waste

Marine net pen aquaculture shares similarities with land-based concentrated animal feedlot operations, which concentrate large numbers of animals in a confined space and produce large volumes of waste containing fish feces, uneaten food, drugs and drug residues, pesticides, fungicides, other pollutants and potentially harmful pathogens. A salmon farm of 200,000 fish releases an amount of nitrogen, phosphorus, and fecal matter roughly equivalent to the nutrient waste in the untreated sewage from 20,000, 25,000, and 65,000 people, respectively.

The Department of Ecology just went through a multi-year process to designate Puget Sound as a no-discharge zone for vessel sewage in order to protect water quality. It should not proceed with plans to expand marine net pen aquaculture which will potentially reverse the benefits derived from banning vessel sewage in the region.


Net pen aquaculture inherently is unsustainable and is not a safe and responsible use of Washington’s public waters and natural heritage. The ecological risks associated with net pen aquaculture do not outweigh the potential commercial benefits of the marine aquaculture industry. In addition, local economies could suffer as wild fish and shellfish populations decline, with negative consequences for local tribal, commercial and recreational fisheries. In Washington, state coastal waters include culturally and historically sensitive areas, high public use areas, and shipping lanes. Specifically, the Straight of Juan de Fuca has multiple stakeholders with overlapping interests, including tribal harvests, recreational fishing and boating, and commercial fisheries.

Instead of soliciting recommendations to expand an unsustainable industry, the Department of Ecology should devote resources to develop management guidelines for truly sustainable aquaculture, such as land-based recirculating aquaculture systems.
Thank you for the opportunity to submit comments.


Eli Penberthy

PCC Natural Markets Public Affairs

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