Proposed organic standards for aquaculture

November 3, 2008

Ms. Valerie Frances, Executive Director
1400 Independence Ave., SW.
Room 4008–So., Ag Stop 0268
Washington, DC 20250–0268

Re: docket # AMS-AMS-08-0083 Aquaculture fish feed and net pens

It is stunning and deeply disturbing that the NOSB would consider open water net pens for finfish to be certified as “organic” operations.

As a certified organic retailer and the nation’s largest consumer-owned grocer, our 45,000 member/owners believe the organic label warranties that a product has been produced using environmentally, economically and socially friendly practices. We also are familiar enough with open water net pen aquaculture to know that putting the organic seal on farmed finfish from open water net pens is fundamentally opposite to anything environmentally friendly or sustainable.

Production and handling

As residents of one of the two states in the U.S. that has allowed open water net pen salmon farming, we can attest that there is no way imaginable that such operations do not cause severe damage to our waters, to fishing families, and to our coastal communities.

Organic foods, whether from plants or animals, are produced under conditions that can be controlled. This cannot be said for fish grown in open waters, given the fluid nature of water.

For instance, Section 205.201 of the proposed aquaculture standards lays out production and handling specifics, as though any standards ever could address the problems caused by open water net pen aquaculture. All the specifics circumvent and ignore the fundamental fact that open water net pen aquaculture is not compatible with the principles of organics.

Section a (7) (1) talks about mapping the production area, as though open water areas can be controlled and section (v) does not suggest that there won’t be impacts, but rather obliquely would require “a description of measures that will be implemented to minimize impacts” – as though ANY measures could prevent what all systems have demonstrated. In other words, the language acknowledges that attempts at mitigation is the best the proposal could achieve.

Privately owned finfish operations in Washington are riddled with pathogens and more than 600,000 farmed fish have escaped into open waters here, exposing our native stock to disease. Non-native salmon are invasive now, competing with native strains for food and spawning grounds. ecause of these escaped fish and the sea lice epidemics that they’ve caused, wild salmon populations are threatened with extinction. But escaped fish are not the only pollutants from floating feedlots.

Section viii (b) of 205.201 (a) (7) specifies that an aquaculture system must include “A waste management plan that provides for: Composting or recycling of waste biological materials to the extent practicable.” Setting “the extent practicable” as a standard is wholly insufficient. In open waters, there is no system that could control the inevitable pollution.

Section xi (a) further states that the location of net pens “minimizes impact to surrounding environment, limits waste accumulation, and minimizes impact to the migratory and reproductive patterns of local wild fish populations…”

The esteemed Arthur H. Whiteley, professor emeritus, Department of Zoology at the University of Washington, compared waste generated by four fish farms near Bainbridge Island (30 minutes from Seattle by ferry) to the amount generated by 830,000 Seattle residents — who recently paid for an expensive sewage collection system to protect Puget Sound waters!

The West Point Treatment Plant cost more than $573 million to build and $80 million per year to operate. It releases around 4 million pounds of sterilized total suspended solids into Puget Sound annually.

Dr. Whiteley compared that to the amount of waste flushing into Puget Sound from salmon farms in Rich Passage, across from Seattle. Based on inputs of feed and numbers of fish permitted by the Department of Ecology, he calculated these fish farms produce more than 5,180,000 pounds of feces annually. Fish farm sewage is untreated and non-sterile and the cost to fish farmers for this use of our public waters is zero.

Although aquaculture proponents try to convince the public they’re protecting wild fish, their industry is causing a significant net loss of protein. The explosive growth of salmon farming has led to unsustainable overfishing in our oceans. Anchovies, mackerel, herring, sardines and other small fish are scooped up to be macerated and made into feed pellets for farmed fish.

These small fish are essential components of the ocean food chain and meet the subsistence needs of people in poorer regions of the world. When turned into fodder for fish in cages, two-thirds or more of their protein value is lost. This is not sustainable and incongruent with organic principles.

Mollusks and plant-eating fish can be farmed sustainably, creating a net gain of protein. But the fish proposed for ocean pens are carnivorous species.

As aquaculture moves towards production of more carnivorous species, the collapse of wild fish populations will be hastened while depriving fishing communities of the fish so important to their diet and income.

Economic and social damage

Subsidized, industrial fish products flooding the marketplace have caused devastating economic downturns for once-successful family businesses. There’s a lot at stake.

In addition to what’s happened with salmon, wild black cod (also known as sablefish) has a value of more than $141 million annually to local boats. Wild Pacific halibut, another abundant and high-value wild fish, brought $168 million to harvesters in 2004, many living in the Puget Sound area.

According to a study by Dr. Rosamond Naylor, senior fellow in Environmental Science and Policy at Stanford University, wild salmon incomes and license values dropped dramatically when farmed salmon replaced wild salmon in restaurants and stores. Between 1990 and 2002, the price for many limited-entry salmon permits in Alaska fell by 75 to 90 percent, plummeting in one fishery — Bristol Bay — from $300,000 to $30,000. Thousands of families lost significant income in the last decade because of artificially low fish prices and many face serious debt and bankruptcy.

After several years of low fish prices and reduced processing capacity, the Bristol Bay Native Corporation invited oil exploration under the waters of the richest wild salmon-producing region of the world. Other remote villages are considering opening up their coastlines to oil, gas and mineral extraction, further jeopardizing wild fish, the natural environment, traditional cultures and economies.

How in the world has the NOSB gotten to where it even considers the possibility of accepting net pens for organics?

It appears that the current NOSB needs to be reminded of the work and findings on aquaculture done by previous task forces and boards. Few of the archival records from a previous task force prior to 2001 appear to be available on the NOSB web site. Why is this?

The NOSB web site, however, does contain one letter from June 30, 2006 from the Monterey Bay Aquarium to the NOSB. The aquarium’s Aquaculture Analyst (Corey Peet, M.S.) and Science Manager (George Leonard, Ph.D.) stated that they were concerned about the make-up of the NOSB panel and its lack of conservation voices, with the exception of Dr. Rebecca Goldburg. We know that Dr. Rebecca Goldburg was opposed unequivocally on scientific grounds to allowing net pen systems ever to be considered for organic status because of the environmental damage they cause.

In addition to agreeing with the findings of the Monterey Bay Aquarium, we also agree with the findings of Food and Water Watch, especially regarding concerns about the depletion of wild fish stocks to feed captive fish and the concentration of contaminants in fish feed and oil.

The facts have not changed over the past few years. If anything, the scientific evidence has mounted that open water net pen aquaculture for finfish is environmentally destructive and not compatible with organic principles.

Lest it be overlooked, I wish to call attention to today’s announced “Declaration Against Unsustainable Salmon Farming,” (
International-Declaration-Against-Unsustainable-Salmon-Farming-se/1405.html) submitted to the United Nations by an international group of scientists, conservationists, tourism operators and owners, and citizens. It reports that wild salmon populations are crashing wherever there are salmon farms due to pathogen amplification and genetic pollution, that local resources are being fouled by drug and waste releases, and that salmon farms are taking more wild fish than they produce, impoverishing putting the global food supply from our oceans.

It’s difficult to avoid concluding that the NOSB has succumbed to the aquaculture industry’s propaganda and its relentless pressure to be able to cash in on the organic label’s good name — which won’t remain good for long if the NOSB allows such proposals as this one to be approved.

In the first page of the Proposed Organic Aquaculture Standards for Fish Feed and Related Management Issues, the “Background” section reveals the very backward context of even why NOSB is addressing net pen aquaculture. It portrays a sequence of events where the NOSB hosted a symposium to “explore the range and depth of scientific and environmental challenges facing global aquaculture. The NOSB realized the need to implement rule changes to allow certification of aquatic species, but there was a critical challenge: providing adequate supplies of essential nutrients to a new industry with non existing sources of fish meal and fish oil. At the spring 2008 NOSB meeting, the National Organic Program states that wild caught fish could be considered by the board as a viable alternative for fish meal and fish oil …”

Yes, global aquaculture faces challenges. Yes, there are critical challenges in sourcing “adequate nutrients” for captive fish, yet it is not the NOSB’s purpose to solve inherent problems in every food production system nor to make any system acceptable. Not everything can be organic, pure and simple. In fact, it is the express purpose of organic standards to warranty that the process and methods of food production are environmentally sustainable.

It’s our position that finfish aquaculture and open net pens should not be permitted – let alone granted certified organic status. We conclude that closed-containment production practices are required for finfish aquaculture and only for non-carnivorous species. Whether or not closed systems ever could reach organic standards is doubtful.

These proposed standards indicate that the NOSB is trying to make rules to fit a fatally flawed concept in finfish aquaculture.

Tracy Wolpert
Chief Executive Officer
PCC Natural Markets

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