The Dangers of Industrial Ocean Fish Farming The Dangers of Industrial Ocean Fish Farm Farming l 1 Publication Information: Hallie Templeton with Friends of the Earth U.S. Friends of the Earth U.S. Washington, D.C. 1101 15th Street NW, 11th Floor Washington, D.C. 20005 Berkeley, California 2150 Allston Way, Suite 360 Berkeley, California 94704 Please visit us at www.foe.org DISCLAIMER: The authors believe the information in this report comes from reliable sources, but cannot guarantee the accuracy or completeness of this information. The authors disclaim any liability arising from use of this document and its contents. 2 l The Dangers of Industrial Ocean Fish Farm Farming Cover/inside cover image: By Benson Kua CC BY-SA 2.0 “Fish schooling in aquarium tunnel”, 2010 Table of Contents I. Introduction ................................................................................................................................5 II. What is Industrial Ocean Fish Farming? ............................................................................5 III. Industrial Finfish Farming Burdens the Environment and Society ............................7 IV. Industrial Ocean Fish Farming in the United States ....................................................20 V. Solutions to Industrial Ocean Fish Farming are Available and Obtainable ............22 VI. Endnotes ................................................................................................................................26 The Dangers of Industrial Ocean Fish Farm Farming l 3 . o: st. Cre Shutterstock 4? 4 The Dangers of Industrial Ocean Fish Farm Farming I. Introduction The seafood business is booming. It comprises over 16% of the protein we eat worldwide, the majority of which is farmed.1 In the last 30 years, global fish farm production increased from 5 million to 63 million tons.2 Aquaculture recently surpassed global beef production,3 and by 2030, it is projected that over 60% of the world’s seafood will be farmed.4 species, and genetically modified ingredients such as corn and soy. In other words, the salmon on your plate could very well be unhealthy, inhumane, and unsustainable. Thankfully not all seafood production methods are bad, and you can continue to feel good about the fish you eat. There are many sustainable ways to produce seafood, Many people opt for seafood over terrestrially-raised including land-based recirculating farms, ocean-based meat because they want better nutrition, a more humane farms utilizing entire water columns, and even some option, and a smaller environmental impact. However, wild-caught fisheries. not all seafood is created equal. Much of our available seafood has been mass-raised and harvested in indus- We want you to know your seafood’s story. Read trial ocean farms, pumped with agricultural drugs and our report to find out all you need to know to make a pesticides, and provided feed comprised of overfished healthy, informed choice that is good for you and for the II. What is Industrial Ocean Fish Farming? Simply put, aquaculture is the farming of underwater organisms, like mollusks, crustaceans, and fish. There are many forms and methods of aquaculture that occur around the world in ponds, rivers, oceans, estuaries, and even land-based facilities. Aquaculture is no stranger in the United States. Although aquaculture production initially had the purpose of enhancing sportfishing opportunities, farmers started raising catfish in ponds and harvesting shellfish from enhanced open-water beds in the early 1900s.5 However, a new form of aquaculture has recently surged in popularity and is beginning to take over our oceans. Industrial ocean fish farming – sometimes referred to as open ocean or marine aquaculture – is the mass rearing and harvesting of finfish in areas of the ocean in underwater nets, pods and cages. This farming technique is extremely risky and fraught with environmental and socio-economic havoc. These CAFOs of the sea impose significant harm on public health, the environment, and the people, industries, and economies which rely on the ocean and its many resources. The Dangers of Industrial Ocean Fish Farm Farming l 5 Industrial ocean fish farming techniques: Industrial ocean fish farms are inherently unsustainable and cause extreme harm in countless ways. As with the mass production characteristic of most corporate-controlled industries, costs and expenses are cut to the absolute minimum with an eye toward maximum profitability. Unfortunately, the only beneficiary of this business model is the corporation, and the victims include the farmed fish, the ocean ecosystem and its inhabitants, the economy, and consumers. These facilities are essentially underwater factory farms, but with even less pollution controls. They are used to farm massive populations of finfish in net pens, pods, and cages that provide no real barrier between the farm and the ocean. This allows for free exchange between the net pens and the open water, including direct deposits of untreated fish waste, diseases and parasites, excess feed, agricultural drug residues, chemicals and anti-foulants from the farm’s infrastructure, and oftentimes spills and escapes of farmed fish – all dumped right into the surrounding environment. This open exchange also attracts predators and other wildlife to congregate around the farms, which then get entangled in nets, harassed by acoustic deterrents, and hunted. 6 l The Dangers of Industrial Ocean Fish Farm Farming Typically, the farmed fish and enclosures are fully submerged so that workers must dive to access them directly, with numerous platforms and walkways above the surface for workers to access the remainder of the infrastructure – much like an oil rig. There are oftentimes no barriers between the elements and the farm, such that workers are directly impacted by severe ocean conditions, including strong wind and wave activity from all directions, short and steep wave patterns, and strong currents. The farms are usually anchored to the ocean floor, held up by buoys and other flotation mechanisms, and connected by walkways, tubing, ropes, or other surface-level infrastructure. However, this model is fallible and structures can easily float away from their positions and nets can become disconnected due to tides, winds, and other elements. Over time, this shifting stresses the mooring and weakens the infrastructure, which creates a heightened risk of damage to the farm and often leads to releasing additional debris, trapping and harming wildlife, and spilling farmed fish into the ocean. Photo: View of fish farm from underwater. Credit: Getty III. Industrial Finfish Farming Burdens the Environment and Society. Industrial ocean fish farming is extremely problematic for public health, the economy, and the environment. Continuing to allow mega-corporations to factory farm seafood in our public waterways will only continue to benefit corporations and force us to bear its burdens. Underwater factory farms significantly harm the ocean ecosystem. From the release of untreated fish waste and excess nutrients to the overuse of antibiotics and endangerment of marine life, industrial ocean fish farms are nothing but bad news for our oceans. The ocean ecosystem is interconnected such that any impact to one species has a rippling effect on a number of other species. To that end, the significant impact that industrial ocean fish farms has on even the smallest fish no doubt takes a toll on the nearly extinct orca whale.6 Pests, disease, and agricultural drugs: It is no secret that a massive population of animals in a closed space will breed pests and disease. Farmed fish in net pens are hosts to a variety of pests and diseases, including sea lice, infectious salmon anemia, and Piscine Reovirus, just to name a few. Rather than solve the root of the problem – that is, by sustainably farming animals in more humane conditions – mega-farms simply add to the problem by using pesticides and a pharmacopeia of agricultural drugs in an attempt to control pests and disease. A number of industrial ocean fish farms have embraced pesticides to ward off sea lice and other parasites. Not only do these dangerous chemicals kill off sea lice, but also other marine life nearby the farm. It was recently uncovered that the Scottish government likely colluded with the pharmaceutical company Merck to cover-up the “widespread damage to wildlife” from a sea lice pesticide.7 The fish farm chemical, known as emamectin and marketed as Slice, was found to have contaminated at least 45 Scotland lochs, causing “substantial, wide-scale reductions” in crabs, lobsters and other crustaceans.8 Yet Scottish fish farms continue their widespread use of the drug and allegedly collude with the government to prevent heightened regulations for the fatal substance. “It is no secret that a massive population of animals in a closed space will breed pests and disease. Farmed fish in net pens are hosts to a variety of pests and diseases, including sea lice, infectious salmon anemia, and Piscine Reovirus, just to name a few. Industrially farmed fish contains an alarming amount of other toxins that have horrific health risks when consumed. A 2004 study comparing two metric tons of farmed and wild salmon purchased from stores around the world showed that farmed fish contained consistently and significantly higher concentrations of PCBs (which can cause a slew of side effects ranging from cancer to reproductive problems), dioxins (highly toxic chemicals causing cancer, developmental and reproductive issues), and the widely banned insecticides toxaphene and dieldrin (which generate deleterious reproductive effects).9 A recent test of farmed salmon from U.S. stores support this finding: on average, the farmed salmon tested by the Environmental Working Group contained 16 times more dioxin-like PCBs than amounts detected in wild salmon, four times the levels detected in beef, and 3.4 times the levels found in other seafood.10 Bacteria found in the environment develop antimicrobial resistance through contact with already resistant bacteria, antibiotics, and disinfectant agents released by human activity. People and livestock are then exposed to this resistance through food, water, and air. 11 The World Health Organization recently published a study that found an increased presence of antimicrobial resistance in farmed fish due to heavy use of antibiotics.12 The WHO has classified antimicrobial resistance as one of the major threats for the human population of the twenty-first century, 13 and the United Nations recently reported the same concerns.14 Industrial ocean fish farming is significantly contributing to this public health crisis. In Chile alone, antibiotics are used at a higher rate by industrial ocean fish farms than any other player in the meat industry.15 The Dangers of Industrial Ocean Fish Farm Farming l 7 Photo: Tilapia pens in Laguna de Bay are choked by an algal bloom they helped create. Credit: National Geographic Creative via Alamy Stock Photo Industrially farmed animals are sometimes given antibiotics to treat and prevent disease, but often misused for growth acceleration. For farmed fish, antibiotics not only leave residues in your seafood, but they also leach into the ocean, contaminating nearby water and marine life. In fact, up to 75% of antibiotics used by the industrial ocean fish farming industry are directly absorbed into the surrounding environment.16 When a farmed fish escapes, it immediately increases competition for the limited space and resources that native marine life – including wild fish and other species – need to feed, live, and reproduce. Studies show that farmed fish typically outgrow and outcompete their wild counterparts.18 Because many farms raise non-native fish, like Atlantic salmon farms in the Pacific Northwest, an escape carries with it the risk of spreading non-native diseases and pests. Farmed fish, which are genetically bred to grow bigger and faster, pose threats of genetic degradation and reproduction issues to wild species in the event of cross-breeding.19 There is also the risk that escaped, farmed salmon will prey on juvenile salmon and smaller, forage fish, further stressing and decreasing populations of wild stocks. Massive farmed fish spills: Industrial ocean fish farm containments are inherently fallible due to their use of materials that allow free-exchange with the ocean and being sited in locations with harsh marine conditions. One of the most likely events to occur when a net pen ruptures is the escape of farmed fish in massive numbers. Each single enclosure within a multi-unit farm can The release of non-native species is considered a biocarry hundreds of thousands of farmed fish.17 logical pollutant, threatening the environment much like the release of chemicals, toxins, and other contamEven the smallest rupture can allow for these fish to inants.20 Therefore, the release of these invasive fish begin escaping, and oftentimes extreme weather con- species into public water may be a violation of state and ditions that caused the rupture prevent workers from federal environmental and clean water laws.21 accessing the facility to mitigate harm and make repairs. Therefore, farmed fish continue to escape into the surrounding environment until the pen is repaired, or what The industry claims that an escaped farmed fish in the wild would behave much like an escaped land-based is more likely, until it is empty. farm animal, or “dairy cows getting lost in the Serengeti.”22 8 l The Dangers of Industrial Ocean Fish Farm Farming These farmed animals have been described by the industry as sluggish and unable to compete in the wild. These claims are wholly incorrect. Months after their August 2017 escape from a Washington State facility, farmed salmon are being found alive and well hundreds of miles from the farm.23 In fact, a three-year study conducted on Vancouver Island in 2014 estimated that over half of 41 rivers surveyed had escaped Atlantic salmon adults and juveniles, showing successful reproduction of farmed fish in the wild.24 The industry’s comparison of fugitive farmed fish to dairy cows simply misses the mark. The terrain surrounding a land-based farm is much more diverse than that which surrounds a net pen operation – with far more fences and barriers between the farm and surrounding land. For starters, the farmed dairy cow would likely have to cross roads, jump fences, and find a field or other land for feeding. No doubt, these hurdles would impact any creature’s energy level and ability to compete successfully. However, with a farmed fish, the escape of a net pen places it directly into the primary competition area, among other marine life. Without having to force additional energy to seek out faraway and difficult-to-reach feeding and spawning areas, a farmed fish could evenly compete with its wild counterparts. Indeed, an analysis of the stomach contents of both wild, native and escaped, farmed salmon species indicated that farmed salmon species adapt well to “wild” life in the ocean.25 And research in another study strongly suggests that farmed Atlantic salmon are “naturally reproducing” and “may be capable of colonizing and persisting” in the wild.26 On August 19, 2017, over 263,000 farmed Atlantic salmon escaped from an industrial net pen facility in Puget Sound.27 This facility was discovered to have had structural defects months prior to the spill, which were left neglected by owner Cooke Aquaculture until the entire facility ruptured.28 Cooke first attempted to outrageously blame the rupture on a recent solar eclipse, but later reneged when news broke of its reckless maintenance practices.29 A state investigation also revealed that Cooke misrepresented critical details about the spill - from the seriousness and cause of the spill, to the number of fish released to Puget Sound.30 Further, despite Cooke’s claims that the farmed fish will not survive in the wild, as of publishing this report, many of the farmed fish are still thriving and swimming free – some have even been documented as far north as Vancouver Island and the west end of the Strait of Juan de Fuca and as far south as Tacoma, at least as far as 100 miles from the farm.31 Some wild-caught fishers in Washington are actually reporting catches of more farmed, Atlantic The Dangers of Industrial Ocean Fish Farm Farming l 9 salmon on their trips than the fish they actually seek.32 Pollution, discharge and eutrophication: Industrial ocean fish farms are sited in public waterways and take advantage of being able to directly release into the ocean an alarming amount of chemicals, untreated fish waste, pathogens, and excess nutrients, which directly harms our oceans. by humans, causing metal poisoning, gastrointestinal disorders, tremors, ataxia, paralysis, vomiting and convulsion, depression, and pneumonia.41 Unlike their terrestrial counterparts, underwater fish farms do not utilize any type of waste treatment or ventilation to mitigate waste, pollution, and discharge. Rather, they rely on water flow and currents to flush pollution away from the farm – so it’s simply “out of sight, out of mind” for these corporations. But this method of waste management only pushes the burden onto the ocean ecosystem, impacting the ocean floor, the water column, and marine life. Moreover, this method of waste “management” is ineffective, as circulation and water flow is often reduced by various circumstances, including net fouling, mesh size of the nets, shape, changes, and contours of the seafloor, configuration of the pens, and varied density in the layers of the water columns.42 Studies show that an industrial ocean fish farm operation of 200,000 salmon will release nitrogen equivalent to the untreated sewage of nearly 20,000 people, phosphorus equivalent to nearly 27,000 people, and fecal matter equivalent to nearly 63,000 people.33 In 2000, a study of the Scottish net pen industry found that its salmon farms produced excess nitrogen and phosphorous equivalent to the untreated sewage of 3.2 and 9.4 million people, respectively.34 The industry has undoubtedly grown substantially in the past 17 years, thus increasing these numbers for Scotland and the Greenhouse gas emissions and ocean acidification: surrounding ocean environment. Although it seems as if the current federal administration wants to erase all mentions of climate change entirely, When excess nutrients like these are added to water, this doesn’t change the fact that climate change is real, a process called eutrophication occurs. This is the and that human activity – especially industrially farmed process where water becomes too enriched, causing animals – is a lead cause of rising global temperatures. environmental degradation and effects such as low Specifically for industrial ocean fish farming, studies dissolved oxygen levels, murky water, death of sea- have shown this method of seafood production is nearly grasses and corals, fish kills, low- or no-oxygen “dead twice as greenhouse gas-intensive as wild, capture zones,” and harmful algal blooms. 35 The EPA has fishing,43 and industrially farmed salmon is more enviacknowledged that industrial ocean fish farms (which ronmentally harmful than all other seafood products.44 it calls “concentrated aquatic animal production”) contributes to eutrophication of waterways, and that many Many industries and production methods associated states with fish farms have reported impairment to their with industrial ocean fish farming “constitute a largely waterways and low water quality due to excess nutrient undefined source of greenhouse gas emissions,” and overloading.36 their contribution to ocean acidification through greenhouse gas emissions is significant. 45 The net pen The infrastructure of industrial ocean fish farms also industry relies on the following carbon sources: “direct contains a combination of various chemicals and use of fossil fuels in production activities; indirect fossil heavy metals to prevent corrosion and other damage fuel use, expressed as embodied energy; conversion from abrasive ocean conditions. These antifoulant of natural ecosystems or agricultural land; [and] stock substances often leech off the farm over time, contami- respiration and waste decomposition.” 46 However, nating the water and the farmed fish.37 For example, net the transportation, processing, and distribution of this pen facilities often incorporate copper into their struc- supply chain are by far the dominant contributors of tures for its anti-foulant properties. Copper is extremely emissions.47 toxic to marine life, causing mortality and other adverse effects on survival, growth, and reproduction, and has Nicknamed “the evil twin of global warming,” ocean been known to alter brain function, enzyme activity, acidification is becoming a widespread threat in the blood chemistry, and metabolism.38 Alarming amounts U.S., and the industrialization of our oceans is to of accumulated copper have been detected in sediment blame.48 Billions of tons of the greenhouse gas carbon near net pen farms, and continues to harm marine life dioxide (CO2) are released from anthropogenic, or years after the net pens have been removed from the man-made, activities, and about half of this is absorbed area.39 Zinc is also popular in the net pen industry for by our oceans.49 Industrial salmon farms contribute the its anti-foulant properties, and is highly toxic to marine highest carbon dioxide emissions out of the entire sealife.40 These heavy metals also leech into the farmed food sector (including capture fisheries).50 And as the fish and can cause extreme harm when consumed presence of industrially farmed seafood grows, so too 10 l The Dangers of Industrial Ocean Fish Farm Farming “Of all the New England states, Maine’s shellfish industry suffers the worst effects of ocean acidification. Unfortunately, Maine is still also home to the majority of industrial ocean fish farms in the region.” Photo: Oyster farm. Credit: Shutterstock will its emissions of harmful CO2 and other greenhouse gases. Like all living things, the ocean ecosystem and its marine life require a specific pH balance to thrive. When the ocean water absorbs CO2, certain chemical reactions change the biological makeup of the water and reduce the pH value – thus making it more acidic.51 Ocean acidification is a threat on multiple fronts, because it impacts a number of biologically important minerals and nutrients. For instance, the reduced pH changes the concentration and saturation states of calcium carbonate minerals, which are essential for building the skeletons and shells of numerous marine organisms52 and coral formation.53 NOAA has reported that ocean acidification directly alters smell-driven behaviors of salmon populations, which – when functioning properly – help fish avoid dangerous waters.54 estimated that the total global cost of ocean acidification for the shellfish industry could exceed $ 100 billion (USD).58 And as industrial ocean fish farming continues to acidify the ocean, this number can only be expected to grow. Of all the New England states, Maine’s shellfish industry experiences the most significant impacts of coastal acidification.59 Maine should be taking steps to mitigate these harms by decreasing reliance of industries that contribute to ocean acidification. Unfortunately, Maine has a history of permitting the vast majority of industrial ocean fish farms. 60 Underwater factory farms are inhumane. From the farmed fish to the surrounding marine life, industrial ocean fish farming imposes a feedlot-style environment that takes a widespread toll on animals due to water This creates a vicious circle, as ocean acidification quality issues, escapes, disease and parasites, predahas been shown to negatively impact the aquaculture tor control, and feed sourcing. industry – especially for shellfish farmers. Oyster farmers face significant problems for larval production and midstage growth of their species as a result of ocean Net pen operations cause chronic stress and health acidification.55 In the mid-2000s, it was reported that problems for farmed fish populations. As with most, if oyster larvae were dying en masse at some production not all, industrial farming operations, animal welfare is facilities, with mortality totaling 100 percent at some one of the lowest priorities and profits are the highest. locations.56 Mussel farmers are also seeing negative To that end, factory farms house massive populations impacts on final shell growth and thickness and severe of animals without regard for well-being, and industrial development and hatching problems due to changes finfish farms are no different. in pH of the surrounding water.57 In 2011, one study The Dangers of Industrial Ocean Fish Farm Farming l 11 Net pens expose farmed fish to degraded water quality, which is one of the most important factors affecting fish health. Finfish are highly sensitive to pollution and water quality issues due to the large surface area of their gills.61 Water quality in intensive settings like a net pen operation can be degraded by a number of factors, including fish respiration, waste, and excess feed – which are exacerbated by intense stocking densities – and direct exposure to anti-foulant chemicals and heavy metals that secrete toxins directly into the water from the net pen infrastructure.62 Exposure to poor water quality over time can cause fish to experience health problems and infection risk, high mortality rates, and chronic stress, which causes reduced growth and reproductive performance, and increase susceptibility to disease and parasites.63 There are a handful of diseases that farmed fish – typically farmed salmon – suffer, including infectious salmon anemia, Piscine Reovirus, and Heart and Skeletal Muscle Inflammation. Infectious salmon anemia (ISA), formerly known as hemorrhagic kidney syndrome, is a highly contagious, fatal virus that can have a cumulative mortality rate exceeding 90% of infected populations.64 Although this disease primarily infects farmed Atlantic salmon, other species can carry and it has been documented to cause illness in other species as well, including coho salmon and rainbow trout.65 Fish suffering from ISA exhibit lethargy, anemia, leukopenia, ascites, exophthalmia, internal bleeding, and increased mortality rates. Of great concern is the ability of ISA to rapidly mutate and increase its virulence – which means that the disease can adapt and emerge as an even more severe and harmful virus that can impact a wider range of species, including native, wild fish stocks.66 Pscine Reovirus (PRV) is a highly infectious pathogen widely found in farmed Atlantic salmon, but can also impact and transfer to a range of other fish species. Although much about PRV remains unknown, it is widely suspected as the cause of Heart and Skeletal Muscle Inflammation (HSMI) in finfish, which causes fish to become lethargic and more vulnerable to predators.67 HSMI causes lesions and severe damage to the heart and skeletal muscles, and has nearly a 100% 12 l The Dangers of Industrial Ocean Fish Farm morbidity rate in farmed salmon populations.68 PRV also causes erythrocyte inclusion, a disorder of the red blood cells, and is documented to have decreased the success rate of at least one species of wild salmon attempting to return to upstream.69 A recent study confirmed that wild salmon exposed to industrial ocean fish farms are significantly more likely to contract PRV than those species without contact.70 The lead author of the study confirmed that industrial ocean fish farms must be removed “from key salmon migration routes, or we risk the complete loss of wild salmon” in those areas.71 Industrial ocean fish farms are also an ideal breeding ground for sea lice, allowing the parasite to thrive and grow exponentially before being released from the farm back into the ocean. In fact, salmon farms are the most significant source of sea lice epizotics (exceptionally heavy and fatal infestations) on juvenile wild salmon in Europe and North America.72 Sea lice infest and reduce survival of juvenile salmon populations – the smaller the fish, the greater the damage. And because juvenile salmon occupy the outer-most, higher-risk areas in a school, their increased mortality increases the risk of predation for the entire school.73 Sea lice can also carry and spread dangerous viruses from one fish to another. Sea lice are documented as the most pathogenic parasite in salmon farming, and in 2016 cost the global industry about $1 billion (USD) annually. 74 This cost has impacted the wholesale cost of salmon, which increased as much as 50% in 2016.75 The industry’s primary solution to sea lice is the use of pesticides. Not only do these chemicals kill the sea lice, but they also kill off other vital marine life in the area. And studies show that sea lice are beginning to exhibit drug resistance to these pesticides.76 Farmed salmon are three times more likely than their wild relatives to suffer deformities that cause deafness. These farmed salmon are given growth accelerators, and such a rapid change in size causes a deformity in the ear that is irreversible and worsens with age.77 Sadly, this deformity affects more than 95% of fully-grown hatchery-produced fish. All of these issues —the lack of hearing abilities, deformities, and growth accelerators — raise significant concerns for the welfare of farmed fish, who are unable to express their natural behaviors and live a life that is free from disease. Wildlife is attracted to net pens. Industrial ocean fish farms inherently attract predators and other wildlife. Whether these animals hope to feed on plump, farmed fish contained in open nets, or forage on excess feed and nutrients that surround the farm, one thing is clear: these facilities are a floating attractive nuisance for marine life, with a deadly bite. In March 2017, a Hawaiian monk seal was found dead, tangled in the nets of a Hawaii fish farm that is owned by Blue Ocean Mariculture and partially funded by the National Oceanic and Atmospheric Administration (NOAA). The highly endangered monk seal – there are only 1,400 left in the wild – wandered into the nets, likely looking for fish to eat. NOAA officials announced that the farm recently attracted and trapped a shark around that same time.78 In 2016, industrial ocean fish Photo: Divers and farms in B.C. contributed to the entanglement of three humpback whales in the span of just a few weeks, two of which resulted in deaths.79 So many predators are attracted to net pen operations globally that workers have crassly taken to shooting and killing animals on sight – even species that are listed as endangered in the U.S. – preferring “cheap bullets” to more humane ways of deterrence and stock protection, such as improved anti-predator nets.80 For the first half of 2017, Scotland’s industrial ocean fish farms contributed to 50% more seal killings than the same period for 2016 – most being shot on sight by workers.81 British Columbia follows suit: since 1990, B.C. fish farms shot and killed more than 7,000 marine mammals: almost 6,000 harbor seals, 1,200 California sea lions and 363 endangered Steller sea lions. 82 with the almaco jacks a Pacific bottlenose dolphin visit in a pen at a fish farm off The y Photo Big Island, Hawaii. Credit: Alam pen operations globally that workers So many predators are attracted to net animals on sight – even species that ing kill d an ng oti sho to en tak ssly cra e hav are listed as endangered in the U.S. The Dangers of Industrial Ocean Fish Farm Farming l 13 Photo: Close-up of large group of fish in fish farm.Credit: Getty images. These floating feedlots are tremendously wasteful. From the diets of farmed fish to the number of farmed fish deaths due to pests and disease, industrial ocean fish farming contributes to a significant amount of waste annually. The diet for the most popular farmed fish results in a net protein loss: The most popular and widely farmed finfish, Atlantic salmon, is carnivorous. The diet for this species results in a “protein in, protein out” deficiency. In other words, it takes significantly more protein to feed a farmed Atlantic salmon than is produced at harvest. Studies have reported that it requires four or more pounds of wild fish to produce one pound of farmed salmon or other carnivorous fish.83 Because the majority of this protein is derived from fish meal and fish oil, it is easy to see how this diet has led to overfishing problems. The higher demand for fish feed from industrial ocean fish farms has caused a surge in value for fish feed – especially in light of the more limited availability of forage fish species. In today’s capitalist society, it comes as no surprise that a slew of corporations have jumped into the market. Past reports projected that the fish feed industry will be worth over $70 billion in the next couple Industrial ocean fish farms use wasteful, unsustainable, and unhealthy fish feed. To maximize profits, the net pen industry contributes heavily to harmful forage-fish sourcing practices and widespread use of GMO ingredients and other unhealthy additives for its fish feed. Industrial ocean fish farms are wiping out forage fish species. To meet the protein needs of their stocks, industrial ocean fish farms rely on fish meal and oil from smaller, lower-trophic level ocean fish such as anchovy, herring, and krill – also known as forage fish. In fact, 30 million tons of these fish are caught and processed annually to feed farmed fish. Within a decade, it is projected that the global aquaculture industry will use two-thirds of world fish meal production, and there may already be a serious fish oil shortage.86 This shortage has caused many manufacturers to substitute genetically engineered ingredients, such as corn, soy, and algae, which means more environmental degradation and a less nutritious fish for consumers. Factory fish farms toss millions of fish each year. In addition to “routine” losses due to fish spills, diseases, parasites, and other issues plague the stocks of indusof years.84 However, that figure has recently been blown trial ocean fish farms, often causing significant death out of the water – the fish feed industry is worth over tolls. The Scottish net pen industry admitted to throwing away over 10 million fish in 2016 – nearly a quarter $100 billion today.85 of its entire stock, and more than double the figure 14 l The Dangers of Industrial Ocean Fish Farm Farming Photo: Aerial view of Cooke Aquaculture’s Cypress Island facility before salmon spill (left) and after (right).Credit: Beau Garreau. from previous years.87 A single incident at a fish farm in Tasmania – caused by human error – resulted in the mass death of 30,000 juvenile farmed fish.88 These seafood corporations can simply write off these deaths as “business losses,” thus benefitting from the mortalities and having no incentive to improve their poor farming practices. Underwater factory farms are taking a significant toll on society and the economy. Mega-corporations are taking over our oceans and seafood production, which puts truly sustainable fishing communities and producers out of business. This industry has made clear that it’s willing to place profits over sustainability – forcing society to shoulder the burdens. Corporations are taking control of our oceans and seafood production. In 2015, it was reported that only a handful of corporations control nearly 20% of the global marine catch (9-13 million tons) and 40% of the largest and most valuable fish stocks, including farmed salmon and fish feed production.89 The ten largest seafood companies in the world raked in over a third of total seafood revenues, and the top 25 companies accounted for nearly half of all revenue.90 This equates to an alarming amount of power, and allows corporations to dominate business structures, production methods, and management policies within the industry – and takes away from the amount of decision-making power you have over what you eat. This power also provides corporations disproportionate influence over the dynamics of the ocean ecosystem and seafood production globally. Cooke Aquaculture – the fifth largest salmon farmer in the world, and the single largest salmon farmer outside of Norway – has its sights set on controlling America’s coastline by purchasing its competition.91 In 2016, Cooke was listed as the largest growing seafood corporation in the world.92 Cooke is the principle industrial ocean fish farming corporation in our domestic waterways, with eight Atlantic salmon facilities in Washington State, several facilities scattered throughout Maine’s waterways, and many more in the works. It seems as if Cooke may also be planning to gain control over additional stages of the seafood farming process; the corporation recently purchased Omega Protein Corporation, which was a leading provider of fish feed.93 Cooke Aquaculture’s poor maintenance of a facility in Washington State caused a catastrophic spill of more than 263,000 non-native Atlantic salmon into Puget Sound and Pacific waters.94 Cooke eventually apologized for the event after first trying to blame it on a recent solar eclipse.95 However, despite the spill and public outcry, the corporation soon thereafter moved millions more Atlantic salmon fry and eggs into other Washington State facilities (one of which was found to have structural flaws and neglected maintenance).96 What is more, a state investigation recently uncovered that Cooke significantly misled the public about the spill – “from the seriousness and cause of the initial trouble at the farm in July, to the number of fish released to Puget Sound.”97 Rather than Cooke’s figure of approximately The Dangers of Industrial Ocean Fish Farm Farming l 15 160,000 escaped fish, the actual number is at least 263,000.98 And of this number, at least 206,000 of the non-native fish are still unaccounted for (which is more than double what Cooke represented).99 In response to this misconduct, Washington State officials have canceled Cooke’s lease for the Cypress Island facility and fined the company $332,000.100 Cooke has also recently been reprimanded by state officials for repeatedly violating pollution laws by power washing its equipment in public waterways at another facility,101 and the state is being sued by Cooke for attempting to completely shutter a second operation for breaking multiple lease terms, including polluting Styrofoam debris and using missing or damaged infrastructure.102 One thing is clear: Should the status quo continue, another catastrophic fish spill is just waiting to happen. ocean fish farms. The waning native salmon populations cause direct harm to our tribal nations, who hold the native species as sacrosanct as part of their spiritual and cultural identities.104 Tribal communities located near these factory farms are directly impacted. Their fishers have been put out of work, fish processing and canning plants are being shuttered, and their local economies are suffering.105 Marine waters that are tainted by industrial fish farms are also unavailable for commercial and recreational fishing, ship traffic, renewable energy infrastructure, and tourism-related activities. These competing activities, especially tourism, generate significantly more revenue for coastal communities than industrial fish farms. Moreover, these farms are typically owned by Governments rely on corporate-controlled industrial mega-corporations that are willing to endanger the ocena fish farms to mitigate their own environmental ocean and its inhabitants in order to turn a profit. harm. Governing bodies leave a number of environmental protection and mitigation efforts to the corporation’s Working at an industrial ocean fish farm is one of the responsibility and “best management practices.”103 But world’s most dangerous jobs. The Bureau of Labor because corporations are profit driven, and often sac- Statistics recently listed aquaculture as the most dan106 rifice sustainability to save money, they largely choose gerous job in the United States. Industrial ocean fish cost-effective measures over environmentally-sound farming facilities are exposed to severe marine condioptions. Further, because these floating factory farms tions, including strong wind and wave activity from all have a disproportionate amount of control over the directions, short and steep wave patterns, strong curindustry, these decisions and business practices rents, seasonal anoxic (oxygen-lacking) conditions that become the standard for industry participants hoping can prevent operators from being able to access their cages, ranging in days to weeks.107 When operators do to compete. access the facilities, they could easily be caught in any Industrial ocean fish farms are harming local com- of the above conditions, without ready access to first mercial, tribal, and recreational fisheries, coastal aid or other treatment. Moreover, safeguards put into place at these facilities are often woefully insufficient to communities, and related economies. properly prevent injury. Industrial seafood farms damage small, family-owned fisheries, associated seafood industries, and workers. One worker at a Cooke Aquaculture facility in Maine These underwater factory farms produce the highest recently lost multiple fingers while on the job, due to amount of fish at the lowest cost possible, which places Cooke’s alleged negligence, failure to provide adequate downward pressure on fish prices across the board. safety equipment to employees, and failure to provide This reduces the price that most consumers are willing proper training.108 In 2013, an employee working on to pay all seafood products, which directly harms the a Mediterranean net pen farm was bitten by a shark, sustainable and wild-caught seafood industry. Further, which was attracted to the fish and excess feed in the industrial seafood farms threaten the integrity of wild net pens.109 Finally, in November 2017, a Nepalese net fish populations that are key to the wild-caught fishing pen worker went missing from the fish farm after a thunindustry’s success, and the coastal communities they derstorm damaged the facility.110 These are just a few examples of the workplace accidents that can – and do support. – occur at industrial ocean fish farms. Tribal nations are also experiencing strife from industrial 16 l The Dangers of Industrial Ocean Fish Farm Farming Photo: Nha Trang, Vietnam. June 23,2013. Workers are feeding barramundi fish in cage culture in the Van Phong bay in Vietnam. Credit: Getty images. Industrial ocean fish farming facilities are exposed to severe marine conditions, including strong wind and wave activity from all directions, short and steep wave patterns, strong currents, seasonal anoxic (oxygen-lacking) conditions that can prevent operators from being able to access their cages, ranging in days to weeks. The Dangers of Industrial Ocean Fish Farm Farming l 17 IV. Industrial Ocean Fish Farming in the United States Photo: Coastal net pens off the coast of Maine. Credit: Flickr.com/NOAA Industrial ocean fish farming is occurring in nearly every coastal country of the world. The countries producing the most industrially farmed finfish include China, Indonesia, Norway, and Chile.111 The U.S. has made clear that it wants to compete with these countries, and unfortunately, it has chosen to industrialize our oceans in the process. Industrial ocean fish farms are already operating in domestic waters. toward operating an enormous, multi-unit pod facility for striped bass off the coast of New York.115 To aid more startups like these, NOAA has deemed aquaculture in federally-controlled waters as a high priority for the agency and is currently allocating a significant amount of its resources toward developing domestic aquaculture production in all regions of the U.S.116 NOAA recently provided national Sea Grant funding to Hawaii company Kampachi Farms to expand its operations to the Southeastern Gulf of Mexico, which will carry out an on-site aquaculture study while it seeks a permit for commercial operations.117 NOAA also recently announced the availability of more federal Sea Grant funding, as well as a new pilot project, that will fund aquaculture operations in coastal waters of the Atlantic, Pacific, Gulf of Mexico, and even the Great Lakes.118 Industrial ocean fish farms are sited in the U.S. in both the Atlantic and Pacific oceans, and although the approved federal permitting system for these industrial farms in the Gulf of Mexico is currently the subject of litigation, a large-scale facility is preparing to commence operations there. More underwater factory farms like these are likely on the way as NOAA pushes for net pens in federal waters and states continue to permit NOAA is unlawfully regulating aquaculture without facilities closer to the shoreline. proper authority. NOAA is improperly classifying aquaculture as “fishing” under the Magnuson-Stevens Commercial net pen facilities are currently farming Fishery Conservation and Management Act (MagnusonAtlantic salmon in Maine and Washington State (where Stevens Act), 16 U.S.C. § 1801 et seq. NOAA’s definition they are not a native species), and yellowtail in Hawaii. of fishing includes “the catching, taking, or harvesting As mentioned above, Cooke Aquaculture owns and or fish,” but none of these activities involves the culturoperates the vast majority of industrial ocean fish farms ing, growing, and rearing of fish in pens in open waters in the United States. Cooke already operates a num- for eventual harvest. Simply because fish are removed ber of Atlantic salmon facilities that dominate waters in from the industrial farm’s nets at time of harvest does Washington State and Maine, and is actively looking not mean the activity is the same as fishing. Indeed, to expand.112 In Hawaii, finfish are farmed in net pen these activities are farming – just as a chicken or pig is facilities by two principle corporations: Blue Ocean raised for human consumption on a land-based farm. In Mariculture and Kampachi Farms (which is expanding fact, these industrial ocean fish farms are very similar to to the Gulf of Mexico, as detailed below).113 CAFOs on land, which the federal government defines as “an animal feeding operation where more than A number of other companies are also attempting to 1,000 ‘animal units’ … are confined at the facility…”119 startup in domestic waters. A net pen venture led by Seaworld is eying California’s waters near the Port of The conservation and management goals of the San Diego.114 Manna Fish Farms is actively working Magnuson-Stevens Act cannot be met when it is also 18 l The Dangers of Industrial Ocean Fish Farm Farming used to craft a program for industrial ocean fish farming. NOAA is forcing a square peg into a round hole, and is reaching far beyond its authority in attempting to use Magnuson to control these activities. If the agency wants to manage industrial ocean fish farming, specific legislation should be created to do so. In past years it was clear there was no collective Congressional mindset to approve legislation creating a permitting system for these farming activities. As it stands, NOAA is currently sanctioning inappropriate industrial activity in our federal waters. NOAA’s current aquaculture permitting and regulatory scheme for the Gulf of Mexico allows industrial ocean fish farms to harm the ocean and its wildlife through unsustainable and irresponsible business models, such as using net pens that allow for ample fish escapes and the free discharge of pollutants in the form of excess feed, antibiotics, fecal matter, chemicals, and parasites. NOAA should instead be working toward developing an aquaculture program that prevents these serious environmental ramifications, and impose hefty sanctions for violations. NOAA should stop regulating industrial ocean fish farming as a fishing activity under the Magnuson-Stevens Act. This takes away limited agency resources that should support and regulate fishing communities, fisheries, and wild fish stocks. Congress should take steps to explicitly remove fish farming from the definition of “fishing” under Magnuson-Stevens so that it’s unequivocally clear to NOAA that Magnuson-Stevens is not meant for regulation of fish farming activities. New legislation is needed that clearly delineates to NOAA what fish farming is and how it should be regulated. NOAA also provides funding assistance that could be used to aid sustainable farmers and fishing communities; however, industrial seafood farms have taken advantage of these programs to fund their unsustainable practices – including research grants for marine aquaculture technology and financial assistance for fish escapes and deaths that are shrouded as “losses.” Rather than subsidizing industrial seafood farming, which takes precious resources away from sustainable farmers and fishing communities, NOAA should be focusing on developing sustainable seafood production alternatives, and leveling the playing field so that these NOAA is prioritizing underwater factory farms at the sustainable producers can compete with industrial fish expense of truly sustainable fisheries. Currently, NOAA farms that corner the seafood market. is prioritizing the expansion of domestic marine aquaculture, and is already in the practice of devoting much Moreover, NOAA has made a practice of cherry-pickof its meager aquaculture budget to fostering indus- ing its science so that industrial ocean fish farming is trial fish farming practices. NOAA reports that marine portrayed in a far better light than is really the case. aquaculture “enhances coastal resiliency, creates jobs, NOAA has described net pens and cages as “dependimproves food security and human nutrition and is a able,” reported that farmed species will “thrive in the valuable tool to help rebuild some protected species open ocean environment,” noted that these industrial and habitats.” However, as detailed above, it is clear ocean farms will produce “safe and healthy seafood,” that mainstream industrial ocean fish farming is the and characterized the industrial fish feed industry as “ecologically and socio-economically sustainable.”120 problem – not the solution. But as we have provided above, none of these is true. The Dangers of Industrial Ocean Fish Farm Farming l 19 V. Solutions to Industrial Ocean Fish Farming are Available and Obtainable Seafood can be produced sustainably. Whether farmed or wild-caught, there are a number of sustainable options for seafood production that that can continue to meet demands while producing little to no pollution, restoring the ocean ecosystem, protecting wild fish populations, and sustaining local fishing communities. Many of these alternatives are already in use, but simply cannot compete with large-scale, industrial ocean fish farms. of open-source, do-it-yourself plans and resources, including classes, so you can find everything you need to join the movement. In response to the surge of industrial ocean fish farms in British Columbia’s waterways, the Namgis First Nation began farming Atlantic salmon in land-based systems to prove that it can be done without environmental harm. Their facility is called Kuterra – a combination of the Namgis People’s word for salmon (kutala) and land (terra) – and it keeps wild salmon and the waters they live in separate from farming, to grow good quality, healthy farmed fish. Like its fish harvests, the facility itself is thriving: Kuterra produced 3,000 metric tons of fish this year and is expected to break even after less than two years of operations. In case others want to start their own operations, Kuterra is open-sourced and has all of its plans and industry specs posted on its website (www.kuterrra.com) so others can access exactly what they need to get started. There are agro-ecological solutions by farming fish in tanks on land. Land-based recirculating aquaculture systems are closed-loop facilities that continuously filter and recycle water, which requires a small amount of water and releases little to no pollution. Other benefits include biosecurity, as facilities can operate without the addition of antibiotics or chemicals, and space and production efficiency. They can also be operated in tandem with aquaponics – the practice of growing plants using nutrient-rich water. Plants grown in aquaponics systems include algae, seaweeds, basil, okra, lettuce, watermelon, mint, chives, tomatoes, cantaloupe, cucumber, When done well, capture fisheries can continue to proflowers, squash, bok choy, collard greens, sorrel, and duce seafood humanely without harming the ocean arugula, among many others. or its inhabitants. Wild-caught fisheries have been in operation for centuries, and if managed responsibly, Today there are a growing number of successful, recir- can continue to produce healthy, sustainable seafood culating inland fish farm systems. Indeed, according to options for consumers. Sustainable wild fishing can be a recent markets report on land-based fish farming, the achieved with slight modifications to fishing gear and technology has progressed more quickly than expected procedures that increase selectivity for target fish speso that operating a full-scale recirculating farm has cies and reduce bycatch for other species. With these “never looked better” for start-up costs, production equipment and technique variations, fishing commuyield, and profitability.121 nities can operate in ways that allow wildlife to thrive, while still sustaining their industry and livelihood. Recirculating Farms Coalition fosters the development of healthy, natural, and community-based ways to grow A number of organizations have developed resources fresh food. They use closed-loop, land-based farms for consumers to consult in purchasing wild-caught that can grow plants (hydroponics), fish (aquaculture), seafood. These consumer guides research and evalor plants and fish (aquaponics). Their approach to uate environmental impacts of certain fishing activities farming creates green jobs and food security in every to determine which species should be avoided. The community in the United States by focusing on plac- Monterey Bay Aquarium (MBA) regularly updates its ing localized farms in communities and urban areas, Seafood Watch program to provide free guidance to which decreases fuel for transporting food, and pro- consumers, and even has regionally specific pocket vides consumers with fresher, more affordable food. guides.122 MBA analyzes a number of environmental The Coalition’s recirculating farm systems re-use their impacts from wild-caught fishing to make its recommenwater, recycle their waste, utilize renewable energy, dations, including overfishing, illegal fishing, bycatch, and run on very little to no additives, including zero habitat damage, and government oversight programs. antibiotics or other drugs or chemicals. Recirculating Visit www.seafoodwatch.org to find out which seafood Farms Coalition also provides on its website (http:// has a lesser impact on the environment. www.recirculatingfarms.org/links/) free online materials 20 l The Dangers of Industrial Ocean Fish Farm Farming Photo: Fish farming in Myrtoan Sea Credit: Shutterstock Greenpeace also provides free seafood guides for consumers on global and regional levels. The organization’s Red List guides provide scientifically compiled lists of marine species that, for a variety of reasons, should not be made commercially available. Greenpeace looks at various issues, including low stock populations, disruption of the marine food chain, and irresponsible fishing or farming practices that contribute to the destruction of our ocean ecosystem.123 Greenpeace also provides direct links to reputable fish guides from a number of organizations, including the Marine Conservation Society, Forest & Bird, the Australian Marine Conservation Society, and Seafood Choices Alliance.124 provides an integrated, 12-step approach that involves maintaining the natural and unique structure, function, and productivity of each ocean ecosystem in which fisheries operate, and applies science-based models to eliminate harmful fishing techniques such as bottom-trawling, reduce bycatch, and allow wild fish populations to thrive.125 National Geographic Society also works to end “fish factories” and educate the public on ways to make wild-caught fishing more sustainable through technology and fisheries management.117 Some of these sustainable fishing practices include selective, seasonal fishing that allows fish stocks to replenish naturally; strictly avoiding protected areas such as coral reefs; and techniques that avoid waste and bycatch, Advancements in fishing techniques and equipment such as hook-and-line, spearfishing, and cast net can also lead to an even more sustainable wild-caught methods.126 fishing industry. A number of organizations and industry participants are devoted to preventing harm to the Advancements in fishing gear and technologies can ocean from wild-caught fishing while fostering the also help wild-caught fishing be more sustainable. For development of the industry. example, the Burns brothers, longtime fishermen and Ecosystem-based management of capture fisheries has gained traction in many sectors, and has proven effective in working closely with fishing communities to achieve truly sustainable seafood production and better conditions for workers. The World Wildlife Fund cattle farmers, have developed a new fishing vessel that is not only environmentally friendly, but also more humane for fish and safer for workers.127 Blue North is designed to catch Pacific cod using the bottom longline method, which has been rated the greenest, “best choice” catch method.128 The Dangers of Industrial Ocean Fish Farm Farming l 21 Certain ocean-based systems may also sustainably farm seafood. 3-Dimensional ocean farms operate in the ocean, but utilize an entire water column to grow vertical lines of kelp and seaweed interspersed with hanging nets of scallops and mussels, with oyster cages and clams below that. These farms have the potential to be sustainable models, as kelp can absorb five times more carbon than land-based plants, and both the kelp and oysters process nitrogen as they grow. When these farms are designed well and operated sustainably, they can restore rather than deplete our oceans while growing food and fertilizer. where or how fish are being farmed. The industry surge has led to a significantly higher demand for feed, and as a result, forage fish species are being overfished to the brink of extinction to source fish meal and fish oil - the primary ingredients in feed. With an eye toward higher profits, many fish farmers have begun substituting fish meal and oil with cheaper ingredients, such as genetically modified corn and soy. Not only does this result in a less healthy and happy fish, but it also provides consumers with less nutritious seafood. Greenwave is a farmer and fisher-run organization based in the U.S. that works with seafood producers to develop and implement 3D, column-based aquaculture models.129 Greenwave is dedicated to building a truly blue-green economy that creates jobs, mitigates climate change, and grows healthy food for local communities. Their 3D farming models require zero inputs, sequester carbon, and rebuild reef ecosystems, all while producing high yields with a very small footprint. They’re also open source and widely obtainable: anyone with around 20 acres, a boat, and $20,000 can be up and running within a year.130 Thankfully, when used in conjunction with a sustainable fish farming model such as land-based, recirculating systems, there are solutions to nutritiously feeding farmed fish that will not contribute to wiping out forage fish and devastating the ocean ecosystem. Many of these methods involve using insects and non-GMO plants and single-cell organisms like yeast, bacteria, and algae. A number of companies are successfully bringing in millions of dollars for researching the production of sustainable, alternative fish feed production from black soldier fly larvae and other insects.131 Researchers are also reporting that sustainably harvested jellyfish – which have bloomed into overpopulation as a result of Carnivorous, farmed finfish can be fed sustainably. Feed global warming – can be used for nutritious, alternative for farmed fish presents serious problems regardless of fish feed.132 Photo: Sea fish farm. Cages for fish farming dorado and seabass. Credit: Shutterstock 22 l The Dangers of Industrial Ocean Fish Farm Farming Studies have proven that at least eight species of carnivorous fish can thrive on these alternative sources of feed: white sea bass, walleye, rainbow trout, cobia, arctic char, yellowtail, Atlantic salmon and coho salmon.133 There are market-based solutions that will support sustainable seafood. One of the most successful ways to get the seafood industry to shift toward more sustainable production is by increasing the demand for sustainable seafood options. Seafood suppliers, such as grocery stores, markets, and restaurants, should adopt sustainable seafood sourcing policies that are dedicated to purchasing and supplying seafood only from fish farms and capture-fisheries with truly sustainable methods (like recirculating, land-based farms, 3D ocean farms, and environmentally-friendly capture fishers). Consumers can increase demand for sustainable seafood by omitting industrially farmed fish from their diets. Eating smaller or herbivorous fish (and opting for seafood that is produced sustainably, whether farmed or wild-caught, are some ways to contribute to positive, market-based change. Recommendations and Next Steps: • Congress should explicitly remove fish farming from the definition of fishing in the MagnusonStevens Fishery Conservation and Management Act, and pass new legislation that clearly delineates to NOAA what fish farming is and how it should be regulated. • NOAA should stop regulating industrial ocean fish farming as a fishing activity, and develop an aquaculture program that supports truly sustainable fish farming practices, prevents environmental harm from fish farming, and imposes hefty sanctions for violations. • Governing officials should undertake each of the policy recommendations made by the Center for a Livable Future in Ecosystem and Public Health Risks from Nearshore and Offshore Finfish Aquaculture (2017), including increased testing, reporting, and monitoring requirements and development of separate aquaculture regulatory and promotion programs within federal and state governments.134 • A moratorium should be imposed on new marine finfish farms at the state and federal level until the above recommendations are fully implemented. • Prior to purchasing seafood, cosumers and suppliers should consult sustainable seafood guides for recommendations on choices that pose less environmental impacts. Check out www.seafoodwatch.org to get started. The Dangers of Industrial Ocean Fish Farm Farming l 23 VI. Endnotes 1 World Bank, “FISH TO 2030 Prospects for Fisheries and Aquaculture” at 4-5 (2013) www.fao.org/docrep/019/i3640e/i3640e.pdf. 2 Ibid. 3 Food and Agriculture Organization of the United Nations, “The State of World Fisheries and Aquaculture: Opportunities and Challenges” at 90 (2016) http://www. fao.org/3/a-i5555e.pdf; Janet Larsen & J. Matthew Roney, Earth Policy Institute, “Farmed Fish Production Overtakes Beef” (June 12, 2013) http://www.earth-policy.org/ plan_b_updates/2013/update114. 4 FISH TO 2030, supra note 1 at 4-5. 5 Food and Agriculture Organization of the United Nations, “National Aquaculture Sector Overview: United States of America” (last visited Jan. 5, 2018) http://www.fao. org/fishery/countrysector/naso_usa/en. 6 Alison Morrow, King 5 News, “Forage fish indicate ecosystem changes that impact orcas” (Dec. 1, 2017) http://www.king5.com/article/tech/science/environment/ forage-fish-indicate-ecosystem-changes-that-impact-orcas/495916463. 7 Rob Edwards, The Sunday Herald, “‘Cover-up’ claim over ban on fish farm pesticide” (Nov. 5, 2017) http://www.heraldscotland.com/news/ environment/15641686.___Cover_up____claim_over_ban_on_fish_farm_pesticide/. 8 Rob Edwards, The Sunday Herald, “Scottish government accused of colluding with drug giant over pesticides scandal” (June 2, 2017) http://www.heraldscotland.com/ news/15326945.Scottish_government_accused_of_colluding_with_drug_giant_over_ pesticides_scandal/. 20 International Center for Technology Assessment, “Biopollution and Invasive Species” (last visited Jan. 8, 2018) http://www.icta.org/global-warming-and-the-environment/ biopollution-invasive-species/; USDA, Invasive Species & Pests (last visited Jan. 8, 2018) https://www.nrcs.usda.gov/wps/portal/nrcs/main/national/plantsanimals/invasive/. 21 Federal Clean Water Act, 33 U.S.C. §1251 et seq.; Press Release, Wild Fish Conservancy, “Wild Fish Conservancy Files Citizen Suit Against Cooke Aquaculture under the Clean Water Act” (Nov. 13, 2017) http://wildfishconservancy. org/13nov2017pressrelease/at_download/file. 22 Ariel Scotti, Daily News, “Thousands of salmon escape from fish farm, and no one knows what will happen next” (Aug. 24, 2017) http://www.nydailynews.com/news/ national/thousands-salmon-escaped-fish-farm-no-article-1.3439097. 23 Lynda Mapes, The Seattle Times, “Escaped Atlantic salmon found 42 miles up Skagit River” (Dec. 12, 2017) https://www.seattletimes.com/seattle-news/environment/ escaped-atlantic-salmon-found-42-miles-up-skagit-river. 24 Alina Fisher, John Volpe, & Jason Fisher, “Occupancy dynamics of escaped farmed Atlantic salmon in Canadian Pacific coastal salmon streams: implications for sustained invasions,” Biol. Invasions. 16(10) at 2137–2146 (2014) https://link.springer.com/ article/10.1007/s10530-014-0653-x. 25 Jan Arge Jacobsen & Lars Petter Hansen, “Feeding habits of wild and escaped farmed Atlantic salmon, Salmo salar L., in the Northeast Atlantic,” ICES Journal of Marine Science 58 at 916–933 (2001) https://academic.oup.com/icesjms/articlepdf/58/4/916/6756187/58-4-916.pdf. 26 John Volpe et al. “Competition among juvenile Atlantic salmon and steelhead: relevance to invasion potential in British Columbia,” Can. J. Fish. Aquat. Sci. 58 at 197–207 (2001) http://69.90.183.227/doc/articles/2007/A-00533.pdf. 27 Lynda V. Mapes, Seattle Times, “Fish farm caused Atlantic salmon spill near San Juans, then tried to hide how bad it was, state says” (Jan. 30, 2018) https://www.seattletimes.com/seattle-news/ fish-farm-caused-atlantic-salmon-spill-state-says-then-tried-to-hide-how-bad-it-was/. 9 Hites R, et al. “Global Assessment of Organic Contaminants in Farmed Salmon” Science 303(5655) at 226-229 (2004) https://www.preventivecare.com/shared/pdf/ GlobalAssessmentSalmon-Hites.pdf. 28 Ibid. 10 Kari Hamerschlag, Environmental Working Group, “Meat Eater’s Guide to Climate Change + Health” at 17 (2011) https://static.ewg.org/reports/2011/meateaters/pdf/ report_ewg_meat_eaters_guide_to_health_and_climate_2011.pdf. 29 Lynda V. Mapes, Seattle Times, “Washington musters fisher posse to kill Atlantic salmon that fled pen” (Aug. 22, 2017) http://www.thenewstribune.com/news/local/article168636307.html. 11 United Nations, “Frontiers 2017: Emerging Issues of Environmental Concern” at 15 (2017) https://www.unenvironment.org/resources/frontiers. 30 Mapes, supra note 27. 12 Patrik Henriksson et al. “Unpacking factors influencing antimicrobial use in global aquaculture and their implication for management: a review from a systems perspective,” Sustain. Sci. (2017) https://link.springer.com/content/ pdf/10.1007%2Fs11625-017-0511-8.pdf. 31 Lynda V. Mapes, Seattle Times, “Despite agency assurances, tribes catch more escaped Atlantic salmon in Skagit River” (Dec. 1, 2017) https://www.seattletimes.com/seattle-news/environment/ despite-agency-assurances-tribes-catch-more-escaped-atlantic-salmon-in-skagit-river/. 13 Press Release, WorldFish “Research highlights antimicrobial resistance risk in aquaculture” (Nov. 21, 2017) https://www.worldfishcenter.org/content/ research-highlights-antimicrobial-resistance-risk-aquaculture. 32 Mapes, supra note 23. 14 Frontiers 2017, supra note 11 at 15. 15 Blog, Allison Guy, Oceana, “With record antibiotic use, concerns mount that Chile’s salmon farms are brewing super bugs” (Aug. 1, 2016) http://oceana.org/blog/ record-antibiotic-use-concerns-mount-chile%E2%80%99s-salmon-farms-are-brewingsuperbugs#. 33 Goldburg, Rebecca J. et al.Pew Oceans Commission, “Marine Aquaculture in the United States: Environmental Impacts and Policy Options,” at 13 (2001) https://fse.fsi. stanford.edu/sites/default/files/marine_aquaculture_pew_2001.pdf. 34 MacGarvin, M., Scotland: World Wildlife Fund, “Scotland’s secret? Aquaculture, nutrient pollution eutrophication and toxic blooms” (2000) http://s3.spanglefish. com/s/35331/documents/macgarvin_2000_scotlands_secret.pdf. 35 Goldburg, supra note 33. 16 Frontiers 2017, supra note 11 at 15. 17 Tim Ellis et al., “Development of Scottish Salmon Farming: An example of Sustainable Intensification?” Aquaculture 458 at 82-99 (2016) https://www.sciencedirect.com/science/article/pii/S0044848616300618#. 18 Rosamond Naylor et al., “Fugitive Salmon: Assessing the Risks of Escaped Fish from Net-Pen Aquaculture” BioScience 55(5) at 427-427 (2005) https://academic.oup.com/ bioscience/article-pdf/55/5/427/19414120/55-5-427.pdf. 19 Sten Karlsson, et al. “Widespread genetic introgression of escaped farmed Atlantic salmon in wild salmon populations” ICES Journal of Marine Science, 73(10) at 2488-298 (2016) https://doi.org/10.1093/icesjms/fsw121. 24 l The Dangers of Industrial Ocean Fish Farm Farming 36 EPA cite found in current note 34. 37 South Coast Today, “Sea Floor Still Toxic in Shelburne, NS” (July 8, 2013) http://asf.ca/ sea-floor-still-toxic-in-shelburne-ns.html. 38 EPA, “Aquatic Life Fact Sheets for Zinc” (last visited Jan. 8, 2018) https://www.epa.gov/ sites/production/files/2015-06/documents/ny_al_433_03121998.pdf. 39 Duruibe, J.O. et al., “Heavy metal pollution and human biotoxic effects,” International Journal of Physical Sciences 2(5) at 112-118, 116 (2007) http://www.academicjournals. org/article/article1380209337_Duruibe%20et%20al.pdf. 40 D. Johansson, et al. “The influence of the pycnocline and cage resistance on current flow, oxygen flux and swimming behaviour of Atlantic salmon (Salmo salar L.) in production cages,” Aquaculture, 265(1–4), 271–287 (2007) http://agris.fao.org/agris-search/ search.do?recordID=US201300767598. 60 Ibid at 441. 41 Hamerschlag, supra note 10 at 8; Meat Eater’s Guide: Report, “Climate and Environmental Impacts,” Fig. 1. Full Lifecycle Greenhouse Gas Emissions from Common Proteins and Vegetables (2011) https://www.ewg.org/meateatersguide/a-meat-eaters-guide-to-climate-change-health-what-you-eat-matters/ climate-and-environmental-impacts/. 62 Iowa State University, Center for Food Security & Public Health, “Infectious Salmon Anemia” (2010) http://www.cfsph.iastate.edu/Factsheets/pdfs/infectious_salmon_anemia.pdf. 42 Benedikt Buchspies, et al., “Life Cycle Assessment of High-Sea Fish and Salmon Aquaculture” at 12 (2011) http://esu-services.ch/fileadmin/download/buchspies-2011LCA-fish.pdf. 64 Marcos G. Godoy, et al. “Genetic analysis and comparative virulence of infectious salmon anemia virus (ISAV) types HPR7a and HPR7b from recent field outbreaks in Chile,” Virology Journal 11:204 (2014) https://www.ncbi.nlm.nih.gov/pmc/articles/ PMC4272776/pdf/12985_2014_Article_204.pdf. 43 Stuart Bunting & Jules Pretty, Centre for Environment and Society, Department of Biological Sciences, University of Essex, Aquaculture Development and Global Carbon Budgets: Emissions, Sequestration, and Management Options,” at 3 (2007) http://www. fcrn.org.uk/sites/default/files/Aquaculture_development_and_Carbon_budgets.pdf. 44 Ibid. 45 Seafish, “Greenhouse Gas Emissions in Seafood” at 3 (2014) http://www.seafish.org/ media/publications/SeafishGuidetoGHGEmissionsinSeafood_201409.pdf. 46 Lamont-Doherty Earth Observatory, Columbia University, “What is Ocean Acidification & Why Does it Matter?” (2015) http://www.ldeo.columbia.edu/ news-events/what-ocean-acidification-why-does-it-matter. 47 National Geographic, Ocean Acidification (Apr. 27, 2017) https://www.nationalgeographic.com/environment/oceans/critical-issues-ocean-acidification/. 48 Buchspies, supra note 42 at 12. 49 NOAA, “What is ocean acidification? (last visited Jan. 8, 2018) https://oceanservice. noaa.gov/facts/acidification.html. 50 N.R. Bates et al. “A time-series view of changing ocean chemistry due to ocean uptake of anthropogenic CO2 and ocean acidification,” Oceanography 27(1), at 127 (2014) https://tos.org/oceanography/assets/docs/27-1_bates.pdf. 51 Sena S De Silva & Doris Soto, “Climate change and aquaculture: potential impacts, adaptation and mitigation,” FAO Fisheries and Aquaculture Technical Paper. No. 530, at 151-212, 175 (2009) www.fao.org/docrep/012/i0994e/i0994e04.pdf. 61 Ibid. 63 Ibid. 65 Amy Smart, Montreal Gazette, “Sample of B.C. farmed-salmon ‘blood water’ tests positive for virus: critic” (Nov. 29, 2017) http://www.montrealgazette.com/news/world/ sample+farmed+salmon+98blood+water+tests+positive+virus/16006054/story.html. 66 R.T. Kongtorp et al., “Longitudinal study of a natural outbreak of heart and skeletal muscle inflammation in Atlantic salmon Salmo salar L.,” J. Fish. Dis. 29 at 233–44 (2006) https://www.ncbi.nlm.nih.gov/pubmed/16635063. 67 Alexandra Morton & Richard Routledge, “Risk and precaution: Salmon farming,” Marine Policy 74 at 205-212 (2016) https://ac.els-cdn.com/S0308597X16304390/1s2.0-S0308597X16304390-main.pdf?_tid=55b1a98c-dc5c-11e7-83d8-00000 aacb35f&acdnat=1512767667_9fbc704200790fd11656dceeee2c685d. 68 Alexandra Morton et al. “The effect of exposure to farmed salmon on piscine orthoreovirus infection and fitness in wild Pacific salmon in British Columbia, Canada,” PLOS ONE (2017) http://journals.plos.org/plosone/article/file?id=10.1371/journal. pone.0188793&type=printable. 69 Ash Kelly, CBC News, “New research suggests wild salmon exposed to fish farms have ‘much higher’ rate of viral infection” (Dec. 13, 2017) http://www.cbc.ca/news/canada/ british-columbia/new-research-suggests-wild-salmon-exposed-to-fish-farms-havemuch-higher-rate-of-viral-infection-1.4446839. 70 Mark Costello, “How sea lice from salmon farms may cause wild salmonid declines in Europe and North America and be a threat to fishes elsewhere,” Proceedings of the Royal Society B 276 at 3385-3394 (2009) http://rspb.royalsocietypublishing.org/content/ royprsb/276/1672/3385.full.pdf. 52 Dr. Chase Williams, NOAA, “Ocean Acidification: Salmon and the Puget Sound” (2017) https://vimeo.com/246011446?utm_medium=email&utm_source=govdelivery. 71 Morton & Routledge, supra note 67 at 208. 53 Alan Barton et al., “The Pacific oyster, Crassostrea gigas, shows negative correlation to naturally elevated carbon dioxide levels: Implications for near-term ocean acidification effects,” Limnol. Oceanogr., 57(3), 698–710 (2012) http://onlinelibrary.wiley.com/ doi/10.4319/lo.2012.57.3.0698/pdf. 72 Jenny Hjul, Fish Farmer Magazine, “Sea lice battle boosted by 1.76m grant” at 17 (2016) https://www.fishupdate.com/sea-lice-battle-boosted-by-1-76m-grant/. 54 Alastair Bland, KCET, “Ocean Acidification Makes Shellfish Suffer, Too” (Mar. 28, 2017) https://www.kcet.org/shows/earth-focus/ ocean-acidification-makes-shellfish-suffer-too. 55 Gazeau, F. et al., “Effect of ocean acidification on the early life stages of the blue mussel Mytilus edulis,” Biogeosciences, 7, 2051–2060 (2010) https://www.biogeosciences. net/7/2051/2010/bg-7-2051-2010.pdf. 56 Daiju Narita et al., “Economic Costs of Ocean Acidification: A Look into the Impacts on Shellfish Production, Climatic Change” ESRI Working Paper No. 391 (2012) https:// www.econstor.eu/bitstream/10419/50154/1/662315529.pdf. 57 Christopher Burrell, New England Center for Investigative Reporting, “Ocean acidification threatens Massachusetts shellfish industry” (2017) https://www.necir. org/2017/06/22/ocean-acidification-threatening-massachusetts-shellfish-industry/. 58 George Lapointe, Marine Fisheries and Ocean Policy Consultant to the Northeast Regional Ocean Council, “Overview of the Aquaculture Sector in New England” at 7 (2013) http://georgelapointeconsulting.com/uploads/3/4/3/4/34346476/aquaculture_review_paper.pdf. 59 Stephanie Yue Cottee & Paul Petersan, “Animal Welfare and Organic Aquaculture in Open Systems” J. Agric. Environ. Ethics Vol 22 at 437-461, 440 (2009) http://www. humanesociety.org/assets/pdfs/farm/organic_aquaculture.pdf. 73 Patrick Whittle, Chicago Tribune, “Sea lice are disrupting the world’s salmon industry” (Sept. 18, 2017) http://www.chicagotribune.com/lifestyles/health/ct-sea-lice-salmonindustry-20170918-story.html. 74 Stian Mørch Aaen et al, “Drug resistance in sea lice: a threat to salmonid aquaculture,” Trends Parasitol. 31(2): 72-81 (2015) https://www.sciencedirect.com/science/ article/pii/S1471492214002098. 75 Dr. Nerissa Hannink, University of Melbourne, “Farmed Salmon Are Deaf – And Now We Know Why” (2017) https://pursuit.unimelb.edu.au/articles/ farmed-salmon-are-deaf-and-now-we-know-why. 76 Caleb Jones, U.S. News, “APNewsBreak: Rare Monk Seal Dies in Fish Farm off Hawaii” (Mar. 17, 2017) https://www.usnews.com/news/news/articles/2017-03-17/ apnewsbreak-rare-hawaiian-seal-dies-at-federal-marine-site. 77 Meghan Thomas, CBC News, “2nd humpback death in 2 weeks worries experts, farmed salmon industry” (Nov. 30, 2016) http://www.cbc.ca/news/canada/ british-columbia/humback-whale-deaths-1.3874915. 78 Julia Horton, The Sunday Times, “Fish farms under fire for seal death toll” (Oct. 22, 2017) https://www.thetimes.co.uk/article/ fish-farms-under-fire-for-seal-death-toll-ph5kqwdtq. 79 Undercurrent News, “Scottish salmon farmers shooting more seals in 2017” (Oct. 23, 2017) https://www.undercurrentnews.com/2017/10/23/scottish-salmon-farmersshooting-more-seals-in-2017/. The Dangers of Industrial Ocean Fish Farm Farming l 25 80 Jeff Matthews, Huffington Post, “Seals And Sea Lions Pay The Price For B.C. Salmon Farming” (Apr. 12, 2017) http://www.huffingtonpost.ca/jeff-matthews/salmon-farmsbc_b_9656554.html. 81 Rebecca J. Goldburg et al. “Marine Aquaculture in the United States: Environmental Impacts and Policy Options,” Prepared for the Pew Oceans Commission, Fig. 5, (2001) https://fse.fsi.stanford.edu/sites/default/files/marine_aquaculture_pew_2001.pdf. 82 Jenny Hjul, Fish Update, “Global aquafeed worth $70 billion by 2022” (Nov. 13, 2017) https://www.fishupdate.com/global-aquafeed-worth-70-billion-2022/. 93 Mapes, supra note 27. 94 Cooke Aquaculture, “Statement on Failed Cypress Farm #2” (Sept. 6, 2017) http:// www.cookeseafood.com/cms/wp-content/uploads/2017/09/Statement-on-CypressFarm-September-6-2017.pdf; Mapes, supra note 29. 95 Nathan Pilling, K5 News, “State finds structural flaws in Cooke net pens off Bainbridge” (Oct. 10, 2017) http://www.king5.com/article/tech/science/environment/ state-finds-structural-flaws-in-cooke-net-pens-off-bainbridge/481987779. 96 Mapes, supra note 27. 83 Colin Ley, Ag Funder News, “Aquaculture’s $100bn Feed Challenge Presents Big Opportunity for Entrepreneurs” (Apr. 19, 2017) https://agfundernews.com/aquacultures-100bn-feed-challenge-will-require-20-30-new-alternatives-this-century.html. 97 Ibid. 84 Ibid. 98 Ibid. 85 Goldberg, supra note 81 at 11. 99 Ibid. 86 Rob Edwards, Herald Scotland, “A disgrace: Ten million salmon thrown away by fish farm industry in last year alone” (Oct. 8, 2017) http://www.heraldscotland.com/ news/15583156.A_disgrace__Ten_million_salmon_thrown_away_by_fish_farm_ industry_in_last_year_alone/. 100 Brian Kelly, Bainbridge Island Review, “Cooke Aquaculture Pacific fined by state for polluting water at Bainbridge Island fish pen operation” (Dec. 14, 2017) https://www. bainbridgereview.com/news/cooke-aquaculture-pacific-fined-by-state-for-polluting-water-at-bainbridge-island-fish-pen-operation/. 87 Rob Inglis, Bendigo Advertiser, “Tassal confirms deaths of 30,000 fish at Okehampton Bay site” (Jan. 8, 2018) http://www.bendigoadvertiser.com.au/story/5156457/ tassal-confirms-mass-fish-deaths/. 101 Undercurrent News, “Cooke sues state of Washington to save fish farm’s lease” (Jan. 5, 2018) https://www.undercurrentnews.com/2018/01/05/cooke-to-file-suit-to- 88 Henrik Österblom et al., Plos One, Transnational “Corporations as ‘Keystone Actors’ in Marine Ecosystems” (2015) http://journals.plos.org/plosone/article?id=10.1371/journal. pone.0127533. 89 Undercurrent News, “World’s 100 Largest Seafood Companies” (Oct. 7, 2016) https://www.undercurrentnews.com/report/ undercurrent-news-worlds-100-largest-seafood-companies-2016/. 90 Tom Seaman, Undercurrent News, “World’s top 20 salmon farmers: Mitsubishi moves into second place behind Marine Harvest” (June 29, 2016) https://www. undercurrentnews.com/2016/06/29/worlds-top-20-salmon-farmers-mitsubishi-movesinto-second-place-behind-marine-harvest/; Aslak Berge, Undercurrent News, “These are the world’s 20 largest salmon producers” (July 30, 2017) http://salmonbusiness.com/ these-are-the-worlds-20-largest-salmon-producers/. 91 World’s 100 Largest Seafood Companies, supra note 89. 92 Press Release, Cooke Inc., “Cooke Inc. Acquires Omega Protein Corporation” (Dec. 19, 2017) http://www.cookeseafood.com/cms/wp-content/uploads/2017/12/Cookeacquires-Omega-For-Immediate-Release-Dec-19-2017.pdf. stop-farm-dismantling/. 102 Nathan Pilling, K5 News, “State finds structural flaws in Cooke net pens off Bainbridge” (Oct. 10, 2017) http://www.king5.com/article/tech/science/environment/ state-finds-structural-flaws-in-cooke-net-pens-off-bainbridge/481987779. 103 NOAA, Technical Memorandum NMFS-NWFSC-49, “Common Questions about Atlantic Salmon Net Pen Aquaculture” at 2 (Jan. 2016) http://websrv2.clallam.net/ tm_bin/tmw_cmd.pl?tmw_cmd=FileOp&shl_opt=download&shl_case_no=SHR201600002&shl_id=SHR2016-00002&shl_docfile=EX+6C. 104 Columbia River Inter-Tribal Fish Commission, “Salmon Culture” (last visited Dec. 13, 2017) http://www.critfc.org/salmon-culture/tribal-salmon-culture/ 105 Ellis O’Neill, Oregon Public Broadcasting, “In The Future We Might Farm Fish On Land Instead Of In The Sea” (Dec. 1, 2017) https://www.opb.org/news/article/ future-farming-fish-overland/. 106 Blog, Bureau of Labor Statistics, “Most Dangerous Jobs?” (June 27, 2017) https:// blogs.bls.gov/blog/2017/06/27/most-dangerous-jobs/. 107 Congressional Research Service, “Open Ocean Aquaculture” at 6 (2004) http:// research.policyarchive.org/182.pdf. Friends of the Earth U.S. Washington, D.C. 1101 15th Street NW, 11th Floor Washington, D.C. 20005 Berkeley, California 2150 Allston Way, Suite 360 Berkeley, California 94704 Please visit us at www.foe.org The Dangers of Industrial Ocean Fish Farming. 2018 26 l The Dangers of Industrial Ocean Fish Farm Farming 108 Judy Harrison, WGME News, “Maine man sues salmon farms over loss of fingers” (Oct. 16, 2017) http://wgme.com/news/local/maine-man-sues-salmon-farms-over-lossof-fingers. 120 NOAA, “Offshore Aquaculture in the United States: Economic Considerations, Implications & Opportunities” (2008) http://www.nmfs.noaa.gov/aquaculture/docs/ economics_report/econ_report_all.pdf. 109 Dutch Shark Society, “Sharks and Fish Farms: a Bad Combination?” (Oct. 3, 2013) http://www.dutchsharksociety.org/sharks-and-fish-farms-a-bad-combination/. 121 Amy Smart, The Times Colonist, “Are land-based fish farms a financially viable option?” (Dec. 3, 2017) http://www.timescolonist.com/life/islander/ are-land-based-fish-farms-a-financially-viable-option-1.23111387. 110 Lee Hooi Boon, The Sun Daily, “Nepalese worker goes missing from fish farm after thunderstorm” (Nov. 5, 2017) http://www.thesundaily.my/news/2017/11/05/ nepalese-worker-goes-missing-fish-farm-after-thunderstorm. 122 Monterey Bay Aquarium, “Seafood Watch Standard for Fisheries” (Dec. 20, 2016) http://www.seafoodwatch.org/-/m/sfw/pdf/criteria/mba_seafood%20 watch_fisheries%20standard_version%20f3.2.pdf?la=en. 111 Food and Agriculture Organization of the United Nations, “The State of World Fisheries and Aquaculture” at 29 (2016) http://www.fao.org/3/a-i5555e.pdf. 123 Greenpeace, “Red List Fish” (last visited Jan. 8, 2018) http://www.greenpeace.org/ usa/oceans/sustainable-seafood/red-list-fish/. 112 Cooke has applied for a new industrial ocean fish farm site in Port Angeles, Washington and has recently acquired two seafood companies – Icicle Foods and Omega Protein. Cooke Seafood, Expansion (last visited Jan. 8, 2018) http://www.cookeseafood.com/tag/expansion/. 124 Greenpeace, “Alternative Fish Guides” (Mar. 20, 2014) http://www.greenpeace.org/ international/en/campaigns/oceans/which-fish-can-I-eat/alternative-fish-guides/#a0. 113 Kampachi Farms, LLC, Ocean’s Finest Fish (last visited Jan. 8, 2018) http://www. kampachifarm.com/; Blue Ocean Mariculture, Hawaiin Kanpachi (last visited Jan. 8, 2018) http://www.bofish.com/. 114 Parimal Rohit, The Log, “Offshore fish farm highlights latest round of Blue Economy pilot programs” (Nov. 9, 2017) http://www.thelog.com/local/ offshore-fish-farm-highlights-latest-round-of-blue-economy-pilot-programs/. 115 Kate Riga, 27 East News, “First Big Piece Of Fish Farm Puzzle Arrives On East End” (Sept. 6, 2017) http://www.27east.com/news/article.cfm/East-Quogue/532310/ First-Big-Piece-Of-Fish-Farm-Puzzle-Arrives-On-East-End. 116 NOAA, “Grant Funds Available for Regional Aquaculture Pilot Projects” (Dec. 1, 2017) https://www.fisheries.noaa.gov/feature-story/grant-funds-available-regional-aquaculture-pilot-projects (announcing availability of federal funds for finfish aquaculture projects through the Atlantic, Gulf, and Pacific States Marine Fisheries Commissions); NOAA, “National Sea Grant College Program 2018 Ocean, Coastal and Great Lakes National Aquaculture Initiative” (Dec. 14, 2017) https://www.grants.gov/web/grants/ view-opportunity.html?oppId=299412 (describing competition for grants of federal funds to the “U.S. ocean, coastal and Great Lakes aquaculture sector” for, inter alia, “the aquaculture of ocean, coastal, or Great Lakes fish”). 125 Chris Grieve & Katherine Short, World Wildlife Fund, “Implementation of Ecosystem-Based Management in Marine Capture Fisheries” (2007) http://d2ouvy59p0dg6k.cloudfront.net/downloads/wwf_ebm_toolkit_2007.pdf. 126 National Geographic Society, “Sustainable Fishing” (last visited Jan. 8, 2018) https:// www.nationalgeographic.org/encyclopedia/sustainable-fishing/. 127 Clare Leschin-Hoar, National Public Radio, “Will Fish Get A Humanely Harvested Label? These Brothers Bet $40 Million on It” (June 14, 2017) https://www.npr.org/sections/thesalt/2017/06/14/532845573/ will-fish-get-a-humanely-harvested-label-these-brothers-bet-40-million-on-it. 128 The Burns Brothers’ ship incorporates a controlled capture area to protect the crew from falling overboard, and a stun table that is used for the fish immediately after harvest. Blue North, http://bluenorth.com/home/#/ (last visited Dec. 13, 2017) 129 Grenwave, https://www.greenwave.org/greenwaveorg/ (last visited December 13, 2017) 130 Ibid. 131 Chris Sworder, Cleantech Group, “Feeding Fish to Fish: How Insect Farming Fixes Fishmeal” (Dec. 7, 2017) https://www.cleantech.com/ feeding-fish-to-fish-how-insect-farming-fixes-fishmeal/. 117 Florida Sea Grant Receives $1.1 Million to Support Aquaculture Research, “Villela Epsilon: Pioneering Offshore Aquaculture in the Southeastern Gulf of Mexico” (last visited Jan. 8, 2018) https://www.flseagrant.org/news/2017/11/sea-grant-awards-93m-to-support-aquaculture-research/#project2. 132 Rob Fletcher, The Fish Site, “Could jellyfish fuel fish feed revolution?” (Nov. 6, 2017) https://thefishsite.com/articles/could-jellyfish-fuel-fish-feed-revolution. 118 NOAA, “Grant Funds Available for Regional Aquaculture Pilot Projects” (Dec. 1, 2017) https://www.fisheries.noaa.gov/feature-story/grant-funds-available-regional-aquaculture-pilot-projects; NOAA, “National Sea Grant College Program 2018 Ocean, Coastal and Great Lakes National Aquaculture Initiative” (Dec. 14, 2017) https://www.grants. gov/web/grants/view-opportunity.html?oppId=299412. 134 Jillian Fry, PhD MPH, David Love, PhD MSPH, & Gabriel Innes, VMD, Johns Hopkins University, Center for a Livable Future, “Ecosystem and Public Health Risks from Nearshore and Offshore Finfish Aquaculture” at 13 (2017) https://www.jhsph.edu/ research/centers-and-institutes/johns-hopkins-center-for-a-livable-future/_pdf/ research/clf_reports/offshor-finfish-final.pdf. 133 NOAA & USDA, “The Future of Aquafeeds” (2011) http://www.nmfs.noaa.gov/ aquaculture/docs/feeds/the_future_of_aquafeeds_final.pdf. 119 40 C.F.R. § 122.23 App. B (emphasis added). 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