Marine Aquaculture

U.S. seafood producers are not competing each other, but low-cost foreign producers who do not have to comply with strict and costly regulations.

The claim that commercial fishing and marine aquaculture cannot coexist has been made for the last 39 years and has been proven false for 23 coastal states where the production of Atlantic salmon, oysters, clams and mussels has grown, prospered and in many instances was led by commercial fishermen.

Globally, commercial fishing has continued in concert with the growth in marine aquaculture production, and in the few instances where marine sea cages have been constructed and operated in the United States, i.e., Hawaii, Maine and Puerto Rico, those farms were often welcomed by commercial and recreational fishermen.

As farmers that produce a perishable product competing with the rest of the world for a small sliver of the U.S. seafood market, we believe our focus and the focus of U.S. fishermen should be on becoming the best and most efficient farmers and fishers that we can be. American seafood for the growing U.S. and global marketplace. By focusing on our collective ability to compete in world markets NAA envisions fishers and farmers collaborating to preserve working waterfronts and ensure that coastal communities will remain resilient.

Belle and Nash (2008) noted that escaping fish may pose a variety of environmental risks including pathogen transmission, interbreeding with wild conspecific to introduce new genetics, competition for resources, predation, colonization or disruption or damage to existing commercial or recreational fishing.

The authors concluded: For most of the aquatic species commercially cultured in the United States, these outcomes have neither occurred nor are anticipated to occur because:

• Producers have a strong economic incentive to prevent escape of cultured animals and to recover animals that do escape.
• Most pathogens are naturally occurring and ubiquitous.
• Most species are cultured in their native range.
• Successful introduction and spread of a nonnative species often meet strong biological resistance.
• Federal and state agencies have implemented a variety of invasive-species regulations to prevent, control, manage, or mitigate potential impacts..

This non-regulatory and regulatory framework has been effective for the United States. Farming fish in state waters, less than three miles from the coast and within coastal inlets and bays, is practiced to a limited extent in Hawaii, Maine and Washington.

Atlantic Salmon in Puget Sound

The potential environmental effects of the escape of Atlantic salmon in Puget Sound on Pacific salmon as a result of a net pen system that collapsed has created intense public and media speculation.

Fortunately, several publications have examined this risk and other risks and reported that those risks are manageable or unlikely to be realized. We believe that when the potential effects associated with this escape are thoroughly analyzed this prior work will be confirmed. We are also hopeful that enough time will have passed to then allow a dispassionate discussion and reassessment of Atlantic salmon culture to occur.

We are confident that this assessment will recognize that potential risks are being adequately managed under existing state and federal regulations. It is also unfortunate, that currently little to no recognition of public and private investment to improve Atlantic salmon production characteristics (e.g., weight gain, feed efficiencies), human diet and nutrition, fish health, and reduced environmental effects through fish husbandry, domestication and technology gained by the global production of Atlantic salmon production has not been made known to the public.

In the U.S. farms must comply with strict discharge standards and are closely monitored against a set of environmental impact metrics.

If they exceed those discharge standards or impact metrics their National Pollution Discharge Elimination System (NPDES) permits granted by the U.S. Environmental Protection Agency can be rescinded. Without a valid NPDES permit they must cease operations.

Feed Management and Fish Growth

Feed is a significant cost to all fish farms and can range from 50% to 60% of variable costs. As a consequence, farmers invest in employee training and infrastructure to store, handle, deliver and monitor feed to fish as efficiently and with as little loss as possible.

The practical aspects of feed monitoring technology is rarely presented in science literature; although, sophisticated approaches have been adopted to include cameras, Doppler radar, infrared detection, sonar sensors and water quality sensor arrays. Current feed monitoring in the United States utilizes farm employees observing feed consumption via video for each cage in an array of cages to stop feed delivery when fish near satiation.

Feed conversion ratio (FCR) (weight of feed offered/weight of fish produced) have trended downward as feed management and feed quality have improved from 3:1 (3 pounds of feed to 1 pound of harvested fish) in the 1970s to around 1:1 today.

Fish Density

Fish density in a production system is a complex question dependent upon species behavior, physiology, and water quality. The success of every farm growing animals, terrestrial or aquatic, depends upon the health and growth of the livestock. Fish grown at-sea in net pens benefit from standard practice of a low volume, 2% to 3%, at-harvest of fish relative to the volume of the sea cage or net pen. Excess feed, untreated fish waste and nutrients Current farm and feed management practices refute the claims that offshore marine aquaculture causes water quality or benthic ecology damage.

Farms must conform to established production practices and federal regulations that require the efficient feeding of optimal feed formulations, feed management to reduce feed loss, feeding equipment maintenance, employee training in efficient feeding practices, and recordkeeping and reporting of feed efficiency (conversion of feed to the amount of fish produced).

The United States severely restricts the availability and use of aquatic animal medicines via the Food, Drug and Cosmetic Act. Other chemicals (e.g., disinfectants, detergents or other cleaning agents) that may be used by aquaculture facilities are regulated by the U.S. Environmental Protection Agency (EPA).

The U.S. Food and Drug Administration reviews and approves aquatic animal medicines utilizing the same regulatory paradigm as that for human medicine (e.g., effectiveness to mitigate disease, effects to the animal, effects to the environment directly or indirectly, risk to human health). There are no antibiotics approved for use on marine fish such as cobia, snapper, flounder, halibut, cod or any of the other candidate fish for offshore marine aquaculture.

Antibiotics can only be used in conformance to label instructions or as prescribed by a licensed veterinarian. Federal regulations require that farms report medication use prior to administering a medication and following treatment.

A farm must describe potential chemical use in their EPA permit application and conform to permit conditions if use is allowed. In most cases those permit conditions require environmental monitoring to detect any possible antibiotic residues. If residues are detected farms are required to change their operations to reduce any risk of environmental impacts.

The federal permitting process for offshore farms requires interagency consultations, as authorized by the National Environmental Policy Act, to enforce the provisions of the Endangered Species Act, Marine Mammal Protection Act, Migratory Bird Treaty Act and Magnuson-Stevens Fishery Conservation and Management Act to prevent injury or death to listed species, marine mammals and birds and to prohibit unpermitted fishery harvest, possession or sale.

Unlike fishing gear that is designed to intentionally “catch” animals, aquaculture gear is designed to contain animals being cultured without hurting them or any wild animals that may occur around farms. Federal permit conditions also require that farmers implement specific equipment and management practices to reduce any chance of entanglement (such as using high-tension, abrasion resistant lines and routine surface and sub-surface inspections of farm gear.

Permit conditions s also require routine monitoring and immediate reporting and release of any protected species that has become entangled. In a recent global review of protected species interactions with marine aquaculture (Bath et al. 2023), the authors found 4 fatal entanglements across the entirely of the United States from 1996-2022.

Biofouling in marine environments occurs when animals and plants attach to the hard and soft surfaces associated with fish, shellfish and seaweed production gear (cages, nets, baskets, floats, ropes and anchors). The growing animals and plants will add weight and drag, restrict water flow impacting filter feeding or oxygenation, reduce marketable value or shelter pathogens and parasites. Direct economic costs to the farm have been conservatively estimated at 5 to 15% of production costs.

Offshore marine fish farms must comply with federal regulations applicable for all marine use of antifoulants as does every commercial or recreational watercraft owner, navigation buoy manufacturer or public or private entities that maintain buoys and markers, and similarly for antifoulants applied to marine structures. In the case of commercial net pen farms most farms have eliminated net exchange and the use of antifoulants on nets and are using mechanical robotic net cleaners or copper-alloy metal mesh.

The use and application of antifoulants in the marine environment is regulated by EPA under authority granted the Clean Water Act and Federal Insecticide, Fungicide, and Rodenticide Act. Antifouling coatings registrants must obtain approval from the U.S. EPA’s Office of Pesticide Programs, which oversees periodic pesticide registrations and reviews, and regulates pesticide use to prevent significant adverse effects on non-target organisms. Containers of antifoulants include EPA approved label instructions regulating storage, handling, application, and disposal. The EPA’s Office of Water is responsible for implementing the Clean Water Act, and similar statutes designed to maintain aquatic ecosystems to protect human health; support economic and recreational activities; and provide healthy habitat for fish, plants, and wildlife.

Some critics are concerned that farm-raised fish will displace U.S. fisheries and are cheap and low-quality product.

Fundamentally for U.S. farmers it is very difficult to produce “cheap” fish in the United States because of the plethora of federal and state natural resource and environmental regulations focused on aquatic animal culture, possession, sale and health, water use and quality, land use and access to markets and local, state and national labor, safety, business regulations and permits and mandated minimum wage.

What is also clear – and often missing from the discussion of competition – is that competition will exist with or without domestic aquaculture. The marketplace is global and demand for seafood products is growing. The United States cannot meet consumer seafood demand through wild caught fishing activities alone. Seafood imports and other forms of protein, such as beef and chicken, already provide significant competition. Seafood business executives speaking at the National Marine Aquaculture Summit said that if seafood is not available from U.S. sources, their customers are demanding that they get it somewhere else.

New rules by the U.S. Food and Drug Administration authorized by the Food Safety Modernization Act have added additional regulations for the processing, handling and transportation of animal feeds and human food. Such controls help to make farm-raised seafood products safe and wholesome foods.

As U.S. farmers, we are at a very real price disadvantage and recognize import product prices as being one of our greatest challenges. In response, rather than a protectionist approach, the U.S. aquaculture community has been working to develop markets that appreciate locally grown and high-quality fish, shellfish and seaweed products. And we are working to educate the U.S. consumer of U.S. sustainable production practices, environmental stewardship and the nutritional benefits and value of buying U.S. grown foods.