November 7, 2024
Ms. Noel Sharp
Aquatic Resources Division
Department of Natural Resources
State of Washington
1111 Washington St SE; MS: 47027
Olympia, WA 98504
Re: Department of Natural Resources, Modification of WAC 332-30
Dear Ms. Sharp:
Thank you for the opportunity to comment on the Washington Department of Natural Resources’ proposed modification of WAC 332-30 to better achieve the Department’s management guidelines with respect to commercial finfish net pen aquaculture.
On behalf of the American Fisheries Society (AFS), the AFS Fish Culture Section, and the Western Division of AFS, we respectfully submit the following information for your consideration.
Founded in 1870, AFS is the world’s oldest and largest professional society of fisheries scientists and resource managers. At its core, AFS is an international science organization. The society promotes the conservation and sustainability of fisheries resources and aquatic ecosystems through dissemination of fisheries science via scientific journals on fisheries, conferences, and continuing education. AFS began as a society for aquaculture professionals and many of our members continue to work in aquaculture, particularly in the Western Division of AFS.
The AFS supports sustainable growth of U.S. aquaculture. The demand for fish is expected to grow significantly in the next decade and wild fisheries cannot sustainably accommodate increased harvest pressure to meet consumer demand (FAO 2024). Aquaculture is an opportunity to sustainably address America’s ongoing dependence on imported seafood, relieve local pressures on wild stocks, and bolster waterfront communities (AFS 2020).
There is a lack of scientific evidence to support either a partial or full ban of net pen aquaculture in the State of Washington or elsewhere in the United States. Aquaculture faces a number of persistent, troubling falsehoods regarding the environmental footprint of net-pen aquaculture, perhaps particularly so in the State of Washington. We seek to provide you with the most up-to-date scientific information.
Parasite and disease transmission between farmed and wild stocks occurs in both directions, however, documentation of impacts on wild fish is scant and suggests that impacts are typically small and localized. Introduction of novel pathogens to naive populations is a risk factor that is well-addressed by use of local-origin stocks and routine pathogen testing. Likewise, there is no evidence of escaped farmed salmon causing genetic impacts to wild stocks despite media reports to the contrary. Escapement events have proven to be well-managed via recapture events and the reluctance of farmed fish to disperse and interact with wild fish. Further, with proper siting and best management practices, there is little risk of long-term net pen and/or benthic degradation. These findings are supported by the work of scientists and resource managers with the Washington Department of Fish and Wildlife, Washington Department of Ecology, and others familiar with the circumstances specific to the Evergreen State (Amos and Appleby 1999; WA DoE 2022).
In recent decades, the U.S. has improved its resource efficiency in terms of the amount of fish meal and fish oil used in feeds, and reduced its environmental impacts in terms of the mass loading and impact of nutrient discharge on the receiving ecosystem, the incidence and treatment of fish diseases, the use of antibiotics, and the number and impact of fish escapes, while increasing production. These changes can be attributed to a combination of advances in science and technology, the rising cost of fish meal/oil, improved management, and informed regulatory practices (Rust et al., 2014).
With proper regulatory oversight, adherence to best management practices, and good siting of farms, net pen aquaculture can be accomplished without causing adverse impacts to the surrounding environment or wild fish stocks. An assessment of net-pen aquaculture should consider benefits to food supply, the economy and wild stocks, as well as any risks to the environment.
We urge you to consider the science and to maintain opportunities for properly regulated and environmentally sound net pen aquaculture on state-owned lands in Washington.
Thank you for your consideration.
Sincerely,
Jeff Kopaska
Executive Director