Committing to Sustainability
Pacific Ocean AquaFarms strives to be the model farm to catalyze a new domestic industry and help answer how to feed a hungry world. To do this, science must drive discussion and decision, research and demonstration must provide new and better answers, U.S. ingenuity and innovation must drive technological advances, and best practices and shared learning must continuously raise the bar.
Embracing Regulatory Oversight
The Permitting and Environmental Review Process
The United States has some of the world’s most stringent regulatory food production and environmental standards. POA welcomes this oversight as it ensures transparency, traceability and accountability in producing the safest and highest quality seafood product possible.
- National Oceanic and Atmospheric Administration
– Lead agency for coordinating National Environmental Policy Act (NEPA) review
– Protected Resources review (endangered species, marine mannals, essential fish habitats)
- U.S. Army Corps of Engineers
– Section 10 (Rivers and Harbors Act) permit
- U.S. Environmental Protection Agency
– National Pollution Discharge Elimination System (NPDES) permit
- U.S. Coast Guard
– Aids to Navigation permit
- California Coastal Commission
– Consistency with Coastal Act review
- California Department of Fish and Wildlife
– Aquaculture registration and oversight
Additional review will likely be conducted by other agencies as the project moves through the permitting and environmental review process.
Applying Science and Technology
POA will deploy the latest scientific knowledge and technologies, and focus on best practices in all facets of the operation. Open-ocean finfish farming is constantly evolving and POA will continue to research and adopt proven systems to maintain the highest standards and environmental ethos.
- State-of-the-art siting tools will optimize farm location and minimize conflicts/interactions. ⊕
- New net pen technology will mitigate escapements and entanglements. ⊕
- Innovative feeds will reduce or eliminate net loss of fish protein. ⊕
- Comprehensive fish health management planning will ensure the welfare of our fish. ⊕
- Environmental monitoring to continually evaluate and protect the surrounding ecosystems.
Adhering to Best Practices
1. Comply with all applicable international, national, and local laws and regulations.
POA will meet all legal obligations and adhere to the law to ensure basic environmental and social requirements are met.
2. Conserve natural habitat, local biodiversity and ecosystem structure and function.
POA intends to achieve this through its daily operational protocols and environmental monitoring, thus minimizing or eliminating benthic and water quality impacts and the effects of chemical inputs and nutrient loading.
3. Protect the health and genetic integrity of wild populations.
POA will only rear endemic species with broodstock collected from local populations. The facility will also have a rigorously trained aquatic animal health team that will develop, maintain and follow a comprehensive Fish Health Management Plan. The project will have robust pen engineering and an Escape Prevention and Response Plan within the Operations Plan that minimizes, if not eliminates, any adverse impacts related to escapes.
4. Use resources in an environmentally efficient and responsible manner.
Feed will only be sourced from Best Aquaculture Practices certified feed mills. POA will also follow the latest research in order to implement the most advanced and customized diets for the cultured fish.
5. Proactively maintain the health of cultured fish to minimize the risk of disease.
A California licensed veterinarian with a U.S. Department of Agriculture Category II accreditation will be a part of POA’s aquatic animal health team to develop and implement a comprehensive Fish Health Management Plan.
6. Operate farms with responsible labor practices.
POA will prioritize the health and safety of all of its employees and will ensure all are treated with equality and fairness in an atmosphere without discrimination.
7. Be a good neighbor and conscientious citizen.
POA will engage with local stakeholders and gather input from the community on a regular basis.
Welcoming Input from Subject-Matter Experts
POA has established a Scientific and Technical Advisory Panel comprised of experts from around the nation to review operational protocols and offer advice to the POA Board of Managers. Members of the panel have expertise in areas such as aquaculture, socioeconomics, genetics, animal health, nutrition, water quality, sediment impacts, and agriculture.
Additionally, POA has established a Stakeholder Advisory Panel with members from environmental organizations, the seafood industry, and the commercial and recreational fishing industries to gain insights and advice from their respective specialty areas.
National Oceanic and Atmospheric Administration (NOAA)
– Lead agency for National Environmental Policy Act (NEPA) review
– Protected Resources review (endangered species, marine mammals, essential fish habitats)
California Coastal Commission
– Coastal Act consistency review
– Aquaculture registration and oversight
– Rivers and Harbors Act navigable waters permit
– Aids to Navigation permit
– National Pollution Discharge Elimination System (NPDES) permit
Because of its wide-ranging expertise, the need for other agencies to consult with NMFS on protected habitat and living resources and its experience in conducting NEPA reviews for a wide range of development activities, NOAA has agreed to lead the environmental review process for the proposed POA project. This has been codified by a Memorandum of Understanding dated February 8, 2019 between NMFS, the U.S Army Corps of Engineers and the Environmental Protection Agency, the latter two of which are being solicited for permits for the farm.
Coastal Zone Management Act
This Act encourages coastal states to develop and implement Coastal Zone Management Programs and requires federal agencies to obtain certifications from states that authorized actions are consistent with the state program. NOS scientists and administrators provide to state coastal resource managers and regulators the tools and advice needed for coastal zone development and management.
Rivers and Harbors Act
Section 10 of this Act prohibits the unauthorized obstruction or alteration of any navigable waters of the United States. A permit is required for structures or work in or affecting navigable waters. The ACOE has previously asserted authority under this statute and the Outer Continental Shelf Lands Act (43 U.S.C. 1331 et seq.) to require permits for open-ocean aquaculture facilities, specifically net pens, constructed in the U.S. Exclusive Economic Zone beyond state waters (between 3 and 200 miles from shore). The purpose of these permits is to certify that the project will not impede navigation or negatively affect environmental quality. The POA project would result in the placement of anchors, lines, pens, and buoys in navigable waterways, thus requiring ACOE approval.
The U.S. Environmental Protection Agency (EPA) has regulatory authority over the proposed project under the Clean Water Act (33 U.S.C. ss/1251 et seq.).
Clean Water Act
Section 402 establishes the National Pollutant Discharge Elimination System (NPDES) and authorizes EPA to issue permits for point source discharges of pollutants into waters of the United States. Effluent Limitation Guidelines are established for Concentrated Aquatic Animal Production facilities, including marine net pen aquaculture producing 100,000 pounds (45 metric tons) or more of aquatic animals per year.
The California Department of Fish and Wildlife (CDFW) requires the acquisition of an Aquaculture Registration Permit for every person/entity engaged in the controlled growing and harvesting of fish, shellfish and plants in marine, brackish and fresh water. As the POA project involves the controlled growing and harvesting of marine finfish, an Aquaculture Registration Permit for the facility will need to be obtained. This permit will also address the transport of juvenile California yellowtail (or other selected species) through California waters to the offshores site, and re-entry of the product back through California state waters.
The California Coastal Commission (CCC) retains permit jurisdiction over project areas on public trust lands, tidelands, and submerged lands from the mean high tide line to three nautical miles offshore. Although the project would be located approximately 4 nautical miles (6.4 km) from the shoreline, it is acknowledged that development in waters beyond the 3-mile State limit may still impact waters within the 3-nautical mile zone. Therefore, the California Coastal Commission is being asked to certify that the project would be conducted in a manner that is consistent with California’s Coastal Management Program (CCMP). Section 5 of this report provides a detailed discussion demonstrating consistency with the CCMP. Specifically, since the project requires federal approval from the ACOE, a consistency certification pursuant to Section 307 (c)(3)(A) of the Coastal Zone Management Act (CZMA) is requested for the POA project.
Primary responsibility for the enforcement of U.S. maritime laws and regulations falls upon the U.S. Coast Guard (USCG). The USCG is responsible for managing and regulating provisions for safe navigation of vessels in U.S. waters, as well as the enforcement of environmental and pollution prevention regulations, including the Clean Water Act. The USCG also conducts pollution surveillance patrols to detect unauthorized discharges within the territorial sea and contiguous zone and has enforcement authority over violations. The POA project would result in the placement of anchors, lines, pens, and buoys at a scale that if not properly identified, could pose obstructions to safe navigation, thus requiring USCG approval and an Aids to Navigation permit.
Private Aids to Navigation (PATON)
Installation of navigation lights on floating marine net pen structures to ensure safe navigation are required. Appropriate updates will be made on NOAA navigational charts for the area.
Founded in 1997, GAA is an international non-governmental organization dedicated to advocacy, education and leadership in responsible aquaculture.
The Global Aquaculture Alliance mission is to promote responsible aquaculture practices through education, advocacy and demonstration. For over 20 years, GAA has demonstrated a commitment to feeding the world through responsible and sustainable aquaculture.
GAA upholds and engages stakeholders worldwide who are dedicated to advancing environmentally and socially responsible aquaculture practices. Through the development of the Best Aquaculture Practices (BAP) certification standards, GAA has become a leading standards-setting organization for aquaculture seafood.
A Comprehensive End-to-End Certification
GAA’s BAP certifies each step in the production chain. The standards are built on the four pillars of sustainability: food safety, environmental, social welfare, animal health and welfare.
The assurances provided at the four stages of the production chain are built on the four pillars, as shown below, and traceability is the foundation. The BAP program verifies that the right things are happening throughout the production chain.
ASC certifies environmentally and socially responsible seafood. ASC’s standards for responsible aquaculture address the key environmental impacts of farming, set requirements for workers’ rights and protect communities surrounding certified farms.
The standards were developed in line with the United Nations Food and Agriculture Organization (FAO) guidelines and ISEAL’s (International Social and Environmental Accreditation and Labelling) Codes of Good Practice.
These standards set strict requirements for responsible farming, which encourage seafood producers to minimise the key environmental and social impacts of aquaculture. The current eleven ASC standards cover 17 species groups: including seriola. The robust standards are the result of the Aquaculture Dialogues, a set of multi-stakeholder round-tables that brought together more than 2,000 aquaculture stakeholders.
The ASC standards focus on both the environmental and social impact of farming:
Environmentally – farms must show that they actively minimise their impact on the surrounding natural environment. This extends to careful management of the fish health and resources.
Socially – farms must be a good and conscientious neighbour; that means operating their farm in a socially responsible manner, caring for their employees and working with the local community.
The World Wildlife Fund has been a key part of the initiative to create global standards for aquaculture.
In 2004, WWF initiated and coordinated the Aquaculture Dialogues, a series of eight roundtables that included over 2,000 farmers, retailers, NGOs, scientists and other important stakeholders within the aquaculture industry. Together, the group committed to developing measurable and performance-based standards for responsibly farmed seafood. These standards focus on measureable performance and encourage innovation to reduce environmental impacts.
In 2009, WWF co-founded the Aquaculture Stewardship Council (ASC) with the Dutch Sustainable Trade Initiative (IDH) to manage the global standards and certification programs. ASC works with Accreditation Services International (ASI) to accredit independent certification bodies to audit and certify compliant farms. WWF also engages with governments in countries that produce and export farmed seafood to design regulatory policy that will support a responsible aquaculture industry.
ADVANCES IN SUSTAINABLE FEEDS
This feed used for our yellowtail is designed to optimize health and growth with the following critical conditions:
- nutritional requirements of the fish,
- the conversion efficiency to minimize the waste of feed,
- the cost of ingredients to ensure economic sustainability and affordability of product.
Feed will be purchased from a Best Aquaculture Practices (BAP) certified feed plant to ensure the feed is sourced from a reputable manufacturer utilizing rigorous quality control standards. POA recognizes that feed technology can rapidly change and intends to use the best available product on the market at any given time.
The use of alternative sources of protein to replace fishmeal and fish oil in the diet is a priority.
HSWRI is involved in many research studies evaluating alternative sources of protein and oil (e.g., fish processing cuttings and offal, plant-based protein, micro algae) to substitute for the fishmeal portions of fish feeds. The results of these studies will be integrated into the program as commercially available feed formulations are developed.
Feed is one of the most critical variables for finfish operations across all production stages – often accounting for the highest share of marginal production costs. Fishmeal happens to be very costly, so careful sourcing and use of feed is of paramount importance to both ecological and economic success.
New technologies and innovations are being developed with the goal of completely replacing the use of fishmeal and fish oil in commercial diets.
Many of these methods involve formulas using insects and non-GMO plants and single-cell organisms like yeast, bacteria, and algae. A number of companies are successfully funding researching the production of sustainable, alternative fish feed production from black soldier fly larvae and other insects. Researchers are also reporting that sustainably harvested jellyfish – which have bloomed into overpopulation as a result of global warming – and mealworms can be used for nutritious, alternative fish feed.
SCIENTIFIC AND TECHNICAL
POA has created the Scientific and Technical Advisory Panel (STAP) to review proposed operational practices and offer their informed advice on how those practices can and should be improved. The Panel will provide their input directly to the POA Board of Managers.
The STAP has been established to provide scientific and technical guidance to assist in the federal agencies’ review of the necessary permits – to ensure that the permits that regulate the placement, installation and operation of the POA farm are based on the best available scientific information, and to propose operational conditions that will lead to a dynamically improving sustainable operation of the farm.
The STAP members will review planned operating protocols and again offer critical feedback to the POA Managers for consideration. Once the farm is operational, POA Managers will report to the STAP on key performance and sustainability metrics in order to receive critical feedback.
STAKEHOLDER ADVISORY PANEL
POA will maintain a Stakeholder Advisory Panel (SAP) with members from environmental NGOs, the seafood industry and the commercial and recreational fishing industries to gain their insights and advice from their respective specialty areas.
SITE LOCATION ANALYSIS
NOAA’s National Ocean Service (NOS) has conducted a marine planning and suitability analysis along the San Diego coast and has identified sites as the locations with the greatest relative suitability for aquaculture in the region after minimizing interactions with other user groups. NOS has submitted the analysis of the proposed farm area to the Department of Defense siting clearinghouse to obtain approval from the Department of the Navy for farm operations to occur within.
The primary criteria considered for selecting sites include depth, currents, temperature, bottom sediment type and habitat, proximity to shore-based infrastructure, and input from a range of stakeholders. Over 30 selection criteria were used in this exhaustive analysis.
These included considerations for:
• Administrative Boundaries
• Oceanographic and Biophysical Data
• Natural Resources
• Military Activity
• Commercial Fishing and Fisheries
• Industry and Recreation
• Navigation, and Transportation
FISH HEALTH MANAGEMENT
POA’s Fish Health Management Plan is designed to identify, prevent and mitigate potential risks to fish health.
It follows best management practices as recommended from the Global Aquaculture Alliance (GAA), Food and Agriculture Organization (FAO), United States Department of Agriculture National Aquatic Animal Health Plan (NAAHP; USDA APHIS 2008), World Organization for Animal Health (OIE), American Fisheries Society (AFS), and National Oceanic and Atmospheric Administration (NOAA).
The approach to health management is science-based, flexible and responsive. The Fish Health Management Plan, in accordance with the five principles of the Commercial Aquaculture Health Program Standards (CAHPS; USDA APHIS, 2018), contains the following key components:
- An experienced aquatic animal health team;
- A comprehensive approach to identifying, characterizing and managing risks (including a rigorous biosecurity plan);
- Surveillance that includes regular fish health assessments, morbidity and mortality thresholds for early disease detection, and pre-identification of diagnostic laboratories for specific pathogen testing;
- A plan for investigation of disease including notifying authorities should a reportable disease be detected;
- A plan for responding to disease including routine and emergency response and postoutbreak review.
Pacific Ocean Aquafarms (POA) aims to ensure high standards of care of cultured fish by following animal welfare principles outlined by the American Veterinary Medical Association.
The American Veterinary Medical Association (AVMA) provides guidance regarding humane treatment of animals, including finfish (AVMA 2020). The principles include the following:
- Responsible use of animals for human purposes, such as companionship, food, fiber, recreation, work, education, exhibition and research;
- Decisions regarding animal care, use and welfare shall be made by balancing scientific knowledge and professional judgment with consideration of ethical and societal values;
- Animals shall be provided water, food, proper handling, health care, and an environment appropriate to their care and use;
- Animals should be cared for in ways that minimize fear, pain, stress, and suffering;
- Procedures related to animal housing, management, care, and use should be regularly evaluated;
- Conservation and management of animal populations should be humane, socially responsible, and scientifically prudent;
- Animals shall be treated with respect throughout their lives.
STATE-OF-THE-ART FISH PEN TECHNOLOGY
- POA Fish pens will be engineered to the oceanographic parameters to which the site will be exposed.
- Extensive modeling will be done to calculate oceanographic forces under worse case climatological scenarios.
- POA will be using the Norwegian Standard NS 9415.E to moor the farms. This standard requires strict oceanographic and bathymetric parameter inputs for calculating the engineering and incorporated materials – and protocols for installation, maintenance, and replacement of materials over time.
- Pens will be positioned primarily at the surface. Submergible technology will allow them to be lowered below the surface during heavy weather events.
- POA plans to use a copper alloy mesh (CAM) as the netting material to control fouling organisms and so water flow can be maintained at an optimal level for fish health.
- POA will monitor the copper as part of its routine Water Quality Monitoring SOP so that the efficiency and impacts of this material can be continuously evaluated.
The cage culture system will be designed and engineered to:
- Withstand the highest recorded storm and sea conditions
- Prevent escapement; avoid environment contamination
- Promote fish health
- Prevent predator incursions
- Ensure the safety of the operations – minimizing the risk of accident
- Provide for regular inspection, cleaning, maintenance and repair as needed.