Institute for Fisheries Resources * The Ocean Conservancy  
Pacific Coast Federation of Fishermen’s Associations * Environmental Defense
Monterey Bay Aquarium * Sierra Club * Environment Matters
Food & Water Watch * National Coalition for Marine Conservation
Southeast Alaska Fishermen’s Alliance * Fishing Vessel Owners Association
Go Wild Campaign * Center for Food Safety * Oceana
Alaska Marine Conservation Council * Alaska Trollers Association
Alaska Independent Fishermen’s Marketing Association * Southern Shrimp Alliance
Southeast Alaska Regional Dive Fisheries Association * United Fishermen of Alaska
Pacific Marine Conservation Council * Northcoast Environmental Center
Gulf Restoration Network * Columbia River Crab Fishermen’s Association
Kenai Peninsula Fishermen’s Association * Clean Catch
Small Boat Commercial Salmon Fisherman’s Association * Puget Sound Harvesters

April 23, 2007

Letter to Chairs of the U.S. House Natural Resources and Senate Commerce Committees, and Members of the U.S. Senate and House Subcommittees on Oceans and Fisheries

RE:     NOAA’s offshore aquaculture legislation - OPPOSED

Dear Senator/Representative:

Conservation, food safety, business and fishing organizations from across the nation urge you to oppose legislation proposed and submitted to Congress by NOAA on March 12, 2007 concerning offshore aquaculture in U.S. ocean waters.  We understand that the bill, “The National Offshore Aquaculture Act of 2007,” is being introduced by Representative Rahall, Chair of the House Resources Committee at the request of the Administration.  While a slight improvement over legislation introduced in 2005, we strongly oppose the bill because it appears to promote aquaculture, in particular ocean fish farming, at the expense of marine ecosystems and fishing communities.  We believe that strong standards to eliminate or minimize the significant environmental and socioeconomic impacts of ocean fish farming must be provided in statutory criteria for issuing permits, and not merely addressed in a subsequent rulemaking process.

NOAA’s proposed legislation does not contain adequate standards to eliminate or minimize diseases and parasites transmitted from farmed to wild finfish species; pollution of the marine environment with fish wastes and excess feed; contamination of humans and wildlife from feeds, drugs and chemicals; harm to marine mammals and other wildlife from predator controls; and the decimation of populations of important forage fish like menhaden, herring and anchovies used to feed carnivorous farmed species.  The proposed legislation also fails to develop a precautionary and transparent permitting and regulatory program, provide an adequate role for states and Fishery Management Councils, or protect essential fish habitat and other sensitive ocean sites. 

Some of these issues have been addressed in legislation enacted in California in 2006 (the Sustainable Oceans Act) and in the recommendations of the Woods Hole Oceanographic Institution’s Marine Aquaculture Task Force in 2007 (Sustainable Marine Aquaculture: Fulfilling the Promise; Managing the Risks).  
           
Based on the bill’s inadequacies, and the considerable harm that promoting an unsustainable fish farming industry would have on fishing communities and the marine ecosystem, we urge you to oppose NOAA’s aquaculture legislation as currently written.

Thank you for considering our views, and please feel free to contact any of the groups listed above for more information.

Sincerely,