December 8, 2022 — The following was released by National Fisheries Institute:
Dear Commissioner. Franz:
We, the undersigned, wish to express our collective concern regarding Commissioner’s Order #202211, dated November 17, 2022, directing Department of Natural Resources (DNR) staff to “develop necessary changes to agency rules, policies, and procedures to prohibit commercial net pen aquaculture on state-owned aquatic lands” in the state of Washington, and to demand a third-party review of the science upon which this Order is based.
We represent a broad range of US national, state, and species-specific trade associations whose members either produce or harvest seafood that is destined for both domestic and international markets. Signers also include fisheries scientists, resource economists, veterinary medicine professionals, and other industry stakeholders who —in addition to being concerned about the lack of historical data and peer-reviewed science that would support your Order—are equally concerned about the apparent unilateral and unsupported exercise of government power that does not demonstrate thoughtful, constructive thinking and fairness.
In addition, we find it troubling that the Order:
- Fails to cite any credible, peer-reviewed analysis or analyses:
- Fails to refer to an independent third-party (or even other State agencies) supporting the Order;
- Ignores the recommendations in the April 2022 Washington Department of Ecology document fulfilling a requirement of House Bill 2957 (2018) ordered by the Washington state Legislature, “Commercial Marine Finfish Net Pen Aquaculture in Puget Sound and Strait of Juan de Fuca: Guidance and Risk Management” (Publication number 22-06-008);
- Fails to acknowledge the 40+ years of science that federal and state agencies, including the DNR, have conducted regarding marine aquaculture—science which exists to help inform decision-makers on how to strike a balance between environmental conservation and aquatic food production.
We do not argue that aquaculture is without impact or risk. Zero impact or zero risk is an impossible standard that no food production system can live up to. At the same time, however, marine aquaculture from domestic production helps reduce the carbon footprint from imports.
Given the fact that the commercial net pens affected by this Order occupy approximately .0004% of total state-owned aquatic lands, we believe that a third-party review is needed to show that the Order has no basis in scientific fact and is, in essence, an unsupported action by a government agency.
There are several possible candidates for conducting such a review, and we sincerely hope you and your staff have sufficient confidence in either the University of Washington School of Aquatic and Fishery Sciences, the National Marine Fisheries Service, and/or the NOAA National Center for Coastal Ocean Sciences as capable of examining an action that most of the US seafood industry believes to be just plain wrong.
We look forward to hearing from you.
Respectfully,
Jeanne McKnight, Ph.D., Executive Director
Northwest Aquaculture Alliance
Jim Parsons, CEO
Jamestown Seafood
President, Northwest Aquaculture Alliance
Linda A. Chaves, M.S.
Senior Advisor on Seafood and Industry Issues, NOAA (Retired)
NOAA National Aquaculture Coordinator (Retired)
John Dentler, Esq.
Chairman, Kurt Grinnell Aquaculture Scholarship Foundation
President Emeritus, Northwest Aquaculture Alliance
Walton W. Dickhoff, Ph.D.
NOAA Fisheries Senior Scientist (Retired)
University of Washington Professor of Fisheries (Retired)
John Forster, Ph.D.
Stolt Sea Farm Washington – General Manager (1984-1994)
Columbia River Fish Farms – Co-Owner (1994-2001)
Frederick Goetz, Ph.D.
NOAA Fisheries Biologist (Retired)
Professor Emeritus, University of Wisconsin-Milwaukee
Robert N. Iwamoto, Ph.D.
Northwest Fisheries Science Center – NOAA (Retired)
Don Kent, M.S.
President/CEO – Hubbs Sea World Research Institute
Hugh Mitchell, M.S., DVM
Aquatic NW Veterinary Services
John Moehl, Ph.D.
Senior FAO Aquaculture Officer (Retired)
Aquaculture Specialist – Realized Expectations/AFFIRM
Stephen G. Newman, Ph.D.
President/CEO – Aquaintech Inc.
Gil Sylvia, Ph.D.
Professor Emeritus, Department of Applied Economics – Oregon State University
Director, Coastal Oregon Marine Experiment Station (Retired)
US State and National Trade Associations
Tony Vaught, President
California Aquaculture Association
Robert Rheault, Ph.D., Executive Director
East Coast Shellfish Growers Association
Tiffany Conner, Education Coordinator
Florida Aquaculture Association
Paul Hundley, Founding Director
Florida Marine Aquaculture Coalition
Brian Perkins, CEO
Ronald P. Weidenbach, President
Hawaii Aquaculture and Aquaponics Association
Sebastian Belle, Executive Director
Dan Vogler, President
Michigan Aquaculture Association
Paul Zajicek, Executive Director
National Aquaculture Association
Gavin Gibbons, Vice President
Clinton Bentz, President
Oregon Aquaculture Association
Bill Lynch, President
Fritz Jaenike, President
Mark Ely, President
Cc:
Governor Jay Inslee
Senator Andy Billig, Senate Majority Leader
Senator John Braun, Senate Republican Leader
Representative Laurie Jinkins, Speaker of the House
Representative Joe Fitzgibbon, House Majority Leader
Representative J.T. Wilcox, House Republican Leader
Senator Kevin Van De Wege, Chair – Senate Agriculture, Water, Natural Resources & Parks Committee
Senator Judy Warnick, Ranking Member
Representative Mike Chapman, Chair – House Rural Development, Agriculture, & Natural Resources Committee
Representative Bruce Chandler, Ranking Member