Fishy Farms Updates

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Fishy Farms Updates September 2009

About Food & Water Watch is a nonprofit consumer advocacy organization headquartered in Washington, DC that runs cutting-edge campaigns to help ensure clean water and safe food. We work with various community outreach groups around the world to create an economically and environmentally viable future. We advocate for safe, wholesome food produced in a humane and sustainable manner, and public rather than private control of water resources, including oceans, rivers and groundwater. The Food & Water Watch Fish Program promotes clean, green, safe seafood for consumers, while helping to protect the environment and support the long term well-being of coastal communities. Food & Water Watch 1616 P St. NW, Suite 300 Washington, DC 20036 tel: (202) 683-2500 fax: (202) 683-2501 [email protected] www.foodandwaterwatch.org

California Office 25 Stillman Street, Suite 200 San Francisco, CA 94107 tel: (415) 293-9900 fax: (415) 293-9908 [email protected]

Copyright © July 2009 by Food & Water Watch. All rights reserved. This report can be viewed or downloaded at www.foodandwaterwatch.org.

Table of Contents Overview.......................................................................................... 1 Atlantic Marine Aquaculture Center - New Hampshire.................2 Kona Blue Water Farms..................................................................3 Cates International (Hukilau Foods)..............................................6 Additional Hawaiian Operations....................................................8 Hawaii Oceanic Technologies, Inc..................................................8 Indigo Seafood, LLC........................................................................9 Maui Fresh, LLC............................................................................10 Snapperfarm and Open Blue Sea Farms........................................11 Hubbs-SeaWorld Offshore Aquaculture Demonstration Project............................................................... 12 Ocean Steward Institute................................................................ 14 Gulf of Mexico Fishery Management Plan.................................... 14 What Next?.................................................................................... 15

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Since the initial release of Fishy Farms in October 2007, there have been many regional and national developments regarding the status of open ocean aquaculture (OOA) in the United States. Food & Water Watch is planning a full-length follow-up report. Until that release, this update covers significant developments in OOA as a supplement to the original Fishy Farms report.



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Open Ocean Aquaculture (OOA) is the mass production of finfish in huge, often over-crowded cages out in open ocean waters. OOA in federal waters – from about three to 200 nautical miles off the coast, except in the Texas and the West Coast of Florida, where state waters extend to 9 nautical miles – is often called “offshore aquaculture.” Since the release of Fishy Farms, the National Oceanic and Atmospheric Administration (NOAA) has continued to push the development of this industry. Both regional plans and state projects have moved forward, and new federal legislation is expected to be introduced for approval by Congress that will allow standardized national regulation for offshore aquaculture in federal waters. However, there still has not been a bill to address the many potential negative effects on the environment, consumers, and coastal communities from a nationwide offshore aquaculture industry. In Hawaii, state-controlled waters have become a testing ground for OOA, but Kona Blue and Cates International (now called “Hukilau Foods”) have struggled to attain profitability and prove sustainability.

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Rather than spend more time and money on offshore aquaculture, the United States should avoid promoting this troubled industry and focus energy and financial resources to develop a more sustainable, recirculating aquaculture industry. The following are updates to profiles of aquaculture operations featured in Fishy Farms:

Atlantic Marine Aquaculture Center New Hampshire The University of New Hampshire’s Atlantic Marine Aquaculture Center (AMAC), directed by Richard Langan, has not fared well since it was featured in the 2007 Fishy Farms report. All of the program’s progress reports on finfish aquaculture, updated regularly from 2000 onward, cease after 2007.1 A call placed to AMAC’S former spokesperson, Dolores Leonard, in August of 2009 revealed that the project had lost most of its funding after 2007, leading to a reduction in staff, and that research activities were therefore greatly curtailed.2 NOAA granted federal funding to AMAC as a stopgap measure in July and August of 2008. The first grant provided $474,999 to “support the advancement and improve the economic viability of offshore fish farming.”3 The second grant allotted $355,000 for research on offshore cage technology, and to find ways to optimize feeding processes, reduce fish stress and promote fish growth.4 Both grants were announced by Senator Judd Gregg of New Hampshire, who has been a supporter of AMAC since the program’s inception in 1997. These federal funds, however, were merely a drop in the bucket for UNH. The project received about 2

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nineteen million in financial support from NOAA between 1997 and 2007.5 Senator Gregg announced that the funding would “bolster the long-term success of aquaculture off New Hampshire’s coasts” – a claim that is somewhat debatable, given the program’s struggles in the last two years.6 In early 2007, Langan observed: “At the University of New Hampshire, eight years of research and technology development have led us to conclude that a commercially viable and environmentally sound offshore aquaculture industry is an option for the U.S.”7 Yet the subsidies that have been granted to UNH’s AMAC now total over twenty million dollars. With staffing reduced so much that the center cannot even produce annual progress reports on its research (which is funded by public dollars), it is clear after more than a decade that the venture has not been the success that was originally hoped. Langan himself told Congress in 2006 that one of the center’s main goals was to explore the “economic viability of farming finfish,”8 and claimed, in 2008, to “recognize the need to improve [the] efficiency [of offshore farming] in order to be commercially viable.”9 Twelve years and twenty million dollars were still not enough for Langan to bring the operation to viability. Rather than proving offshore aquaculture to be commercially viable and environmentally sound, Langan has shown how expensive and difficult open ocean aquaculture operations can be.

Kona Blue Water Farms In the fall of 2007, Kona Blue applied to expand each of its cages from 2,800 – 3,200 cubic meters to 6,200 cubic meters.10 However, the company faced opposition from the Fishy Farms Sept. 2009

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community, including Native Hawaiian groups: “What has not been addressed [by Kona Blue],” said Kale Gumapac, representing a Big Island alliance, Mano O Ku Hawaii, “has been the impact to customary practices and cultural traditions.”11 Two contested cases were filed against the application, and the company subsequently withdrew the request.12

Without approval to expand, Kona Blue found it difficult to continue operation under existing conditions. Despite $1.8 million in funding from NOAA, millions in tax technology credits given to aquaculture operations in Hawaii, nearly $10 million from investors, and a product that retails at $17 a pound for fillets, Kona Blue is not achieving profitability.13,14 In April 2009, Kona Blue received approval for a Supplemental Environmental Assessment for “Modification to the 4

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net Pen designs within the Production Capacity and Farm Lease Area for Kona Blue’s Offshore Open Ocean Fish Farm off Unualoha Point, Kona, Hawaii.”15 The assessment, which did not involve increased production or lease size, was written to accompany the company’s request for greater flexibility in net pen type and configuration. Kona Blue wrote that: “The preferred revision to the CDUP would allow for any combination of net pen sizes, forms or materials, within the limitations described above. This will allow Kona Blue to innovate, test and refine the various combinations of these parameters, in order to identify and then implement the most economical, efficient, and safest option for net pen configuration.”16 In other words, after six years of operation, Kona Blue has not yet settled on a type of cage or configuration that will allow for sustained operation. Kona Blue may claim to be “a fledgling industry, developing innovative new technologies,”17 but that argument no longer stands up after years of experimentation. Kona Blue claims that continuing offshore aquaculture operations will lead to economic benefits,18 but it provides relatively few jobs.19 Part of this reconfiguration is to eliminate the need for divers employed to clean the cages: “We believe that the only way for Kona Blue to achieve profitability for our Kona operation is by reducing our reliance on SCUBA divers.”20 In June 2009, Kona Blue requested approval to pay rent owed to Hawaii Board of Land and Natural Resources (BLNR) in installments. Neil Sims, chief executive officer of the company, explained in his letter: “We are severely cash constrained at the moment.” The company owed $57,990.82 in rent.21 Fishy Farms Sept. 2009

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In other efforts, Kona Blue has received a permit for a site in Mexico where it is finalizing financing and hopes to begin production. In its land-based research site at Keahole Point, the company is experimenting with spawning and raising grouper fingerlings. The company has not received or applied for permits to place grouper in offshore cages.22 As quoted in Fishy Farms, Sims has said that a vast expansion of the offshore aquaculture industry “would not be sustainable” without development of alternative feed. Kona Blue has found one alternative ingredient – but not one that most consumers would expect their “sustainably-produced” fish to eat: poultry by-products in the form of poultry oil and poultry meal. Kona Blue is also conducting trials in land-based tanks on soy feed, in conjunction with the U.S. soy board, and their soy has not been certified GMO-free.23 Since 91% of the soy grown in the U.S. is genetically engineered,24 it is highly unlikely that any feed not specified as GMO-free would be natural. It is troubling to imagine what effects this GMO soy could have on the marine environment if fed (in mass quantities) to ocean-farmed fish. Soy is high in estrogen, which studies have indicated may have a damaging effect on wild fish populations by impacting their ability to reproduce.25

Cates International – now Hukilau Foods “It is hard, and I don’t want to be here, but I don’t any see alternative.” – Randy Cates, founder of Hukilau Foods, 2009.26 According to Cates, the open ocean farming industry is the only sector poised to provide enough seafood for the growing demand. Perhaps he is not familiar with alternatives like re6

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circulating aquaculture and traditional Hawaiian fishponds, which are not associated with problems like fish escapes and pollution that open ocean facilities encounter. In 2006, Cates entered into an agreement with Visionary LLC, a company owned by Steve Case of AOL-Time Warner,27 to form the company Grove Farm Fish & Poi, LLC –49 percent owned by Cates International, and 51 percent owned by Visionary. The ocean lease for the aquaculture facility was transferred to this company in 2007 and the fish farm was re-named Hukilau Foods. Visionary agreed to contribute $500,000 to the new company, as well as a subsequent contribution up to $4.5 million. The new joint company also assumed Cates’ $1 million debt to National Marine Fisheries Service.28 This merger has enabled the company to invest in building a new fish hatchery, which allows the company to expand greatly in size. Hukilau plans to expand its ocean lease from 28 to 61 acres, replace four 3,000-cubic-meter cages with 6,000-cubic-meter cages, and quadruple production to 5 million pounds of moi per year.30 This expansion would mean that the amount of fish waste coming from the project would be approximately equal to the amount of untreated sewage generated by the entire city of Boston.31 Even worse, the operation is already located near a known dead zone, a protected marine sanctuary, and within an area contaminated by dredged material in Mamala Bay.32 Despite this, the Office of Conservation and Coastal Lands (OCCL) issued a FONSI (Finding of No Significant Impacts) on the Environmental Assessment on July 29, 2009, giving a green light to move forward with the project.33

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Additional Hawaiian Operations – Hawaii Oceanic Technologies, Indigo Seafood, Maui Fresh Fish Three more companies have begun to plan, or have applied for permits for aquaculture facilities. Hawaii Oceanic Technologies, Inc. Hawaii Oceanic Technologies, Inc. (HOT) plans to place a dozen untethered, self-powered open-ocean fishpens off the Big Island’s North Kohala coast to grow 6,000 tons of ahi tuna per year. The company has applied for a 247-acre lease. HOT first submitted a Draft Environmental Assessment to the Department of Land and Natural Resources (DLNR) in June 2007, but it was not accepted, so the company resubmitted it to DLNR in January 2008, along with answers to the questions that had been raised. DLNR took no action on the document, and strongly recommended the company perform a full Environmental Impact Statement (EIS) to provide more details.34 On July 7, 2009 the Office of Conservation and Coastal Lands (OCCL) determined that the Final EIS was acceptable despite noting that “there are still unresolved issue (sic) regarding the level of environmental and project disclosure, analysis regarding the engineering design of the proposed engine, fish feed components, lack of benthic studies in the project area, and lack of shark, marine mammal and endangered species plan.”35 On March 14, 2009 a notice of public hearing was posted for an April 14, 2009 hearing on HOT’s proposed project, but it did not solicit public written comment.36 However, according to communication with DLNR staff, comments are 8

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being accepted, and the CDUA is planned to be scheduled for disposition during a September 2009 BLNR meeting.37 Environmental and native Hawaiian communities have both spoken in opposition to this proposal. Concerns include the importation of massive amounts of fish feed (12,000 tons), the contents and source of the feed ingredients, negative impacts from feed on the marine environment, infringement upon cultural resources, and negative impacts on fish populations, marine mammals and fishing from the entire operation. The proposed site is located just outside the Hawaiian Islands Humpback Whale National Marine Sanctuary.38 Indigo Seafood, LLC A company called Indigo Seafood, LLC has proposed a new open ocean aquaculture venture in the Kawaihae area, half a mile off the coast of the Big Island, Hawaii. They have not yet submitted official applications or documents to the state, but have made presentations stating that they are seeking an 80acre lease for the purpose of growing moi (to begin with) in Fishy Farms Sept. 2009

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3,251 cubic meter aquapod cages.39 The company proposes to install two cages each year until it reaches a total of ten cages and is producing 1,000-2,000 tons of fish annually.40 Maui Fresh Fish, LLC Maui Fresh Fish, LLC has expressed interest in farming opakapaka in 7,000-cubic-meter aquapods off the South shore of Lanai, Maui. The company hopes to raise fish at a land-based hatchery on the North shore of Maui in the Kahakuloa side and then grow them to market size in open water cages. In 2008 the company was preparing an Environmental Assessment to lease approximately 100 acres of ocean space.41 As of August 2009, this document or any official applications have yet to be submitted. With two open ocean aquaculture facilities in operation, one in the permitting process, and two additional operations being planned, Hawaii has become a testing ground for OOA, and yet the industry here has yet to prove that it can be profitable, sustainable, and agreeable to members of the community and native Hawaiian groups. Despite all the effort being put into finfish aquaculture in Hawaii, algae production has proven to be more profitable. In 2008, algae was the largest aquaculture product in Hawaii, accounting for 45 percent of sales.42

Snapperfarm and Open Blue Sea Farms From 2007 to early 2009, Snapperfarm, Inc. of Puerto Rico ramped up operations, experimenting with new technology and increasing production levels before moving operations south to Panama. The company experimented with a futuristic technology – the self-propelled Aquapod, designed by Ocean Farm Technologies: an enormous geodesic ball with two eight-foot propellers that could 10

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roam the ocean untethered – on the farm in 2008.43, 44 Brian O’Hanlon is enthusiastic about this robotic machine: “The further we go with cage technology, the deeper and further offshore we can go…[,]” he explains.45 By 2009, O’Hanlon’s company maxed out at fifty tons of Culebran cobia – the annual quota as mandated by United States regulatory agencies.46 A news interview in 2007 reveals O’Hanlon’s intentions: he hoped to grow the facility 1,500% – up to production of 750 tons.47 A facility of this scale could have enormous implications for the natural ecology of the oceans surrounding the Puerto Rican island of Culebra, and likely well beyond, given the massive amounts of waste that fish farms can generate through excretion and leftover feed that passes through the cages. After spending eleven years trying to make Snapperfarm run profitably in Puerto Rico, O’Hanlon finally packed up in early 2009, unable to obtain permitting for increased production in the U.S. He complained in April of 2009 that the regulatory process through United States agencies in Puerto Rico was prohibitive to his company’s growth,48 and headed south to Panama to start up Open Blue Sea Farms. O’Hanlon’s Open Blue Sea Farms has equally lofty – and just as alarming – aspirations. Raising cobia, the same species as was grown at Snapperfarm, the company’s stated Fishy Farms Sept. 2009

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intentions are “to launch the world’s largest, next generation open ocean free-range fish farm in 2009.”49 The aquaculture company’s claim to produce “free-range fish” is questionable in itself, as the fish are only as “free to roam” as the confines of their floating vinyl-coated wire mesh cage, which is moored to the ocean floor.50,51,52 O’Hanlon is currently raising additional capital for this new venture.53 On August 31, 2009, Open Blue announced that its a cquisition of Pristine Oceans, another cobia fish farm in Panama, makes it the world’s largest open ocean aquaculture operation.54

Hubbs-SeaWorld Offshore Aquaculture Demonstration Project The Hubbs-SeaWorld Research Institute – a non-profit research institute associated with the for-profit SeaWorld – is currently planning to develop the first commercial open ocean aquaculture project in federal waters, five miles off the coast of San Diego, California. Building on its fish farming enterprise in Baja California, Mexico, Hubbs-SeaWorld is proposing to grow 1,000 metric tons of striped sea bass to start, with the goal to produce 3,000 metric tons of fish annually by the fifth year of operation. This is more than five times the current production capacity of the largest existing open ocean aquaculture operation in the United States.55 Although this is pitched as a pilot research project, respresentatives of Hubbs-SeaWorld have explicitly boasted that the facility will ultimately be transferred to a for-profit business entity.56 Hubbs-SeaWorld and the for-profit corporation would share revenue from the project.57 12

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From 1998 to 2007, Hubbs-SeaWorld Research Institute received more than $700,000 from the Department of Commerce for open ocean aquaculture research.58 Now, after receiving public dollars to fund its preliminary work, HubbsSeaWorld plans to make money off a public resource. Hubbs-SeaWorld has not committed to using alternative feeds or limiting the amount of fishmeal and oil used in feed, or to a specific plan to minimize or eliminate escapes of farmed fish, so the project could increase pressure on already-stressed wild fish populations through the use of wild fish in feed, or by competition and co-mingling resulting from escapes. If the Hubbs-SeaWorld project were to move forward in current conditions, it would be the first commercial fish farm located in U.S. federal waters. Hubbs-SeaWorld has chosen to site the project just out of reach of California’s law that deals with the problems posed by marine aquaculture facilities.

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Ocean Steward Institute In February of 2008, it was announced that many of the aquaculture advocates discussed in this report had come together to form a new trade organization: the Ocean Steward Institute (OSI).59 Operating under the guise of “ocean stewardship,” the organization is actually little more than an industry group seeking to influence policy and promote OOA, despite its many shortcomings and poor environmental record. The Institute’s board of directors includes none other than Brian O’Hanlon of Snapperfarm and Open Blue Sea Farms, Neil Anthony Sims of Kona Blue Water Farms, and David Tze of Aquacopia, the venture capital firm, as well as a few others, who are all owners or managers of major seafood processors and retailers. Open ocean aquaculture has a number of documented problems. A much better option would be for Aquacopia to turn its attention (and investments) towards recirculating aquaculture systems (RAS) and integrated aquaponics, onland systems that sidestep most of the environmental concerns, like pollution, associated with open water aquaculture and all but eliminate the risk of escapement.

Gulf of Mexico Fishery Management Plan for Regulating Offshore Marine Aquaculture in the Gulf of Mexico The Gulf of Mexico Fishery Management Council, with the help of the agencies they advise, NOAA and National Marine Fisheries Service (NMFS), and the push of special interests serving on the council, developed a regional plan for offshore aquaculture. The Council and NMFS, despite years of work on the program (first as an amendment to existing fishery 14

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management plans and then as a plan itself), ultimately produced a plan to allow offshore aquaculture in the Gulf of Mexico that fails to meets assorted legal requirements, including those under the National Environmental Policy Act, Magnuson-Stevens Fishery Conservation and Management Act, Public Trust Doctrine, and others. NMFS and the Council have spent outrageous amounts of time and money only to further this environmentally and socio-economically problematic and unsustainable industry. Between contractors hired by NMFS to work on the plan, flights down to the Gulf for NMFS and NOAA staff, wages paid to Council members and staff for meetings devoted to aquaculture, etc., one half a million dollars were spent developing the plan.60 On September 3, 2009, the Gulf plan became effective, without NMFS formal approval. Under current law, inaction by the agency on a fishery management plan equals assent to its finalization. With the agency already underfunded and understaffed, there are real concerns about how NMFS will be able to handle managing both farmed and wild fish. Many are certain that with an emphasis on fish farming, wild fisheries will get less attention than they already do, further exacerbating mismanagement and depletion.

What Next – A Future for Offshore Aquaculture? The open ocean aquaculture companies currently in operation, those that have been proposed, and management plans or regulation developed to date have only served to warn against this new industry. They have proven that OOA is not equipped to meet a growing demand for seafood, conserve ocean resources, or protect wild fisheries and the communities that depend upon them. Fishy Farms Sept. 2009

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The industry is still struggling to develop alternative feed sources; minimize fish escapes; determine the best cage types; avoid negative interactions with fishermen and coastal communities; and achieve profitability. Rather than pour more money and resources into offshore aquaculture, Congress, NOAA, and aquaculturists would be wise to leapfrog this troublesome technology and focus on developing land-based recirculating aquaculture in the United States: a cleaner, greener, technology.

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ENDNOTES Atlantic Marine Aquaculture Center, University of New Hampshire. “Progress reports: Finfish.” Accessed 28 August 2009. Available at http://amac.unh.edu/publications/publications_archive.html#finfish 2 Leonard, Dolores. University of New Hampshire, Atlantic Marine Aquaculture Center. Personal communication, August 2009. 3 “NOAA Awards Funds to Portsmouth aquaculture firm, UNH,” SeaCoastOnline, 31 July 2008. Available at http://www.seacoastonline.com/apps/pbcs.dll/article?AID=/20080731/ BIZ/807310420&sfad=1 4 “UNH gets $355K for aquaculture research,” SeaCoastOnline, 28 Aug 2008. Available at http://www.seacoastonline.com/apps/pbcs.dll/article?AID=/20080828/BIZ/80828044, 5 Food and Water Watch, Fishy Farms, Oct 2007, page 7. 6 “UNH gets $35K for aquaculture research,” Op cit. 7 Christian Science Monitor, letter by Richard Langan, Director, Atlantic Marine Aquaculture Center, University of New Hampshire, “How Offshore Fish Farms Can Be Safe,” 25 Jan 2007. Available at http://www.csmonitor.com/2007/0125/p08s01-cole.html 8 Statement of Richard Langan, Director, University of New Hampshire, Senate Committee on Commerce, Science and Transportation, Subcommittee on National Ocean Policy Study, Washington, DC, April 6, 2006. Available at http://ooa.unh.edu/news/4_2006/congress/ full_testimony.html 9 “Gregg Announces Funding for New Hampshire Aquaculture Initiatives.” [Press Release] Office of Judd Gregg, July 30, 2008. 10 Kona Blue Water Farms, LLC. “Draft Supplemental Environmental Assessment for An Expanded Production Capacity and extended Farm Lease Area for Kona Blue’s Offshore Open Ocean Fish Farm Project off Unualoha Point, Kona, Hawaii.” September 10, 2007. 11 “Kona fish farm facing expansion opposition.” Associated Press, January 21, 2008. Available at: http://savekauai.org/oceans/kona-fish-farm-facing-expansion-opposition 12 Kona Blue Water Farms, LLC. “Final Supplemental Environmental Assessment for a Modification to Net Pen Designs within the Existing Production Capacity and farm Lease Area for Kona Blue’s Offshore Open Ocean Fish Farm off Unualoha Point, Kona, Hawaii.” April, 2009 at 3. 13 See Fishy Farms, p. 11 14 Kona Blue Water Farms, LLC. “Final Supplemental Environmental Assessment for a Modification to Net Pen Designs within the Existing Production Capacity and farm Lease Area for Kona Blue’s Offshore Open Ocean Fish Farm off Unualoha Point, Kona, Hawaii” at xxvi. 15 Kona Blue Water Farms, LLC. “Final Supplemental Environmental Assessment for a Modification to Net Pen Designs within the Existing Production Capacity and farm Lease Area for Kona Blue’s Offshore Open Ocean Fish Farm off Unualoha Point, Kona, Hawaii.” Op cit. 16 Ibid at iii 17 Ibid at xiii 18 Ibid at 30 19 Ibid at 22: “The Kona Blue operation currently employs a total of 33 professional and semi-professional workers, down from a previous high of 49 employees six months ago.” 20 Ibid at 10 21 State of Hawaii Department of Land and Natural Resources submittals, GL S05721, August 28, 2009. 22 Personal Communication. Kelly Coleman, Vice President of Marketing, Kona Blue Water Farms, July 28, 2009. 1

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Ibid. “Adoption of Genetically Engineered Crops in the U.S.: Soybean Varieties.” Data Set, Economic Research Service, United States Department of Agriculture. www.ers.usda.gov/ Data/BiotechCrops/ExtentofAdoptionTable3.htm 25 Kidd, Karen. “Effects of Synthetic Estrogen on Aquatic Population: A Whole Ecosystem Study,” Freshwater Institute, Fisheries and Oceans Canada 26 Bianchi, Alessandra. “The next seafood frontier: The ocean,” CNNMoney.com, April 28, 2009. 27 Fujimori, Leila. “AOL-Time Warner’s Steve Case buys Kauai lands for $25 million.” Sstarbulletin.com, July 8, 2001. 28 Consent to Assign General Lease No. S-5654 Cates International, Inc., Assignor to Grove Farm Fish and Poi, LLC, Assignee. Board of Land and Natural Resources, February 9, 2007, Exhibit C. Available at: http://state.hi.us/dlnr/chair/meetings/submittals/20070209/ ld/D%20-%20Land%20Division%20-%20Submittals%20D11.PDF 29 “Report to the Twenty-Fourth Legislature, State of Hawaii, 2008 Regular Session: Implementation of Chapter 190D, Hawaii Revised Statutes Ocean and Submerged Lands Leasing.” Department of Agriculture and Department of Land and Natural Resources, Nov. 2007 at 9. 30 Aquaculture Planning & Advocacy LLC. “Final Environment Assesment: Proposed Expansion of Hukilau Foods Offshore Fish Farm, Mamala Bay, Oahu, Hawaii.” July 29, 2009, p. 3 and 8. 31 Calculations conducted by and on file at Food & Water Watch. For more information contact 202.683.2500 32 “Fate of Dredge Disposal Material and Polluted Sediment, Offshore Honolulu, Hawaii.” USGS, Western Coastal and Marine Geology. Available at: http://walrus.wr.usgs.gov/ mamalabay/ ; Aquaculture Planning & Advocacy Op cit at 25 ; And Information gathered from Google Earth Ocean Layer. Contact Food & Water Watch for more information: 202.683.2500. 33 Memo from Katherine Puana Kealoha, Office of Environmental Quality Control to Sammuel J. Lemmo, Office of Conservation and Coastal Lands, July 29, 2009. Attached to Aquaculture Planning & Advocacy Op cit. 34 “Report to the Twenty-Fifth Legislature, State of Hawaii, 2008 Regular Session: Implementation of Chapter 190D, Hawaii Revised Statutes Ocean and Submerged Lands Leasing.” Department of Agriculture and Department of Land and Natural Resources, at 7-8, Dec. 2008. 35 Lemmo, Samuel J. “Acceptance of Final Environmental Impact Statement for the Hawaii Oceanic Technology Ahi Aquaculture Project, Offshore Waters of Malae Point, North Kohala, Island of Hawaii.” Memo to Office of Environmental Quality Control, July 7, 2009. Attached to: Tetra Tech, Inc. “Final Environmental Impact Statement for the Ahi Aquaculture Project Kohala Coasta, Hawaii.” May 25, 2009. 36 Notice of Public Hearing on Proposed Land Use Within the Conservation District, March 14, 2009. Available at: http://hawaii.gov/dlnr/occl/hearings-workshops 37 Personal Communication. Dawn Hegger, Department of Land and Natural Resources, August 12, 2009. 38 Tetra Tech, Inc. “Final Environmental Impact Statement for the Ahi Aquaculture Project Kohala Coasta, Hawaii.” May 25, 2009 at 1-8. 39 McVey, Jim. “Informal Presentation: Indigo Seafood.” Kohala Ranch, Hawaii, May 23, 2009. On file at Food & Water Watch 40 McVey, Jim. Indigo Seafoods Meeting, Spencer Beach Park, Kawaihae, Hawaii, May 22, 2009. And McVey, Jim. Indigo Seafoods Presentation. Kohala Ranch Polo Field, Hawaii, May 23, 2009. Transcriptions from meetings on file at Food & Water Watch 41 Maui Fresh Fish, www.mauifreshfish.com, 2008. Referenced August, 2009. 23 24

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Lum, Curtis. “Aquaculture sales net record $34.7M,” Honoluluadvertiser.com, August 31, 2009. 43 “Researchers test-self-propelled fish farm.” IntraFish, September 10, 2008. 44 Cohen, Andrea. [Press Release] “MIT tests self-propelled cage for fish farming.” Massachusetts Institute of Technology, September 2, 2008. 45 Handwerk, Brian. “Giant Robotic Cages to Roam Seas as Future Fish Farms?” National Geographic News, August 18, 2009. 46 “Fish farm leaves Culebra for Panama – Unable to land permits to increase production, finally pack up,” Caribbean Update, Caribbean Update, Inc, July 5, 2009. 47 Thurston, Lawson D. “Snapperfarm looks to increase local production from 50 to 750 tons.” Carribean Business, Jan. 11, 2007. http://www.caribbeanbusinesspr.com/archives/ ArcDetail2.php?archID=22126&q= 48 Bianchi, Alessandra. Op cit. 49 Open Blue Sea Farms. “Who We Are,” 2009. Referenced August 2009. Available at: http://openblueseafarms.com/who_we_are/our_company.html 50 Open Blue Sea Farms. “Open Blue Cobia: Free-Range.” 2009, Referenced August 2009. Available: http://openblueseafarms.com/open_blue_cobia/free_range.html 51 “Free-range,” despite having no standard definition according to the United States Department of Agriculture, generally means that the animals being raised are “free to roam.” The label is unverified by any particular source or agency, and therefore its meaning and usage are inconsistent among producers and farmers, and between species. See Consumers Union Guide to Environmental Labels: http://www.greenerchoices.org/ecolabels/label.cf m?LabelID=111&searchType=Label&searchValue=free%20range&refpage=labelSearch&re fqstr=label%3Dfree%2520range 52 Bianchi, Alessandra. Op cit. 53 Open Blue Sea Farms. “Who We Are,” Op Cit. 54 Open Blue Sea Farms. [Press Release]. “Open Blue Sea Farms’ Panama Acquisition Creates World’s Largest Open Ocean Aquaculture Operation.” August 31, 2009. 55 Hukilau’s current production capacity is 1.2 million pounds a year (or 544 metric tons) and Kona Blue is currently producing 500 tons a year. See: Aquaculture Planning & Advocacy LLC. “Final Environment Assesment: Proposed Expansion of Hukilau Foods Offshore Fish Farm, Mamala Bay, Oahu, Hawaii.” Op cit at 8 and; Kona Blue Water Farms, LLC. “Final Supplemental Environmental Assessment for a Modification to Net Pen Designs within the Existing Production Capacity and farm Lease Area for Kona Blue’s Offshore Open Ocean Fish Farm off Unualoha Point, Kona, Hawaii.” Op cit. at x. 56 Kent, Donald. “Development of Marine Aquaculture. A National Imperative — A San Diego Opportunity.” Presentation on Hubbs-SeaWorld Research Institute Aquaculture Project at Surfrider Member Meeting, La Jolla, CA. March 18, 2009 57 Lee, Mike. “Institute proposing fish farm in federal waters; Project off San Diego still must clear hurdles.” San Diego Union-Tribune. February 2, 2009. 58 “Recipients of the 2006 NOAA National Marine Aquaculture Initiative Grants.” National Oceanic and Atmospheric Administration. September 2006; “The Saltonstall-Kennedy Grant Program: Fisheries Research and Development. Report 1998.” Financial Services Division, National Oceanic and Atmospheric Administration. Aug. 1, 1998. 59 “New Offshore Aquaculture Trade Organisation Reveals New Board.” TheFishSite, Feb. 25, 2008. 60 Calculations conducted based on information obtained through Freedom of Information Act requests Food & Water Watch submitted to NOAA regarding the amount of money spent by NOAA and/or NMFS’s employees, agents, and/or assigns regarding the Gulf of Mexico Fishery Management Council’s Fishery Management Plan (FMP) for offshore aquaculture. 42

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