The Project:

Hawaii Ocean Technology’s (HOT) has been granted a Conservation District Use Application for its ahi aquaculture project. They plan to use 247 acres off the north Kohala coast of the island of Hawaii to hold 12 orb-like cages for growing tuna for export outside of Hawai'i.

Read why ten eminent scientists recommend against instituting aquaculture fisheries in the Gulf of Mexico

The Problems:

• Fish Farming promotes the proliferation of antibiotic-resistant bacteria, which can infect humans. 
  The industrialization of aquaculture has resulted in many of the same environmental and human health problems currently created by livestock factory farms. In addition to polluting aquatic ecosystems with the enormous volume of waste produced by the fish they confine, aquaculture facilities threaten the environment and human health by releasing hazardous substances such as pesticides, antibiotics, and other drugs into the aquatic environment.
  
  HOT fails to elaborate on potential health issues that may occur when thousands of fish are confined in a small space. Often, industrial aquaculture facilities address this problem by utilizing the same irresponsible antibiotics practices as industrial livestock operations; rather than reducing the density of fish, fish farms continuously administer sub- therapeutic doses of antibiotics. This promotes the proliferation of antibiotic-resistant bacteria, which can infect humans.  The problem is exacerbated by cages and net pens allowing antibiotics and antibiotic-resistant bacteria to pass freely into surrounding waters.
  
  
• Farmed Fish Strip the ocean of fish for their feed
  HOT states a 100 pound tuna requires approximately 200 pounds of dry feed. One thousand tons of feed stock per month will be required when fully operational by 2013 yet they admit that the specific components of fish meal and fish oil to be used as feed is at present unknown.
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• Farmed Fish Breed Disease which is passed on to wild fish
  The risk of disease transmission is increased when imported, unprocessed fish are used as feed therefore it is imperative to disclose what the components of this feed will be. Further, when feed accumulates on the seafloor, it is eventually decomposed by bacteria, which consume oxygen dissolved in the water and can thus create hypoxic “dead zones” below aquaculture facilities.
  
  
• Waste—The Hawaii County Department of Research and Development states that the project could generate as much as 2,000 tons of “offal” yearly and asks for details in how it would be handled (page 13). HOT replies (page 14) that “no waste will be introduced into the Big Island landflls.” Where will it go? There is a suggestion that ranchers may be interested in the byproducts. Will that pass Department of Health muster?

• Lease cost—Two existing aquaculture operations in Hawaii pay combined yearly lease revenue to the state of $3500 (Hukilau/Cates= $1400; Kona Blue= $2100). What percentage of $120 million expected yearly revenues will HOT pay the state for exclusive use of 247 acres of ocean resources?

• Noise—No acoustic impact analysis report has been prepared to indicate what combined effects noises in the 70-130 decibel range (page 7) would have on marine mammals.

• Cage fouling—It is unclear how algal fouling would be cleared from the cages (page 9). Would it be accomplished by divers tediously scrubbing the cages on a daily basis, or by raising the tops of the cages to the surface to “air dry” them for hours, as is done regularly by Kona Blue?

• Mortalities—Percentage of dead fish to be removed from cages is estimated at 1% (of 20,000/cage). How is this estimate arrived upon, since this species has not been raised previously in Hawaiian waters? What percentage of “morts” would be tested for disease? How would 2400 dead fish (with possibility of disease) be disposed of? Landfill? Incinerator?

• Size and scope—What is the purpose of proposing such an enormous project despite, “a multitude of untried and untested aspects of this project?” (DAR, page 21-22). Other aquaculture ventures in Hawaii have proceeded with conservative size and project scopes, yet HOT proposes a lease area three times larger, with production scaled at 10-20 times more than Hukilau/Cates and Kona Blue. Why? HOT continues to be vague on the expected yields of their project, by a factor of 100%! They contradict earlier statements of 6,000 ton (12,000,000 pounds) yearly production by stating (page 35) that production will vary between 6,000 or 12,000 tons, “depending upon the final system design.” That is an incredible amount of uncertainty and wiggle room. One obvious discrepancy in their stated impacts is it would then require twice as much fish feed (24,000,000 pounds) yearly for the greater yield.

• Public Trust Doctrine and Precautionary Principle—Food & Water Watch cited Hawaii Constitutional provisions in their August 27, 2009 letter (page 38). These seem every bit as relevant to the review of the applications being sought as any other laws and rules cited in the submittal, yet neither HOT nor staff responded to indicate they were being considered or incorporated in any way.

• Engine design/Hybrid Solar Ocean thermal Energy Conversion Power—The propulsion system originally described in the DEIS subsequently changed by the time the FEIS was issued, thereby denying the public the opportunity to study its potential impacts. Staff notes that HOT submitted the design to them on 9/9/09, meaning the public has not seen it within the framework of legal environmental review, except for in this submittal, only made available to the public four days ago.

• Disease—There is no discussion of how potential disease outbreaks in the cages would be handled. A full mitigation plan must be discussed. Spread of disease, pathogens, and parasites are major negative impacts that have devastated caged and wild populations of fish globally, and is one of the most dangerous side-affects of well-intended aquaculture projects. See attached scientific studies by Gaughan, Frazer (UH), and Tacon & Metian. All three studies, and an attached article about the 85% collapse of Chilean aquaculture stocks, describe catastrophic impacts spread by fish farms.
  
  
  
• Fish food
  It is acknowledged that the enormous amount of food to supply such a large biomass of pelagic fish as proposed will undoubtedly have impacts on the area where it is collected, grown, and/or processed. Studies indicate that harvesting millions of tons of baitfish (sardines, herring, anchovies, menhaden, krill, etc.) worldwide greatly impacts regional ecosystems and competes with wild fish populations’ ability to feed themselves (see: Tacon & Metian).
  
  Therefore, aquaculture operators are continually seeking substitutes to feed their caged stock. Kona Blue has substituted soy protein and chicken trimmings to offset percentages of fish meal and fish oil. Top level piscatavores (fish eaters) like ahi are not expected to have the same growth characteristics as wild fish if they are fed land-based proteins. HOT acknowledges they, “have not identified the best diet yet.” (page 44).
  
  HOT gives a cut and paste answer throughout the submittal that includes these quotes: “HOT will use a feed company which is responsive to our exact specifications, and very transparent about their feed ingredients and processing. At this time the vendor to supply the fish feed has not been selected. So, the specific components of the fish meal, fish oil is currently unknown. HOT has no plans to use GMO soy. HOT will also seek to identify local alternatives…” (page 35 et al).
  
  Considering they are projecting the need for 12,000,000 pounds of feed annually, this language is incredibly vague. There must be full disclosure and understanding of the components of the fish feed, the sources from which they are derived, and the impacts from withdrawing them and importing those resources to Hawaii. Note that 100% of the feed would be imported.
  
  On the same page, HOT claims, “No soy or grains of any kind are expected [emphasis added] to be used as part of the feed. Ahi are carnivorous (meat eaters) not herbivores (vegetable eaters) and the company intends to use a fish feed that contains components consistent with the usual Ahi diet and nutritional profile.” That seems to indicate they would be using 100% ocean-based food, which again brings up questions about cumulative impacts on bait fish stocks. and needs to be clarified and conditioned.
  
  Finally, how much space would be needed to store these enormous amounts of feed? Is there existing facilities in Kawaihae harbor to facilitate this/ How would vermin be kept from moving in and contaminating the feed?
  
• Sustainability
  HOT repeatedly uses the term, “economically sustainable,” which presumably means they hope to have revenues exceed expenses and be financially successful. But it does not address using local resources to create benefits for local people, without depending upon imports and exports to balance the equation. 100% imports and 90% exports does not equal sustainability.
  
  
• Economics
  For a proposal projecting such huge revenues, there is a shockingly small number of jobs expected to be created. Half of these are for divers and laborers. Furthermore, qualifying for Act 221 high tech tax benefits means that a large chunk of state revenues would be avoided. Detailed analysis of expected revenues through taxes and revenues should be disclosed.

Exceptional comments/quotations from the submittal document

“Farm the ocean like we farm the land.” (page 16) The problem with this idealized notion is that this is not a farm; it is an industrial feedlot. As such, problems are similar to factory feedlots for cattle, chickens, or pigs—pollution, pathogens, disease, and the need for antibiotics.

“Marine aquaculture has been well tested, is sustainable, and will create a better product.” (page 19) For those who may believe in this Pollyanna-ish view, I strongly suggest they read the book, “Swimming in Circles.” (Molyneaux)

“The fisherman (sic) of the world can become farmers.” (page 20) (see above)

“In other words, fish poop may be good for the oceans.” (page 35) How much?

“Commercial output is still a long way away.” (HOT-page 40) Then why the rush to approve this enormous project while questions remain unanswered?

“Staff notes the proposed project seems to be more science fiction than reality.” (page 57) It seems unwise to base real permit approvals on so many uncertainties.

Recommendations

Address all unanswered questions, economic, scientific, cultural and environmental concerns and inconsistencies through further research, dialogue, and outreach. Assure the vested rights of Big Island residents to have a bona fide voice in the process by scheduling meetings in West Hawaii. Be certain of the ability to mitigate potential problems and impacts before approving permits to allow the proposal to move forward. As Eden Peart of the Hawaii Farmers Union stated (page 33), “The proposal should not be considered without educational outreach and public hearings.”

Merely to cite ocean fishery mismanagement and plummeting populations of fish species worldwide to justify open ocean industrialized fish feedlots to be constructed is an impetuous approach. Great caution must be taken as we move to create better models for local food production. It is entirely possible that there is greater merit and much more potential for sustainability in reviving historic Hawaiian coastal fishponds, or in pursuing land-based recirculating aquaculture and aquaponics systems that utilize nutrient-rich fish waste to grow vegetables.

HOT submittal to State of Hawai'i

Tacon & Metian—2008 study—global overview on the use of fish meal and fish oil in industrially produced aquafeeds: Trends and future prospects

Gaughan—Spread of viral outbreaks and pathogens in baitfish, mollusks, salmon, tuna, and shrimp aquaculture operations

Gulf Aqua—Ten eminent scientists’ letter to U.S. Dept. of Commerce recommending against instituting aquaculture fisheries in the Gulf of Mexico (Aug. 2009).