In 1999 the Hawaii State Legislature enacted the Ocean and Submerged Lands Leasing Program to allow ocean aquaculture (fish farms) in Hawaiian waters. Shortly thereafter, the State signed its first lease to Cates International closed-cage Moi Farm off of Ewa Beach, Oahu. Today, Cates International raises about 100,000 moi (pacific threadfin) in a spacious closed-cage system anchored to the ocean floor, two miles offshore from Honolulu International Airport. With the recent success of the Cates International closed-cage Moi Farm off of Ewa Beach, caged fish farming in the open ocean is attracting a lot of interest, particularly in Hawaii's Class AA/A Pristine waters.

Although closed-cage fish farms like those of Cates International hold great economic potential for Hawaii, other types of ocean aquaculture can present a danger to our pristine waters. There is a proposal by a privately funded firm, Ahi Nui Tuna Farming LLC, backed by both local and British Columbian investors, to develop a 216 acre open-pen fish farm with an approximate count of 54,000 yellow-fin and big-eye tuna to be located 1/2 mile off the North Kohala coast.

Open-pen aquaculture (which is basically an agricultural feed lot) similar to that of Ahi Nui Tuna Farms is not a "clean" industry. In fact, the open-pen aquaculture industry has developed a global track record for being environmentally unfriendly and polluting. High levels of organic and nutrient pollution (unused feed, ammonia & fish feces) from open cage feed lots has rapidly evolved to become the number one environmental threat to the ocean environment in countries where open-pen aquaculture farms operate.

While Kako'o is optimistic about the future of aquaculture practices in the State of Hawaii, we are highly concerned with the open-pen fin-fish aquaculture tuna grow-out project as it is presently proposed. In the U.S.A., the industry is in its infancy and we feel strongly that the State of Hawaii should proceed with extreme caution. The need for well thought out strategic and tactical plans (with safeguards and accountability) for the systematic deployment of our ocean resources is imperative. We have an opportunity to participate in a leading-edge food production practice that can potentially be beneficial for the State of Hawaii. However, the undertaking should be carefully considered such that we do not repeat the same mistakes that other countries are having with the practice of open-pen tuna farming.

The Environmental Assessment (EA) prepared by Ahi Nui was reviewed by members of our organization. Our overall impression of the EA is that it is a tool of justification for the project rather than a discovery and study of actual impacts. We feel strongly that a comprehensive environmental impact study is needed to more fully disclose any potential environmental issues that may not be readily apparent at this time.

On the surface, the Ahi Nui Tuna Farming venture appears to be beneficial to the local economy for the short term. However, there are potential problems below the surface that could have long reaching effects on the ecosystem and existing marine life. There are always costs associated with actions anytime the course of nature is changed or altered. Many of these costs do not become apparent until long after the damage is done. The Kohala Coast is not a renewable resource and needs to be protected.

Kako'o is highly concerned about the growth of this industry in the State of Hawaii. However, this does not imply that we are opposed to the use of our ocean for aquaculture purposes. We are favorably impressed with the innovative progress of Cates International and feel strongly that this is a good example of marine aquaculture that is sustainable without having detrimental impacts on the ecosystem. Closed-pen fish farms, like those of Cates International hold great economic potential for Hawaii; however, open-pen ocean fish farms can present a serious danger to our Class AA/A pristine waters. One cannot deny the fact that the concentration of fish feces, ammonia and uneaten food in a specific ocean area is in fact an introduction of vast amounts of pollution to the area. Accordingly, there will be environmental issues and consequences that we will have to contend with.

Following are pertinent background reading items that may be of interest. While these cases do not deal specifically with "yellow fin" tuna farming in North Kohala, they do help to illustrate how volatile environmental and ocean use issues can arise.  For example, the Louth Bay Tuna Case (South Australia) is a significant case when it comes to Government and its inability to administer and regulate the resource. We need to ask ourselves if this could happen in the State of Hawaii. A little closer to home - in the State of Maine - which is subject to EPA standards and regulations, the residents are dealing with the environmental ramifications associated with the leasing of "Submerged Public Lands." It is important to note that the environmental damage in this case occurred under the watchful eye of the Maine Department of Marine Resources and the EPA.

Environment, Resources and Development Committee Report on Louth Bay Tuna Farms

Environmental Ruling on Tuna May Risk Aquaculture Industries

An Act to Make Changes to the Laws Governing Aquaculture Leasing

Aquaculture: An Important Coastal Industry, But at What Cost to Marine Habitat

Australia isn't the only place dealing with environmental disasters associated with the aquaculture of fin-fish. There is a lot of informative information on the environmental disasters associated with open pen Salmon Farming. The aquaculture of Salmon is different from that of tuna. However, many of the issues apply to all forms of open pen farming. The Leggatt inquiry from British Columbia has credibility. There ae also many environmental problems associated with open-pen fish farms in Spain.

The Legatt Examination of the Salmon Aquaculture Industry in British Columbia

The Salmon Farming Industry Clearly Out of Balance with BC's Natural Environment.

Citizens' Inquiry to Examine Salmon Farming in British Columbia

Remove Net-Cage Salmon Farms, says Leggatt

Other Articles of World Interest Are:

Images from Open Pen Aquaculture

Nitghtmare in New Brunswick: A Salmon Farming Disease Lesson for BC

Tuna Farm Moratorium Petition Fails to Reach EU Ministers

New WWF Report Says Tuna Farming Will Strike Deathblow to Mediterranean Tuna

Tourism Minister Would Rather See Fish Farms Close Down

Dolphin Mortalities in Tuna Feed Lots near Port Lincoln, South Australia: An Update

Tuna Farming in Louth Bay Still in Doubt

Atlantic Salmon' a Fishy Tale:Chilean Industry Criticized for Pollution

Aquaculture and Pesticides

TIME MAGAZINE-Is Fish Farming Safe?

LA Times- Fish Farms Become Feedlots of the Sea

LA Times- Tired of Swimming Upstream, Salmon Farmer Moving On

Hawaii Related Articles of Interest:

FAD Will Attract Sharks, Frighten Visitors

Ahi Nui Tuna Farm Concerns

Puako Reef May Be In Peril

Open Pen Aquaculture - A Threat to the West Hawaii Tourism Industry

Na Akua Got It Right

Kako'o's Response to Ahi Nui's EA - Why an EIS Should to be Done

Kako'o's Petition for a Contested Case Hearing / Board of Land and Natural Resources

Community Groups Oppose Fish Farms

Tuna Farm To Conduct Full Analysis (EIS)

Honolulu Star Bulletin - Proposed Fish Farm off Kawaihae Delayed

OHA Responds

Leningrad Elarionoff, City Councilman Speaks Out

Implementation of Chapter 190D, Hawaii Revised Statutes, Ocean and Submerged
Lands Leasing

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Tuna Farm Moratorium Petition Fails to Reach EU Ministers

Release from: CARTAGENA, Spain, April 29, 2002 (ENS)
http://www.flmnh.ufl.edu/fish/InNews/tunafarm.htm
April 29, 2002

There is a better than 50/50 chance that people enjoying tuna sushi half a world away in Japan are eating not wild fish but fish that have been fattened on tuna farms in the Mediterranean Sea.
A total of 12 tuna farms now operating in the Mediterranean produced 11,000 tons of tuna fish in 2001 - more than half the traded blue fin tuna in the world.
Two international conservation groups and the largest environmental group in Spain's Murcia province today attempted to sound a warning that an expansion in tuna farming threatens to destroy the already overfished wild tuna in the Mediterranean.
Together with representatives of Greenpeace, and the Asociacion de Naturalistas del Sureste (ANSE), the conservation group WWF tried to call the attention of 15 European Union Agriculture Ministers to the "harmful new trend."
The ministers were onboard the Spanish Navy flag ship Juan Sebastián El Cano on a visit to a bluefin tuna farm located near Tiñoso Cape at Cartagena in Spain's Murcia province. On their sailboat, the environmental groups displayed a banner with the message "STOP Blue Fin Tuna
Overfishing." Their intention was to reach the Spanish Navy ship in a lifeboat displaying a second banner saying "STOP tuna farms" and give the ministerial delegation a document with several petitions concerning tuna farming. But the Spanish government delegation in Murcia stopped the sailboat and prevented the environmentalists from presenting the document to the ministers.
Tuna farming - caging of wild tuna for fattening - is a phenomenon driven mainly by Japanese market demands. Farmed tuna is higher in oil content than wild tuna, which makes it desirable for sushi. The Murcian coast is the biggest producer of fattened captive tuna in the world. Six authorized facilities are currently operating in the area with three new facilities going through the environmental impact assessment process. Most of the tuna farms are located in what the environmentalists term "highly ecological sensitive areas," such as the Azohía-Tiñoso Cape.
Tuna farms are also located in Croatia and Malta. France, Tunisia, and Algeria are interested in developing this activity. Tuna farming contributes to the growing overfishing of the world's most important bluefin tuna breeding population, which lives along the Levantine and Balearic Spanish coast, the groups warn. WWF, Greenpeace, and ANSE fear that the new tuna farming facilities waiting for permission in Murcia, Catalonia, Valencia, and the Balearic Islands will increase the pressure on the bluefin tuna breeding population. But proponents of tuna farming, also known as tuna penning and tuna aquaculture, view the practice as a proactive means to increase the efficiency of the tuna industry while reducing the exploitation of tuna species.
The three environmental groups are denouncing tuna farming as unsound and warn that it could lead to disturbance of local and regional food chains due to the large number of small pelagic fish caught to feed the captive tuna.
From April 15 to 19, THE International Commission for the Conservation of Atlantic Tunas and the General Fisheries Commission of the Mediterranean met in Malta to consider for the first time the effects of bluefin tuna farming on statistics and stock assessment. The report, which was not made public, will become part of the next bluefin tuna stock assessments planned for July 22 to 30 in Madrid.
In addition to a moratorium on the development of new tuna farming in Mediterranean countries, the environmental groups are calling for "establishment of a No Take Zone" for the Mediterranean bluefin tuna breeding population. The groups say there should be "proper and harmonized regulations for tuna farming practices, since these are large scale agro-industrial operations with major environmental impacts."
Dr. Simon Cripps, director of WWF's Endangered Seas Program, said, "The highly migratory blue-fin tuna is already threatened by direct fishing in the Mediterranean. This so-called tuna farming avoids every regional and international rule set up to conserve and manage the fishery. Governments must urgently take action to close yet another loophole within European fisheries management and step up controls on this growing practice while there is still time."

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New WWF report says tuna farming will strike deathblow to Mediterranean tuna:

From WWF Mediterranean Programme Office
Thursday, April 11, 2002

ROME, ITALY - Rome, Italy ­ According to a new WWF report launched today on tuna farming in the Mediterranean, 'tuna penning', or caging of tuna for fattening, is severely threatening the dwindling populations of wild tuna. In view of this threat, the conservation organization calls for a moratorium on the development of new tuna farms in the Mediterranean, until its environmental impacts, particularly on the tuna stock are addressed at the international and national levels.
The report's launch coincides with a meeting on bluefin tuna to be held in Malta from 15 to 19 April, involving the General Fisheries Commission for the Mediterranean (GFCM) and the International Commission for the Conservation of Atlantic Tuna (ICCAT), the organizations responsible for the management of wild tuna in the Mediterranean. WWF calls on GFCM and ICCAT as well as the European Union to set up effective regulations for tuna farming, aimed at rebuilding the overfished tuna stock. WWF recommends that until these regulations are in effect in the region, further development of tuna farming should be stopped.
"Tuna-farming in the Mediterranean is not true aquaculture but just an added final step of a standard fishery which relies on the already overexploited wild tuna stock. This new practice is expanding the market for bluefin tuna, resulting in a further increase in fishing effort," says Dr Sergi Tudela, Fisheries' Officer at WWF Mediterranean Programme.
Tuna farming in the Mediterranean is a phenomenon driven mainly by Japanese market demands. Farmed tuna is higher in oil content which makes it particularly desirable for sushi. Wild tuna, therefore, are put in cages and fattened to improve the oil content of the flesh in order to meet Japanese market standards. The preference for farmed tuna is evident in their increasing exports to Japan, which shot up from 200 tonnes to about 4300 tonnes in just three years.

Another part of the problem is that tuna farming falls in between the definitions of a standard fishery involving capture of wild stock, and true aquaculture where fish are bred and reared in captivity. It is considered a post-harvest practice and therefore falls outside the regulations put in place by GFCM and ICCAT. This situation has resulted in an unregulated growth of tuna farming. Last year, the 12 tuna farms operating in the Mediterranean region produced 11,000 tonnes of tuna, compared to almost nothing five years ago. This is more than half of the world's total.
Although ICCAT and GFCM are responsible for managing bluefin tuna stock in the Mediterranean, the EU could take action to stop the overfishing of tuna and regulate its farming. Many of the tuna farms operating in the Mediterranean are subsidized under the European Union's Common Fisheries Policy (CFP). With the CFP due for a once-in-ten years' review this year, WWF urges the European Union (EU) to decrease the fishing effort on the wild tuna stock, and to regulate tuna farming when reforming the CFP. In addition, the conservation organization calls on the EU to put in place a recovery plan for bluefin tuna in the Mediterranean. "EU, GFCM and ICCAT should define rules for the quantity of tuna captured for farming, and for controlling exports. Furthermore, the Mediterranean States shouldeffectively implement these rules, " says Paolo Guglielmi, Head of the Marine Unit at the WWF Mediterranean Programme.

For more information, contact:
Anne Rémy
Head of Communications
WWF Mediterranean Programme Office
aremy@wwfmedpo.org
Web site: http://www.panda.org/mediterranean

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Tourism Minister Would Rather See Fish Farms Close Down

by Martin Debattista
May 23, 2002

http://maltamedia.com/cgibin/editor/print.pl?article=1525

The Minister for Tourism Michael Refalo goes as far as suggesting that tuna penning operations should close down for the greater benefit of the Maltese tourism industry. Minister Refalo, speaking at the launch of a book about diving as niche tourism Market in Malta, referred to complaints received and voiced his concern about the proliferation of tuna penning operations. "I accept that these enterprises are big money spinners for whoever invests in them and for Malta's foreign exchange earnings. However there is no comparison between them and the contribution that the tourist industry makes in the way of job creation and earnings. If tuna penning operations harm tourism and are a cause of pollution to our seas, then it is the penning operations which must move further out to sea or close down, not tourism," he said. The Minister said that he would organize a trip and personally visit to see tuna penning operations with divers and the media, to see for himself. The Minister also warned that for tourism to succeed everyone has to play a part to ensure the industry's prosperity. "We cannot work at cross purposes. Maltese and visitors insist on clean, unpolluted seas. God has been kind to us. We must therefore see that man also does his bit." Speaking at the launch of the new book "Guide to shore diving in the Maltese Islands", by Peter G. Lemon, Minister Refalo said that diving accounted for around 80,000 visitors annually and that MTA gave great attention and importance to this market segment. He added "motivational travel niches have been instrumental in shielding Malta from the full brunt of the 11th September crisis." The minister also announced that the Blue Dolphin of Malta Trophy for underwater photography, which had been inexplicably discontinued some years back, would be revived and held in November 2002.

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Dolphin mortalities in tuna feedlots near Port Lincoln, South Australia: an update

by Catherine Kemper and Susan Gibbs, South Australian Museum
Extract of Article from Waves - the Newsletter of the Marine & Coastal Community Network
Vol 7, No 3 Spring 2000

There have been few studies of incidental capture of whales and dolphins in Australian waters. The highest recorded bycatch rates (estimated at 4,662 in 2 years) were found in Taiwanese pelagic gillnets off northern Australia in the 1980s (Harwood et al. 1984, Hembree and Harwood 1987). In South Australia, at least 13% of all dolphin carcasses studied are believed to have died as result of entanglement, including many in the tuna feedlots near Port Lincoln (Kemper and Gibbs 1997). With the aquaculture industry set to expand in Australia in the next few years, monitoring and mitigating incidental captures should be a priority for new and existing operations.

Tuna feedlotting has been practised in the Port Lincoln region since 1992 and there are now 110 cages operated by about 12 companies in an area of about 200 km2. Predator exclusion nets (8 to 30 cm stretched mesh size) surround the main nets of many cages. Our initial study identified that large-meshed predator nets were probably responsible for most of the dolphin deaths and the 1997 report recommended either removing them or ensuring that mesh size was less than 8 cm. An unknown number of feedlots have made these changes.

The 1997 report also recommended minimising wastage when feeding tuna, since overfeeding attracts other fish species to the vicinity of the feedlots. The evidence from our study of carcasses strongly suggested that dolphins and sea-lions are eating these other species in the vicinity of the feedlots, and then becoming entangled.

The total known dolphin mortalities in the Port Lincoln tuna feedlots stands at 30 reported and 4 suspected for the period 1990- 1999. Twenty-four carcasses were collected for study at the South Australian Museum. There were about twice as many bottlenose as common dolphins. Seven feedlotting companies have assisted by reporting mortalities, and in the past two years these have been accompanied by detailed information on the nature of the entanglement and net characteristics. These data (on six entanglements) have shown that large-meshed predator exclusion nets were responsible for the mortalities and that body extremities (flipper, nose, tail, head) were caught.

Many dolphins, especially bottlenoses, were juveniles and young sexually mature animals. Of the sexually mature females, most were lactating or pregnant. This could have negative impacts on the population in the Port Lincoln region but the effect of all the mortalities will not be known unless the size of this population is estimated.

In addition to the reported and suspected entanglements, there have been 33 beach-cast or floating carcasses reported in the Port Lincoln region between 1990 and 1999, with most since 1995. Ten have died as a result of accidental or intentional injury by humans and the rest from undetermined causes, possibly including disease. The number for the first half of 2000 is already in excess of 12 dolphins.

The South Australian Museum has been collecting records of dead and stranded dolphins around the South Australian coast for many years. These data suggest that the Port Lincoln region (about 100 km of coast from Cape Donington to Point Bolingbroke) has a disproportionate number of dolphin deaths. Excluding the known tuna feedlot entanglements, 12% of all South Australia's dolphin mortalities between 1990 and 1999 were recorded there. We know that some were intentionally killed and others possibly died of disease but there were many that died of unknown causes because the carcasses were often very decomposed when they were dissected. The cause of so many mortalities needs to be investigated so that the viability of the region's dolphin populations is ensured.

References

Harwood, M. B., McNamara, K. J. and Anderson, G.R.V. 1984. Incidental catch of small cetaceans in a gillnet fishery in northern Australian waters. Reports of the International Whaling Commission 34:555-559.

Hembree, D. and Harwood, M. B. 1987. Pelagic gillnet modification trials in northern Australian seas. Report of the International Whaling Commission 37:369-373.

Kemper, C. M. and Gibbs, S. E. 1997. A study of life history parameters of dolphins and seals entangled in tuna farms near Port Lincoln, and comparisons with information from other South Australian dolphin carcasses. Unpublished report to Environment Australia. 47 pp.

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TIME MAGAZINE - Is Fish Farming Safe?

Aquaculture has become the world's fastest-growing food business. But it's
taking a hit from environmentalists
By TERRY MCCARTHY/CAMPBELL RIVER

Monday, Nov. 25, 2002

Flying in a seaplane up the east coast of Vancouver Island in British Columbia you see little but forested hills, a myriad of islands and the blue waters of the narrow channel that runs from Seattle to the Alaska Panhandle. As the plane drops over a ridge, a floating hut appears, anchored in the channel and nestled in a grid of net-covered pens. It all looks innocuous enough - no smoking chimneys, no visible plumes of discharge, no growling of chainsaws, not even a road.

This is Venture Point, 15 minutes northeast of Campbell River by air, one of 91 salmon farms licensed to operate in British Columbian waters. They produce some 50,000 tons of salmon a year, most of it destined for the U.S. market. Young men work their way along the floating walkways around the 10,000-sq.-ft. pens, tossing brown food pellets that are met by a swirl of fish. In these 12 pens, there are about 1 million salmon, each a delicious, silver-sided beauty, and when harvested in 18 months, they will fetch more than $10 million in retail sales.

What could be wrong with this picture? The farm-grown harvest is cheap, predictable and year-round. "A fillet of farmed salmon in your supermarket is fresher than a wild fish netted at sea that can take five to six days to get to harbor," says Odd Grydeland, 54, former president of the British Columbia Salmon Farmers Association and an executive at Heritage Salmon, based in New Brunswick, B.C. Moreover, each farm-grown salmon means, in theory, one less fish taken from wild stocks that have been declining for decades. (Farm-raised fish now make up most of the fresh salmon sold in U.S. supermarkets.)

But the story isn't that simple. Salmon farming can be a dirty business. According to Otto Langer, 56, a biologist who worked 30 years for Canada's Department of Fisheries, a large salmon farm may pour as much liquid waste into the sea as a small city. Add to that the plagues of destructive sea lice that thrive in densely packed salmon pens and the schools of farm-grown fish that inevitably escape to the open sea, where they spread diseases and compete for food and breeding grounds with wild stocks.

Because salmon are voracious eaters of smaller species, it takes several pounds of wild fish, ground up into meal, to yield 1 lb. of farmed salmon - an exchange that depletes the world supply of protein. The diet of farmed salmon lacks the small, pink-colored krill that their wild cousins eat, so the flesh of farmed fish is gray; a synthetic version of astaxanthin, a naturally occurring pigment, is added to the feed.

Aquaculture - the commercial raising of fish - is being touted as a "blue revolution," a seagoing version of the Green Revolution that vastly multiplied agricultural output in underdeveloped countries. But just as the Green Revolution sparked concerns about its reliance on pesticides and chemical fertilizers, so has the blue revolution provoked a rebellion among scientists and environmentalists who fear that the industry, if left unregulated, could wreak havoc in oceans and estuaries. "We are not against
aquaculture," says Langer, "but we are against the way it is being done now."

It has been several decades since there were enough fish in the sea to meet, on a sustainable basis, the growing worldwide demand for seafood - which accounts for 16% of global animal-protein intake, up from 14% in the early 1960s. About half the world's wild fisheries have been exhausted by overfishing. In the North Atlantic, one of the most depleted oceans, populations of popular fish (cod, flounder, haddock, hake and tuna) are just one-sixth of what they were a century ago. A European Union panel last week
backed calls for a total ban on the fishing of cod in the North Atlantic and a moratorium on the fishing of haddock and whiting there.

Aquaculture was supposed to pick up the slack. It's already the world's fastest-growing food industry, with production increasing more than 10% a year. Farmed fish and shellfish supply 30% of all the seafood consumed worldwide today, up from 10% two decades ago.

But while the principles of aquaculture are generally accepted, experts fiercely debate which types of fish farming are safe to pursue. Says Andrew Fisk, 37, aquaculture coordinator for Maine's department of marine resources: "Aquaculturists used to be the good guys, and now they aren't, and there is a lot of anger on both sides."

On an eco-friendly scale, bivalves generally rate highest among the more than 220 species of fish and shellfish that are cultivated commercially. Mussels and oysters are filter-feeders that make the surrounding water cleaner, so small-scale farming of them is not usually harmful to the ecosystem. Farming of crayfish in China - the largest supplier to the U.S.--is a relatively low-maintenance, drug-free business carried out in rice paddies. Next come the vegetarian freshwater species that do not need large quantities of fish meal - carp, catfish and tilapia. At the bottom are salmon and shrimp, onetime luxury foods that, thanks to aquaculture, can be
purchased around the world in any season at supermarket prices. Both species eat several pounds of fish meal to gain a pound of weight. And both create lots of waste.

T I M E B O N U S S E C T I O N / G L O B A L B U S I N E S S / F I S H
F A R M I N G

To see fish farming at its worst, travel to Chile, where salmon farming has boomed in the past decade and generates $1 billion a year in export revenue. "A film of feed leftover made of fish oil, animal fat and transgenic soybean oil floats on the water around the salmon farms," says Ronald Pfeil, 67, a cattle farmer in Chile's remote Aysen region. "When the tide is low, the
beaches stink."

Under international pressure, Chile introduced strict new regulations in January. But the problems surrounding fish farming are complex, and some are only dimly understood. Daniel Pauly, 55, a professor of fisheries science at the University of British Columbia, has calculated that it takes 2 to 5 lbs. of anchovies, sardines, menhaden and the other oily fish that comprise fish
meal to produce 1 lb. of farmed salmon, which he says makes no sense in a world trying to increase the amount of available protein. Kentucky State University biologist James Tidwell, 47, a former president of the World Aquaculture Society, points out, however, that wild salmon are bigger eaters than that - consuming at least 10 lbs. of fish to add 1 lb. in weight - and argues that harvesting large amounts of short-lived species like menhaden is no more harmful than mowing the lawn. "Fish-meal fish are nature's forage,"
he says. "Cropping them merely increases their productivity." Disease is always a problem when fish are raised in close quarters. After a 1999 outbreak of infectious salmon anemia in fish farms in Scotland, all the farm-grown fish within 25 miles were slaughtered. A similar anemia outbreak in Maine two years ago led to the destruction of more than 2.5 million fish - and to federal insurance payouts totaling $16 million. "The more aquaculture there is," warns Callum Roberts, senior lecturer in marine
conservation at the University of York in England, "the more disease there will be."

Some of the antibiotics that fish farmers give their stock to minimize disease pass easily into the surrounding environment, and some are highly toxic. Last year traces of the banned drug nitrofuran, which is dangerous to humans, were found by European Union inspectors in shrimp from Myanmar, Thailand and Vietnam. According to Wang Sihe, an expert with the Jiangsu
Seawater Fisheries Research Institute, Chinese shrimp farms have mixed fish food with antibiotics and dumped it into fish ponds. Chloramphenicol, an antibiotic that can cause fatal anemia in humans, has also been used. The fetid water that runs off shrimp farms is particularly damaging to the environment. Thailand, with 25,000 coastal shrimp farms, is the world's largest exporter of shrimp--$3 billion worth in 2001 alone. Through last June, Thailand accounted for 28% of the shrimp imported into the U.S. But
this commerce is costly. Long strips of coastline south of Bangkok now look like powdery gray moonscapes. Shrimp farms can raise the salinity of the surrounding soil and water, poisoning the land for agriculture. Some flush their effluent into the sea, killing mangrove trees. Shrimp farming is also practiced in Brazil, India and Ecuador, and in the U.S. in Florida, South Carolina and Texas. Parasite infestation is another chronic problem of high-density seafood farms. One of the most damaging organisms is the sea louse, which breeds by the millions in the vicinity of captive salmon. In 1989 Peter Mantle, who owns a wild salmon and sea-trout sport fishery in Delphi on the west coast of Ireland, discovered that young trout returning to his river from the
ocean were covered with lice that were boring through the trouts' skin and feasting on their flesh. The sea lice were breeding near newly installed salmon farms in the inlet fed by his river. By the time the salmon farmers started dosing their pens with anti-sea-lice chemicals, the sea-trout fisheries of the west of Ireland were effectively dead. "Sea-trout fishing was sustainable and eco-friendly," says Mantle, "but the salmon farms killed it off within a decade."

In the long run, wild-fish stocks may face an even greater threat from captive fish escaping and competing with or consuming native fish, or cross-breeding with them and diluting the genes that have helped them survive. Fish escapes are common: nets are ripped open by predators or storms, fish in ponds get swept into channels by rainfall, others are released accidentally during transport. Bighead and silver carp that were introduced to China's plateau lakes in the 1950s have cleared those waters vof whole species of indigenous fish. And Asian carp, which were introduced in Mississippi Delta catfish ponds to control parasites, escaped in the
early 1990s and have migrated up the Mississippi and Illinois rivers to within 25 miles of Lake Michigan, threatening native fish with their voracious feeding habits.

Experts say aquaculture done right could easily feed the world without polluting it. A favored method of environmentalists is the hard-walled pen system that isolates the fish from the surrounding water in 40-ft.-deep tanks and catches their waste in the bottom. Even more secure are containment ponds built onshore into which seawater is pumped. Agrimarine Industries in Cedar, B.C., is testing a site with eight tanks 100 yds. from the sea and 40 ft. above it. But production costs are expected to be about $2.20 a fish - double what it costs to raise a salmon in a net pen. Although salmon farming for decades has been a highly profitable industry
and shows strong promise for the long term, profits are being squeezed today - making it more difficult for operators to adopt more expensive, eco-friendly methods. About 75% of salmon-farming firms are relatively small and privately held and don't make their finances public. The large, publicly held companies in the business - including Dutch food producer Nutreco Holdings NV and Norwegian seafood giants Fjord Seafood ASA, Stolt Sea Farm and Pan Fish ASA - are feeling the pinch. Pan Fish recently reported a quarterly operating loss of $18.5 million.

The Chinese, who have been farming fish for 2,000 years, pioneered a method in which nothing is wasted. Farmers dig ponds around rice paddies and feed carp in the ponds with weeds from the rice field. The silt from the ponds is used as fertilizer for the fields, and crabs are grown to eat pests. Some of those techniques are being adapted in Western fish farms. In Tuscaloosa,
Ala., Dan Butterfield, 59, raises bass, carp, catfish and other species in the same pond; the sun and the catfish feces stimulate the growth of phytoplankton, which feeds the other species. His water stays relatively clean, with no need to discharge wastes. "I am probably the most environment-friendly fish farmer in the country," claims Butterfield, who figures he nets about $1,000 an acre each year on his 150 acres of ponds. But these alternative techniques tend to be expensive and difficult to scale up, which make them a hard sell for U.S. fish farmers. "The challenge is to have the industry grow in a way that is both ecologically sensitive and
sustainable," says Rebecca Goldburg, 44, a scientist who co-authored a report on the aquaculture industry last year for the Pew Oceans Commission. "But until the government steps in, there will be no incentive for the
industry to act."

Boatmen who catch wild fish and shellfish are often more strictly regulated than seafood farmers, whose wholesome image has helped them resist government oversight. But after eight years of discussion, shrimp farmers around the world are considering adoption of a universal certification process that would require them to comply with standards on the siting of ponds, effluent treatment, the reduction of chemicals and disease management. In exchange, their products would be labeled eco-friendly. By
2004, labels indicating whether seafood is farmed or wild will become mandatory in the U.S. (though they won't be required on restaurant menus).

Jason Clay, 51, a senior fellow at World Wildlife Fund who helped develop the standards, is optimistic that they will be accepted. "As the industry gets more competitive, those who survive will be those who do it better and cleaner," he says.

Except in Maine, there's little talk of certification systems among salmon farmers. But there are quiet moves to clean up the industry from within. "A lot of farms were badly run," admits Peter Sawchuk, 49, who has been farming salmon in British Columbia since 1989 for Marine Harvest and Agrimarine. "They were overfed, poorly sited and there was too much drugging. But now we
are getting better. We are not in the business of destroying our farms." Venture Point, near Vancouver Island, is something of a showcase. Underwater video cameras monitor the salmon feeding so that extra pellets are not added after the fish have stopped eating. And those pellets contain up to 60% soy meal instead of fish. Nutreco, the company that owns Venture Point,
individually vaccinates young salmon, reducing the need for larger quantities of antibiotics later on. Venture Point was located in a narrow channel east of Vancouver Island to take advantage of powerful currents that prevent wastes from building up under the pens.

If techniques like those used at Venture Point are widely adopted, fish farming could become sustainable while remaining profitable. If methods don't change, either voluntarily or by government regulation, we may get plenty of fish and shrimp to eat - at least for a while - but lose the wild stocks they came from and the clear blue waters in which they once swam

- With reporting by Andrea Dorfman/New York, Christobal Edwards/Santiago, Stefanie Friedhoff/Walpole, Maine, Helen Gibson/London, Mike Goettig/Kunming, Robert Horn/Bangkok, Frank Sikora/Birmingham and Jiang Xueqin/Wuxi

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Fish Farms Become Feedlots of the Sea

Los Angeles Times - latimes.com
December 9, 2002
By Kenneth R. Weiss, Times Staff Writer

Like cattle pens, the salmon operations bring product to market cheaply. But harm to ocean life and possibly human health has experts worried.

PORT McNEILL, Canada -- PORT McNEILL, Canada -- If you bought a salmon filet in the supermarket recently or ordered one in a restaurant, chances are it was born in a plastic tray here, or a place just like it.

Instead of streaking through the ocean or leaping up rocky streams, it spent three years like a marine couch potato, circling lazily in pens, fattening up on pellets of salmon chow.

It was vaccinated as a small fry to survive the diseases that race through these oceanic feedlots, acres of net-covered pens tethered offshore. It was likely dosed with antibiotics to ward off infection or fed pesticides to shed a beard of bloodsucking sea lice.

For that rich, pink hue, the fish was given a steady diet of synthetic pigment. Without it, the flesh of these caged salmon would be an
unappetizing, pale gray.

While many chefs and seafood lovers snub the feedlot variety as inferior to wild salmon, fish farming is booming. What was once a seasonal delicacy now is sometimes as cheap as chicken and available year-round. Now, the hidden costs of mass-producing these once-wild fish are coming into focus.

Begun in Norway in the late 1960s, salmon farming has spread rapidly to cold-water inlets around the globe. Ninety-one salmon farms now operate in British Columbian waters. The number is expected to reach 200 or more in the next decade.

Industrial fish farming raises many of the same concerns about chemicals and pollutants that are associated with feedlot cattle and factory chicken farms. So far, however, government scientists worry less about the effects of antibiotics, pesticides and artificial dyes on human health than they do about damage to the marine environment.

"They're like floating pig farms," said Daniel Pauly, professor of fisheries at the University of British Columbia in Vancouver. "They consume a tremendous amount of highly concentrated protein pellets and they make a terrific mess."

Fish wastes and uneaten feed smother the sea floor beneath these farms, generating bacteria that consume oxygen vital to shellfish and other bottom-dwelling sea creatures.

Disease and parasites, which would normally exist in relatively low levels in fish scattered around the oceans, can run rampant in densely packed fish farms.

Pesticides fed to the fish and toxic copper sulfate used to keep nets free of algae are building up in sea-floor sediments. Antibiotics have created resistant strains of disease that infect both wild and domesticated fish.

Clouds of sea lice, incubated by captive fish on farms, swarm wild salmon as they swim past on their migration to the ocean.

Of all the concerns, the biggest turns out to be a problem fish farms were supposed to help alleviate: the depletion of marine life from overfishing.

These fish farms contribute to the problem because the captive salmon must be fed. Salmon are carnivores and, unlike vegetarian catfish that are fed grain on farms, they need to eat fish to bulk up fast and remain healthy.

It takes about 2.4 pounds of wild fish to produce one pound of farmed salmon, according to Rosamond L. Naylor, an agricultural economist at Stanford's Center for Environmental Science and Policy.

That means grinding up a lot of sardines, anchovies, mackerel, herring and other fish to produce the oil and meal compressed into pellets of salmon chow.

"We are not taking strain off wild fisheries. We are adding to it," Naylor said. "This cannot be sustained forever."

In British Columbia, the industry, under pressure from environmentalists, marine scientists and local newspapers, is taking steps to mitigate some of the ecological problems.

"We have made some mistakes in the past and we acknowledge them," said Mary Ellen Walling, executive director of the British Columbia Salmon Farmers Assn. "We feel the industry is sustainable, if well-managed, and we have a code of practices that is followed by all of our member companies."

Nearly 30 farms are preparing to move to less ecologically fragile areas, under orders from Canadian authorities.

Some farms have installed underwater video cameras to detect when fish quit feeding, so workers can stop scattering food pellets. Many farms are switching to sturdier nets to stop fish from escaping and keep out marauding sea lions, which are shot if they penetrate the perimeter.

The industry now recognizes that it will soon be pushing the limits of the ocean.

"There will come a time when our industry will use more of the fish oil and fish meal than is available," said Odd Grydeland, an executive at Heritage Salmon in British Columbia. "Our biggest challenge is to find substitute grains for fish meal and fish oil."

Farm-raised salmon now dominates West Coast markets, arriving daily from Canada and Chile. About 80% of the salmon grown in British Columbia goes to markets from Seattle to Los Angeles.

The salmon industry took off so fast in British Columbia in the 1980s that the provincial government, worried about the environmental toll, imposed a ban in 1995 on any new farms.

The industry responded by stuffing, on average, twice as many fish into each farm. Today, farms typically put 50,000 to 90,000 fish in a pen 100 feet by 100 feet. A single farm can grow 400,000 fish. Others raise a million or more.

The moratorium on new farms was lifted in September by the provincial government after voters elected a pro-business slate of lawmakers and administrators. As a result, 10 to 15 farms are expected to open each year over the next decade.

Five international companies -- three of them based in Norway -- control most of the existing farms. Nearly all are situated around Vancouver Island, which begins outside Seattle's Puget Sound and extends up the coast for 300 miles.

It's a lightly populated place of stunning beauty. Cedar, hemlock and Douglas fir grow right down to the high-water mark.

Massive tides flush rich blue-green waters through the archipelago of islands, straits, bays and inlets, nurturing five types of wild salmon. These, in turn, attract seals, sea lions, white-sided dolphins and the world's best known pods of killer whales.

Residents rely on boats and seaplanes to reach surrounding islands that host many of the farms. Each farm is a cluster of pens, often interconnected by metal walkways and tethered offshore by a lattice of steel cables, floats and weights.

In the midst of this idyllic setting, signs of strain on the marine environment are bubbling to the surface much the way diseases and parasites, incubated in European salmon farms, fouled the fiords of Norway and the lochs of Scotland.

In Norway, parasites have so devastated wild fish that the government poisoned all aquatic life in dozens of rivers and streams in an effort to re-boot the ecological system.

"The Norwegian companies are transferring the same operations here that have been used in Europe," said Pauly, the fisheries professor. "So we can infer that every mistake that has been done in Norway and Scotland will be replicated here."

Dale Blackburn, vice president of West Coast operations for Norwegian-based Stolt Sea Farm, said his staff works very closely with its counterparts in Norway. But, he said, "It's ridiculous to think we don't learn from our mistakes and transfer technology blindly."

Still, more than a dozen farms in British Columbia have been stricken by infectious hematopoietic necrosis, a virus that attacks the kidneys and spleen of fish.

Jeanine Siemens, manager of a Stolt farm, said, "It was really hard for me and the crew" to oversee the killing of 900,000 young salmon last August because of a viral outbreak.

"We had a boat pumping dead fish every day," she said. "It took a couple of weeks. But it was the best decision. You are at risk of infecting otherfarms."

Farms are typically required to bury the dead in landfills to protect wild marine life and the environment. But Grieg Seafood recently got an emergency permit from the Canadian government to dump in the Pacific 900 tons of salmon killed by a toxic algae bloom. The emergency? The weight of the dead fish threatened to sink the entire farm.

About 1 million live Atlantic salmon -- favored by farmers because they grow fast and can be packed in tight quarters -- have escaped through holes in nets and storm-wrecked farms in the Pacific Northwest.

Biologists fear these invaders will out-compete Pacific salmon and trout for food and territory, hastening the demise of the native fish. An Atlantic salmon takeover could knock nature's balance out of whack and turn a healthy, diverse marine habitat into one dominated by a single invasive species.

Preserving diversity is essential, biologists say, because multiple species of salmon have a better chance of surviving than just one.

John Volpe, a fisheries ecologist at the University of Alberta, has been swimming rivers with snorkel and mask to document the spread of Atlantic salmon and their offspring.

"In the majority of rivers, I find Atlantic salmon," Volpe said. "We know they are out there; we just don't know how many, or what to do about them."

His research focuses on how Atlantic salmon can colonize, if given a chance. It has terrified the U.S. neighbors to the north. Alaskan officials banned fish farms in 1990 to protect their wild fishery. So they don't take kindly to British Columbian farms creeping toward their southern border.

Although native Pacific salmon are rare and endangered in the Lower 48,Alaska's salmon fisheries are so healthy they have earned the Marine Stewardship Council's eco-label as "sustainable." The council's labels are designed to guide consumers to species that are not being overharvested.

Recently, the prospect of genetically modified salmon that can grow six times faster than normal fish has heightened anxiety. Aqua Bounty Farms Inc., of Waltham, Mass., is seeking U.S. and Canadian approval to alter genes to produce a growth hormone that could shave a year off the usual 2 1/2 to three years it takes to raise a market-size fish.

Commercial fishermen and other critics fear that these "frankenfish" will escape and pose an even greater danger to native species than do the Atlantic salmon.

"Nobody can predict just what that means for our wild salmon," Alaska Gov. Tony Knowles said. "We do see it as a threat."

Canadian commercial fishermen, initially supportive of salmon farms, have grown increasingly hostile. They were stunned in August when their nets came up nearly empty during the first day of the wild pink salmon season in the Broughton Archipelago at the northeast end of Vancouver Island.

"There should have been millions of pinks, but there were fewer than anyone can remember," said Calvin Siider, a salmon gill-netter. "We can't prove that sea lice caused it. But common sense tells you something, if they are covered by sea lice as babies, and they don't come back as adults."

Alexandra Morton, an independent biologist and critic of salmon farms, began examining sea lice in 2001 when a fishermen brought her two baby pink salmon covered with them.

Collecting more than 700 baby pink salmon around farms, she found that 78% were covered with a fatal load of sea lice, which burrow into fish and feed on skin, mucous and blood. Juvenile salmon she netted farther from the farms were largely lice-free.

Bud Graham, British Columbia's assistant deputy minister of agriculture, food and fisheries, called this a "unique phenomenon."

"We have not seen that before. We really don't understand it," he said. "We've not had sea lice problems in our waters, compared to Scotland and Ireland."

Salmon farmers point out that the sea louse exists in the wild. Their captive fish are unlikely hosts, the farmers say, because at the first sign of an outbreak, they add the pesticide emamectin benzoate to the feed.

Under Canadian rules, farmers must halt the use of pesticides 25 days before harvest to make sure all residues are flushed from the fish. If that's done, officials said, pesticides should pose no danger to consumers.

European health officials have debated whether there is any human health risk from synthetic pigment added to the feed to give farmed salmon their pink hue.

In the wild, salmon absorb carotenoid from eating pink krill. On the farm, they get canthaxanthin manufactured by Hoffman-La Roche. The pharmaceutical company distributes its trademarked SalmoFan, similar to paint store swatches, so fish farmers can choose among various shades.

Europeans are suspicious of canthaxanthin, which was linked to retinal damage in people when taken as a sunless tanning pill. The British banned its use as a tanning agent, but it's still available in the United States.

As for its use in animal feed, the European Commission scientific committee on animal nutrition issued a warning about the pigment and urged the industry to find an alternative. But in response, the British Food Standards Agency took the position that normal consumption of salmon poses no health risk. No government has banned the pigment from animal feed.

Scientists in the United States are far more concerned about a pair of preliminary studies -- one in British Columbia and one in Great Britain -- that showed farmed salmon accumulate more cancer-causing PCBs and toxic dioxins than wild salmon.

Scientists in the U.S. are trying to determine the extent of the contamination in salmon and what levels are safe for human consumption.

The culprit appears to be the salmon feed, which contains higher concentrations of fish oil -- extracted from sardines, anchovies and other ground-up fish -- than wild salmon normally consume. Man-made contaminants, PCBs and dioxins make their way into the ocean and are absorbed by marine life.

The pollutants accumulate in fat that is distilled into the concentrated fish oil, which, in turn, is a prime ingredient of the salmon feed.

Farmed salmon are far fattier than their wild cousins, although they do not contain as much of the beneficial omega-3 fatty acids.

The industry complains that environmental activists have misinterpreted the contaminant studies, needlessly frightening consumers.

"The concern is that people will stop eating fish," said Walling, of the British Columbia Salmon Farmers Assn. "Salmon is a healthy food choice. Our Canadian government says this is a safe food."

Environmentalists in British Columbia and Scotland recently launched campaigns urging consumers to boycott farmed salmon until the industry changes many of its practices.

At the least, they want the farms to switch to solid-walled pens with catch basins to isolate farmed fish -- and their diseases, pests and waste -- from the environment. The ideal solution, they say, is to have the farmed stock raised in landlocked tanks.

Protests notwithstanding, the industry is expected to get a lot bigger. Demand for seafood is rising and will double by 2040, according to the U.N.'s Food and Agriculture Organization. Nearly half the world's wild fisheries are exhausted from overfishing, thus much of the supply will likely come from farmed seafood.

"Aquaculture is here to stay," said Rebecca Goldburg, a biologist who co-authored a report on the industry for the Pew Oceans Commission. "The challenge is to ensure that this young industry grows in a sustainable manner and does not cause serious ecological damage."

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LA Times- Tired of Swimming Upstream, Salmon Farmer Moving On

By Kenneth R. Weiss , LA Times Staff Writer

TOFINO, Canada -- Bill Vernon, one of British Columbia's pioneering salmon farmers, cannot wait to escape the business.

For 18 years, the founder of Creative Salmon has weathered Pacific storms that can rip apart nets and empty his investment into the sea. He has survived algae blooms that can wipe out an entire year's crop in hours.

He has struggled to control parasites and diseases. He has battled marauding sea lions and fended off European conglomerates that have gobbled up most of the region's independent salmon farmers.

Yet it was another threat, one from his own community, that pushed him to retire just shy of his 50th birthday.

"I shot a bunch of sea lions a few years ago," Vernon said. "I've had people phoning and threatening to kill me and my family. It's worn me out."

Vernon is a casualty of growing friction in British Columbia over salmon farms. The irony of Vernon's departure is that he has worked hard to solve - or avoid - many of the ecological problems that have plagued salmon farms.

He rejects the idea of raising Atlantic salmon in Pacific waters. His company is one of the few that grows native chinook salmon, even though they are not as profitable as the faster-growing Atlantic species.

"If the MBAs were looking at this operation," he jokes, "they would say, 'What are you doing?' "

He packs fewer fish in each pen than the industry average to reduce disease, pests and mortality. He has stopped using pesticides and cut back on antibiotics. "This year, we harvested a million and a half fish," Vernon said, "and none of them have had antibiotics."

He rids his nets of algae and mussels through labor-intensive scrubbing, rather than soaking the nets in copper sulfate and contributing to the buildup of toxic copper on the sea floor.

He regularly tests his salmon feed to avoid elevated levels of cancer-causing PCBs or toxic dioxins. He has installed perimeter nets around his farms to keep sea lions away. That way, his crews no longer have to shoot them to protect the caged salmon.

He was vilified after his workers shot sea lions, which is legal in Canada. A local environmental group, Friends of Clayoquot Sound, published gruesome photos of a burial pit with more than a dozen of the marine mammals.

Vernon says he was targeted because he obeyed the law, burying the carcasses on land rather than leaving them to disappear in the ocean as some otherfarmers do.

"I had an environmental group say to me, 'It's too bad it was you. You areone of the good guys.' "

Vernon has been a vocal critic of industry practices.

"The industry has made huge improvements, but can make much, much more," he said. "If Atlantic salmon farmers want to continue, they need to take current standards and raise them."

Vernon believes salmon farming will never be wholly organic. It's too difficult to control every aspect of farming the sea. Nor, he said, will fish raised in pens ever match those from the wild - in taste, appearance or quality.

"We just can't," he said. "We are going to end up with a higher fat fish. The [caged] fish just don't get as much exercise as wild salmon."

Vernon still believes that farmed salmon are needed more than ever, as wild stocks decline and the global appetite for salmon increases.

He has sold his company to his employees and leaves with a mixture of pride in his business and sorrow over tensions with the community.

Yet Vernon's efforts have not gone unrewarded. Whole Foods Market, the largest U.S. retailer of natural foods, sells Creative Salmon's chinook fillets in some of its stores.

"We look for the most eco-friendly methods available," said Kate Lowrey-Monteilh of Whole Foods. "We embrace those vendors who can give us those options."

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FAD will Attract sharks, frighten visitors
Viewpoint

By Mark Grandoni
President Kako'o
North Kohala
West Hawaii Today - October 2, 2002

Jim Rizzuto's article (Sept. 16) regarding the Ahi Nui Tuna Farming Company's proposed aquaculture venture off of Kawaihae & the creation of a "super" FAD (Fish Aggregating Device) that will attract fish thus making it better for local fisherman has some truth in it but the type of fish that will visit our near shore waters may be not "the kine" we all have in mind.

Although the extent of my fishing these days is trolling a small plastic squid from the back of my kayak, I am a former commercial fisherman and have a B.S. & A.S from the University Of Rhode Island in Marine Resource Development & Commercial Fisheries Technology. For those of you not familiar with what a degree in Marine Resource Development is, it basically means,
"How to exploit the oceans natural & living resources for money & profit without considering any environmental impacts." As a Peace Corp volunteer in the Philippine Islands and working alongside The United Nations/FAO Fisheries Bureau & The Philippine Bureau Of Fisheries and Aquatic Resources (kind of like our DLNR) I spent two years setting up FAD systems in the
South China Sea and did a study on the impacts of this Tuna/ FAD system on the local Municipal Fisheries. Though I'm not claiming here to be an expert by any means on Fishing & FADS, I have had some experience.

A FAD is basically a raft/buoy/float anchored offshore in the migrating paths of pelagic swimming fish (like Tuna). Attached to this buoy and weighted down is a cargo net (we used coconut fronds in the PI). The cargo net is hanging underwater within the photosynthesis zone (@100 ft). Over time, the net deteriorates and begins to collect algae, plankton and other
assorted ocean crud, attracting species of small bait fish which come to feed or take shelter in this vegetative growth. In turn, passing schools of pelagic fish are attracted by the abundance of these food fish, and aggregate around the FAD. Like an oasis in the desert, in essence a small food chain ecosystem is created in the middle of the migrating zones and the pelagic swimming fish stop for a bite to eat and take some R&R from their long journey.

Ahi Nui's Tuna Farm will act like a Shallow-water FAD. FADs do work to attract fish, no doubt. However, shallow water FADs don't act the same as Deep-water FADs. For Example, operating off of Ewa Beach, Cates International Moi farm currently reported that only broom tail file fish
(loulu), mullet and palani are present in large numbers. Those expecting Ahi & Marlin and spectacular sport fishing as envisioned by Mr. Rizzuto may be disappointed, but if you've ever heard the tales of Old Hawaii and of King Kamehameha's favorite fish of sport, then get ready because shark hunting may be back in vogue.

There is a general consensus among local fisherman that the Ahi Nui cages will draw sharks. Ahi Nui in their Draft Environmental Assessment says an increase in the number of Sharks "may" take place and then cites the increase of sharks at other aquaculture ventures. If sharks do appear, Ahi Nui Tuna Farming Co. states that they will consult with local Hawaiians and
the Hawaii State Shark Task Force and that is the extent of their Environmental Assessment addressing this possibility. No mention was made of the fact that within an estimated time frame of 4 years (2006) at build out of 18 cages covering 16 acres of ocean, the biomass of live ahi swimming around in these cages will be 4,473,000 pounds. That's a lot of fish! 54,000 to be exact. To feed these future sashimi delights, an estimated 534,308 lbs of fish food per month will be needed. Of this, 15% or 80,000 pounds of uneaten food will be discharged "monthly" into the near shore waters. Coupled with the fact that Ahi Nui states that 90, 824 pounds of fish feces per month will be discharged also, doesn't common sense say that all this excess feed and fecal matter in the ocean water may attract sharks. Ahi Nui does not address this possible impact.

Ahi Nui intends to process their product alongside their cages on boats. Doesn't common sense say that all this excess blood in the water from processing 54,000 fish along with the uneaten food & feces may attract sharks? Ahi Nui does not address this possible impact.

The waters North of Keahole Point to Upolu Point have been designated as part of the Hawaiian Islands Humpback Whale National Marine Sanctuary. National Marine Fisheries research has shown that the Kawaihae region to be the area of highest whale concentrations for the Big Island. Doesn't common sense say that an increase in sharks may impact newly born whale calves? Ahi Nui does not address this possible impact.

Let's not forget also that the Kohala Coast is dependent on tourism and ocean recreation acts like a Tourist Attracting Device in aggregating tourists to our hotels. How many incidents at Hapuna Beach involving sharks would it take to impact Big Island tourism? Some people I've talked with say "no impact' and cite the few fairly recent shark attacks on Maui and how Maui tourism is as strong as ever. This may be well and true but Maui doesn't have a 16 acre "super" Shark Attracting Device with a biomass of over four million pounds of Ahi Tuna sitting in its near shore waters. Ahi Nui does not address this possible impact on West Hawaii tourism.

I have read Ahi Nui's Environmental Assessment and the overall impression of the EA is that it is a tool of justification for the project rather than a discovery and study of actual impacts. A further significant study should be initiated in an independent Environmental Impact Statement (EIS). The Ahi Nui project is very important because it will set a precedent for other similar projects. What is the big picture going to look like when we are looking at more of these farms along our coast?

Overall, I tend to agree with the local fishermen in that there will be additional sharks drawn to the Kawaihae area. Nothing comes without a cost and the cost that is emerging on the horizon is one of a "quality of life" and "personal safety issue" for all those that kayak, canoe, swim, snorkel, surf or dive. I agree with the local fisherman. There will be additional sharks drawn to the Kawaihae area. Nothing comes without a cost.

On October 7 (6:00 pm) at the Kealakehe School Cafeteria a public hearing concerning Ahi Nui Fish Farming Co. has been scheduled by the DLNR. This is the public's time for input. If you're concerned about this project, pro or con, or just curious, please attend this meeting. To ask for an independent EIS, you can write to DLNR, c/o Mr. Traver Carroll, 1151 Punchbowl St, Honolulu, 96813. The more the DLNR hears from the public and what they have to say, the more inclined they are to make their permit decisions.

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Ahi farm concerns
Editor

By Kristi Kranz
Hawi
West Hawaii Today - October 4, 2002

I am concerned about the proposed Ahi Nui Fish Farm in the Kawaihae, South Kohala area. I am just one of many paddlers, swimmers, and divers who access the coastal waters from Puako to Mahukona, and my concern is about the environmental impacts of aquaculture pollution from the proposed fish farm on the surrounding marine ecosystem.

I looked up the copy of the environmental assessment for the project and found very little information about the potential for ocean pollution. I did an Internet search using the keywords "aquaculture pollution from tuna farming" and the first four of dozens of links prompted me to write this letter.

Did you know that pollution of ocean water from fish waste and nutrification from fish feed results in pollution levels equal to that of urban sewage outfalls?

Did you know that tuna farming in Australia has been underway for some time already and that aquaculture pollution is such a major environmental threat that in May 2002, Australia's Environment Minister Robert Hill introducednew legislation to protect the Great Barrier Reef from potential aquaculture pollution?

Did you know that tuna farming in Australia is one of the largest known causes of death of dolphins through drowning after getting entangled in nets? And are you aware that Kawaihae has a resident spinner dolphin population and that dolphins like to rest in areas of sandy bottom similar to where Ahi Nui will be located?

Did you know that to keep out predators some fish farms emit low frequency sonar similar to what the U.S. Navy tested here on the Big Island a few years ago?

Did you know about the degradation of near shore areas of fish farms from net cleaning, maintenance servicing and processing?

Did you know that in 1996 unusual weather conditions in Australia swept up the tuna waste from the sea floor and turned $40 million worth of farmed fish into landfill?

Not enough is known about the potential for harm to our precious ocean and coastal environment from this proposed fish farm. I think a full environmental impact statement should be done before we jump into something that could have very negative long-term results.

Start with these links and go from there. See for yourself what adverse affects we may be looking at:

http://www.abc.net.au/7.30/stories/s76981.htm

http://www.ccsa.asn.au/news/tunavic.html

http://www.ccsa.asn.au/news/tuna.htm

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Reef may be in peril
Editor

By Dick Boyd
Hawi
West Hawaii Today - October 7, 2002

Puako Reef could be threatened if the Ahi Nui Tuna Farm proceeds.

Nutrient over enrichment resulting from land-based pollution is one of the leading causes for the destruction or bleaching of coastal reefs. This pollution can come from inland raw sewage spills and the agricultural use of nitrogen based fertilizer that all contribute to the growth of both green and red algae. The algae growth suffocates the corals, resulting in the death of the coral. There are other factors like sedimentation and the use of pesticides that contribute to the destruction of reefs. At the end of the day, living coral requires "nutrient-poor water" to survive.

Ahi Nui Tuna Farming LLC has submitted a draft environmental assessment, which is under review by the DLNR and the DOH, for an open pen tuna feedlot operation to be located 4.5 miles north of Kawaihae and one half mile offshore. According to the draft EA, it is expected that by 2006, 54,000 ahi, weighing a total of 4,473,000 pounds, will occupy 18 open pen cages, covering 16 acres of ocean. An estimated 534,308 lbs. of fish food per month will be needed to feed the Ahi. Of this, 15 percent or 80,000 pounds of uneaten food per month will be discharged into the near shore waters. Ahi Nui states that 90,824 pounds of fish feces per month will also be discharged into the water.

The company estimates that an average half knot current combined with billions of gallons of sea water will dilute and carry away the pollution resulting from the containment of this large bio-mass. Their logic escapes me. It appears that their solution is to "end pollution through dilution." Pages 42 and 43 of the draft EA present tables showing parameters for theoretical cage volumes and ammonia concentration analysis. These assumptions may be acceptable to the scientific community. However, the draft EA fails to address Murphy's Law which states, "anything that can go wrong will go wrong."

In the real world, the ocean has its own set of laws that continually change over time. For example, fishermen who have made their livings from the ocean in the Kawaihae area know that there are periods of time each year when the current is simply stagnant. In other words, there is a close to zero current. What is going to happen to all of that pollution discharged from Ahi Nui when the current isn't moving? What is going to happen when - not if - we get extended periods of a "Kona or south current?"

Perhaps those excess nutrients" will cause an algae bloom that will affect the water quality of our pristine beaches (turning the clear turquoise blue to a sludge green, like in Kihei on Maui).

In the absence of "current direction and velocity surveys" taken over a period of years, no one can really say what the impact to the Puako Reef will be.

The better question is: Do we want to take the risk of sacrificing one of our most precious reefs for the profits of Ahi Nui?

If you have concerns contact the DLNR at toll free 974-4000 and at the dial tone push 70439#.

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Open Pen Aquaculture - A Threat to the West Hawaii Tourism Industry

By Mark Grandoni

In 1999 the Hawaii State Legislature amended Chapter 190D HRS and enacted the Ocean and Submerged Lands Leasing Program to allow ocean aquaculture (fish farms) in Hawaiian waters. Although fish farms like the Cates International closed-cage Moi Farm off of Ewa Beach hold great economic potential for Hawaii, other types of ocean aquaculture can present a danger to our pristine Class A waters.

Ahi Nui Tuna Farming, LLC, a privately funded local firm backed by both local and British Columbian investors, has submitted a Draft Environmental Assessment (EA), which is currently under review by the DLNR for an open-pen aquaculture operation to be located 4.5 miles north of Kawaihae and one half mile offshore. Open pen aquaculture (which is basically an agricultural feed lot) similar to Ahi Nui Tuna Farms is not a "clean" industry. In fact, the open pen aquaculture industry has developed a global track record for being environmentally unfriendly and polluting. For example, Australia has called out a moratorium on the formation of any new open pen farms because of the severe environmental damage caused by this type of operation. This action was taken after a short ten years, which illustrates that severe environmental problems develop quickly. High levels of organic and nutrient pollution (unused feed, ammonia & fish feces) from open cage feed lots has rapidly evolved to become the number one environmental threat to Australia's ocean environment.

According to the Draft EA published by Ahi Nui, it is expected that by 2006, up to 54,000 Ahi, weighing a total of 4,473,000 pounds (2,000 tons), will occupy 18 open pen cages, covering 16 acres of ocean. An estimated 534,308 lbs (267 tons) of fish food per month will be needed to feed the Ahi. Of this, 15% (industry standard) or 80,000 pounds (40 tons) of uneaten food per month will be discharged into the near shore waters. Ahi Nui states that 90,824 pounds (45 tons) of fish feces per month will also be discharged into the water. If that isn't enough, the fish will eliminate 43,500 pounds (22 tons) of ammonia per month, or 522,000 pounds (261 tons) per year.

Industry research over the last decade in Australia has shown that for open pen farms every 1,000 tons of fish produces as much waste as 7,000 humans. Using the 95 tons/month waste (unused feed & fecal matter) from the Draft EA, this
gives us 1,140 tons of waste/year - or the equivalent waste of about 8,000 humans (667 humans /month). Common sense says that this is a LOT of WASTE, maybe even the equivalent sewage discharge from a small coastal subdivision of people being dumped directly into the Kawaihae near shore waters every month. And that is conservative!

According to the Draft EA, the company estimates that an average 1/2 knot northerly current combined with billions of gallons of sea water will dilute and carry away the pollution resulting from the containment of this large bio-mass. The 1/2 knot current data was obtained from the Waterworld Movie EA, conducted during the week of February 2-9, 1994, as a basis for establishing the average current flow and velocity. The location of this data collection is 2 miles away from the proposed site of the Ahi Nui fish farm cages.

Pages 42 and 43 of the Ahi Nui Draft EA present tables showing "Parameters for Theoretical Cage Volumes and Ammonia Concentration Analysis." These assumptions may be acceptable to the scientific community. However, local
fishermen that have made their livings from the ocean in the Kawaihae area know that there are periods of time each year when the current is simply stagnant. In other words, there is a close to zero current. Former Kawaihae harbormaster, Mr. Bill "Papa" Akau, now retired and considered one of the few genuine "voices of wisdom" (Kupuna) in the North Kohala Hawaiian community, testified at a recent public hearing before the DLNR that the currents run both North and South. However, after a certain point north of Mahukona they turn out and then turn back in, which creates a suction effect. That is why in the Kawaihae area one will often see the same rubbish (oceanic flotsam & jetsam) floating around for weeks at a time.

What is going to happen to all of that pollution discharged from Ahi Nui when the current isn't moving? What is going to happen when - not if - we get extended periods of a "Kona or south current?"

Perhaps those "excess nutrients" will cause an algae bloom that will affect the water quality of our pristine AA waters (turning the clear turquoise blue to a sludge green,like in Kihea on Maui.)

It appears that Ahi Nui's solution is to "end pollution through dilution." This theory has already been tried and tested with the dumping of human waste into the ocean environment. It failed then. Is there something about this situation that is so unique that Ahi Nui believes it will somehow not fail in this regard? If this were human waste from a coastal subdivision of say 667 people, I have little doubt that the collective resources of the DLNR & the Department of Health (as well as those of the Federal Government) would be marshaled and levied on the subdivision for pumping waste directly into the ocean environment.

The Ahi Nui project is very important because it will set a precedent for other similar projects. What is the big picture going to look like when we are looking at more of these farms along our Kohala-Kona coastline? Accordingly, we should be concerned that the environmental issues associated with open pen aquaculture may cause considerable damage to West Hawaii's tourism industry. The hotels along the South Kohala Coast are centered on ocean recreation. Moreover, these hotels are the number one employer of jobs on the Big Island. The visitor industry has become the County of Hawaii's major economic activity in the past decade. The growth of Hawaii County in terms of employment, population, income and economic activity during recent years has been more closely tied to the visitor industry than any other sector of the economy. The Big Island continues to attract substantial investor interest in the visitor industry. To date, over one billion dollars of planned construction of resort-residential complexes have been announced in addition to the substantial investment already in place. Most of these plans are for West Hawaii. Ahi Nui anticipates that within four years the company will be directly employing up to 100 local staff. However there is no comparison between these "farm jobs" and the contribution that the tourist industry makes in the way of job creation and revenue generated for the State.

In the absence of "Current Direction and Velocity Surveys" taken over a period of years, it is difficult to determine what the impact to West Hawaii tourism will be. Do we want to take the risk of sacrificing the number one driving factor in the Big Island economy for the profits of Ahi Nui? Especially when we realize that the entire basis of their scientific reasoning hinges upon the accuracy of a one week current study prepared for the movie Waterworld - a movie which ended up being famous as the "largest financial disaster" movie ever made by Hollywood.

If open pen aquaculture operations harm tourism and are a cause of ocean pollution to our West Hawaii coastline, then all the work and planning invested by the County of Hawaii and the billions of dollars invested by private concerns will be for naught.

Amendments made to Chapter 190D requires that the DLNR adhere to the "National Environmental Policy Act" and must "consider mitigation measures to address adverse impacts on the ocean. Furthermore, Chapter 190D specifically calls for an Environmental Impact Statement (EIS) to be prepared for individual projects. Yet the DLNR has refused to require Ahi Nui to prepare an EIS. Instead they have only asked for an Environmental Assessment, which is a far less rigorous study and known to be a tool of justification for a project rather than a discovery and study of actual impacts.

The State and County of Hawaii must not work at cross purposes. Unless we have a scientifically conducted base line study on the water quality and marine life from open pen aquaculture, the risk of allowing these farms alongside our tourist industry is too great. This base line study can only be determined if a comprehensive scientific EIS is conducted.

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Na Akua Got It Right

by David Holzman

Na Akua (Hawaiians' Higher Natural Powers) provided everything humans needed in a perfect balance with the world's natural processes. Unfortunately, man's greed has led him to seek changes that are out of balance with the world's natural processes. West Hawaii is now faced with a proposal for open pen fish farm and we must make wise decisions if we are to save our ocean while building our economy.

In 1999 the Hawaii legislature amended Chapter 190D HRS and enacted the Ocean and Submerged Lands Leasing program to allow ocean aquaculture in Hawaiian waters. Closed-pen fish farms hold great economic potential for Hawaii; however, open-pen ocean fish farms can present a serious danger to our Class A pristine waters. The difference can be As much as the difference between an open sewer and a sewage treatment plant.

There is a proposal by a local firm Ahi Nui Tuna farming, LLC before DLNR to develop 216 acres of open pen fish farm with an approximate 54,000 fish off the North Kohala coast. Ahi Nui is being promoted by two Hawaiian fisherman and their foreign investors who admit that they do not have the $5 to $10 million dollars it would take to build 18 open pens near to the Kohala coast This should be of great concern to DLNR since only multinational corporations have the experience running large industrial open pen fish harms. What protection do we have if Ahi Nui sells out to a multinational foreign company who couldn't give a hoot about our ocean?

Open pen fish farms similar to Ahi Nui Tuna Farms are not a "clean" industry. In fact, the open pen fish farm industry has developed a global track record for being environmentally unfriendly and polluting. For example, Australia has called for a moratorium on the formation of any new farms because of the severe environmental damage caused by these farms. This action was taken after a short ten years, which illustrates that severe environmental problems develop quickly. High levels of organic and nutrient pollution (tons of unused feed and fish feces) from open pen farms (which is basically an industrial agricultural feed lot) has become the number one environmental threat to Australia's ocean environment.

Chapter 190D HRS requires the DLNR and Department of Agriculture (DOA) submit a progress report to the Legislature on the implementation of aquacultulre programs prior to each regular session. This five-year program was implemented to gain direct experience with ocean aquaculture and " must adhere to the National Environmental Policy Act and must "consider mitigation measures to address adverse impacts on the ocean".

Unfortunately, this well thought out Federal-State program is not being followed by Ahi Nui and it appears as if the DLNR is trying to circumvent the will of the Legislature to give fast track approval of Ahi Nui's  permit before there is a change in the Administration:

Ahi Nui's  Environmental Assessment (EA) is deficient on the following points:

*1.Ahi Nui's EA provides insufficient information on the water quality-monitoring program. Although selecting the Marine Science Program, University of Hawaii, Hilo is appropriate there is no details nor a written commitment from the head of the Marine Science Program UHH that they can meet the water testing requirements of the NPDES/ZOM permit.

*2. The EA's ocean bottom survey by two commercial divers is totally inadequate to provide a base line of the ocean bottom, the species and amount of marine flora and fauna off the Kohala coast. Without a base line the Legislature's annual review of the program under the Chapter 190D HRS would be almost impossible to conduct. Only an independent scientific study with professionals trained in marine biology  are qualified to establish a base line to determine if any damage is being done to marine life.

3. The EA's site selection made no reference to the site selection methodology being developed by the DOA with funds from the National Sea Grant Office. Ahi Nui's site selection process appears to be guided more by their concern for proximity to an international airport and Kawaihae Harbor.

4.On water quality the EA is very misleading in comparing Ahi Nui's large open pen tuna farm with the small closed pen Hawaii Offshore Aquacluture Research Project off Oahu that adhered to Federal water quality standards. The project must be delayed until it can include the NPDES/ZOM standards. Without these standards in place the Legislature will be unable to fulfill its annual oversight review of the progress and possible damages of open pen fish farms to Hawaii waters.

With all of these shortcomings you would think that the UH "experts" and DLNR staff would be calling for tighter protections in the EA but that is not what happened at the public hearing at Kealakehe Middle School on October 7th. The UH "experts" and State employees that had an vested interest in promoting aquaculture flew over from Oahu and in their black shoes and long pants stood out among the angry fishermen from Kohala who were opposed to the Ahi Nui project. These UH "experts" testifying in favor of the project gave no technical or scientific evidence in support of open pen fish farms. Their testimony was either anecdotes or simple illustrations in support of Ahi Nui. Even worse they stated that if Ahi Nui polluted our ocean DLNR would shut them down.

How naïve do they think we are? We all know how terrible the State government has been in the monitoring and enforcement of the State laws on the Big Island. Among all the angry testimony in opposition the UH "experts", State employees, and the young Hawaiians from Ahi Nui overlooked the wisdom of the kupuna who told the wonderful story of how when she was a little girl her mother would take her to Kawaihae to fish and there was a shark who stayed below a shelf and if he gave his permission they were able to take nine fish, no more just nine. The message was so profound--- Na Akua maintained a well-balanced ocean between man and fish and we should do every thing we can to keep it in balance

If you agree call  Paul Whalen, (586-9385) Jim Rath, (586-8510), Helene Hale (586-6530), Russell Kokubun (586-6760), Lorraine Inouye (586-7335) and each of the candidates running for State office on the Kona side. Ask them to contact DLNR and insist that Ahi Nui follow the Federal/State provisions of Chapter 190D HRS and conduct a comprehensive Environmental Impact Statement.

BACK

As the infancy of open-pen fish farming in Hawaii unfolds, the environmental
consequences of decades old open-pen fish farming in Australia, the birthplace of the industry, has called out for a moratorium on any new farms. High levels of organic and nutrient pollution (unused feed & fish feces) from open cage feed lots has become the number one environmental threat to Australia's ocean environment. A new Aquaculture Act, to address the environmental consequences of the rapid growth in farming fish is now being drafted by the Australian governmnet and due to be completed by the end of this year.

Ahi Nui Issues that need to be addressed in an EIS.

According to the Draft EA, "The company will work with local fishermen to create a consistent product supply for the local tuna market if this is advantageous for the local fishermen and the local tuna market. It is not the intention of this project to displace locally caught wild tuna from the Hawaiian Market."

Q) What assurances do the AHI fishermen have to ensure that the company does not negatively impact the local wholesale prices of AHI. Who is going to represent the fishermen and who will make the determination about the impact on Ahi Prices? How can the Ahi Fishermen stop the company from dumping product on the local market if it is determined that the company is becoming a major supplier?

Section 2.2 Site Selection: This section makes no reference to the site selection methodology being developed by the State Department of Agriculture (DOA) and University of Hawaii (UH) with funds from the National Sea Grant Office. Ahi Nui's site selection process appears to be guided more by their concern for proximity to an international airport and Kawaihae Harbor. We request that the site selection by redone to adhere to the DOA and UH specifications.

Section 2.6.2 Disposal of Processing by products: The company plans to filter blood water before it is taken to a land based disposal or disposed of into the ocean. The company plans to dispose of harvest waste into the landfills which is current practice by local fish processors.

Q) Who in the DOH is going to audit the filtration process to ensure that blood water is not discharged into the ocean? What is the frequency of these audits and what are the procedures for the enforcement of the clean water standards? What are the sanctions that can be imposed upon the company for waste water violations? Who is going to pay for this monitoring and for the ongoing measurement of the water quality standards? What about sharks at harvest time?

Section 2.6.3 User Conflicts: The company intends to be a "good neighbor" but property owners along the coast were not consulted. An EIS must have the input from the homeowners associations from:
Hawaiian Homes
Kohala Estates
Kohala Waterfront
Kohala LLC
Kohala Ranch
Disclosure to the homeowners associations to include the following:
Visual impact on current and future homes, Recreational vs commercial use of ocean, potential for increased sharks, pollution from the farm, Economic impact on property values.

Unknown impact on whale and spinner dolphins.

The Draft EA did not state what size of boats will be permitted to be moored at the offshore location. Will there be any other structure built on top of the platforms for employee comfort or harvesting?

Note that noise produced from commercial operations was not adequately addressed in the draft EA. This includes the use of acoustical devices for deterring predators. The company should address this in an EIS. All costs for the elimination of noise must be incurred by the company.

Section 2.6.5 Exclusive use of Lease Area: How does the company plan to financially compensate the public and the fishermen for the loss of the 16 acres that will be designated exclusive use? An EIS needs to address this issue.

Section 2.6.7 Water Quality: The company states that one of the fist victims of environmental degradation is the farm itself. This is not necessarily correct. A significant amount of damage can be incurred by the surrounding ecosystems, reefs and other biotia before the farm shows signs of distress. The company states that water quality and ocean substrate monitoring will be conducted as specified by the DOH and the DLNR to adhere to state regulations. Monitoring of the following is acknowledged:

Redox, temperature, salinity, phosphorus, nitrogen, turbitity and PH and bottom decomposition impact is planned.

NOTE: THE COMPANY FAILS TO MENTION MEASUREMENT OF AMMONIA DISCHARGE WHICH IS THE BEGINNING OF THE NITROGEN CONVERSION CYCLE. ANY TESTING MUST INCLUDE MEASUREMENT OF AMMONIA. NITROGEN TESTING MUST INCLUDE BOTH NITRITE AND NITRATE. Note that nitrate is lowest form of toxicity to marine invertebrates in the nitrogen conversion cycle. Testing of the substrate beneath and surrounding the cages to include Hydrogen sulphide H2S.

The company will conduct ongoing measurements of water quality but, Water quality testing should be also be performed frequently by an independent agency on an audit basis. Findings of water quality violations from the audits should be grounds for immediate closure of the farm. What are the DOH and DLNR water quality standards? Who will pay for the agencies continuous monitoring of water quality and what sanctions will apply for any violations? What are the vertebrates and invertebrates in 216 acres that might be potentially impacted? What are there current densities? What period of time was used as a baseline study? Who will be responsible for reviewing any changes in these populations and what agency is responsible for acting on those changes?

No mention is made about the testing for heavy metals in the areas below the cages. Copper in minute concentrations is highly toxic to marine invertebrates. In fact, copper has been used by fish farmers in other parts of the world to prevent the growth of barnacles on the anchor lines and cages. The consequences associated with this practice have been disastrous to the marine invertebrate populations around the farms. The company must be specific about what chemical means, if any, they will deploy for the removal of barnacles and other critters that will eat the anchor lines.

Current:
The practice of open pen aquaculture depends on current flow to dilute the pollution. The company claims that currents strong enough (average .5 knots to 2.0 knots) and water depth are enough to facilitate dispersion of any fish waste material from the cage system. See discussion under 2.6.10 wind waves current.
Company uses HOARP of Ewa beach in Oahu as a comparison for an aquaculture operation in a similar environment. This is an apples to oranges comparison because the HOARP project is a closed cage, submerged system and located 2 miles off shore as opposed to 1/2 mile off shore

Also,The EA on pages 23-24 concerning water quality provides insufficient information on the water quality-monitoring program. Although selecting the Marine Science, Chemical Oceanography Division, University of Hawaii, Hilo is appropriate there is no details on which students will do the testing under what Professors' supervision. The use of summer students or lower division students who have not been adequately trained is of great concern. In addition, there has in the past been a shortage of lab space at UHH and that could present a problem in testing the water within the six hour time period required by EPA standards or specifications required in the NPDES/ZOM permit.

We request that a more detailed statement be prepared in an EIS that will cover the names and time commitment of the Professors supervising the water quality testing, the number of students, the amount of their training and the UHH Marine Science's agreement that one monitoring buoy is sufficient. Furthermore, that it is placed at the proper cite and if it needs to be moved periodically to account for the changing currents. Furthermore, a written commitment from the head of the Marine Science Program UHH that they can meet the requirements of the NPDES/ZOM permit.

Pages 23-24 on water quality is misleading in comparing Ahi Nui's large open pen tuna farm with the small closed pen Hawaii Offshore Aquacluture Research Project off Oahu that adhered to Federal water quality standards. We request that an EIS include the NPDES/ZOM standards. Without these standards in place the State legislature under Chapter 190D HRS will be unable to fulfill its annual oversight review of the progress and possible  damages of open pen aquaculture in Hawaii waters.

Section 2.6.8 Ocean floor: The company has failed to address the vertebrate and invertebrate sea life that will be impacted by the addition of the tuna farm. It would be gross negligence on the part of the approving agencies to accept "one unidentified sand worm" as being the only form of sealife that might be potentially impacted. A real EIS must address the impact on stationary and migratory vertebrates or invertebrates that use this area under consideration. The company failed to acknowledge the presence of spinner dolphins and what impact the net cages might have on that population. The company needs to address in an EIS the impact that the 6 inch mesh cages might have on any juvenile migratory pelagic fish including small ONO that might become caught in the mesh. The company failed to mention the tiger and blue sharks that inhabit the area and what impact the cages might have on those populations.

2.6.9 Biota: The company fails to identify any sea life other than a sand worm in the subject area that might be impacted. This is unacceptable. There needs to be a full accounting of the vertebrate, and invertebrate life in the area that live there or migrate through there.

Section c fails to address the spinner dolphins.

What is their contingency plan if a whale does become entangled? What are the reporting requirements for any entanglements?

The ocean bottom survey by commercial divers is totally inadequate to provide a base line of the quality of the ocean bottom, the species and amount of marine flora and fauna for the State Legislature's annual review of the program under the revised Chapter 190D. We request an independent scientific study with professionals trained in marine biology working for at least one to two years who are qualified to establish a base line to determine if any damage is being done to marine life.

Section 2.6.10 Wind waves and Current: The practice of open pen aquaculture depends on current flow to dilute the pollution. The company claims that currents strong enough (average .5 knots to 2.0 knots) and water depth are enough to facilitate dispersion of any fish waste material from the cage system. See discussion under 2.6.10 wind waves current.

The company relies upon an interview with Daniel and the Water word Movie study conducted during the week of February 2-9, 1994 as a basis for establishing the average current flow and velocity. Note that the location of the data collection was 2 miles from the lease site. This is an important piece of information because the rock walls at the harbor create areas or zones where the water does not move at all. THIS IS THE AREA OF GREATEST WEAKNESS IN THE DRAFT EA.

Currents are different from year to year and day to day for that matter. Any fisherman will tell you that. If the currents don't move as they predict in their model assumption on page 42 then the ammonia concentration estimates will skyrocket around and under the cages. This is where the raw sewage issue becomes more important. They call it "nutrient enrichment" but those are just fancy marketing words for "pollution."

Mr. Bill Akau the old Kawaihae harbormaster has stated in a personal interview that the current runs north and south but after a certain point north of Mahukona, it turns out toward XX bouy and then turns back in creating a suction effect. This is why those of us that fish will often see the same rubbish floating around for weeks at a time. Also, there are times when the current flows into and away from shore. This of course will have a direct impact on the near shore reef.

2.6.12 Fish Feed: The company hopes that the food for the farm will eventually be produced locally. Are there plans to manufacture this food in the Kawahaie area? If yes, will there be odors produced from production and how does the company plan to deal with this issue?..

Other Issues not addressed in the Draft EA:

Increased traffic and parking at Kawaihae harbor.

Increased load on the boat ramp

What are the enforcement resources that will be required to monitor and police this industry?

What will be the cost to the public for additional manpower in government?

What are the sanctions that can be imposed on the company for violations of standards.

What are the standards?

Exactly what are the 100 jobs that would be created and what is the average pay per hour for each classification of job.

All chemicals used for any operation to be listed in the EIS.

Shark control. Who will bear the cost?

Tourisim impact

Genetic engineered fish?

Industrial operations in a tourist destination.

Public Trust Doctrine & Ceeded lands. Native Hawaiian gathering and fishing rights.

BACK

1. Name: Kamakani 'O Kohala Ohana, Inc. dba Kako'o Phone: 808-889-0227

2. Address: P.O. Box 550, Kapa'au, HI 96755

3. Attorney (if any): Not At This Time

4. Address:

5. Subject Matter: Ahi Nui Tuna Farming LLC, CDUA HA-3098 and request for a Lease for Marine Activities.

6. Date of public hearing / Board meeting: October 7, 2002

7. Legal authority under which hearing, proceeding or action is being made: Hawaii Administrative Rules (HRS) Title 13, Department Of Land And Natural Resources (DLNR), Subtitle 1 Administration, Chapter 5, Conservation District.

8. Nature of your specific legal interest in the above matter, including tax map key of property affected:

8.1 Kamakani O Kohala Ohana (Kako'o) is a 501(c)(3), non-profit organization with an active membership of 300 families based in North Kohala, including families of Hawaiian ancestry claiming traditional and customary access, gathering and spiritual rights on the properties (ocean lease site) which are the subject of applicant Ahi Nui Tuna Farming LLC's CDUA.

8.2 Kako'o members also include many fisherman, paddlers, swimmers, surfers, kayakers and divers who consistently and for a long time have accessed (both commercially for a living or recreationally as an activity) the coastal waters where the proposed open pen tuna farm (lease) lies within the Conservation District, Submerged Lands, Subzone (R) Resource, in the North Kohala District.

8.3 Kako'o and its members are entitled to environmental review under Chapter 343, Hawaii's Revised Statutes, which chapter guarantees consideration of environmental concerns.

8.4 Kako'o can assist the board in developing a more complete record which includes testimony, including expert testimony, and other evidence presented by and on behalf of community residents in North & South Kohala and other persons actually affected by the proposed action.

9. The specific disagreement, denial or grievance with the above matter. Considering the overall economic, environmental, cultural and social impacts of Ahi Nui Tuna Farming our specific disagreement is that Ahi Nui Tuna Farming LLC plans in the conservation district in North Kohala does not represent the environmental, economic, cultural and social interests of "substantial public interest" for all of our members that fish, kayak, paddle, swim, snorkel, surf or dive in the coastal waters where the proposed open pen tuna farm (lease) lies within the Conservation District, Submerged Lands, Subzone (R) Resource, in the North Kohala District.

10. Outline of specific issues to be raised:

10.1 The proposed open pen tuna farm (lease) lies within the Conservation District, Submerged Lands, Subzone (R) Resource, in the North Kohala District. This proposed land use is not consistent with the purpose of the Conservation District, Submerged Lands, Subzone (R) Resource and the Public Trust Doctrine.

10.2 The proposed land use does not comply with the provisions contained in Chapter 205A, Hawaii Revised Statutes (HRS), entitled "Coastal Zone Management". Section 205A-2; Objectives and Policies. Especially recreational resources, historic resources, scenic & open space resources, coastal ecosystems, economic uses and management development.

10.3. The proposed land use will cause substantial adverse impact to existing natural resources within the surrounding area, community and region.

10.4 The existing physical and environmental aspects of the land, such as natural beauty and open space characteristics, will not be preserved or improved upon.

10.5 The proposed land use will be materially detrimental to the public health, safety and welfare.

10.6 The proposed land use will cause substantial adverse impact to the traditional and customary access, gathering and spiritual rights of Native Hawaiians

11. Outline of basic facts:

11.1 Conservation District:
This proposed land use is not consistent with the purpose of the Conservation District, Submerged Lands, Subzone (R) Resource and the Public Trust Doctrine. By Public Trust one means the right of the people to have lands, waters and living resources protected for their use. The principle that upholds these rights is called The Public Trust Doctrine.

11.2 Adverse impact to Existing Natural Resources:
Open pen aquaculture similar to Ahi Nui Tuna Farms is not a "clean" industry. In fact, the open pen aquaculture industry has developed a global track record for being environmentally unfriendly and polluting. For example, high levels of organic and nutrient pollution (unused feed, ammonia & fish feces) from open cage feed lots has rapidly evolved to become the number one environmental threat to Australia's ocean environment. Fish feces concentrated in a specific ocean area is in fact introduction of vast amounts of pollution to the area, plain and simple. In the absence of "Current Direction and Velocity Surveys" taken over a period of years, it is difficult to determine what the impact to the ocean environment will be. Unless an EIS is done to collect baseline data on water quality, mobile marine life and immobile marine life makeup, distribution and abundance, ocean current variations, etc., there will be nothing to measure potential impacts against.  Comprehensive baseline data can only be collected if an independent scientific EIS is conducted.

11.3. Scenic Beauty:
Scenic Beauty is one of the many reasons that residents and tourists enjoy the Kohala Coast. This natural beauty is part of our resource that must be preserved. The addition of an open net tuna farm will be detrimental to that natural beauty, both above and below the water. The visual impact that the tuna farming operation will have on the existing view plane Along Akoni Pule Highway is not consistent with the County of Hawaii's General Plan (GP)

11.4. Safety & Welfare:

11.4.1 Safety - Shark Attraction Device (S.A.D.)
Ahi Nui claims that their cage system will act as a Fish Aggregation Device (FAD) and attract fish thus making it better for the local fishermen. This statement is being made by the company to garner support from the local fishing community. Ahi Nui in their Draft Environmental Assessment says an increase in the number of sharks "may" take place and then cites the increase of sharks at other aquaculture ventures. An increase of sharks is a quality of life and personal safety issue for those members of Kako'o that kayak, canoe, swim, snorkel, gather, surf, or dive the coastal waters where the proposed open pen tuna farm (lease) lies within the Conservation District, Submerged Lands, Subzone (R) Resource, in the North Kohala District.

11.4.2 Welfare - Local Fishing
The ONO and Mahi fishermen who are members of Kako'o will suffer hardship if the State allows these areas of ocean to be leased out to private enterprise for tuna farming. The area selected for the location of the net system is directly in the ONO fishing lane. The ONO and Mahi fishermen who are members of Kako'o will suffer hardship if the State allows these areas of ocean to be leased out to private enterprise for tuna farming.
Ahi Nui Tuna Farming will be catching their young tuna for their cage systems from the "WILD". Catching AHI on a year round basis risks over-fishing the AHI population. High mortality rates of the AHI are associated with the capture and towing operations. Both of these factors combined will have a significant economic affect on local Ahi fisherman . Marketing factors should be reviewed . If 54,000 tuna are caught annually by Hawaii's hand line fleet for the Ahi Nui project, who's going to supply the local markets? Is there any written guarantee that none of the fish will be sold in Hawaii? This would place all of our small boat tuna fishermen who are members of Kako'o out of business rather quickly.

11.5 Traditional and customary access, gathering and spiritual rights
Kako'o members include families of Hawaiian ancestry claiming traditional and customary access, gathering and spiritual rights on the properties (ocean lease site) which are the subject of applicant Ahi Nui Tuna Farming LLC's CDUA. These families are concerned that the operations of Ahi Nui would impede these rights.

12. The relief or remedy to which you seek or deem yourself entitled:

12.1 We ask for a Environmental Impact Statement (EIS) be performed in order to collect comprehensive baseline data on water quality, mobile marine life and immobile marine life makeup, distribution and abundance, ocean current variations, etc. along the Kohala Coast. Comprehensive baseline data can only be collected if an independent scientific EIS is conducted.

12.2 State of Hawaii should adopt the Federal Policy Framework For Offshore Marine Aquaculture. Although the policy currently is for 3-200 miles of the U.S. Ocean Zone, we believe that the Class A pristine waters of Hawaii are such a valuable cultural and economic asset they should receive the highest protection from aquaculture pollution.

12.3 Declare a moratorium on all open pen aquaculture private business ventures including Ahi Nui Tuna Farming Co. until new Federal/State open-pen ZOM regulations and site selection standards have been developed and experimentally tested and independently verified on a small scale.

12.4 Companies seeking to engage in open pen aquaculture should be required to post a bond in the event of environmental harm caused by the company.

12.5 Preservation of the customary access, gathering and spiritual rights of families of Hawaiian ancestry claiming these rights on the properties (ocean lease site) which are the subject of applicant Ahi Nui Tuna Farming LLC's CDUA.

The above-named person hereby requests and petitions the Board of Land and Natural Resources for a contested case hearing in the matter described above.

Date:__________________________ _________________________________________

  
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Community Groups Oppose Fish Farms

Friday, November 08, 2002 - By Dave Smith/ Tribune-Herald

One of two Big Island companies seeking to establish fish farms off the West Hawaii coast has run into some community opposition.

Two Kohala groups have asked for a contested case hearing on the proposal by Ahi Nui Tuna Farming LLC to establish a fish "growout" facility 4 1/2 miles north of Kawaihae.

The Waimea - based company wants to install floating net cages in water 170 feet deep and located 1,100 to 3,800 feet from the shore. Ahi Nui plans to take young bigeye and yellowfin tuna caught with barbless hooks in Hawaiian waters and keep them in the pens for up to eight months. During that time the fish will double or triple their weight, company officials say, and will then be sold to sushi and sashimi markets primarily in Japan.

Ahi Nui is seeking a lease from the state to cover 216 acres offshore for up to 18 cages which would cover about 16 acres. The company needs a variety of other permits including approvals from the U.S. Army Corps of Engineers and the state Department of Health and an aquaculture license from the state Department of Land and Natural Resources.

The operations also need a conservation district use permit which the two Kohala groups are challenging.

In its request for a hearing, one of the groups consisting of the Kawaihae Fishing Association and four individuals said the tuna farm would have negative impacts on the environment. The request asks that the DLNR ensure that the project will not have negative impacts on commercial and recreational fishing in the area.

The other group contesting the use permit is Ka'makani 'O Kohala Ohana, also known as Kako'o, which is comprised of fishermen, divers, surfers, paddlers and others who use the coastal waters.

In a letter to the DLNR, Kako'o President Mark Grandoni said that such open pen aquaculture has developed a "global track record for being environmentally unfriendly and polluting." He said in Australia a moratorium has been called on new fish farms because of pollution from fish waste and uneaten food.

Grandoni cites Ahi Nui's draft environmental assessment for the project as saying that, when fully operational in 2006, the pens will contain 54,000 ahi weighing a total of 2,000 tons which will monthly discharge 45 tons of feces into the water and leave 40 tons of uneaten food.

"Open pen fish farming (which is basically an agricultural feed lot) is in effect using the marine environment as an open sewer," Grandoni wrote, adding that his group requests that a more comprehensive environmental impact statement be done for the project.

However, Ahi Nui officials say the fish farm will not adversely affect the environment because the pens will be regularly flushed by strong currents moving through deep water. They say that a sandy bottom underneath means that coral reefs won't be directly affected and that water quality will be regularly monitored by the Department of Health to ensure that permit requirements are being met.

Company officials also say the farm's location is outside of areas regularly used for water sports including
recreational and commercial fishing.

Last Friday the state Board of Land and Natural Resources agreed to the appointment of a hearings officer to oversee the matter.

The other company seeking to develop a fish farm, Kona Blue Water Farms, filed a Conservation District Use Application late last month.

Kona Blue Water Farms, a division of Black Pearls Inc., a marine biological research and aquaculture company based at the Natural Energy Lab at Keahole Point, is seeking a lease for 81 acres for both floating and submerged pens.

Instead of using wild caught stock, the Kona Blue Water Farms project would use only hatchery - raised fish that are native to Hawaiian waters for Hawaii's restaurant market. The company said it would start with mostly mahimahi and possibly opakapaka, the Hawaiian pink snapper, which the firm has had success in hatching and raising.

The company's draft environmental assessment for the project also maintains that the deep water and strong currents in the area will minimize any negative environmental impacts from the farm.

Company officials say the farm will also provide long - term benefits to Hawaii's bottomfish stocks by reducing
commercial fishing pressures.

Both companies are holding numerous meetings with community and other groups to explain their proposals.

If the projects are approved there would be three fish farms in Hawaii. Cates International already produces some 10,000 pounds of Pacific threadfin monthly from two cages off the Oahu coast.

Dave Smith can be reached at dsmith@hawaiitribune - herald.com

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Tuna Farm To Conduct Full Analysis (EIS)

By BOBBY COMMAND/ West Hawaii Today

A petition drive and a North Kohala watchdog group have raised enough concerns to compel a company planning to raise ahi in pens off leeward North Kohala to prepare a detailed analysis of the project.

Ahi Nui Tuna Farming LLC will conduct a full environmental impact statement for the proposal, which plans to raise 4.4 million pounds of yellowfin tuna in open pens four miles north of Kawaihae.

Local fisherman and Kohala Estates resident Tom Oiye, and the environmental group Kamakani O Kohala have questioned the impact fish waste and uneaten fish food will have on the area. They also are concerned the operation will attract more sharks to the area.

But Clayton Brenton, spokesman for the project, said many of the concerns may have been stirred by those who used the Internet to find examples of projects that have not gone particularly well. "But there's lots of reasons for that," Brenton said. "Some of them are not using modern technology and methodology." Brenton said there are also many good projects in the world. "We're trying to do something good," he said. "If I didn't think it was good I would not do it."Brenton also said many of those who had concerns did not take the time to contact Ahi Nui."We're trying to be a part of the community," Brenton said. "But it works both ways."

Oiye, a Kohala Estates resident and fisherman, said he is worried about the long - term impacts of the activity. Oiye recently turned in a petition with more than 160 names asking for more a more detailed analysis of the project. "I am concerned about the global reputation that the open pen aquaculture industry has developed over the last 10 years," Oiye said. "I'm concerned wedon't make the same mistakes in other places."

While Oiye said he is not necessarily against the project, the petition he mailed to various state agencies specifically states, "We do not support the use of the Kohala ocean front for the purpose of tuna farming." However, Oiye later added he would like to see it work in harmony with the rest of the community. "There must be some real positive examples where a has tremendous successes," Oiye said. "But where that has happened they've done things correctly, with the right legislation, monitoring and enforcement on the part of the local government."

A Kamakani O Kohala Web site spells out in an article entitled, "An Unfriendly Environmental Industry Seeks a Foothold in North Kohala Waters," its opposition to the project. The article claims the project is materially detrimental to the public health, safety and welfare. It calls for an independent EIS, moratorium on all open pen fish farm projects until site selections standards are developed and tested independently and demands companies wishing to operate such farms post a bond in case of damages.
Brenton said the preparation of an EIS will delay the operation's startup bynine months to one year.

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Honolulu Star Bulletin - Proposed Fish Farm off Kawaihae Delayed

Proposed fish farm off Kawaihae delayed -Community concerns prompt Ahi Nui Tuna to prepare an EIS
Honolulu Star Bulletin December 2, 2002

By Craig Gima
cgima@starbulletin.com

A Big Island company's plans to raise and sell up to 4.4 million pounds of ahi in underwater pens off of Kawaihae have been delayed to address environmental concerns raised by two community groups.

Ahi Nui Tuna Farming LLC will conduct a full environmental impact statement on the project -- a process that will postpone the proposed start-up of the operation by nine months to a year, said Clayton Brenton, Ahi Nui's fish-farming expert.

"We're all trying to make this work for the community," he said. "The logical thing is to try to resolve the concerns."

The company is proposing to catch juvenile big-eye and yellowfin tuna and raise them until they are ready for market in underwater cages over 216 acres of ocean about four miles north of Kawaihae.

At first Ahi Nui will raise the fish in six cages 165 feet across and 60 feet deep, anchored in about 170 feet of water 1,100 to 3,800 feet from shore. If the venture is successful, the company may expand to up to 18
cages.

The operation could bring in up to $10 million a year and create 50 to 100 jobs, Brenton said.

But local fishermen and others in the area are concerned about how the project will affect the environment and their access to the ocean.

"We have a stake in the area. We live there and we fish there. What if it gets polluted? We can't just pull up our stakes and fish somewhere else," said Andy Ho, a member of the Kawaihae Fishing Association, a group of fishermen, including native Hawaiians, formed because of their concerns about the project.

"We'd like to see the Kawaihae area have something for our children and our children's children," he said.

Ho's group and another organization called Ka Makani O Kohala Ohana, composed of fishermen, divers, surfers and paddlers, have asked for a contested-case hearing over state permits needed for the project to begin operations.

The controversy is being watched closely by others involved in the fledgling open-ocean farming industry here.

"We're on the frontier here," said John Corbin, manager of the aquaculture development program in the state Department of Agriculture.

Ahi Nui's project is one of four ventures that are seeking or have gotten leases and permits to use state ocean waters for aquaculture.

Cates International already produces thousands of moi in open-ocean cages off of Ewa.

Another company, Black Pearls Inc., has gotten approval to raise oysters in waters off Honolulu Airport, and a company called Kona Blue Water Farms hopes to raise mahimahi off of the Natural Energy Lab at Keahole Point on the Big Island.

"Open-ocean leasing for aquaculture has been a new thing for Hawaii," Corbin said. "The community that cares about the ocean are going to have concerns about these projects."

Corbin says some of the issues raised about the Ahi Nui project are specific to its proposed location, while concerns about pollution have been raised over other aquaculture projects.

Ho said Ahi Nui's project is in an area where people fish for ono, mahimahi, kona crab and opelu. He has questions about the impact that fish waste and uneaten fish food will have on the fishing ground and about restrictions on access to the fishing area.

"There are some real environmental concerns that I think the public needs to be aware of before we put our wholesale stamp of approval on it and say go," said Tom Oye, a fisherman and member of Ka Makani O Kohala Ohana.

Oye is also concerned that the uneaten food and the fish will attract sharks and have an impact on dolphins.

He said the project will also be visible from the shore and could spoil what is now an unobstructed view.

Brenton said there will still be access to most of the 216 acres of ocean around the cages. He said the fish and the excess fish food will attract more fish to the area, improving the catch for local fishermen.

Because people need to be taken to and from the fish cages, Brenton says the project needs to be located within five miles of Kawaihae Harbor for it to be successful. But he said the EIS will look at the feasibility of moving the project to another area with less impact.

Brenton argues that ocean currents should keep fish and food waste from building up in the area and that there will be strict environmental monitoring.

"We're not even at one-tenth the density of the moi project off of Oahu, and they're not having any environmental impact," he said.

Based on the moi project and in changes on incidents of sharks around artificial reefs, he does not believe there will be an increase in dangerousshark activities.

The community groups say fish farms in other countries have had pollution problems, and not enough is known about how it would affect Hawaii's environment.

"The state of Hawaii, in exuberance to attract new industry, may not be adequately prepared with proper laws, proper management, proper manpower to stay ahead of this industry," Oye said.

Brenton says the environmental assessment the company completed answers some of their concerns, but Ahi Nui is willing to delay the project at a cost of several hundred thousand dollars to conduct a full EIS.

"If that's what it takes to establish a level of confidence in the community, then that's what we'll do," he said.

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OHA Responds - Clayton Brenton, Project Director of Ahi Nui Farms was quoted as saying : "The land committee of the Office of Hawaiian Affairs has given this project its "blessing" and has offered to write "a letter of support.""

OHA responds
West Hawaii Today- December 02, 2002

Editor:
As chair of the Office of Hawaiian Affairs Committee on Land, I would like to clarify some statements made by Mr. Clayton Brenton in his letter to the editor on Oct. 15.

Ahi Nui and Anthony Anjo were both invited to the Land Committee meeting on Sept. 26 to testify on their respective positions regarding this project. Only representatives of Ahi Nui showed up. Robert Cabos and Clayton Brenton gave a very informed presentation which answered many of the questions Board members had about this project. At the end of the presentation, Robert Cabos was asked if he would like any action from OHA. He responded that they were just there to present information and that no action was needed. Mr. Brenton stood up and said that a letter of support would be appreciated.

However, the committee did not take action on a letter of support because an aquaculture policy was to be presented to the Committee on Policy and Planning Chaired by John Waihee IV the following week. As chair of the Committee on Land, I thought it better to allow the Committee on Policy and Planning to take the lead on recommending for, or against fish farms.

As you may be aware, the Office of Hawaiian Affairs passed a policy encouraging Hawaiians to become involved in Fish Farming on Nov. 6, at its meeting on Kauai. Although aquaculture farms are not without problems, we
believe that fish farms are a modern extension of ancient Hawaiian aquaculture practices and will serve to conserve ocean resources in the long run. Through the policy, OHA will ensure that it can more effectively and
comprehensively address many of environmental and cultural concerns fish farming raises.

Through the adoption of the policy, we choose not to support or deny any particular project, but to look at the overall effect of fish farming on Hawaiian culture, Hawaiian rights, and Hawaiian ocean practices, while at
the same time, striving to better the conditions of Native Hawaiians.

Donald B. Cataluna
Trustee
Chairman
Committee on Land

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Leningrad Elarionoff, city councilman at the Waimea Community Association meeting on November 7, 2002 spoke and said the folowing:

"I have read the Draft EA. I am a fisherman. I have three comments on site selection:"

"The EA states that trolling is done north of Red Hill. This is not true."

"The EA states that this is not a waterway used by local paddlers and boaters. This is not true."

"The EA states that this is not a marine-mammal resting place. This is not true."

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