Redwood Region Audubon Society

September 20, 2022

Humboldt County Board of Supervisors

Kathy Hayes, Clerk of the Board

Re: Nordic Aquafarms California, LLC

PLN-2020-16698-APPEAL

Virginia Bass, Chair, Board of Supervisors Supervisors:

Redwood Region Audubon Society is a 501c3 public benefit corporation that acts to promote a wise, balanced, responsible and ethical use of natural systems on a local, national and global scale with an emphasis on birds.

We have appealed the Planning Commission’s certification of Nordic Aquafarms California's final environmental impact report (FEIR) based on non-compliance with the California Environmental Quality Act.

Text in italics is from the FEIR. Comments are in plain text.

Failure to Consider Project Alternatives

^{The California Environmental Quality Act (CEQA) Guidelines state that an}^“^{EIR shall describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives}^”^{(Section 15126.6).}

^{The CEQA Guidelines state that}^“^{the range of alternatives required in an EIR is governed by a rule of reason}^”^{that requires the EIR to set forth only those alternatives necessary to permit a reasoned choice. The alternatives shall be limited to ones that would avoid or substantially lessen any of the significant effects of the project. Of those alternatives, the EIR need examine in detail only the ones that the Lead Agency determines could feasibly attain most of the basic objectives of the Project (Section 15126.6).}

Seawater intake

CDFW recommends the FEIR include a comparative analysis of entrainment and impingement impacts associated with each of the alternative seawater sources. As discussed in DEIR Section 4.3.3, Alternative 3 considered three water source alternatives:

Terrestrial slant wells( groundwater wells)
Humboldt Bay seawater wells(also groundwater wells)
Oceanic seawater intake (surface waters)

According to NAFC:

As the terrestrial and Humboldt Bay slant wells would withdraw groundwater, no entrainment or impingement of fish would occur. However, terrestrial slant wells were determined infeasible, as the limited yield of each slant well was insufficient to meet the water supply needs of the Project (page 4-16 and 4-17). The DEIR found that construction of Humboldt Bay seawater wells would require substantial in-water work and could result in biological and water quality impacts (page 4-18) and would therefore be more biologically impactful than the proposed water source. An oceanic seawater intake would presumably also be designed to comply with the NMFS 1997 fish screen design criteria and would thus result in an equivalent level of impingement and/or entrainment of marine life as the Project’s proposed Humboldt Bay screened water intake, albeit species composition may vary. Thus, there is not a water source alternative that results in less impingement and/or entrainment that is also (a) feasible and (b) less biologically impactful to construct and operate. Given the information referenced above, no further analysis or modifications to the DEIR are proposed specific to this comment.

NAFC plans on withdrawing 10 million gallons per day of seawater from Humboldt Bay from an intake structure which has no permit and might never be permitted. Detailed environmental impact analysis consist primarily of an endangered species act compliance study for longfin smelt that has not been completed. Environmental impact is not limited to endangered species. A detailed biological assessment is required to determine if there is a significant environmental impact to the North Humboldt (Arcata) Bay Estuary on which over 500,000 migratory shorebirds depend upon for their seasonal migration.

Nordic’s FEIR failed to consider moving saltwater intake offshore as recommended in 1997 National Marine Fisheries Service guidelines that were provided to Humboldt Bay Harbor, Recreation, and Conservation District (District) by consulting firm SHN. The letter from SHN was an appendix to the Draft EIR.

The consequences of having the NAFC seawater removed from Humboldt Bay to be used to supply a land based fish farm is that significant natural resources that should be supporting commercially important fish and wildlife will instead be reduced in supply and availability. Many sensitive species of fish and marine life will be adversely impacted by impingement and entrainment (see our appeal letter of 8-17-22 for species list).

The offshore alternative was considered infeasible and unsuitable due to “presumed” marine life in the intake zone even though no surveys were conducted to allow for comparison with the Humboldt Bay intake. Presumptions do not provide an adequate basis to evaluate the “comparative merits of the alternatives” (Section 15126.6). The cursory analysis of an offshore seawater intake did not take into account that offshore water is usually colder than Humboldt Bay water and that a 1ºC difference in temperature equals almost 150 million BTU which would be 4.39 megawatts per day less energy required for chilling water for the project. Although detailed calculations would be required to determine a more accurate long term energy savings estimate, these rudimentary findings demonstrate that there is potential for long term significant energy savings that has not been considered in the feasibility evaluation of offshore seawater intake. We are puzzled as to why an alternative that could be an advantage to NAFC was not further evaluated.

We find that information on the NAFC preferred alternative, and lack of meaningful consideration of the NOAA preferred alternative offshore intake to be insufficient for informed evaluation and decision making regarding the comparative merits of the alternatives.

Fish Feed & Marine Ingredients

According to NAFC:

Aquaculture is among the most feed efficient production models in farming. A common measure of efficiency is feed conversion ratio (FCR), which is calculated as the ratio of feed intake to weight gain with lower FCR values indicating higher efficiency.

Typical FCRs for animals raised using commercial feeds and intensive production methods are as follows (Fry 2018):

- Beef cattle:6.0–10.0 pounds of feed intake to produce one pound of live weight
- Pigs:2.7–5.0 pounds of feed intake to produce one pound of live weight
- Chickens:1.7–2.0 pounds of feed intake to produce one pound of live weight
- Farmed fish and shrimp:1.0–2.4 pounds of feed intake to produce one pound of live weight.

Farm raised Atlantic salmon have a higher protein retention and calorie retention than pig and cattle as well as a higher edible meat per unit of feed than poultry (Fry 2018). For salmon, a typical FCR in net pen farming is approximately 1.3. In modern land-based RAS facilities FCR for Atlantic salmon is often between 1.05 -1.1 (DEIR page 4-16; Table 4-2). Thus, NAFC’s land-based farm is among the most efficient ways of producing protein-rich food.

Redwood Region Audubon Society expressed concern in comments on the DEIR about the negative environmental impacts of harvesting forage fish (herring, anchovy, sardine, capelin, etc.) to process into fish feed for farming piscivorous fish, such as salmon. These impacts are well documented in peer reviewed studies and related articles in publications as provided in the appendix. Impacts include depletion of forage fish not only for wild fish and seabirds but also depletion of edible fish for people, particularly in west Africa, for whom these fish are a major source of protein.

Responses to DEIR comments on fish food uses false comparisons and information irrelevant to environmental impact. For example, the following feed conversion table was provided comparing beef cattle, pigs and chickens to farmed fish and shrimp. It is important to consider that the table is “Typical FCRs for animals raised using commercial feeds and intensive production methods…” Typical production methods using typical feeds for for raising livestock” often contribute to significant environmental impacts and does not consider less impactful alternatives such as grass fed beef. Furthermore, Atlantic salmon is not specifically addressed in the table. FCRs are for internal evaluation of feeding efficiency and do not equate to environmental impact.

According to NAFC:

NAFC does not and would not be harvesting wild fish or manufacturing fish feed at any of its facilities including this Project. Pages 2-38 of the DEIR list feed guidance that favors ingredients that are viable alternatives to harvest fisheries and includes the use of by-product trimmings, algae oils, insect meals, etc.

As described on pages 2-38 of the DEIR, NAFC recognizes the importance of the Fish-In-Fish-Out (FIFO) score as a measure of ecological efficiency of feed and the Project will include target limits that are among the best in the industry. In fact, Nordic Aquafarms’ Fredrikstad Seafoods land-based facility growing Atlantic salmon in Norway, regularly achieves a FIFO score of 0.8 meaning more fish protein would be produced by the farm than whole fish included in the feed. NAFC will target, at least, the same high standard for the Marine Ingredients

Note:Fredrikstad Seafoods lost money on Atlantic Salmon and has converted to Yellowtail.

The proponent also erroneously implies that a highly efficient Fish-in-fish-out (FIFO) score somehow negates environmental impact, claiming that more fish protein is produced than is used in the fish food. This red herring bears little or no relationship to the environmental impact of using wild-caught fish for fish food. Peer reviewed research by Willer, et al at Universities of Cambridge, Lancaster and Liverpool found that “179,000 tonnes of salmon produced in Scotland required fish food from 460,000 tonnes of wild-caught fish, 76% of which was edible”. This equates 2.57 pounds of will-caught fish in for every pound of fish out. This research also found that “Over 72% of protein in feed is lost in salmon production, while feed accounts for over 90% of the detrimental environmental impacts of salmon aquaculture.” Although this research applies to Scottish pen farmed salmon it does show the inherent inefficiency of farm raising salmon and that the amount of wild-caught fish in feed represents only a fraction of the amount of wild-caught fish to produce that feed.

The above information establishes, with reasonable certainty, that the project would have a significant negative environmental impact with regard to fish feed. The DEIR also provided inaccurate and misleading information regarding fish feed impacts. Once again, misleading information is provided to the extent that evaluation of the comparative merits of the alternatives cannot be evaluated (Section 15126.6).

Due to the absence of appropriate information in the FEIR on the environmental impacts of fish food to be used to feed the project’s salmon, and refusal to disclose the nature of that fish food, we demand that the project use fish food that does not include ingredients from wild-caught fish.

Wastewater Disinfection and Sampling Standards

Master response 4 describes in some detail the control of disease and fish health within the farm but does not explicitly describe how viral pathogens will be prevented or detected in the liquid waste stream. While fish health is a good first line of defense for preventing disease within the farm itself, equally stringent measures should be taken to protect wild fish from virally contaminated wastewater discharged to the ocean.

There should be new and expanded conditions for approval of the Nordic Coastal Development Permit (CDP), that require weekly monitoring of all wastewater originating from inside the RAS facility that is supervised by an independent qualified third party (preferably a contractor selected by the CDFW) and meeting nationally recognized standards for wastewater testing for viruses. Monitoring must include tests sensitive to presence or absence of all fish viruses of concern.

Conditions for Approval

Based on the lack of sufficiently detailed alternatives provided in the DEIR the appellants request:

Operating permit of phase 2 of the proponents preferred alternative be dependent on full compliance of phase 1.
Detailed analysis and feasibility study of an offshore seawater intake
Detailed analysis and feasibility study of a closed loop system
Full biological analysis of the Humboldt Bay seawater intake
Weekly independent third party viral analysis of all wastewater exiting the RAS facility.
Fish feed shall not include ingredients from wild-caught fish.

Respectfully submitted,

Jim Clark, Conservation Committee co-Chair

Redwood Region Audubon Society

Appendix

Maximizing sustainable nutrient production from coupled fisheries-aquaculture systems

David F. Willer,
James P. W. Robinson,
Grace T. Patterson,
Karen Luyckx

Citation: Willer DF, Robinson JPW, Patterson GT, Luyckx K (2022) Maximising sustainable nutrient production from coupled fisheries-aquaculture systems. PLOS Sustain Transform 1(3): e0000005. https://doi.org/10.1371/journal.pstr.0000005

Editor: Semra Benzer, Gazi Universitesi, TURKEY

Received: June 3, 2021; Accepted: January 11, 2022; Published: March 1, 2022

Copyright: © 2022 Willer et al. This is an open access article distributed under the terms of the Creative Commons Attribution License, which permits unrestricted use, distribution, and reproduction in any medium, provided the original author and source are credited.

Data Availability: All data is available in the manuscript or supplementary materials.

Funding: D.F.W. was funded by the Department of Zoology and a Henslow Fellowship at Murray Edwards College, University of Cambridge. J.P.W.R. was funded by a Leverhulme Trust Early Career Fellowship. K.L. was funded by the Waterloo Foundation. The funders had no role in study design, data collection and analysis, decision to publish, or preparation of the manuscript.

Competing interests: The authors have declared that no competing interests exist.

Fishmeal and fish oil are key components of fed aquaculture, comprising 76% and 71% of global resources used in aquafeeds, respectively. Yet 90% of fishmeal and fish oil is derived from nutritious food-grade fish such as sardines and anchovies that could be fed directly to humans.

The salmon industry, which from 1998 grew by 270% to become the most valuable sector in aquaculture at US$ 23 billion in 2018, is particularly reliant on feed from wild-caught fish. Over 72% of protein in feed is lost in salmon production, while feed accounts for over 90% of the detrimental environmental impacts of salmon aquaculture. Marine feeds are also increasingly produced using forage fish caught off West Africa, likely impacting fish consumption in places with high levels of food insecurity. Growth in salmon production is therefore expected to increase pressure on wild-caught fish populations globally, particularly impacting tropical nations by removing an irreplaceable source of nutrients. Though these issues may be mitigated by uptake of alternative aquaculture feeds, including plant-based sources (soy, corn, wheat) and novel feeds (insects, bacteria), it remains unclear whether these products can be produced at sufficient scale. Furthermore, evidence that plant-based feeds decrease the nutritional value of farmed fish may disincentivize adoption of alternative feeds. (Excerpt from Abstract)

https://www.theguardian.com/environment/2022/mar/02/wild-fish-stocks-squandered-to-feed-farmed-salmon-study-finds

Feedback, which campaigns for sustainable food supplies, worked with researchers from the universities of Cambridge, Lancaster and Liverpool to investigate feed sources – and the nutrients transferred from them – in the Scottish salmon industry, Britain’s largest food export. They calculated that in a single year, 179,000 tonnes of salmon produced in Scottish aquaculture farms consumed fish meal and fish oil produced from 460,000 tonnes of wild-caught fish, 76% of which was edible.

In their paper, published on the research forum Plos Sustainability and Transformation, they said: “Most edible wild-caught fish species in [fish meal and fish oil] have higher concentrations of key micronutrients than farmed salmon, and for some of these micronutrients, as little as 1% is retained in farmed salmon.

Monterey Bay Aquarium:

Many fish, like salmon or sea bass, are carnivores — they eat fishmeal and fish oil. Every year, millions of tons of wild fish, like sardines and anchovies, are caught and processed into fishmeal and fish oil to feed farm-raised species. Using wild-caught fish to feed farmed fish contributes to the overfishing pressure on wild fish populations. But farmers have options that can reduce the reliance on wild-caught feed.

Instead of using wild sources, fishmeal can be made from scraps of fish (both wild and farmed) processed for human consumption. Ingredients from plant and animal agriculture — like soy and poultry — are also used to make high protein ingredients.

More recently, insects, algae, and single-cell organisms have been tested to provide many of the same nutrients to farmed fish as more traditional ingredients do. Many of the major feed manufacturers are investing in the development of these alternative feeds and some fish farmers have found success using them.

All feed ingredients have some environmental footprint, so choosing aquaculture feeds that are both good for farmed fish and have minimal impacts on the ecosystem is important.

Taking fish out of fish feed can make aquaculture a more sustainable food source

Pallab Sarker, University of California, Santa Cruz

Published: December 14, 2020 8.20am EST

The Research Brief is a short take about interesting academic work.

The big idea

Aquaculture, or fish farming, is the world’s fastest-growing food production sector. But the key ingredients in commercial fish feed – fishmeal and fish oil – come from an unsustainable source: small fish, such as anchovies and herring, near the base of ocean food webs.

My colleagues and I have developed a high-performing, fish-free aquaculture feed that replaces these traditional ingredients with several types of microalgae – abundant single-celled organisms that form the very bottom of the food chain in fresh and saltwater ecosystems around the world. To test this approach, we developed our feed for Nile tilapia – the world’s second-most-farmed fish, exceeded only by carp.

Our research showed that tilapia fed our fish-free diet grew significantly better, achieving 58% higher weight gain than tilapia fed conventional feed. The resulting cost per kilogram of tilapia raised on our feed was lower than for fish raised on conventional commercial feed. And our feed yielded a higher level of a key fatty acid that is important for human health, DHA omega-3, in the resulting tilapia fillets.

Small schooling species such as sardines, sauries, and smelt – commonly known as forage fish – play a critical role in sustaining the ocean. These species eat tiny plants and animals, in turn becoming an important food source for bigger fish, seabirds and marine mammals. Pew Charitable Trusts

Why it matters

About 19 million tons of wild fish – some 20% of the total quantity caught around the world – are rendered into fish meal and fish oil every year, even though 90% of these harvested fish are fit for human consumption. Analysts project that aquaculture feed demands for fish meal and fish oil could outstrip the supply of small forage fish, also known as prey or bait fish, by 2037. If this happens, it could have disastrous consequences for human food security and marine ecosystems.

Received: June 3, 2021; Accepted: January 11, 2022; Published: March 1, 2022

Data Availability: All data is available in the manuscript or supplementary materials.

Competing interests: The authors have declared that no competing interests exist.

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