U.S. GOVERNMENT PUBLISHING OFFICE

37–301 PDF WASHINGTON : 2019

S. HRG. 115–655 

GROWING THE FUTURE: 

OPPORTUNITIES TO SUPPORT DOMESTIC 

SEAFOOD THROUGH AQUACULTURE 

HEARING 

BEFORE THE

COMMITTEE ON COMMERCE, 

SCIENCE, AND TRANSPORTATION 

UNITED STATES SENATE 

ONE HUNDRED FIFTEENTH CONGRESS 

SECOND SESSION 

JANUARY 30, 2018 

Printed for the use of the Committee on Commerce, Science, and Transportation 

( 

Available online: http://www.govinfo.gov 

(II) 

SENATE COMMITTEE ON COMMERCE, SCIENCE, AND TRANSPORTATION 

ONE HUNDRED FIFTEENTH CONGRESS 

SECOND SESSION 

JOHN THUNE, South Dakota, Chairman 

ROGER WICKER, Mississippi 

ROY BLUNT, Missouri 

TED CRUZ, Texas 

DEB FISCHER, Nebraska 

JERRY MORAN, Kansas 

DAN SULLIVAN, Alaska 

DEAN HELLER, Nevada 

JAMES INHOFE, Oklahoma 

MIKE LEE, Utah 

RON JOHNSON, Wisconsin 

SHELLEY MOORE CAPITO, West Virginia 

CORY GARDNER, Colorado 

TODD YOUNG, Indiana 

BILL NELSON, Florida, Ranking 

MARIA CANTWELL, Washington 

AMY KLOBUCHAR, Minnesota 

RICHARD BLUMENTHAL, Connecticut 

BRIAN SCHATZ, Hawaii 

EDWARD MARKEY, Massachusetts 

TOM UDALL, New Mexico 

GARY PETERS, Michigan 

TAMMY BALDWIN, Wisconsin 

TAMMY DUCKWORTH, Illinois 

MAGGIE HASSAN, New Hampshire 

CATHERINE CORTEZ MASTO, Nevada 

JON TESTER, Montana 

NICK ROSSI, Staff Director 

ADRIAN ARNAKIS, Deputy Staff Director 

JASON VAN BEEK, General Counsel 

KIM LIPSKY, Democratic Staff Director 

CHRIS DAY, Democratic Deputy Staff Director 

RENAE BLACK, Senior Counsel 

(III) 

C O N T E N T S 

Page 

Hearing held on January 30, 2018 ......................................................................... 1 

Statement of Senator Thune ................................................................................... 1 

Statement of Senator Nelson .................................................................................. 3 

Prepared statement .......................................................................................... 4 

Statement of Senator Klobuchar ............................................................................ 21 

Statement of Senator Blunt .................................................................................... 23 

Statement of Senator Hassan ................................................................................. 31 

Statement of Senator Blumenthal .......................................................................... 34 

Statement of Senator Cantwell .............................................................................. 36 

Statement of Senator Sullivan ............................................................................... 37 

WITNESSES

Mark Luecke, Managing Director and CEO, Prairie AquaTech .......................... 4 

Prepared statement .......................................................................................... 6 

Kelly Lucas, Ph.D., Director, Thad Cochran Marine Aquaculture Center, University of Southern Mississippi ........................................................................... 8 

Prepared statement .......................................................................................... 9 

Barton Seaver, Director, Sustainable Seafood and Health Initiative, Center 

for Health and the Global Environment, Harvard T. H. Chan School of 

Public Health ........................................................................................................ 12 

Prepared statement .......................................................................................... 14 

Donald B. Kent, President and CEO, Hubbs-SeaWorld Research Institute ....... 16 

Prepared statement .......................................................................................... 18 

APPENDIX

Letter dated February 13, 2018 to Hon. John Thune and Hon. Bill Nelson 

from Kathryn Unger, President; Tony Dal Ponte, Vice President; Max 

Holtzman, Secretary; and Bill Dewey, Treasurer, Stronger America 

Through Seafood Campaign ................................................................................ 41 

Prepared Statement of the National Aquaculture Association ............................ 44 

Written Comments by the San Diego Unified Port District ................................ 49 

Response to written questions submitted to Mark Luecke by: 

Hon. Roger F. Wicker ....................................................................................... 51 

Response to written questions submitted to Dr. Kelly Lucas by: 

Hon. Roger F. Wicker ....................................................................................... 52 

Hon. Bill Nelson ............................................................................................... 53 

Hon. Catherine Cortez Masto .......................................................................... 54 

Response to written questions submitted to Barton Seaver by: 

Hon. Roger F. Wicker ....................................................................................... 54 

Hon. Bill Nelson ............................................................................................... 55 

Hon. Edward Markey ....................................................................................... 56 

Hon. Catherine Cortez Masto .......................................................................... 57 

Response to written questions submitted to Donald B. Kent by: 

Hon. Roger F. Wicker ....................................................................................... 57 

Hon. Bill Nelson ............................................................................................... 59 

(1) 

GROWING THE FUTURE: 

OPPORTUNITIES TO SUPPORT DOMESTIC 

SEAFOOD THROUGH AQUACULTURE 

TUESDAY, JANUARY 30, 2018 

U.S. SENATE, 

COMMITTEE ON COMMERCE, SCIENCE, AND TRANSPORTATION, 

Washington, DC. 

The Committee met, pursuant to notice, at 10 a.m. in room SR– 

253, Russell Senate Office Building, Hon. John Thune, Chairman 

of the Committee, presiding. 

Present: Senators Thune [presiding], Blunt, Heller, Fischer, 

Gardner, Sullivan, Young, Nelson, Cantwell, Klobuchar, Tester, 

Blumenthal, and Hassan. 

OPENING STATEMENT OF HON. JOHN THUNE, 

U.S. SENATOR FROM SOUTH DAKOTA 

The CHAIRMAN. Good morning. Thank you all for being here. 

Today we’re going to hear from some remarkable leaders in the 

field of aquaculture. They are working to ensure Americans have 

access to safe and sustainably grown seafood from right here at 

home. 

Many of us have benefited from aquaculture, perhaps without realizing it. For years, lakes and rivers in my home state of South 

Dakota have been stocked with juvenile game fish raised in hatcheries. The town of Spearfish houses the Fish Culture Hall of Fame, 

which documents the history and importance of this type of aquaculture. The effort it took to transport fish eggs and juvenile fish 

in the days before refrigeration or reliable transportation is truly 

impressive. 

Thanks to its vast coastlines, the United States has the largest 

Exclusive Economic Zone in the world, and yet we import 90 percent of our seafood. Half of those imports are not wild caught and 

are farmed in other countries around the world where we have little control over the practices and conditions in which the seafood 

is grown or harvested. 

Domestic farming of seafood done in a safe, well-monitored manner can provide economic opportunities for all Americans, both for 

our coastal and inland communities. Agricultural states like mine 

can play an important role in providing feed for fish farms, and everyone benefits from having increased domestic seafood production. 

Currently, however, those seeking to expand the domestic farming of seafood often face a confusing regulatory maze. Permits for 

an aquaculture farm may be required from the U.S. Army Corps 

2 

of Engineers, the National Oceanic and Atmospheric Administration, the Environmental Protection Agency, the Coast Guard, the 

Department of Agriculture, and the Food and Drug Administration. 

This overlapping web of Federal jurisdiction and lengthy, sometimes unending, permitting process can take 10 years or more, 

scaring many investors away. Too often, this results in entrepreneurs taking their skills, talents, and ideas overseas to a more 

business-friendly environment. 

The United States is a global leader in how to manage wildcaught fisheries, but we regularly send our expertise, our innovation, and our dollars overseas when it comes to aquaculture. Rather 

than buying seafood from a global market that has seen repeated 

instances of labor and environmental violations, we should do a 

better job at home. It’s time we straighten our Byzantine permitting regime and start growing some more fish. 

Our witnesses today are working to promote aquaculture in the 

United States and will share with us some of their ideas to reduce 

the barriers to aquaculture and support innovative strategies for 

food security. 

I’m pleased to welcome a fellow South Dakotan, who is bringing 

South Dakota soy into the fish farming market in a big way. Mr. 

Mark Luecke is the CEO of Prairie AquaTech, a technology company that has developed and patented a high-protein fish feed from 

soy meal. Prairie AquaTech is based in Brookings, South Dakota, 

and due to high demand in their product, they will be breaking 

ground on a new commercial facility this spring that will process 

30,000 tons of feed per year. 

As a scientist and the Director of the Thad Cochran Marine 

Aquaculture Center at the University of Southern Mississippi, Dr. 

Kelly Lucas will testify about her work overseeing a $25 million 

aquaculture facility, which employs cutting-edge technology, peerreviewed research, and hands-on testing to grow fish in an environmentally responsible and economically feasible manner. 

Mr. Barton Seaver began his career as a celebrity chef here in 

Washington, D.C., where he realized the key role aquaculture plays 

as a sustainable food resource and the importance of seafood in a 

healthy diet. He is the author of seven highly regarded books and 

is an internationally recognized speaker on the topic of sustainable 

seafood and aquaculture. 

Testifying with firsthand experience in aquaculture is Mr. Don 

Kent, who has spent many years working to get a commercial-scale 

fish farm up and running off the coast of Southern California. 

Aquaculture is the fasting growing food industry in the world. If 

encouraged in the United States, it has the potential to create jobs 

and boost the economy from states like South Dakota to the coasts. 

As Department of Commerce Secretary Wilbur Ross has stated, 

‘‘This country, with its abundant coastline, should not have to import billions of pounds of seafood each year.’’ Let’s harness this opportunity and become the world leader in safe and sustainable domestic seafood production. 

And with that, I will recognize our Ranking Member, Senator 

Nelson, who knows a little bit about seafood and oceans and coastlines and all that sort of thing. 

So, Senator Nelson. 

3 

STATEMENT OF HON. BILL NELSON, 

U.S. SENATOR FROM FLORIDA 

Senator NELSON. It’s especially important to have aquaculture 

that is under conditions that are not just so nasty and putrid as 

we’ve learned about some of the aquaculture in foreign countries. 

The CHAIRMAN. Yes. 

Senator NELSON. And, indeed, as the Chairman has said, Florida 

has long been known as the fishing capital, 2,300 miles of shore 

land, by the way, only exceeded by Alaska. But Alaska doesn’t have 

a lot of beaches. 

[Laughter.] 

The CHAIRMAN. Yes, that’s true. 

Senator NELSON. It’s fishing-friendly weather, millions of dollars 

of shrimp, snapper, grouper, spiny lobster, stone crabs on the 

plates of Americans’ restaurants, and yet there’s room to grow. 

America consumes the second largest amount of seafood in the 

world, but 90 percent of it comes from other countries, and that’s 

huge. We need to dramatically grow our domestic seafood capacity, 

and I think marine aquaculture should be a part of that. 

A variety of fishermen, entrepreneurs, academics, and environmental groups have started to come together to figure out how we 

can develop a sustainable aquaculture industry. Just last year, a 

group at the University of Miami received a million dollar grant 

from the National Sea Grant college program to advance technology for captive spawning of different marine species. 

I’ve been to the little town of Cedar Key, which back in the old 

days was a flourishing little coastal town, but had gone into significant decline economically when seafood had lessened as an industry, not unlike the oysters in Apalachicola Bay, and what they have 

done is they have started an aquaculture industry in Cedar Key, 

which is turning things around. So the question is: How do we turn 

all of this interest into commercially viable businesses? 

Permitting marine aquaculture is not a simple matter. In any 

aquaculture permitting process, we must ensure that consumers 

are able to distinguish, full disclosure, between fish that have been 

raised in a pen and fish caught by commercial fishermen in the 

wild. We also need to protect our environment. Any type of permitting framework needs to ensure that we avoid harmful effects of 

waste, discharge, fish disease, chemical and drug use, and invasive 

species. That is why I’m concerned that 90 percent of our consumption in America that comes from foreign shores; they are not paying attention to these things. 

I want to thank our witnesses for being here today. Donald Kent, 

President and CEO of Hubbs-SeaWorld Research Institute, which 

is a major institution in the South. And we have an opportunity 

as a nation to develop a sector that will bring jobs and economic 

growth, and especially to those little fishing communities. 

So I look forward to hearing the results of this panel. And you 

don’t have much seafood. 

[Laughter.] 

[The prepared statement of Senator Nelson follows:] 

4 

PREPARED STATEMENT OF HON. BILL NELSON, U.S. SENATOR FROM FLORIDA

Florida has long been called the fishing capital of the world. With roughly twentythree hundred miles of shoreline and year-round, fishing-friendly weather, Florida 

is the source of hundreds of millions of dollars of shrimp, snapper, grouper, spiny 

lobster, and stone crab on the plates of America’s restaurants and households. 

Even so, there is room to grow this important sector of our economy. Although 

America consumes the second largest amount of seafood in the world, over ninety 

percent of it comes from other countries. That is a staggering percentage, Mr. Chairman. 

We need to dramatically grow our domestic seafood capacity and I think that marine aquaculture should be a part of that. 

A variety of fishermen, entrepreneurs, academics and environmental groups have 

started to come together to figure out how we can develop a sustainable U.S. marine 

aquaculture industry. 

And Florida is leading the pack. Just last year, a group at the University of 

Miami received an almost one million dollar grant from the National Sea Grant college program to advance technology for captive spawning of different marine species. 

The question is: how do we turn all of this interest into commercially viable businesses? This is where we have run into problems in the past. 

Permitting marine aquaculture is not a simple matter. In any aquaculture permitting process we must ensure that consumers are able to distinguish between fish 

that have been raised in a pen and fish caught by commercial fishermen. We also 

need to protect our environment. Any type of permitting framework needs to ensure 

that we avoid harmful effects of waste discharge, fish disease, chemical and drug 

use, escapes and invasive species. 

I also want to thank our witnesses for testifying today, especially Donald Kent, 

President and CEO of the Hubbs-SeaWorld Research Institute. 

We have the opportunity as a nation to develop a sector that will bring jobs and 

economic growth to many communities across the Nation. We need to take advantage of it. I look forward to hearing our witnesses’ ideas on the best paths forward. 

The CHAIRMAN. But they have a few people that come through 

the cities in Las Vegas and consume a good amount. That’s right. 

As I mentioned earlier, we’ve got a great panel. I want to welcome Mark Luecke, who is the Managing Director and CEO of 

Prairie AquaTech; Dr. Kelly Lucas, Director of the Marine Aquaculture Center at the University of Southern Mississippi; Mr. Barton Seaver, who is a Chef and Author, as has been pointed out; and 

Dr. Donald Kent, President and CEO of Hubbs-Seaworld Research 

Institute. 

So we’ll proceed on my left, and your right, with Mr. Luecke. And 

if you could confine your oral remarks to 5 minutes or so, we’ll 

make sure that your entire statement gets made part of the hearing record. And we look forward to asking you some questions. 

So, Mr. Luecke, please proceed. Welcome. 

STATEMENT OF MARK LUECKE, MANAGING DIRECTOR 

AND CEO, PRAIRIE AQUATECH 

Mr. LUECKE. Chairman Thune, members of the Committee, 

thank you for the opportunity to speak with you this morning on 

aquaculture, an important topic for each of your states and for our 

country. 

My name is Mark Luecke. I’m the Managing Director and CEO 

of Prairie AquaTech, a specialty feed ingredient and aquaculture 

technology company based in South Dakota. Like many of your constituents, I grew up on a small family farm in rural America. I 

graduated from business school and migrated to larger markets, 

pursuing a career in finance and eventually becoming an entrepreneur. 

5 

Nine years ago, a group of civic leaders recruited me back to my 

home state to start South Dakota Innovation Partners. We had a 

mission of commercializing research from our Nation’s land-grant 

universities where innovation in agriculture was occurring. Our national security interest of protecting our country’s food supply, the 

process of getting crops from our farmers’ fields to food on our 

plates, became our investment thesis, more specifically, animal 

health and nutrition. In fact, a milestone that one of our companies 

will achieve this week is becoming the first USDA-licensed vaccine 

production facility in the State of South Dakota. This company, 

Medgene Labs, has a focus on foreign animal diseases that threaten our food supply. 

Prairie AquaTech started with research at South Dakota State 

University that received both public and private funding. Technology transfer policies based on the Bayh-Dole Act allowed us to 

license the technology and begin the commercialization process. We 

constructed a 30,000-square-foot pilot-scale facility with support of 

the Brookings Economic Development Corporation and the Department of Commerce’s Economic Development Administration. This 

facility, the AgTech Center for Rural Enterprise, has a mission of 

scaling and de-risking university technologies and starting new operating companies to support job growth in rural communities. 

With further public and private support from the National 

Science Foundation and the USDA’s Small Business Innovation Research Programs, the United Soybean Board, South Dakota Soybean Alliance, Indiana Soybean Alliance, Soy Aquaculture Alliance, 

and many private investors, Prairie AquaTech developed a sustainable plant-based protein ingredient that is being used in many locations around the country, including a large fish supplier to Whole 

Foods Market in the State of Wisconsin. 

Committee members will appreciate that the seed funding provided by the NSF, USDA, and others has put Prairie AquaTech in 

a position to close on $60 million of private funding next month. 

This funding will be used to construct a large protein ingredient 

production facility in rural South Dakota. We take our responsibility of generating a return on both public and private investment 

very seriously, and we believe we have done so with Prairie 

AquaTech. 

While Prairie AquaTech is an extraordinary example of the effectiveness of public-private partnerships, it is important for Committee members to understand that our collective work is only beginning. Despite a number of important policy statements supporting the growth of a sustainable aquaculture industry in the 

United States, we have made limited progress. Seafood remains 

one of our country’s highest trade deficits in the natural resource 

category, while aquaculture remains one of the fastest growing segments in the agriculture outside the U.S. 

We believe the reasons for our country’s slow growth in aquaculture include: one, the unavailability of high-quality feed ingredients produced locally, which equates to over 50 percent of fish production costs; two, the unavailability of investment capital to construct more fish production facilities; and, three, an inefficient regulatory pathway permitting fish production facilities while preVerDate Nov 24 2008 09:04 Aug 12, 2019 Jkt 000000 PO 00000 Frm 00009 Fmt 6633 Sfmt 6601 S:\GPO\DOCS\37301.TXT JACKIE
6 

serving our marine and land-based environments. An opportunity 

exists to improve our position. 

With partner support, Prairie AquaTech has solved the first challenge of high-quality feed ingredients produced locally. Soybean 

farmers across many of your states have been searching for new 

and higher value uses of soybean meal, given an increase in supply 

and global competition. The process developed by Prairie AquaTech 

opens a new global market for our soybean farmers by eliminating 

allergenic proteins and sugars found in soybean meal that limit inclusion levels in aquaculture feed. 

The process also increases phosphorus availability to the animal 

so that fish production facilities no longer discharge phosphorus in 

the surrounding environment. Imagine our country feeding local 

plant-based protein ingredients that are 100 percent digestible to 

fish, which have the highest feed conversion rate of all animals in 

an environmentally conscious manner. This is a major win for all 

of our constituents. 

However, we need the Committee’s support to increase the availability of investment capital to construct more fish production facilities in the U.S. Unlike investments in software companies, these 

facilities have a long lead time to design, construct, start production, and achieve break-even. This long lead time creates risk and 

prevents investors and lenders from supporting these projects. 

We propose a public-private advisory group with a mission of recommending economic policies to the Committee that create incentives and reduce risks for private investors and lenders to support 

more fish production facilities. 

Similarly, we need the Committee’s support to establish an efficient regulatory pathway permitting fish production facilities in the 

U.S. Multiple Federal and state agencies claim and disclaim jurisdiction in the current regulatory pathway, which is unproductive to 

building an industry. The public-private advisory group would further recommend regulatory policies supporting entrepreneurs, investors, and lenders. 

I appreciate the Committee members’ time and attention. 

Thank you very much, Chairman Thune. 

[The prepared statement of Mr. Luecke follows:] 

PREPARED STATEMENT OF MARK LUECKE, MANAGING DIRECTOR AND CEO, 

PRAIRIE AQUATECH

Chairman Thune, Members of the Committee, thank you for the opportunity to 

speak with you this morning on aquaculture—an important topic for each of your 

states, and for our country. 

My name is Mark Luecke. I am the Managing Director and CEO of Prairie 

AquaTech, a specialty feed ingredient and aquaculture technology company based 

in South Dakota. Like many of your constituents, I grew up on a small family farm 

in Rural America. I graduated from business school and migrated to larger markets, 

pursuing a career in finance and eventually becoming an entrepreneur. Nine years 

ago, a group of civic leaders recruited me back to my home state to start South Dakota Innovation Partners. We had a mission of commercializing research from our 

Nation’s land grant universities, where innovation in agriculture was occurring. Our 

national security interest of protecting our country’s food supply—the process of getting crops from our farmers’ fields to food on our plates—became our investment 

thesis; more specifically, animal health and nutrition. In fact, a milestone that one 

of our companies will achieve this week is becoming the first USDA-licensed vaccine 

production facility in the State of South Dakota. This company, Medgene Labs, has 

a focus on foreign animal diseases that threaten our food supply. 

7 

Prairie AquaTech started with research at South Dakota State University that received both public and private funding. Technology transfer policies based on the 

Bayh-Dole Act allowed us to license the technology and begin the commercialization 

process. We constructed a 30,000 square foot pilot scale facility with support from 

the Brookings Economic Development Corporation and the Department of Commerce’s Economic Development Administration. This facility, the AgTech Center for 

Rural Enterprise, has a mission of scaling and de-risking university technologies 

and starting new operating companies to support job growth in rural communities. 

With further public and private support from the National Science Foundation and 

USDA’s Small Business Innovation Research Programs, the United Soybean Board, 

South Dakota Soybean Association, Indiana Soybean Alliance, Soy Aquaculture Alliance, and many private investors, Prairie AquaTech developed a sustainable, plantbased protein ingredient that is being used in many locations around the country, 

including a large fish supplier to Whole Foods Market in the State of Wisconsin. 

Committee Members will appreciate that the seed funding provided by the NSF, 

USDA, and others has put Prairie AquaTech in a position to close on $60 million 

of private funding next month. This funding will be used to construct a large protein 

ingredient production facility in rural South Dakota. We take our responsibility of 

generating a return on both public and private investment very seriously, and we 

believe we have done so with Prairie AquaTech. 

While Prairie AquaTech is an extraordinary example of the effectiveness of public/ 

private partnerships, it is more important for Committee Members to understand 

that our collective work is only beginning. Despite a number of important policy 

statements supporting the growth of a sustainable aquaculture industry in the 

United States, we have made limited progress. Seafood remains one of our country’s 

highest trade deficits in the natural resource category, while aquaculture remains 

one of the fastest growing segments in agriculture outside the U.S. We believe the 

reasons for our country’s slow growth in aquaculture include: (1) the unavailability 

of high quality feed ingredients produced locally, which equates to over 50 percent 

of fish production costs, (2) the unavailability of investment capital to construct 

more fish production facilities, and (3) an inefficient regulatory pathway permitting 

fish production facilities while preserving our marine and land-based environments. 

An opportunity exists to improve our position. 

With partner support, Prairie AquaTech has solved the first challenge of high 

quality feed ingredients produced locally. Soybean farmers across many of your 

states have been searching for new and higher value uses of soybean meal given 

an increase in supply and global competition. The process developed by Prairie 

AquaTech opens a new global market for our soybean farmers by eliminating allergenic proteins and sugars in soybean meal that limit inclusion levels in aquaculture 

feed. The process also increases phosphorus availability to the animal so that fish 

production facilities no longer discharge phosphorus into the surrounding environment. Imagine our country feeding local, plant-based protein ingredients that are 

100 percent digestible to fish, which have the highest feed conversion rate of all animals, in an environmentally conscious manner—this is a major win for all constituents. 

However, we need the Committee’s support to increase the availability of investment capital to construct more fish production facilities in the U.S. Unlike investments in software companies, these facilities have a long lead time to design, construct, start production, and achieve breakeven. This long lead time creates risk and 

prevents investors and lenders from supporting these projects. We propose a public/ 

private advisory group with a mission of recommending economic policies to the 

Committee that create incentives and reduce risks for private investors and lenders 

to support more fish production facilities. 

Similarly, we need the Committee’s support to establish an efficient regulatory 

pathway permitting fish production facilities in the U.S. Multiple Federal and state 

agencies claim and disclaim jurisdiction in the current regulatory pathway, which 

is unproductive to building an industry. The public/private advisory group would 

further recommend regulatory policies supporting entrepreneurs, investors, and 

lenders. 

I appreciate the Committee Members’ time and attention; thank you very much, 

Chairman Thune. 

The CHAIRMAN. Thank you, Mr. Luecke. 

Dr. Lucas. 

8 

STATEMENT OF KELLY LUCAS, PH.D., DIRECTOR, 

THAD COCHRAN MARINE AQUACULTURE CENTER, 

UNIVERSITY OF SOUTHERN MISSISSIPPI 

Dr. LUCAS. Mr. Chairman and members of the Committee, thank 

you for inviting me to testify before you today. For the record, I’m 

Dr. Kelly Lucas, Director of the Thad Cochran Marine Aquaculture 

Center at the University of Southern Mississippi. 

The Center includes approximately 100,000 square feet of culture 

space devoted to environmentally responsible and economically feasible marine aquaculture. Our research focuses on alleviating the 

bottlenecks that constrain the production of marine species. As you 

both have mentioned, the United States imports over 90 percent of 

our seafood, and half those imports are aquaculture products. We 

have a $14 billion seafood trade deficit. 

With the growing demand for seafood and static wild-capture 

fisheries since the 1990s, aquaculture must continue to grow to 

meet this demand. While the United States has seen an increase 

in aquaculture production, mostly in land-based operations or in 

sheltered nearshore waters, we remain a minor producer. Nevertheless, we are a major supplier, an exporter of equipment, feed, 

and advanced technology. 

We have a choice: we can continue to source our new seafood 

supply from abroad, or we can use our expertise to develop the domestic capacity to supply our needs. Sourcing from other countries 

means that the United States misses out on the opportunity to create jobs that generate wealth in our communities and provide safe, 

local, sustainable seafood products. There is a growing consensus 

among scientists, resource managers, and industry that diversification of aquaculture, to include offshore farming, could expand our 

capacity for local safe seafood production. 

Coastal communities are recognizing that aquaculture presents a 

sustainable business alternative. These communities have the infrastructure, such as the boats and the processing plants, the seafood markets, and the working waterfronts, to help support operations, and aquaculture can consistently supply products to keep 

these businesses operating. 

Other businesses, such as feed suppliers, equipment companies, 

and repair shops will also grow in these communities. Several offshore aquaculture operations use advanced remote sensing, unmanned systems, and artificial intelligence. This sector of the Blue 

Economy would also continue to expand to meet industry needs. 

Regulatory uncertainty has widely been mentioned as a barrier 

to offshore aquaculture. The Gulf of Mexico Fishery Management 

Plan for Aquaculture, or the Gulf Rule, published in January 2016. 

The plan established a regional permitting process to manage offshore aquaculture in an environmentally and economically sustainable manner. However, investors have expressed concerns regarding the time, actual cost, and uncertainty of permit approval. Additional industry concerns with the Gulf Rule relate to the permit duration, the size of the restricted zones around the permitted areas, 

and community acceptance. 

There is a concern that the Magnuson-Stevens Act is not the 

right tool for regulating aquaculture. Offshore aquaculture legislation could provide more certainty for permitting and management 

9 

of aquaculture operations. Diversification of seafood products 

through systems, species, and location will help build a more resilient community and will help increase production to meet demands. 

The aquaculture industry has made advancements. However, 

there still are challenges and needs. Although we have made advancements in fish feed and have reduced reliance on forage fish, 

we should continue to identify alternative sustainable feeds for 

large-scale aquaculture. Improvements in net and cage technology 

have decreased chances of escapes; however, we can continue to improve the containment systems with new materials and remote 

monitoring technology. Continued use of unmanned systems could 

further improve safety, provide more timely and accurate assessments, and potentially reduce costs. 

The development of hatchery capacity and the refinement of culture techniques is vital to industry development. Commercial operators need a reliable and consistent source of disease-free larval 

fish. Whereas some larval fish species can be reliably supplied, 

many other species that are high value and fast growing lack sufficient research development. 

The use of selective breeding as a tool to increase production is 

far behind the plant and farm animal industries. Selective breeding 

of fish with higher growth rates can generally be completed in less 

time than breeding of farm animals. Domestication of new species 

and offshore aquaculture will require monitoring and adaptive 

health management plans to reduce disease and outbreaks. 

Supporting aquaculture development by mechanisms similar to 

those used to support agriculture can help industry grow. The agricultural industry grew vastly from public support of research occurring at universities, state and Federal laboratories, and research 

stations spread across the Nation to bring techniques directly to 

farmers. Aquaculture can benefit from a similar approach of competitive peer-reviewed-based research funding and extension funding to advance the technology and the development. 

Advancement of aquaculture, especially selective breeding, health 

management, and culture species can take multiple years for significant gains, and long-term funding programs will be critical to 

success. Public and private partnerships will also be important to 

help address industry needs, promote industry growth, and successfully transfer technology and techniques. 

I appreciate the opportunity to testify before this Committee regarding aquaculture. I believe the time is now for the United 

States to become more self-reliant in the production of seafood. 

[The prepared statement of Dr. Lucas follows:] 

PREPARED STATEMENT OF KELLY LUCAS, PH.D., DIRECTOR, THAD COCHRAN MARINE

AQUACULTURE CENTER, UNIVERSITY OF SOUTHERN MISSISSIPPI

Mr. Chairman and members of the Committee, thank you for inviting me to testify before you today. For the record, I am Dr. Kelly Lucas—Director of the Thad 

Cochran Marine Aquaculture Center (TCMAC)-University of Southern Mississippi— 

Ocean Springs. The Center includes approximately 100,000 square feet of culture 

space devoted to environmentally responsible and economically feasible marine 

aquaculture. Our research focuses on alleviating the bottlenecks that constrain the 

production of marine species. We work with government and industry to address research that will advance sustainable aquaculture on land and in coastal and marine 

environments. Prior to my appointment at USM, I was chief scientific officer for the 

10 

Mississippi Department of Marine Resources, the state agency with regulatory authority for managing and conserving coastal and marine resources. My testimony 

will provide both a science and management perspective. 

The United States imports over 90 percent of our seafood and half the imports are aquaculture products. We have a $14 billion-dollar seafood trade deficit. With 

a growing demand for seafood and static wild capture fisheries since the 1990s, 

aquaculture must continue to grow to meet increasing demand. While the United 

States has seen an increase in aquaculture production, mostly in land-based operations or in sheltered nearshore waters, we remain a minor producer. Nevertheless, 

we are a major supplier and exporter of equipment, feed and advanced technology. 

We have a choice. We can continue to source new seafood supply from abroad or 

we can use our expertise to develop the domestic capacity to supply our needs. 

There is a risk in continuing to source aquaculture products from abroad. Several 

of the major producer countries do not have the environmental standards we have 

in the United States and they do not have robust disease management regulations. 

Further, they tend to lack transparency which creates easy avenues for fraud and 

quality issues. New supply is also often from countries with political uncertainty or 

geopolitical instability that can threaten the supply chain and create food insecurity. 

Importantly, sourcing from other countries means the United States misses out on 

the opportunity to create jobs that generate wealth in our communities and provide 

safe, local, sustainable, seafood products. 

Opportunities 

There is growing consensus among scientists, resource managers and industry 

that diversification of aquaculture to include offshore farming could expand our capacity for local, safe, seafood production. Even some environmental groups have expressed interest in the potential for aquaculture to supply a healthier protein with 

less impact than that from other animal sources. This is not to say that there is 

no opposition to aquaculture. However, public engagement and outreach on advances in aquaculture can help educate consumers and address concerns. By siting 

aquaculture farms away from sensitive habitats in deep waters with adequate currents the potential for pollution is reduced. Improved materials for containment and 

remote sensing technology has decreased the likelihood of fish escapement. Remotely controlled feeding and observation systems have helped create a mechanism 

for reducing over-feeding and improved feeds have reduced the reliance on forage 

fish. 

The economic success of sustainable commercial operations abroad and in Hawaii, 

Maine and New Hampshire have created a renewed optimism for offshore commercial development. Coastal communities are recognizing that aquaculture presents a 

sustainable business alternative. These communities have the infrastructure such as 

boats, processing plants, seafood markets and working waterfronts to help support 

operations and aquaculture can consistently supply products to keep these businesses operating. Other businesses, such a feed suppliers, equipment companies and 

repair shops also grow in these communities. Several offshore aquaculture operations use advanced remote sensing, unmanned systems and artificial intelligence. 

This sector of the blue economy would also expand to meet industry needs. 

Businesses need regulatory certainty to reduce the risk of investment. Regulatory 

uncertainty has been widely mentioned as a major barrier to offshore aquaculture. 

The Gulf of Mexico Fishery Management Plan for Aquaculture in the Gulf of Mexico 

(Gulf Rule) published in January of 2016. The plan established a regional permitting process to manage offshore aquaculture in an environmentally sustainable 

manner and NOAA worked with Federal permitting agencies to create a coordinated 

permit process. The estimated cost for engineering, siting and environmental assessment to permit a commercial structure under the Gulf rule has been estimated at 

$1 million dollars. However, investors expressed concerns regarding the time, actual 

cost and uncertainty of permit approval. Additional industry concerns of the Gulf 

Rule relate to permit duration, size of restricted zones around permitted areas and 

community acceptance. The day the Gulf Rule was announced several groups filed 

a lawsuit challenging NOAA’s authority for permitting aquaculture under the 2007 

Magnuson-Stevens Act. There is a concern that the Magnuson-Stevens Act is not 

the right tool to regulate aquaculture. Offshore aquaculture legislation could provide 

more certainty for permitting and management of aquaculture operations. 

Opportunities also exist for the growth of land-based and near-shore aquaculture. 

Land-based aquaculture in recirculating closed loop systems is advantageous for numerous reasons. Land-based, recirculating systems provide a controlled environment 

that allows year round production, increased biosecurity that reduces the occurrence 

and spread of disease, and the capability for reusing and recycling water to decrease 

the waste and increase sustainability. Because such systems are self-contained and 

11 

decoupled from a water source, they can be located almost anywhere near the markets they serve where they create local jobs and supply safe, fresh, local, seafood 

for consumers. Near-shore aquaculture in the United States also has been increasing. Shellfish aquaculture has expanded into new geographic areas and production 

has increased significantly along coastal shorelines. Seaweed aquaculture has been 

increasing in several regions of the United States. Growth of near-shore finfish operations also has occurred in regions with nearshore water-depths sufficient to support the structures. Diversification of seafood products through systems, species and 

location will help build a more resilient industry and will help increase production 

to meet demand. 

Challenges and Needs 

For the aquaculture industry to be successful on a scale necessary to meet demand, there are things that still need to be addressed. Although we have made advancements in fish feed and have reduced reliance on forage fish, we should continue to identify alternative sustainable feeds for large-scale aquaculture. Improvements in net and cage technology have decreased chances of escapes; however, we 

can continue to improve containment systems with new materials and remote monitoring technology. Unmanned systems and artificial intelligence can aid operators 

in tasks such as cleaning cages, feeding fish and detecting potential problems. This 

technology decreases reliance on divers and helps improve safety of operations. Continued use of these systems could further improve safety, provide for more timely 

and accurate assessments, and potentially decrease cost. The development of hatchery capacity and refinement of culture techniques is vital to industry development. 

Commercial operators need a reliable and consistent source of disease-free larval 

fish from documented broodstock. Whereas some larval fish species can be reliably 

supplied, many other species that are high value and fast-growing lack sufficient research development. Other challenges for hatcheries include a shortage of customers 

to purchase fish and keep the hatchery operating while waiting on domestic industry development. The use of selective breeding as a tool to increase production is 

far behind the plant and farm animal industries. Selective breeding of fish with 

higher growth rates can generally be completed in less time than breeding of farm 

animals. Fish convert feed to meat more efficiently than terrestrial animals and the 

ability to produce a steady fish supply can meet the increasing demand for protein. 

Fish health management is also critical to increasing aquaculture production. For 

some species raised in re-circulating systems or pond culture disease has been well 

studied and management for prevention has been important for success. Domestication of new species and offshore culture will require monitoring and adaptive health 

management plans to reduce disease and outbreaks. 

Supporting aquaculture development by mechanisms similar to those used to support agriculture can help industry grow. The agriculture industry grew vastly from 

public support of research occurring at universities, state and Federal laboratories 

and research stations spread across the Nation to bring techniques directly to farmers. Aquaculture can benefit from a similar approach of competitive peer-reviewed 

based research funding and extension funding to advance research and development. Advancement of aquaculture, especially selective breeding, health management and culture techniques can take multiple years for significant gains and longterm funding programs will be critical to success. Public and private partnerships 

also will be important to help address industry needs, promote industry growth and 

successfully transfer technology and techniques. 

Concluding Remarks 

I appreciate the opportunity to testify before this Committee regarding aquaculture. I believe the time is now for the United States to become more self-reliant 

in the production of seafood. We can create jobs and reduce the seafood trade deficit 

while supplying safe, local, sustainable, seafood. Diversification of aquaculture production in addition to commercial fishing can help supply seafood to help meet the 

growing demand. Government, universities and industry working together can help 

create regulatory certainty, address research needs and advance sustainable aquaculture. 

The CHAIRMAN. Thank you, Dr. Lucas. 

Mr. Seaver. 

12 

STATEMENT OF BARTON SEAVER, DIRECTOR, SUSTAINABLE 

SEAFOOD AND HEALTH INITIATIVE, CENTER FOR HEALTH 

AND THE GLOBAL ENVIRONMENT, HARVARD T. H. CHAN 

SCHOOL OF PUBLIC HEALTH 

Mr. SEAVER. Hi. Good morning, Chairman Thune and all the 

Ranking Members here. An incredible opportunity and honor to be 

here representing my home state of Maine and all of the coastal 

communities along this great Nation’s shorelines. 

I want to talk a little bit today just about why aquaculture matters, why seafood is important to us, and a little bit of the opportunity that resides within it for us to look ahead, too, as so many 

of my fellow panelists have spoken about, and I look forward to 

continuing conversation. 

So in Maine, we have a slightly unique cultural dynamic. There 

we honor the legacy and the presence of the lobster fisheries specifically, also the fin fisheries. The working waterfronts that they 

support, the sophisticated cold chain supply systems, individual 

boat operators, owners, ice producers, the cold chain, all of it there. 

There’s a strong apprentice program, a strong presence and legacy 

of this industry. And there we view lobstering and fishing as a 

noble profession, one that is very essential to the state’s identity. 

But this genuflection to the men and women harvesting seafood is 

not shared by all communities in America, and rarely so actually 

only in specific areas around the country. 

When we, as citizens, as an analogy, envision an agricultural 

scene, we envision amber waves of grain, the fruited plain, the picturesque red barns. We get this. This is American iconography, a 

conjuring that represents and renders farming as the best possible 

use of fertile land. But when we think of the ocean, it’s often wilderness that captures our imaginations about it. We value the open 

sea because the hand of man is simply not present. But I argue 

that we must emotionally embrace farming our seas and fishing 

them so as we do farming the land. And this is an important part 

of putting the culture into aquaculture. 

There is more America underwater than there is above it. As 

Chairman Thune mentioned, we have more—there is more coastline in America and the longest—the largest Exclusive Economic 

Zone. Recently, a study mapped global marine aquaculture productivity concluded that in an area the size of the ocean, just an area 

of the ocean the size of Lake Michigan, we could sustainably farm 

as much seafood as is currently captured globally in the wild. With 

that amount of opportunity, it is incredible. 

And as railroads once allowed our expansion westward, aquaculture will be the vehicle that allows us to pioneer our path into 

a new economic geography. In eras past, the rallying cry was, ‘‘Go 

west, young man!’’ and it was 40 acres and a mule that allowed us 

to succeed. And today, that same rallying cry is, ‘‘Go west, young 

person!’’ It’s going to be 20 acres of marine lease and an outboard 

that is going to get us there. 

In a paper by esteemed colleague Michael Rubino and Gunner 

Knapp, they say that the biggest impediment to developing American aquaculture is the industry’s lack of social license. And an industry gains social license when the general public understands the 

benefits that it brings to the table, and for aquaculture, that is a 

13 

healthier citizenry. It is economic opportunity and a chance to 

maintain out leadership on a global stage presenting a consistent 

model for responsibly and ecologically sustainable practices. 

Seafood is an important part of our diet, as Americans, and 

should be more so. If Americans followed our own government’s 

recommendations to eat omega-rich seafood twice a week, 55,000 

lives would be saved annually from stroke and heart disease, and 

yet only 1 in 10 Americans follow these regulations. It’s not a 

stretch to say that America—a ‘‘Made in the USA’’ stamp of 

sustainably produced domestic aquaculture could inspire confidence 

and lead to increased consumption. 

Further, the average age of fishermen in this country is growing, 

and few participants are joining their ranks. A lack of jobs and 

prosperity in wild fisheries has led young people in coastal communities to look for work elsewhere. This is particularly true in 

Maine. Aquaculture could provide that missing opportunity in an 

exciting and innovative new industry, and this is already happening, beginning to happen, in Maine, where sons and daughters 

of fishermen are operating dozens of oyster, mussel, seaweed, fish 

farms. 

But I cannot stress enough how much aquaculture must coexist 

in parallel with our wild fisheries, as they will augment each other 

and ultimately raise the profile and value of each of each other’s 

products. 

And I would also like to touch briefly on the notion that about 

how investment in and growth of domestic aquaculture will affect 

our trade imbalance in seafood. I think it’s very important from a 

public health perspective that we acknowledge that access to sustainable healthy protein, healthy seafood, is imperative in America’s society. What we should be focusing on is growing increased 

consumption, going from 15 pounds per person per year to 25 

pounds, and it is within that increased consumption that America’s 

aquaculture industry should find its opportunity to provide for 

America’s table. 

A thoughtful and inclusive approach to aquaculture regulation 

will set in motion a very compelling American success story, will 

author a new chapter in our economic history, and I ask this Committee, in its wisdom, to consider regulations that are offered—that 

are oriented to and governed by regional knowledge. One size does 

not fit all. And though we need overarching regulations, please consider that there are cultures that will be commended—that will be 

purposed with executing aquaculture. And any aquaculture farm 

must be ecologically and culturally relevant to the area in which 

it is produced. 

It is my hope ultimately that my son, 16 months old, grows up 

on the coast of Maine in the—with all of the opportunity that aquaculture presents to him, amongst thriving neighbors, and with a 

dream that he, too, might nobly provide for America’s tables. 

Thank you so much for the opportunity to be here today. 

[The prepared statement of Mr. Seaver follows:] 

14 

1Mapping the global potential for marine aquaculture http://www.nature.com/articles/ 

s41559-017-0257-9 2The Political Economics of Marine Aquaculture in the United States http://www.tand 

fonline.com/doi/abs/10.1080/23308249.2015.1121202?journalCode=brfs21 

PREPARED STATEMENT OF BARTON SEAVER, DIRECTOR, SUSTAINABLE SEAFOOD AND

HEALTH INITIATIVE, CENTER FOR HEALTH AND THE GLOBAL ENVIRONMENT, 

HARVARD T. H. CHAN SCHOOL OF PUBLIC HEALTH

Good afternoon Chairman Thune, Ranking Member Nelson and all other members 

of the committee. I am honored to be here speaking on behalf of my neighbors in 

coastal communities throughout America. We have very good reason to consider the 

promising future of aquaculture. 

I began my career as a chef here in Washington, D. C. I used that platform to 

espouse a negative view of aquaculture. My opinion was based on a limited scope 

of information I gathered from environmental advocacy groups concerning the state 

of the aquaculture industry at that point in time 15 years ago. As my career progressed, I gained an understanding of the full context of aquaculture’s impact, both 

positive and negative. 

I left the restaurant industry 8 years ago and took an assignment as a National 

Geographic Explorer. My mission focused on marine ecosystems, discovering strategies to minimize human impact upon them. I came to understand that the whole 

concept of environmental sustainability hinges on thriving coastal communities. 

Certainly, the coastal way of life depends on a resilient underlying marine ecosystem to which we must be good stewards. But I believe that in aquaculture, we 

can sustainably capitalize on the positive impact marine ecosystems have on these 

communities and the wider population. 

I now live in a Maine coastal community where I am raising my son. His ability 

to thrive depends on the well-being of the entire community. As such, this topic has 

become a deeply personal issue. 

In Maine we honor the legacy of the lobster fishery that supports working waterfronts, a sophisticated cold chain system, bait suppliers, individual boat owners, and 

a strong apprentice program. We view lobstering as a noble profession, one essential 

to the state’s identity. But this genuflection to the men and women harvesting seafood is not widespread beyond Maine. 

When we as citizens envision an agricultural scene, we see amber waves of grain, 

the fruited plains, stoic white farm houses and picturesque red barns; a conjuring 

that renders farming the best possible use of fertile land. We value land for our 

presence there. But when we think of the ocean, it’s the wildness that captures our 

imaginations. We value the open sea because the hand of man is not present. I 

argue that just as we emotionally embrace farming the land, so must we embrace 

fisheries and aquaculture. 

The diesel engine pushed Americans westward to manifest destiny. But we’ve hit 

hard limitations—depleted aquifers, soil erosion, and changing weather events—to 

further increasing agriculture production on land. We need to look to the oceans for 

long-term food security. More of America sits under the ocean than above it. We 

have the longest coastline in the world and the largest exclusive economic zone. In 

a study mapping the global potential for marine aquaculture conducted by a group 

of University of California at Santa Barbara scientists concludes that in an area of 

the ocean the size of Lake Michigan that is ripe for aquaculture, we could 

sustainably farm fish equal to the amount of seafood currently caught globally in 

the wild today.1

As railroads facilitated westward expansion, aquaculture will pioneer a path into 

an ocean geography that will become Blue America. In eras past, the rally cry was 

‘‘Go west, young man!’’ And the means to settlement and prosperity was 40 acres 

and a mule. Today, that same sentiment comes in the declaration ‘‘Go wet, young 

person!’’ It will be 20 acres of marine lease and an outboard motor that will get us 

there. 

In a paper on the political economics of marine aquaculture in the United States,2

scientist Gunner Knapp, recently retired from the University of Alaska, and Michael 

Rubino, Director of the Office of Aquaculture at NOAA’s Fisheries Service, say the 

biggest impediment to developing American aquaculture today is the industry’s lack 

of social license. An industry gains social license when the general public understands the benefits it brings to the table. For aquaculture, those include a healthier 

citizenry as Americans will have better access to more seafood; economic opportunity by way of new jobs, and, a chance to maintain our leadership on the world 

15 

3 Association between Dietary Factors and Mortality from Heart Disease, Stroke, and Type 2 

Diabetes in the United States https://jamanetwork.com/journals/jama/article-abstract/2608 

221 4Scientific Report of the 2015 Dietary Guidelines Advisory Committee https://health.gov/ 

dietaryguidelines/2015-scientific-report/PDFs/Scientific-Report-of-the-2015-Dietary-GuidelinesAdvisory-Committee.pdf 

stage as a consistent model for responsible and ecologically sustainable aquaculture 

practices. 

Seafood is an important ingredient in a healthy diet. Fish—compared to cows, 

sheep, pigs and chickens—levy the least environmental impact to produce, and their 

protein is healthier for the human diet. If Americans followed our own government’s 

recommendation to eat omega-3 rich seafood just two times a week, 55,000 lives 

would be saved annually from heart disease and stroke annually.3 And yet, only 1 

in 10 Americans follow these guidelines.4 It is not a stretch to say that developing 

the United State aquaculture industry as a trusted source for seafood would lead 

to increased consumer confidence and consumption. 

This nation was founded on cod and the backs of the men and woman who fished 

them. The ocean economy spurred the economic and political freedoms we enjoy 

today and we have watched as it atrophied before our eyes. The once mighty North 

Atlantic fishery struggles mightily now. While we manage our wild fisheries well, 

the bounty is a fraction of what it once was. 

The average age of fishermen is increasing and few new participants join their 

ranks. A lack of wild fishing jobs drives young people in coastal communities to seek 

work elsewhere. Aquaculture could provide that missing opportunity in an exciting 

and innovative industry. It could offer a fishing family’s son or daughter an opportunity, a step towards to owning a small business and a chance to remain in their 

coastal community and contribute to its evolving maritime heritage. This is already 

happening in Maine where sons and daughters of fishermen operate dozens of oyster, mussel, seaweed, and fish farms. 

I cannot stress enough that for all of the opportunity aquaculture presents, it exists in parallel with our storied wild fisheries. Aquaculture is not a replacement for 

wild fisheries but an augmentation to their culture and economy that will raise the 

profile and value of all American seafood. 

I want to touch briefly on the assertion that an investment in American aquaculture will level the trade imbalance between domestic and foreign seafood. We 

should not seek to decrease imports of healthy seafood but work to increase overall 

seafood consumption to drive demand seafood raised in our own waters. As the goal 

is to get more people eating more seafood for a healthier America, we cannot vilify 

responsibly sourced seafood imported from other parts of the world. Doing so would 

diminish consumer confidence in all seafood. 

The committee holds this hearing at a unique moment because we have the opportunity to be architects of a substantial new economy. A thoughtful and inclusive approach to regulating aquaculture will set in motion a compelling American success 

story. I ask this committee to set regulations that are oriented to and governed by 

regional knowledge. While we need overarching guidelines, one size will not fit all 

as aquaculture is a product of a community and is unique to the environment in 

which it is executed. Likewise, we must move forward with the understanding that 

not all forms of aquaculture are culturally or ecologically appropriate for all places. 

Please consider giving residents of those places—especially First Nations People and 

those with a significant heritage in fishing—the chance to decide what aquaculture 

means for them and let them design regionally specific methods in pursuit of the 

seemingly inexhaustible potential of America’s Blue Economy. 

It is my hope that my son grows up surrounded by opportunity, thriving neighbors, and a dream to nobly provide food for America’s tables. Again, I thank you 

for the honor of appearing before you today. And I stand ready to answer any questions you or your staff may have now or in the future. 

The CHAIRMAN. Thank you, Mr. Seaver. 

I have to step out momentarily, so I’m going to hand the gavel 

over to Senator Blunt. 

But, Mr. Kent, Dr. Kent, good to have you here. Please, proceed. 

16 

STATEMENT OF DONALD B. KENT, PRESIDENT AND CEO, 

HUBBS-SEAWORLD RESEARCH INSTITUTE 

Mr. KENT. Thank you. My name is Don Kent, and I’m the President and CEO of Hubbs-SeaWorld Research Institute. I want to 

thank Chairman Thune, Ranking Member Nelson, and the other 

members of the Committee for this opportunity to discuss the opportunities and concerns arising from the development of marine 

farming in our Nation’s waters. 

I’ve been involved in aquaculture research for over 40 years and 

have worked on research involving the culture of a wide range of 

species, including plants, shellfish, and finfish. 

Our Institute is a nonprofit scientific research organization dedicated to advancing a healthy ocean environment to the benefit of 

both human and animal populations. As a part of this mission, we 

have developed a comprehensive aquaculture research program 

looking at the feasibility of not only restoring depleted marine 

stocks, but also developing a broader sustainable seafood production capability. 

Our Nation leads the world in the production of farm products 

except for seafood. Presently, the United States is a minor player 

in aquaculture production, but the second largest consumer of seafood. The resulting dependence on importing farmed seafood from 

other countries could be reversed by the United States using its existing regulations to demonstrate best management practices for 

seafood in the open ocean. The lack of a Federal management 

framework to grow fish in the Exclusive Economic Zone is a significant barrier to reaching this goal and presents an almost insurmountable barrier to investors that would rather invest in farms 

in other countries and import the product into our Nation. 

Our Nation has invested heavily in marine aquaculture research, 

resolving issues like fishmeal replacement, disease prevention and 

management, open ocean equipment engineering, and domesticating regionally appropriate species for culture, and our Institute 

and its collaborators have contributed significantly to setting the 

stage for offshore farming. 

The research we have conducted over the decades has not gone 

unnoticed. To demonstrate the potential for open ocean farming, 

the Institute has provided juvenile fish reared in our hatchery to 

farms off the coast of Baja California, Mexico, farms funded and operated by Americans. These farms have expanded well beyond the 

demonstration scale and are now selling the majority of their product to U.S. markets. 

For more than a decade, we have been working without success 

to permit a farm off the coast of Southern California. This one 

farm, while using less than a square kilometer of open ocean space, 

would produce five times more seafood than all the commercially 

harvested seafood in San Diego County while supporting 70 farm 

jobs as well as an additional 200 or more indirect jobs. The problem 

is not a lack of regulatory process, but, rather, the lack of Federal 

research—excuse me—the Federal leadership in managing that 

process. 

Agencies like the Army Corps of Engineers and the Environmental Protection Agency know what permits are needed and understand their authorities. The limiting factor has been a lack of 

17 

defined leadership for the required environmental review. As both 

the Corps and the EPA were disinclined to accept that responsibility, in 2014, we submitted permit applications to these agencies, 

but it took 7 months before the EPA finally agreed to lead a single 

consolidated NEPA review process in collaboration with the Corps 

and NOAA fisheries under the auspices of a multiagency MOU. 

After both the EPA and Army Corps had published their individual notices of intent in the Federal Register and had each received comments following the extended public review periods, the 

wheels came off the wagon. Eleven months after agreeing to take 

the lead, the then EPA Regional Director recanted the agreement, 

forcing two disconnected and independent reviews, and cost us 

more than a year of lost effort. 

A year later, NOAA fisheries offered to undertake the lead even 

though their agency did not need to issue a permit for the project. 

Hopefully, we are now moving forward and are trying to assure our 

understandably nervous investors that we have a viable permitting 

process to guide us. 

The need for expanding domestic aquaculture and recognizing its 

net positive environmental impact has become more prevalent over 

the past decade. Numerous studies point to marine farming as the 

most sustainable way to grow animal protein for human consumption. Marine conservation groups as diverse as the Coastal Conservation Association, the Nature Conservancy, and World Wildlife 

Fund are interested in improved technologies and best practices, 

enhancing a positive role of aquaculture in the U.S., reducing the 

Nation’s reliance on imported farmed seafood and commercially 

caught wild finfish, that are far more difficult to manage and far 

more subject to fluctuations in the ocean environment. 

Last week, the Yale School of Forestry and Environmental Studies published an article stating ‘‘if you look at best management 

practices in aquaculture, there’s nothing comparable in terms of 

land-based meat production that has such a low level of environmental impacts.’’ 

The limited scope of the U.S. marine aquaculture industry will 

not expand without access to the offshore Federal waters. Urgency 

needed is clear authority for U.S. aquaculture entrepreneurs to operate in the EEZ while complying with existing regulations and 

doing so and creating a viable, competitive business model. 

Marine aquaculture in the EEZ promotes public health, food security, and American economic interests, but only if government 

provides clear and timely legal authority for our private sector’s 

mission and removes unwarranted regulatory obstacles. We need a 

consistent, predictable, efficient permitting process to incentivize 

American investors, keeping their capital here, thereby creating a 

new paradigm for domestic seafood production toward higher food 

security, lower transport costs, more American jobs, and a larger 

tax base, and rebirth of our working waterfronts. 

Thank you very much for this opportunity. 

[The prepared statement of Mr. Kent follows:] 

18 

PREPARED STATEMENT OF DONALD B. KENT, PRESIDENT AND CEO, 

HUBBS-SEAWORLD RESEARCH INSTITUTE

My name is Donald Kent and I am the President and CEO of the Hubbs-SeaWorld 

Research Institute. I want to thank Chairman Thune, Ranking Member Nelson, and 

the other Members of the Committee for this chance to discuss opportunities and 

concerns arising from the development of marine farming in our Nation’s waters. 

I have been involved in aquaculture research for over 40 years and have worked 

on research involving the culture of a wide range of species including plants, shellfish and finfish. In addition to these brief remarks, I will append an annotated list 

of references for the Committee’s consideration. 

Our Institute is a non-profit, scientific research organization dedicated to advancing a healthy ocean environment to the benefit of both human and animal populations. As a part of this mission, we have developed a comprehensive aquaculture 

research program looking at the feasibility of not only restoring depleted marine fish 

stocks, but also developing a broader sustainable seafood production capability. 

Our nation leads the world in the production of farmed products except for seafood. Presently, the United States is a minor player in aquaculture production but 

the second largest consumer of seafood. The resulting dependence on importing 

farmed seafood from other countries could be reversed by the United States using 

its existing regulations to demonstrate best practices for farming seafood in the 

open ocean. The lack of a Federal management framework to grow fish in the Exclusive Economic Zone is a significant barrier to reaching this goal, and presents an 

almost insurmountable barrier to investors that would rather invest in farms in 

other countries and import the product into our markets. 

Our nation has invested heavily in marine aquaculture research resolving issues 

like fish meal replacement, disease prevention and management, open ocean equipment engineering and domesticating regionally appropriate species for culture, and 

our Institute and its collaborators have contributed significantly to setting the stage 

for offshore farming. The research we have conducted over the decades has not gone 

un-noticed. To demonstrate the potential for open ocean farming, we have provided 

juvenile fish reared in our hatchery to farms off the coast of Baja California, Mexico; 

farms funded and operated by Americans. These farms have expanded well beyond 

the demonstration scale and are now selling the majority of their product to U.S. 

markets. 

For more than a decade we have been working, without success, to permit a farm 

off the coast of southern California. This one farm, while using less than a square 

kilometer of open ocean surface area, would produce 5 times more seafood than all 

the commercially harvested seafood in San Diego County while supporting 70 direct 

farm jobs as well as additional 200 or more indirect jobs. The problem is not a lack 

of regulatory process, but rather the lack of Federal leadership to manage that process. 

Federal agencies, including the Army Corps of Engineers (Corps) and the Environmental Protection Agency (EPA) have relevant permitting authorities and understand those authorities. The limiting factor has been a lack of defined leadership 

for the required environmental review, as neither the Corps nor the EPA has been 

willing to accept that responsibility. In 2014 we submitted permit applications to 

these agencies, but it took seven months before the EPA finally agreed to lead a 

single, consolidated NEPA review process in collaboration with the Corps and 

NOAA Fisheries under the auspices of a multi-agency Memorandum of Understanding. After both the EPA and Corps had published their individual Notices of 

Intent in the Federal Register and had each received public and various agency comments following extended public review periods, the wheels came off the wagon. In 

March 2016, 11 months after the EPA agreed to lead the joint NEPA review, the 

Regional Director of the EPA recanted the agreement thereby bifurcating the conjoined environmental reviews into two, disconnected and independent reviews. 

A year later in the spring of 2017, NOAA Fisheries, based on their unique aquaculture and marine resources expertise, offered to undertake the lead agency role 

for the requisite NEPA review even though their agency does not have permitting 

authority for aquaculture at this time. (NOAA Fisheries is consulted by EPA and 

the Corps via their respective consultation processes.) We are hopeful that we now 

have a process to move the environmental review process forward with NOAA Fisheries leading NEPA review, and the EPA and the Corps as cooperating or participating agencies and are trying to assure our understandably nervous investors that 

this time there will be no recanting of the process. 

As the recognition over the past decade of the need for expanding domestic aquaculture has become more prevalent, far more attention is being paid to the potential 

for a net benefit to the environment that would result from farming more seafood. 

19 

1 Content compiled by Paul W. Zajicek, Executive Director of the National Aquaculture Association for its Marine Aquaculture Committee 

Numerous studies now point to marine farming as the most sustainable way to grow 

animal protein for human consumption. Marine conservation groups as diverse as 

the Coastal Conservation Association, The Nature Conservancy and the World Wildlife Fund are exploring how improved technology and best practices can enhance the 

potential positive role aquaculture could play in reducing the U.S. seafood market’s 

sole reliance on commercially caught wild finfish and imported farmed seafood products. Many studies now point to the need to turn to aquaculture to meet the growing demand for protein since terrestrial based animal production puts far more pressure on limited natural resources. Last week the Yale School of Forestry and Environmental Studies published an article in which Dr. Steve Gaines, the Dean of the 

Bren School of Environmental Science & Management at UC Santa Barbara, stated: 

‘‘If you look at best management practices in aquaculture, there’s nothing comparable 

in terms of land-based meat production that has such a low level of environmental 

impacts.’’ 

The limited scope and size of today’s U.S. marine aquaculture industry simply 

cannot substantially expand without access to the offshore waters controlled by the 

Federal Government, the Exclusive Economic Zone (EEZ). However, access alone is 

not sufficient, and will not create the fertile environment for private investment in 

U.S. marine aquaculture. What is urgently needed is clear legal authority for U.S. 

aquaculture entrepreneurs to operate in the EEZ in compliance with existing regulatory programs toward implementation of viable business models that will prosper 

in the highly competitive global seafood marketplace. 

Offshore marine aquaculture in the EEZ holds tremendous potential for advancing the public health, food security and economic interests of Americans, but those 

interests can only be served if government provides the legal authority for the private sector to fulfill that mission without unwarranted regulatory obstacles. We 

need to establish a consistent, predictable and efficient permitting process that will 

incentivize American investors into keeping their investment capital in this country 

to create a new paradigm for domestic seafood production thereby leading to higher 

food security, lower transportation costs to our seafood supply chain, more American 

jobs, a larger tax base and greater utilization of our working waterfronts. 

Additional Comments and References1 to Augment the Testimony Presented by Donald Kent to the Commerce, Science and Transportation 

Committee of the United States Senate’s hearing on Growing the Future: 

Opportunities to Support Domestic Seafood through Aquaculture. 

Over the last 20 years, responsible environmental stewardship has become the 

proven business model in the states or territorial waters of Maine, Washington, Hawaii and Puerto Rico where commercial scale net pens have been operated to farm 

Atlantic salmon, Almaco jack or cobia. Additionally, shellfish farming is expanding 

in Alabama, Alaska, California, Connecticut, Florida, Hawaii, Louisiana, Maine, 

New Hampshire, New Jersey, New York, Maryland, Massachusetts, North Carolina, 

Oregon, Rhode Island, Virginia, South Carolina and Washington, growing abalone, 

clams, oysters, geoduck, mussels or scallops. These farms have been managed in 

compliance with state and Federal regulations with Best Management Practices, 

along with the provisions of long-term lease agreements with the states or territory. 

All such operations are conducted with regulatory transparency supported by environmental monitoring data and periodic reporting for these operations in publicly 

available documentation required by state and Federal agencies. 

It is abundantly clear: the limited scope and size of today’s U.S. marine aquaculture industry simply will not substantially expand without access to the majority 

of offshore waters that are controlled by the Federal Government. Large-scale marine aquaculture production in the United States would create the ability to: 

• Close a significant gap in U.S. food security (availability) through the farming 

of seafood products in U.S. waters rather than relying as the United States currently does on foreign seafood sources for 90 percent of the seafood consumed 

by our citizens. 

• Create ancillary equipment and service businesses and new jobs within coastal 

and inland communities. 

• Accelerate technological development to reduce production costs and minimize 

adverse environmental effects. 

• Maintain working waterfronts and build upon the existing and unique knowledge, skills and abilities possessed by commercial fishers. 

20 

2 Rubino, Michael (ed). 2008. Offshore Aquaculture in the United States: Economic Considerations, Implications & Opportunities. U.S. Department of Commerce; Silver Spring, MD; USA. 

NOAA Technical Memorandum NMFS F/SPO–103 3 Nash, C.E. 2004. Achieving Policy Objectives to Increase the Value of the Seafood Industry 

in the United States: The Technical Feasibility and Associated Constraints. Food Policy 29:621– 

641. 4Knapp, G. and M.C. Rubino. 2016. The political economics of marine aquaculture in the 

United States. Reviews in Fisheries Science and Aquaculture 24(3): 213–229. 5Goldburg, R. and T. Triplett. 1997. Murky Waters: Environmental Effects of Aquaculture in 

the United States. Environmental Defense Fund, New York NY 

• Preserve rural and coastal communities by providing economic development and 

diversification opportunities and jobs consistent with community desires for a 

sustainable future. 

While these potential outcomes are well-documented,2 we have yet to make any 

significant advances in U.S. marine aquaculture production in the 37 years since 

passage of the National Aquaculture Act of 1980. Currently marine farming production is approximately 45,500 tons valued at $327 million and supplies about 3 percent of U.S. seafood consumption. Federally managed waters beyond coastal state 

boundaries, termed the Exclusive Economic Zone, encompass 4.4 million square 

miles (11.3 million square kilometers). A U.S. study estimated that 195 square miles 

(500 sq. km) of ocean, managed under existing regulations, could produce 1.3 billion 

pounds (600,000 metric tons) or more of high quality seafood.3 Theoretically, the 

farming of 970 sq. miles (2,500 sq. km), an area representing .0002 percent of the 

Exclusive Economic Zone, less than half the size of Delaware, would double U.S. edible seafood production or an area the size of the Pentagon could produce 220 million 

pounds (100,000 MT). A doubling of U.S. aquaculture production to about 1 million 

tons could create an estimated additional 50,000 farm and non-farm jobs.4

Over the last 20 years, rather than acknowledging the many advances in marine 

aquaculture production practices and successful management strategies for adverse 

environmental impacts, the environmental community continues to restate a variety 

of potential adverse environmental effects of aquaculture based on outdated production methods and standards.5 We note the U.S. Environmental Protection Agency 

has held authority under the Clean Water Act to regulate discharges from fish 

farms for decades. During a four-year period, 2000–04, the agency completed a detailed technical review of its standards and modern aquaculture methods, including 

those used for marine aquaculture. The Clean Water Act regulations for aquaculture 

met all standards of environmental protection mandated by Congress and additional 

regulatory standards were found to be unwarranted. Current regulatory authority 

exists to appropriately protect marine water quality and benthic environmental systems, manage fish escapes, and require responsible drug and chemical use. Basic 

and applied research supported by governmental agencies and the private sector has 

led to continuing improvements in reducing the use of essential fish meal and fish 

oil components in pelleted aquaculture feeds. 

Over the last 20 years, responsible environmental stewardship has become the 

proven business model in the states or territorial waters of Maine, Washington, Hawaii and Puerto Rico where commercial scale net pens have been operated to farm 

Atlantic salmon, Almaco jack or cobia. Additionally, shellfish farming is expanding 

in Alabama, Alaska, California, Connecticut, Florida, Hawaii, Louisiana, Maine, 

New Hampshire, New Jersey, New York, Maryland, Massachusetts, North Carolina, 

Oregon, Rhode Island, Virginia, South Carolina and Washington growing abalone, 

clams, oysters, geoduck, mussels or scallops. These farms have been managed in 

compliance with state and Federal regulations with Best Management Practices, 

along with the provisions of long-term lease agreements with the states or territory. 

All such operations are conducted with regulatory transparency supported by environmental monitoring data and periodic reporting for these operations in publicly 

available documentation required by state and Federal agencies. 

The inherent sustainability of aquaculture production as practiced in the United 

States is recognized by marine education organizations, academic institutions and 

national agricultural and aquaculture organizations as vividly described in recent 

videos: 

• Aquarium of the Pacific, Perspectives on Marine Aquaculture in California and 

the U.S.: https://vimeo.com/211721422 and Marine Aquaculture: a tool for conservation: https://www.youtube.com/watch?v=ygoU5knT7ww. 

• University of Miami, The Business of Aquaculture: https://www.youtube.com/ 

watch?v=2vduoM7hYKA. 

21 

• University of Maine, Farming the Sea: https://science360.gov/obj/video/ 

ae3d54f0-eb7e-4b0d-9db8-379be48f7b04/farming-sea 

• Soy Aquaculture Alliance, The Working Waterfront—American Aquaculture in 

the 21st Century: https://www.youtube.com/watch?v=aGgtS4v9WBM. 

Senator NELSON. May I just ask, Mr. Kent, are you headquartered at Melbourne Beach? 

Mr. KENT. Our—we have our laboratory—one of our laboratories 

at Melbourne Beach and another laboratory in San Diego. So we 

operate on both coasts of the United States. 

Senator BLUNT [presiding]. I thank all of you for your testimony. 

We will start our 5-minute round of questions. 

And, Senator Klobuchar, if you want to start that, that will be 

great. 

STATEMENT OF HON. AMY KLOBUCHAR, 

U.S. SENATOR FROM MINNESOTA 

Senator KLOBUCHAR. Thank you, Senator Blunt, you and the 

Chairman, and Senator Nelson. 

Minnesota is into fishing, as you probably know. We’re the land 

of 10,000 lakes. One of our TV stations for the Super Bowl that’s 

going to come to Minnesota has actually installed an ice fishing 

hole on the roof, and people are going up there and ice fishing in 

5 degree weather. 

So my question is about aquaculture, though, because we also 

have some exciting developments there. Cargill Aqua Nutrition is 

a leader in supplying sustainable nutrition solutions for aquaculture farmers. But we also have a company called Tru Shrimp 

that is currently developing some jobs in southwestern Minnesota. 

I actually just visited them this past summer, and they’re going to 

break ground on a $50 million facility that will produce 9 million 

pounds of shrimp annually right near the South Dakota border actually, and this is in Luverne, Minnesota. 

And, Mr. Lucas, can you talk about the role of a reliable water 

source? Dr. Lucas, I’m sorry, could you please describe that? Because one of the reasons they could locate down there is we’ve got 

this Lewis and Clark water project going with the Federal Government, South Dakota, Minnesota, and Iowa. 

Dr. LUCAS. Yes, thank you. So our center also employs recirculating aquaculture technology. And the great thing about these 

land-based recirculating systems is they can locate pretty much 

anywhere. And the use of the recirculating systems to salt the 

water artificially, and you flow the water through the systems. So 

you’re able to mechanically filter and biologically filter as well as 

sterilize the water so that you can reuse it. So it makes the use 

of water very efficient. And so they’re able to produce. And so the 

great thing is you can be really close to your market supply. And 

these facilities can locate anywhere and be part of the chain and 

help provide local, safe, sustainable seafood to their consumers. 

Senator KLOBUCHAR. Right, exactly. And do you see, Dr. Lucas, 

maybe Mr. Kent, just what are some of the obstacles—water is one 

of them—if you’re in a location like our company is, but we fixed 

that, other obstacles to going forward with this? 

Dr. LUCAS. Yes, ma’am. I think, like I said, the ability to be able 

to use the artificial seawater is great. I think the other thing is 

22 

consumer education, making sure people know that there is a domestically produced seafood product, that it’s local, that it came 

from their environment, that it helped create jobs in their environment. So I think education is also critical to getting people to understand that this is helping support their local working population 

as well as provide them with some sustainable seafood product that 

is very healthy. 

So in terms of land use, being able to do something similar, 

which is on a recirculating basis, or using the same water and 

using it, you know, even if you discharge water to grow plants or 

something like that, is very beneficial. 

Senator KLOBUCHAR. Thank you. 

Do you want to add anything, Mr. Kent? 

Mr. KENT. Well, certainly. I think there’s a wide range of technologies that can be brought to bear in developing aquaculture. We 

use recirculation in our hatchery operations. And, as Dr. Lucas 

suggested, being close to market is critical in producing the product 

right now. Importing so much of our seafood means that there’s a 

huge cost in bringing that product in. 

Senator KLOBUCHAR. Exactly. 

Mr. KENT. At the same time, if we have recirculation going on 

in some areas, we can also have open ocean farming going. We 

have 37 million people in California, quite a few people in Florida. 

In fact, 70 percent of the world’s population lives within the coastal 

zone around the world. So being able to utilize the ocean in combination recirculating technology means that we can get product 

closer to market, cutting the cost of producing that as well as reducing the energy requirements in transporting that product 

around the world. 

Senator KLOBUCHAR. Thank you. I mentioned Cargill Aqua Nutrition with aqua feed, but, Mr. Luecke, we also will see some big 

benefit for grain farmers. What types of benefits would they potentially see from further development of the inland aquaculture? I 

keep emphasizing ‘‘inland,’’ because of where my state is, like Missouri. Yes. 

Mr. LUECKE. Yes, no, thank you, Senator Klobuchar. And consistent with what Dr. Lucas and Mr. Kent were saying, I think 

transportation is an important topic, and we’re excited to be about 

60 miles to the west of Tru Shrimp in Minnesota, so we’re very excited about the project that they have. We hope to be providing 

feed to them at some point. 

And so regarding transportation, being able—in Minnesota, the 

State of Minnesota produces a lot of soybeans as well. So being 

able to take soybeans out of our farmers’ fields, process them locally, and then quickly move them into a value-added product like 

a fish or a shrimp is absolutely critical because we’re reducing 

transportation costs all the way through the value chain. 

Senator KLOBUCHAR. Exactly. And is soybeans something like 45 

percent of shrimps’ diet, is that right? 

Mr. KENT. It’s close to 45 percent. 

Senator KLOBUCHAR. Yes. 

Mr. KENT. And, you know, interestingly, what the other panelists 

have talked about is the use of forage fish or fishmeal as the primary protein source. And what our process has done is we’ve taken 

23 

soybean meal and taken the allergenic proteins and the allergenic 

sugars out of soybean meal, increased the protein level to 70 percent, which is what shrimp and fish want nutritionally. So having 

a technology that comes out of a land-grant university being commercialized, scaled up, and then being applied to companies like 

Tru Shrimp is a great opportunity for agriculture and for aquaculture. 

Senator KLOBUCHAR. Mm-hmm. And with the low commodity 

prices right now, I think it would just be really helpful for soybeans 

and really all grains if this could move forward. 

Mr. KENT. It’s adding value to the crops coming out of the farmer’s field. 

Senator KLOBUCHAR. OK. Well, thank you. Well, maybe I’ll see 

you there next time I visit. 

Mr. KENT. I look forward to it. 

Senator KLOBUCHAR. Thank you. 

STATEMENT OF HON. ROY BLUNT, 

U.S. SENATOR FROM MISSOURI 

Senator BLUNT. Thank you, Senator Klobuchar. I was wondering 

how long it would take Senator Klobuchar to mention the Super 

Bowl. 

[Laughter.] 

Senator KLOBUCHAR. Ah, well, we keep mentioning that even 

though the Vikings aren’t in it, and we are now going to be hosts 

to the Philadelphia fans. Not too easy for us after that game. 

Senator BLUNT. There you go. It took 11 seconds, by the way. 

[Laughter.] 

Senator BLUNT. And not bad time on task, 11 seconds to get 

there. 

On this topic, with what’s going to happen with world food demand, the incredible change in what it’s going to take to feed people over the next 25 or 30 years, I think the generally accepted estimate is that world food demand doubles between now and 2050, 

on the topic of just hatching to table, I think aquaculture either recirculating or on the coast, is about as quick as anything, but a little more information on that would be helpful. How quick does this 

process move along with the kind of product that Mr. Seaver and 

others who are preparing that product would want to have, that 

families would want to have? This is a pretty efficient process, I 

think. 

Mr. Kent, do you want to start talking about that a little bit? 

Mr. KENT. Certainly. The estimate is something like 400 to 500 

million metric tons of protein more required than what we have 

now. 

Senator BLUNT. Mm-hmm. And this is 33 years from now. 

Mr. KENT. Yes. 

Senator BLUNT. Growing every year between now and then. 

Mr. KENT. What’s been interesting is back in the eighties, about 

a third of our protein was coming from the ocean globally, but only 

a small percentage of that was aquaculture. Now it’s still about 30 

percent, but it’s half and half. And if we try to get the makeup of 

the protein, that difference, that, say, 300 more million metric tons, 

the effect on the terrestrial side of things is going to be dramatic. 

24 

Beef, cattle, chicken: I mean, these are all important protein 

sources, but they’re far more requiring of resources to grow, water. 

I live in the largest agricultural state in the Nation, we do $45 billion a year, and 80 percent of our water goes to food production. 

And when we have a drought like we had over the last few years, 

we lose 10 percent of our productivity. So having the ocean available, or recirculation, means that we become independent of what’s 

going on in the terrestrial environment. 

Also, these animals are inherently more efficient. The food conversion efficiency for a white sea bass or a yellowtail, some of the 

species we work with, is about 1.5:1. The protein gets converted 

much more efficiently from the food source into making protein. 

The primary reason for that is these animals aren’t fighting gravity, they are floating in the environment, they are cold-blooded, so 

they’re not maintaining body temperature. And also, as far as 

space goes, you can stack them in a cage the way you can’t stack 

cows. So it is a much more efficient process. And utilizing the ocean 

means that we’re not—we don’t have to have the land or the fresh 

water to grow some of these species. 

Senator BLUNT. And I don’t think I have an answer. Give me an 

example of one or more of the species you like to work with. 

Mr. KENT. Key species we like to work with is California 

yellowtail. It’s imported for the sushi trade, for hamachi. All the 

hamachi in the U.S. is farmed in Japan. 

Senator BLUNT. And you start with a hatchling? 

Mr. KENT. We start with adult fish weighing 30, 40 pounds. We 

get eggs that are about a tenth of a millimeter—or, excuse me, a 

tenth of an inch in diameter. We will harvest about 120,000 1-gram 

fish out of an 8-foot pool after 60 days. Those fish will weigh 30 

grams in another 30 days, and they’ll grow to a marketable size of 

4 to 5 kilos in 18 to 20 months, depending on ocean temperature. 

So that may not compare to how fast you can grow a cow, but it 

required a lot less food to get you there. 

Senator BLUNT. Mm-hmm. And on the non-saltwater species, the 

catfish, the tilapia, how do those numbers compare, Dr. Lucas? 

Dr. LUCAS. I am marine species by trade, so I can’t really speak 

to the freshwater species and information. 

Senator BLUNT. Mm-hmm. Can you, Mr. Luecke? 

Mr. LUECKE. Yes, Senator Blunt. They’re faster than marine species. They grow to a smaller size, you know, so 4 to 5 pounds, typically 6, 8 months, you know, for a medium-size trout or slightly 

faster for tilapia. 

Senator BLUNT. Six to 8 months? 

Mr. LUECKE. Mm-hmm. 

Senator BLUNT. Mm-hmm. 

Mr. LUECKE. And I think, you know, one of the important things 

to think about when you think about both the water supply and the 

sustainability of, you know, the nutritional process, we’re looking 

at, as Mr. Kent mentioned, the entire nutritional value chain. So 

how efficient are we converting one protein to another? 

So we look at the digestibility of the ingredients. So we want to 

make sure that the ingredients that we’re feeding to any type of 

fish, whether it’s freshwater or marine species, are very digestible. 

So we look at how digestible the protein that we’re feeding them 

25 

is. For example, fishmeal, which is a less sustainable ingredient, is 

about 85 to 90 percent digestible. Our soy product is 100 percent 

digestible. And what that means is that the animal is using that 

ingredient much more efficiently. 

And then back to Mr. Kent’s comments, that animal, the fish, 

can actually convert that into a fish filet on a 1:1 for 1.5:1 basis. 

So it’s a very efficient process when you look at the digestibility of 

the ingredient. 

Now, one other factor with the digestibility of ingredients is that 

you get a much cleaner water if the ingredient is digested. For example, the phosphorus in soybean meal or in fishmeal is—without 

other processing, is not fully digested by the animal. So when 

you’re feeding fishmeal, about 50 percent of the phosphorus goes 

into the surrounding environment. When you feed an advanced soy 

protein, 100 percent of the phosphorus is being digested, so you’re 

not discharging that into the environment. So the digestibility of 

nutrients is absolutely critical to the growth of the fish. 

Senator BLUNT. And, Mr. Seaver, how about just generally the 

digestibility of the fish? I mean, how would fish, as we’re thinking 

about this, as a protein source both mix in with the other protein 

sources available to you, as an entrepreneur and to people who are 

consuming, and what advantage do you get when that fish is close 

rather than further away? 

Mr. SEAVER. Well, there are a number—thank you for the question. There are a number of benefits, physically speaking, from the 

public health side. Diversity in our diet is not what it should be 

in terms of our protein consumption, and beginning to not necessarily reduce—well, there’s an opportunity really to radically increase the amount of seafood that we consume, and I think that especially when it comes to the local opportunities, as Senator 

Klobuchar was speaking to, there is really a lot of opportunity to 

create a narrative around seafood, that this is produced locally, this 

is shrimp from Minnesota, gets attention on a menu, it gets that 

menu item to sing, it gets it onto the table. And so there are the 

efficiencies there that Mr. Kent spoke to about in terms of the energy efficiencies. 

But then also we’ve been speaking largely around finfish, but 

there is also the opportunity to look at marine shellfish production, 

and especially when we speak to oysters, clams, mussels, scallops— 

no offense to the soybean farmers of America—but those things 

feed themselves completely, and while I very much support all 

these efforts as well, I think we need to be looking at the farming 

of shellfish varieties as truly just a magnificent opportunity as 

they, in fact, improve the quality of water in which they are grown. 

And they also are—while we are speaking here about large-scale 

opportunities and large-scale investment that’s needed to go offshore, when you’re speaking about nearshore and inshore aquaculture, we’re also sort of inherently speaking about the primacy of 

the small farmer owner/operator and the great narrative that is 

there, the job creation that is there. And so when we talk about 

a mussel that can be seeded, attached to a rope, put out into the 

environment, it feeds itself, and in 12 to 18 months be ready for 

the table, this is a commendable opportunity and something I think 

that we should be really supporting full-fledged. 

26 

Senator BLUNT. And I think there is some concern. I don’t know 

who on the panel might be in a position to talk about this, but 

some concern about seafood that is farmed rather than wild caught 

and where it was and how it was grown. And I think there would 

be reasons that Americans would like to think that that seafood 

had come from a place, or fish of any kind, come from a place that 

they had a greater sense of supervision and regulation. We occasionally hear on fish issues that, well, a lot of people got a product 

that didn’t turn out to be a very good product. What would be the 

benefits of more U.S.-grown seafood? 

Mr. Kent? 

Mr. KENT. Well, living within the regulatory framework for how 

all of our food is produced, meets a very high standard. When 

you’re importing so much of your seafood from somewhere else, 

how do you know how it was grown? I’m not suggesting that it 

wasn’t grown properly, I’m just saying it’s very hard to know 

whether it has been or not. And even sometimes the origin gets 

confused. Even the species of what you’re consuming can be confused. But if it’s coming from a farm in your backyard through recirculation, or out in the ocean and coming back into the dock, and 

you’re permitted to grow a given species in a certain way following 

USDA and FDA standards, then you have a lot more reliability on 

the idea that, well, that fish was grown according to the way we 

want it grown. And there are even ways to put traceability into it, 

where you can actually go into the market and put a little code 

that’s called the Q—— 

Mr. SEAVER. QR codes. 

Mr. KENT.—QR code and flash and know when that fish was 

spawned or when the hatch occurred and when it was harvested 

and when it went on ice and when it went into the store. That can 

all be done by the consumer now, which is very difficult to do if 

you’re unloading a freighter full of frozen fish coming from Taiwan, 

but it’s something we can do very readily in our own farming capabilities here in this country. 

Senator BLUNT. And one last question from me for I think Dr. 

Lucas and Mr. Kent. What could the Congress do to help create the 

kind of access that you need to the coast or anything we can do 

to eliminate obstacles you’re finding in aquaculture generally? But 

I think particularly the Federal issue here may be a coastal issue. 

And, Dr. Lucas, why don’t you start, and then Mr. Kent, and 

then we’ll go to Senator Fischer. 

Dr. LUCAS. We have to look at ways to reduce the barriers to 

entry. Businesses need certainty. The permitting is going to be key. 

They need a defined permitting process. They need to know the 

backbone or structure of the permitting that can occur, and that 

can be regionalized in some aspects, but they need to know that 

one agency is in charge. They don’t need to run around to five different agencies who nobody takes ownership. They need somebody 

to have ownership, and they need to get that through designating 

an agency. 

They need to also know that their lease or that their permit is 

going to be of a long enough duration that they can not only capitalize those expenses that went into getting the operation up and 

running, but that they can also see a return on investment and a 

27 

profit. And if they’re good actors, and trust me, they want to be 

good actors. They want to follow all the rules and all the regulations, and they want others that are in the industry to follow those 

regulations, so they’re looking for that level of enforcement. But, 

they want to know if they follow those rules and those regulations, 

that they are going to be able to get a renewed permit, that it’s almost pretty much certain. They want those level of certainties to 

help reduce the risk. 

In addition to that, we need to continue to work with academics 

and governments to decrease some of the things that are barriers 

in terms of production. Businesses often come to us in regards to 

larval culture or hatchery techniques, helping to reduce some of the 

uncertainty there and reduce the bottlenecks that occur in the 

hatchery. They need a safe, disease-free larval fish. Some companies will put that into their vertical integration, they may put the 

hatchery as part of their plan. Others may just purchase from a 

hatchery. 

The other things they come to us about is in regard to selective 

breeding. Universities tend to have access to a lot of equipment in 

terms of being able to look at the genes of fish and help determine 

which fish are going to be more successful in aquaculture. And so 

using those tools as well as disease management, those are things 

that industry often comes to a university to help them with and to 

overcome those barriers as well as continuing to expand the nutrition and look at reducing our reliance on the reduction fishery for 

products. And, of course, advanced technology, which I think will 

continue, continue to grow. 

Senator BLUNT. OK. Mr. Kent, Federal obstacles that we can do 

something about. 

Mr. KENT. Well, wearing my—I’m trying to get a permit hat 

right now, I’d say that the biggest thing that we need is a process 

that’s defined. And as I mentioned, I don’t think it’s really the legal 

permits that are required, the Section 10 or the NPDS permit that 

are a limitation, because the agencies in charge of those understand what their authorities are. 

It’s really the NEPA, the National Environmental Protection Act, 

certification that needs to be done. That needs to be led by an organization, a Federal agency, that has the broad scope of understanding of environmental concerns that people have and how to 

mitigate or eliminate those. And in my mind, that has to be the 

NOAA fisheries. 

NOAA has the—when you talk about habitat, interference with 

other fishing operations, endangered species, these are all consultations that have to be performed with NOAA anyway, so why not 

put them in the authority? They have not only the research, but 

the regulatory experience, to deal with these issues. And if there 

is something that the legislature could do, it might be to mandate 

that through legislation to bring forward a law that said NOAA is 

the lead agency. 

From putting on my researcher hat, the first thing we need is an 

industry. Dr. Lucas’ team, our team, we’re ready to solve problems, 

but we need an industry that needs these problems solved, and 

until we have more aquaculture, we can be working on new diets, 

we can work on species that need to be domesticated, and we can 

28 

work on disease treatments, but until we’re actually going to have 

an industry that uses it, we’re kind of just spending your money 

and not really getting us any return on the investment. So we need 

to start an industry that then the scientific community can rally 

behind and help support in cooperation with the agencies, the 

USDA, NOAA, all the different organizations that recognize needs, 

and science can come and help solve the problems. 

Senator BLUNT. Well, Senator Klobuchar, Senator Thune, and I 

are pretty interested in that industry being also inland and close 

to those consumers, but I think this is an important part of the solution we need for the opportunity and the challenge we’re about 

to face. And I want to thank you for your time today. 

Senator Thune. 

The CHAIRMAN [presiding]. Thank you. Thank you, Senator 

Blunt. And again thanks to our panel, and I appreciate very much 

you being here and sharing your thoughts about what we can do 

to do a better job of growing this economy, growing this business, 

in our country. 

And thank you, Senator Klobuchar, having worked to authorize 

the Lewis and Clark Rural Water Program during my time in the 

House of Representatives, a long history of supporting this important project. And Tru Shrimp’s story shows what’s possible when 

this country has a solid infrastructure backbone. So it’s quite a testament to American hard work and ingenuity, when ‘‘Minnesotagrown’’ includes shrimp, right? 

[Laughter.] 

The CHAIRMAN. Well, we’ve got the Vikings, we’ve got to have 

shrimp, so . . . 

[Laughter.] 

The CHAIRMAN. Sorry. I know, I brought it up. That’s—— 

Senator KLOBUCHAR. We already talked about it. 

The CHAIRMAN. Yes. 

[Laughter.] 

Senator BLUNT. It took Senator Klobuchar 11 seconds to mention 

the Super Bowl. It took you 23 seconds. 

The CHAIRMAN. Oh, did she really get into it? 

[Laughter.] 

Senator KLOBUCHAR. Yes, but Senator Thune does have the Corn 

Palace. 

[Laughter.] 

The CHAIRMAN. Ooh, careful, easy. 

[Laughter.] 

The CHAIRMAN. It’s our pride and joy. 

So, Mr. Luecke, as you well know, and I know you talked about 

this, South Dakota soy is some of the best in the world, and it’s 

used in many products. Some may be surprised to hear that the socalled square states, like ours, have an important role to play in 

fish farming. So could you kind of just tell us how your new commercial-scale facility impacts the local economy in South Dakota? 

Mr. LUECKE. Absolutely. Thank you, Senator Thune. And the 

square states do have an important role to play in aquaculture because right now for aquaculture producers that are trying to get 

started in the United States, the high-quality feed ingredients that 

they depend on, they’re coming from foreign countries like Peru 

29 

and Chili and even Southeast Asia. The forage fish that we’ve 

talked about are what is used in the diets of aquaculture species, 

and that transportation cost to get the high-quality feed ingredients into the United States for aquaculture production is cost prohibitive. And so producers are losing a significant amount of money 

to their bottom line. 

And so what we’re doing with our process and, again, our process 

is taking soybean meal, which is a co-product of soy processing, we 

get soy oil and we get soybean meal, and we’re taking some of the 

things that fish don’t like to eat—the allergenic proteins, the allergenic sugars—we’re taking that out of the soybean meal and really 

making it look like, from a protein ingredient standpoint, the very 

feed ingredient that aquaculture producers are accustomed to feeding the forage fish. It’s a 70 percent protein, very highly digestible. 

So once we can bring that high-quality feed ingredient domestically, we can provide that from the heartland, then we should be 

able to grow more aquaculture facilities because we’re not depending on importing the very feed ingredients that we’re dependent on 

to start this industry. 

So we feel like we’ve got an important role to play. We feel like 

soy has a very important role to play. It’s a sustainable product. 

It has a high amino acid digestibility. And it’s good for the environment, it’s not discharging phosphorus into, whether it’s a recirculating system or a marine environment. So we do, we feel like 

we’ve got a very important role to play. 

The CHAIRMAN. So what would be the economic impact on soygrowing states if the United States were to embrace domestic aquaculture? 

Mr. KENT. Well, it’s significant, Senator Thune, because the— 

right now, you know, we’re feeding a lot of soybean meal to livestock, and as we’ve talked about on the panel, the feed conversion 

ratio of that is—it’s not as efficient as aquaculture. So for a soybean farmer that’s looking for higher value uses of its soybean 

meal, aquaculture is a perfect example. Today, soybean meal trades 

for about $300 a ton whereas fishmeal trades for between $1,500 

and $1,600 per ton. So there’s a significant spread between those 

two high-quality ingredients, and it’s something that our soybean 

farmers can actually take advantage of the marketplace. 

Now, you know as well as I do, when the farmers do well in the 

fields, they’re spending that money locally, and so not only do family farm incomes increase because we found higher value uses of 

a commodity, but the rural communities around them, just like the 

coastal communities, when aquaculture thrives in a marine environment, those rural communities thrive because the farmers are 

buying new pickup trucks, they’re spending money at their local 

grocers, and that money gets recirculated in rural economies. 

And so, again, it’s a very high impact, and it’s not just the farmer 

that’s seeing the impact, it’s really the rural communities around 

them. 

The CHAIRMAN. The critics of aquaculture point to the use of 

fishmeal as feed to suggest that aquaculture is a zero-sum game. 

In other words, by increasing aquaculture, you’re decreasing the 

amount of wild-caught fish available. How does using soy-based 

feed change the impact of aquaculture on our wild-caught fisheries? 

30 

Mr. LUECKE. And that’s one of the biggest problems that we’re 

trying to solve, Senator Thune. And, again, I think everybody on 

the panel can agree that nutrition is a key element. And so you 

want to make sure that you have high-quality ingredients that are 

going into aquaculture production and you have a very efficient 

process. We’ve shown that we can use soy to replace or extend the 

use of fishmeal in diets up to 100 percent. So, again, not only are 

you not in that zero-sum game of fish in and fish out, which is 

what the industry uses, but the retail channel is also looking very 

closely about the traceability of the ingredients that are going into 

fish production. 

So, for example, the retail channel wants to know that because 

a fish is almost a 1:1 basis for what it’s eating to what is being produced on the shelf, they want to know where the ingredients came 

from, and when you can trace that back to the farm, which we can 

do, they get much more comfortable in the product that they’re putting out onto the shelf. 

And the other thing that we mentioned previously on the panel 

is the fact that when you’re feeding forage fish, not only is it a 

zero-sum game, but there are also a lot of things in forage fish, like 

phosphorus, that’s not being completely digested by the animal. So 

one of the things that we have to be very careful of, as stewards 

of our environment, we have to be very careful about the nutrients 

that are fed and not digested. And so with forage fish, 50 percent 

of the phosphorus is not being used by the animal, it’s being discharged into the environment, and that’s harmful. So soy helps all 

of those things and really gives us a step up. It creates a much, 

much cleaner image for aquaculture. 

The CHAIRMAN. Dr. Lucas, the regulatory barriers to offshore 

aquaculture in the United States seem to be a textbook example of 

how regulatory burdens can stifle economic innovation. Could you 

talk a little bit more about the barriers to a healthy aquaculture 

industry in the United States and any suggestions that you might 

have to alleviate those? 

Dr. LUCAS. Yes. So we discussed a little bit earlier about trying 

to make sure we have regulatory certainty, that somebody takes 

ownership of kind of the permit process. I think that’s something 

that this—that Congress could do through legislation, designating 

that person who is going to take ownership of it, work through the 

NEPA process, work through the environmental process. I think 

that’s going to be critical to helping industry move forward. They 

want some certainty that at the end of all the money and all the 

hard work that they put into finding a site, that they are going to 

be able to get a permit and that the permit and the lease duration 

is going to be long enough to not only see a return on their investment, but to also see them be able to profit from their investment. 

They also want to be good actors and want to have the enforcement element piece. They want to know that if they follow all the 

rules and regulations and the monitoring requirements, that they 

will have reasonable certainty that they can renew that permit 

that they’ve been working on. And I think those will be critical 

moving forward for industry. In addition, working with industry 

and developing industry, we are developing an industry, and what 

it looks like on day one will be a lot different than what it looks 

31 

like at year 10 or year 20 and the advancements that we make. 

And some of those things are through research. 

I think Congress and legislation and appropriations that are on 

the scale of what we did with the agricultural industry is critical. 

We used the agricultural industry and we used academia and Federal and State labs to do the research and then do the extension, 

you know, across the Nation to help farmers grow. I think the 

same thing can be done in aquaculture. You can use the same kind 

of pattern of competitive-based research and extension funding and 

those long-term fundings to actually get that technology out to the 

industry and to work with industry. 

I think public-private partnerships will be critical to helping the 

industry advance. And I think that funding along those lines for 

things that are the barriers in terms of being able to do marine 

species offshore will be critical to industry developing. 

The CHAIRMAN. Thank you. 

Senator Hassan. 

STATEMENT OF HON. MAGGIE HASSAN, 

U.S. SENATOR FROM NEW HAMPSHIRE 

Senator HASSAN. Thank you, Mr. Chair. 

And good morning to the panel. Thank you all for being here. 

Aquaculture has brought my State of New Hampshire a new support system to the local seafood industry. In New Hampshire, our 

Sea Grant Program and the University of New Hampshire have 

been working with the Portsmouth Commercial Fishermen’s Association to farm steelhead trout, mussels, and sugar kelp in floating 

pens on the Piscataqua River, and it has been a terrific partnership 

between the state’s Sea Grant Program and the university. It has 

allowed both teams of experts to help train local fishermen in the 

basics of aquaculture, which include feeding, maintenance, harvesting, and packaging the products for sale. 

So my question is to you, Mr. Kent. How else can aquaculture 

be integrated with the existing harvesting and processing sectors 

of the fishing industry? And do you believe fishermen can transfer 

their existing skills to other sectors in the aquaculture industry? 

Mr. KENT. Certainly. I’ve been approached by commercial fishermen that have—are third- and fourth-generation fishermen, and 

they’re going—like my dad fished, I fish, but son is not going to be 

able to do this. 

Senator HASSAN. Right. 

Mr. KENT. And they’re looking at, as Mr. Seaver was talking 

about earlier, this idea that we have a culture of being on the sea 

and providing product and bringing it back to the dock. The big difference is you’re not going to go out and have to find it, it’s sitting 

right there, you know, at the farm—— 

Senator HASSAN. Right. 

Mr. KENT.—and you can harvest it on demand. 

And the other important factor is the idea that for every job in 

the fishing boat or on the farm, there are two, two and one-half 

jobs downstream to keep that industry going: the processing of the 

fish, the distribution, the maintenance of the boats, the nets, and 

everything else. So it really increases the profitability of the working waterfront. And, you know, I’m from San Diego, we were the 

32 

tuna capital of the world, and now our waterfront is made up of 

Hyatt Regency Hotels and maritime museums. 

Senator HASSAN. Right. 

Mr. KENT. Our working waterfront has been reduced down to 

very small areas that there’s heavy competition for putting luxury 

yachts in there instead of fishing boats. 

Senator HASSAN. Right. 

Mr. KENT. So having product coming in means these ports have 

the capacity to say, oh, this is an income stream now that we need 

to maintain, and we need to have the infrastructure in place. 

Senator HASSAN. That is very helpful and I think something that 

the fishermen in my community—you know, New Hampshire’s 

coastline is relatively short, but it is very vibrant, and we’re trying 

to keep it that way. 

Mr. KENT. Well, something to keep in mind is my guys sit at microscopes. 

Senator HASSAN. Yes. 

Mr. KENT. They’re not going to go out pulling nets. We need the 

skill set of guys that can work in a 10-, 12-foot sea, bringing product in, and working, maneuvering boats out there in the ocean. So 

that’s really the people we’re turning to, to run these farms. 

Senator HASSAN. OK. That is very helpful. And I guess the other 

question I have for you is around environmental quality. How can 

we maintain environmental quality and strengthen it while providing the industry with this kind of flexibility it needs to develop 

in offshore areas? 

Mr. KENT. I think it’s really about the location. 

Senator HASSAN. Yes. 

Mr. KENT. If you pick the right site where you’re not interfering 

with other operations and you have the right depth and the right 

current flow, the presence of the farm is undetectable. 

Senator HASSAN. Yes. 

Mr. KENT. And that has been shown in lots of circumstances. 

And that’s a hard lesson that the salmon industry in Chili had to 

learn, that a lot of other industries or a lot of other aquaculture 

industries in other parts of the world have had to learn, is that if 

you pollute the environment that you’re growing your fish in, 

you’re causing yourself problems. 

Senator HASSAN. Right. Yes. 

Mr. KENT. And so picking the site is critical. And so we’ve been 

working with NOAA on doing that as well for our proposed farm. 

Senator HASSAN. Well, thank you very much. 

That’s all the questions I had, Mr. Chair. 

The CHAIRMAN. Thank you, Senator Hassan. 

Senator Klobuchar, anything else? 

Senator KLOBUCHAR. No. I’m all done. I really learned a lot, and 

I’m excited about what you’re doing. Thank you. 

The CHAIRMAN. Let me ask a question, and anybody on the panel 

can respond to it. But your testimonies highlight the economic, environmental, global security and health benefits of increasing domestic aquaculture. However, there is still a perception that farm 

fish is somehow bad or less desirable than other seafood. So what 

is your response to some of those perceptions? 

Dr. Kent, and then we’ll just go across. 

33 

Mr. KENT. Well, the reality is half of the world’s supply is farm 

now, and so it’s if you don’t like the idea of farm fish, then don’t 

eat it, the next guy will. I mean, that’s just flat out the reality of 

it. In fact, what’s so problematic with that attitude is really if you 

grow fish correctly, if you grow shellfish correctly, you have far 

more control over the quality. You don’t have to harvest it until 

Mr. Seaver wants it. On Tuesday, he goes to put a ton of yellowtail 

on the dock; Monday, he will go out to get it; Tuesday morning it 

will be on the dock for him. It’s not going to get any fresher than 

that. And so control over the supply chain is critical in that. Knowing how it’s grown, as we were discussing earlier, is critical in that. 

And we’ve taken our fish and provided it to some of the most discriminating chefs around, and they feel it’s some of the best product they’ve ever worked with. In fact, the head chef for the Hyatt 

Regency said that fish that we provided him was better than anything else he could buy in the market. He’d like to make it a signature dish at all the Hyatt Regencies around the world. So that 

speaks to the quality of how the fish can be harvested and grown 

and provided to the consumer. 

The CHAIRMAN. Thanks. 

Mr. SEAVER. Thank you for that question. Unfortunately, I think 

seafood across the board suffers from the stigma of being somehow 

a lesser protein. In fact, I believe that seafood is the only protein 

that we eat that’s considered guilty before proven innocent, whether it be the quality of the wholesomeness—I’ve never asked, ‘‘Is 

that pork fresh?’’ But I hear that asked. You know, the quality of 

seafood is contended from the minute we decide that we would like 

seafood if we are going to enjoy it at all. And unfortunately, 

through environmental conversation as well as through just cultural conversation, farmed seafood and wild seafood have been put 

into alternate categories, but really they are the same thing. They 

are the source of the healthiest animal protein that we can eat as 

people, and the source of the most sustainable seafood and the 

most sustainable animal protein that we can produce as a nation. 

And so I think that there is a—unfortunately, an illegitimate 

barrier to separating seafood from farmed seafood from wild seafood that we need to address first and foremost. And I think once 

that happens, once we begin to elevate seafood categorically using 

whatever means we might have to do it, whether it is the story of 

local shrimp in Minnesota at the Super Bowl, whether it is soy and 

the opportunities that creates, or whether it is just public health, 

I think using those opportunities, those angles of leverage, to elevate seafood as a aspirational protein in our nation is going to be— 

is going to have a major effect on reducing that stigma and beginning to allow opportunity for the industry that Mr. Kent spoke so 

eloquently about, that Dr. Lucas has spoken so eloquently about, 

allow for that industry to thrive and to grow. 

The CHAIRMAN. And how does the restaurant industry, how do 

people like yourself, chefs, get the message out about the health 

and qualitative advantages of seafood relative to other forms of 

protein? 

Mr. SEAVER. Quite honestly, unfortunately, a lot of us spend our 

time combating negative messaging, and there is so much 

misperception and negative messaging around seafood, and part of 

34 

this is that there has not been a very concerted effort to go proseafood information. It is a very fractured industry unfortunately 

as we look at when we’re talking about imports, exports, the domestically produced, farmed, wild, even the seafood industry internally doesn’t necessarily always have a positive narrative about 

itself. And so when we combat, when we try and talk about seafood, unfortunately we’re oftentimes dismissing the negatives. 

And having the opportunity, especially with colleges and universities, which offer the opportunity to really engage, and you were 

saying the state extension programs and using the academia. Well, 

hey, let’s use the whole campus of academia as a methodology, as 

a means, to really increase the presence of seafood in our dialogue, 

cultural dialogue. And these are also state institutions that have 

massive purchasing power that maybe likely won’t be producing or 

using very high-end products, but certainly can provide opportunity 

I think to invest in and be sort of the building block contractors 

for the seafood being produced. Thank you. 

The CHAIRMAN. Great. All right. 

Senator Blumenthal. 

STATEMENT OF HON. RICHARD BLUMENTHAL, 

U.S. SENATOR FROM CONNECTICUT 

Senator BLUMENTHAL. Thanks, Mr. Chairman. 

And thank you all for being here and for your excellent testimony. Connecticut has a long and historic involvement in shellfish 

and aquaculture and generally the commitment to the environmental treasures that are reflected in this important work. And so 

I would like to begin by asking you about the potential dangers of 

offshore drilling to aquaculture and the kinds of interests it represents. Are you concerned with offshore drilling as a potential 

danger? 

Mr. KENT. We actually have in Santa Barbara, California, we 

have an offshore farm that’s growing mussels, and Santa Barbara 

is probably the center of our oil industry in California. Certainly, 

a leak, a spill, or something would have a devastating effect on a 

farm. At the same time, the increased infrastructure in the ports 

that support offshore drilling can be supportive of aquaculture as 

well. When we originally were proposing a farm, it was off the 

coast of Ventura, and they spotted the dock where the crew boats 

leave to go out to the platforms was right—was the same dock that 

the commercial fishermen offload their product at. So having that 

working waterfront is extremely valuable. That aside, I don’t— 

other than the concerns about leakage or spills or something, I 

don’t see that they’re mutually exclusive. 

Dr. LUCAS. Being from the Gulf of Mexico, we have a relationship 

with our oil industry. And so I speak to the same thing that Mr. 

Kent spoke to in terms of having the infrastructure that’s already 

in place. Also, I know several of the investors have reached out to 

some of the oil companies that may be decommissioning rigs for the 

potential to use those rigs as a station in which they can house 

people, fly in product and stuff, and have their farm far enough 

away that that’s an easier access. Deep water in the Gulf of Mexico 

is not found right offshore, we have to go a good ways, and so looking for those logistics has been important. 

35 

So other than the things that Mr. Kent has spoke to, we understand that there is a greater good for energy producing as well as 

there is a greater good for reducing the seafood trade deficit 

through aquaculture production. 

Senator BLUMENTHAL. Let me ask you about the budget that 

we’ve received from the administration, which cuts back on a number of programs that I think are important to aquaculture; for example, the NOAA Sea Grant Program. Is that kind of program important to you? 

Dr. LUCAS. That kind of program is very important to us. In 

terms of how you see the agricultural industry using land-grant institutions for extension services and getting those products out to 

farmers, the same thing is true of Sea Grant. They work with industry and they work with academics to bridge that gap. So they 

are able to work with the academics and partner with the industry 

to work on what industry needs and then transfer that technology 

over. So they are our extension, and that is very critical to helping 

us advance aquaculture. They have been a huge player in helping 

with aquaculture technology. 

Mr. SEAVER. If I may briefly speak to that as well, Sea Grants 

are inherently attached to and very close to the next generation 

that’s coming up. And in my home state of Maine, this is a very 

big deal that aquaculture presents the opportunity of innovation, of 

excitement, for that young son or daughter to stay in their community, to combat the brain drain of rural coastal communities, and 

to begin to rebuild the vibrancy and heritage of those areas, and 

that slightly less tangible result of that Sea Grant impact, but—— 

Senator BLUMENTHAL. It’s still important. 

Mr. SEAVER.—it’s very intangible on the community. Thank you. 

Mr. KENT. Just on a personal note, as a former Sea Grant trainee, I think it’s a hell of a good program and certainly helped me 

with my career and got me introduced immediately from the academic sector right into the research field, and I think that’s critical, 

is giving students that experience and set them on the course to 

the practical side of science. 

Senator BLUMENTHAL. Let me just close because my time is limited by saying that there are—and I appreciate that perspective on 

Sea Grant. Another Federal program is the Seafood Import Monitoring Program that establishes reporting and recordkeeping requirements for certain kinds of fish so as to make sure of their origin. The program unfortunately applies only to 13 species. So much 

of the world’s seafood comes from sources that could be misrepresented or mislabeled. I’ve worked with a number of my colleagues 

on this issue, including Senator Wicker, from Mississippi, whom 

you no doubt know. And I’m hopeful that we can expand this program. 

In the meantime, domestic aquaculture could overcome some of 

these issues, I think, and ensuring confidence in the origins and integrity of our seafood supplies. So I hope that this point will be emphasized as well, and I’m assuming that all of our panelists would 

agree with that point today. And I’m not going to overstay my time, 

but thank you, Mr. Chairman. 

The CHAIRMAN. Thank you, Senator Blumenthal. 

Senator Cantwell. 

36 

STATEMENT OF HON. MARIA CANTWELL, 

U.S. SENATOR FROM WASHINGTON 

Senator CANTWELL. Thank you, Mr. Chairman. 

Mr. Seaver, thank you and all the panelists for being here. Bristol Bay supports about 20,000 jobs in commercial and recreational 

fisheries and as well as restaurants, which I’m guessing you’re here 

to represent. Recently, the EPA announced they would not withdraw the proposed determination under the Clean Water Act. However, they are not finalizing it either, so it’s a question about what 

remains and what they will do. 

How important is Bristol Bay salmon to the restaurant industry? 

Mr. SEAVER. Bristol Bay salmon and all that it represents—the 

jobs, the culture, the heritage, the communities, that is the—those 

are the very basic underpinnings of what restaurants serve both in 

terms of what we give, but also who we serve. 

Bristol Bay salmon specifically is—you know, we have strategic 

oil reserves in this Nation. That is our strategic salmon reserve. 

That is our strategic food reserve. In fact, it is also our strategic 

example of how and why fisheries should be managed as we do. I 

don’t think that there is—it’s hard to say that one fishery is more 

important than another, but I think Bristol Bay sets the example 

of what all fisheries should be, and should be held up and preserved as an American icon in that way, and everything possible 

should be done to protect them—the fisheries—and those who fish 

them. 

Senator CANTWELL. Thank you. 

Mr. Kent, well, or in general to our panelists, so last August we 

had a pen holding more than 300,000 farmed Atlantic salmon that 

broke and released thousands of Atlantic salmon into the Salish 

Sea. So this caused very great concern to us because the wild Pacific salmon compete for resources and prey and obviously they can 

carry different diseases. So the negative impact on Pacific salmon 

is something that we just can’t sit still for. So we need to do something. 

The Federal response to the pen failure was very uncoordinated 

in the sense that this pen hadn’t been examined since 1987. This 

partly falls under the jurisdiction of the Army Corps and partly 

under NOAA. We also just had a mussel issue in the Northwest, 

too. 

So who owns the—particularly when it comes to this netting 

issue? If there had been an inspection in both of these cases, we 

might have determined something before. So I don’t know who the 

best person to answer this is. 

Mr. KENT. I don’t know that I am, but I’ll take a shot at it. 

Senator CANTWELL. Yes. Thank you. 

Mr. KENT. It was a very unfortunate occurrence that happened, 

and equipment has to be maintained, and maybe there is a little 

complacency that occurs within an industry that has been operating for 40 years and is using technology from back 40 years ago. 

Out in the open ocean, it’s a much more rigorous environment, and 

the cages have to be inspected more often. You have moorings that 

are going down to 300 feet of depth, and that’s something where 

a diver doesn’t swim down there everyday, but remotely operated 

37 

robots can do that. And that would be part of what we’re trying to 

do. 

And more importantly than anything else, I know there has been 

a lot of statement about, well, the fish appear to be malnourished 

and they look like they’re healthy enough and they didn’t think 

there was going to be an adverse impact in some of the reports that 

I’ve seen, but the reality is, why are we trying to grow species that 

are not native to a given area in a new area? We should be growing 

Pacific salmon in the Pacific, white sea bass in California, red 

drum in the Gulf, and Atlantic salmon on the Atlantic coast. Let’s 

grow the species that are appropriate and not move these things 

around. 

Some California abalone farmers imported South African abalone 

one time to see if they could grow nicely in San Diego and ended 

up with a parasite, the sabellid worm, that not only spread through 

the farms, but it spread into the wild population. This is the kind 

of commonsense thing that really should be avoided, and, you 

know, trying to—I don’t have a—I don’t have a solution for how to 

deal with the Atlantic salmon issue in Puget Sound, but it’s not the 

direction I would go in, in starting a farm. There are species in 

each region that should be grown in that region. 

Senator CANTWELL. Nor would I. Nor would I. 

Anybody else? 

Dr. Lucas, did you want to mention something there? 

Dr. LUCAS. I echo what Mr. Kent said. I’ll also say that, you 

know, we’ve improved a lot of technologies now. I mean, the new 

materials that are coming out for some of these cages as well as 

the remote detection devices and stuff, industry needs to advance, 

like you said, and look at some of these things, especially for offshore. And I think that the intensive monitoring programs that go 

along with that can go a long way in helping to prevent an instance 

like you had. 

Senator CANTWELL. Well, I’m definitely going to look in further 

to whether the Army Corps and NOAA need to play a stronger role 

in making sure that things are being inspected. We can’t have 

something there since 1987 not being inspected. I guarantee you, 

protecting the wild Pacific coast salmon is something our country 

believes in, and we’re going to fight to make sure that it is protected. 

Thank you. 

Thank you, Mr. Chairman. 

The CHAIRMAN. Thank you, Senator Cantwell. 

Senator Sullivan. 

STATEMENT OF HON. DAN SULLIVAN, 

U.S. SENATOR FROM ALASKA 

Senator SULLIVAN. Thank you, Mr. Chairman. 

I appreciate the witnesses here. I appreciate Senator Cantwell’s 

comments, all of which I agree with. And, Mr. Seaver, your comments on Bristol Bay salmon were also something that was music 

to my ears. You didn’t add that farm-raised seafood doesn’t even 

remotely compete with wild Alaska seafood, whether it’s Bristol 

Bay salmon or otherwise, in terms of taste and texture. And I guarantee you if every single person in this room did a blind taste test, 

38 

it would be 100 percent for the wild Alaska salmon. But I know 

that’s not what you’re here to testify about. 

[Laughter.] 

Senator SULLIVAN. I think that’s a fact, and maybe I can submit 

something for the record that makes it 100 percent clear. 

But, you know, Mr. Kent, I actually want to follow up on what 

Senator Cantwell asked about the massive Atlantic salmon 

escapement from an operation in Washington State, and, of course, 

that brought enormous concern to Alaskan fishermen in terms of 

the impacts on healthy stocks. And do you think there is something 

we can do? It does seem somewhat uncoordinated, but a policy perhaps, that you mentioned that just makes sense, hey, if there’s a 

risk, and there is always going to be a risk, right? I mean, we want 

to minimize that risk certainly, but if there is a risk, does it make 

sense to kind of do this checkerboard approach to having species 

that have no business being any part of that world out in that part 

of the world when there’s a risk? I mean, it seems to me that might 

be a policy area that we could pursue that might make sense. 

Right? Why do we want very foreign species in an area if there is 

a risk that you could see some kind of escapement that could cause 

damage and certainly cause worry to the fishermen who fish for 

the wild Alaska salmon or other wild Alaskan products? 

Mr. KENT. It’s a very good question. And I don’t know exactly 

what agency would handle it. I go back to this concept of best management practices. My recommendation would be that in an open 

system that’s out in the environment, that we ought to be growing 

the species that are native to that area. In a recirculating system, 

of course, you can grow something that, you know, in Minnesota we 

can grow a foreign species in an enclosed tank without much 

chance of that escaping and endangering endemic species in the 

area. 

And then back to Mr. Seaver’s point, I think it’s also playing to 

the idea of the culture within a given area. If we’re going to be 

growing species that are native to a certain area, there’s a grouper 

in the Gulf, I mean there’s this respect for that fish down there, 

salmon in the Pacific Northwest, cod in other parts of the country. 

White sea bass in San Diego, red drum in the Gulf. We have these 

existing fisheries that aren’t in some cases able to produce enough 

of what we need. And building off of that market regionally I think 

is of benefit. There’s no reason why we can’t bring a red drum fillet 

into San Diego and enjoy it, or a white sea bass into Apalachicola, 

Florida, but at the same time, we don’t want to grow them there. 

We want to grow them in our own regions. 

Senator SULLIVAN. Let me ask kind of a related question. It’s 

kind of a federalism, and, Dr. Lucas, maybe you can start by addressing it in a little bit of background. Since 1990, finfish aquaculture has been prohibited in Alaska’s state waters. However, 

Alaska does choose to allow certain forms of aquaculture, such as 

salmon fishery enhancement through hatcheries and aquatic farming of shellfish and seaweeds. And in 2016, we created, in my state, 

the Alaska Mariculture Task Force to help accelerate development 

of mariculture. 

But I think it begs a question: How can the Federal Government 

help coastal states, like mine, develop the types of aquaculture that 

39 

they choose to that have the support of the citizens, like some elements of mariculture, while also maintaining their right to choose 

what not to do? And this discussion kind of impacts that. 

So there needs to be, in my view, a very healthy federalism component here about what a state and its citizens and its fishermen 

support. How can we do that better? 

Dr. LUCAS. Well, to begin with, I know social license, that we call 

it, or industry, they are looking to go into an area where they’re 

accepted. And that’s part of going into an area where you’re doing 

species that are already part of the heritage and already part of 

the culture and already are an important part of the community. 

The industry looks for things like that. They want to work with 

their local communities. 

I think in the case of states, there are a couple of options for 

states that do have CZMA through consistency, that they could not 

allow certain species that weren’t part of their state plans for 

states that don’t have the CZMA. I think potentially doing some 

kind of opting program where you could opt out of, you know, species that you didn’t—that your state doesn’t wish to engage in, as 

long as there is some certainty there that—I mean, you can’t just 

opt in 1 year and opt out. You want some kind of plan as to how 

those were chosen, and I do believe Alaska has a law that doesn’t 

allow for the finfish aquaculture, so that would probably be something that would have to grow in support from the public before 

that law was even changed in your state to allow for it. You do 

have great shellfish work and even some of the seaweeds, the 

macroalgae, I’ve been working with some of the people from Alaska 

on that, and so I think that’s great. But it’s part of the social acceptance. 

We, as a community, need to get out there and engage in the 

public in terms of what aquaculture really looks like because what 

they see—what they see is some of these farms from overseas, and 

these areas that don’t have the robust environmental regulations 

that we have do not have the robust regulations for drugs, such as 

through the FDA, don’t have the transparency that we have. And 

when people can see that transparency and they can see a video, 

like the QR codes we were talking about where you take a picture 

and you see the farmer out there working on their farm and bringing their fish in to the dock, you can help create that local farm 

to the table, that I’m helping my community, I am helping people 

with jobs, and I am able to eat a local, safe, sustainable product. 

And so I think there is a role for states. I don’t think, you 

know—if you don’t want somebody there in terms of industry, they 

likely also don’t want to be there because that would be combative. 

So I think states do have a role in saying what species occur off 

their coastlines. 

Senator SULLIVAN. Great. Thank you. 

Thank you, Mr. Chairman. 

The CHAIRMAN. Thank you, Senator Sullivan. 

And, Senator Cantwell, anything else? 

Senator CANTWELL. I can’t wait till Copper River salmon season. 

[Laughter.] 

The CHAIRMAN. OK. I want to referee this one right one here, but 

. . . 

40 

[Laughter.] 

Senator CANTWELL. We’re in agreement. 

The CHAIRMAN. They’re in agreement. Yes. All right. Yes, both 

of you have a great interest in this subject, and it’s an important 

one. And I appreciate our witnesses’ testimony today and insights 

about how we can grow and strengthen and improve the impact of 

aquaculture on the economy here in the U.S. When we are getting 

so much of the seafood that we consume in this country from other 

parts around the world, it makes no sense. 

So we appreciate the good work that all of you are doing on that 

front and look forward to partnering with you in the future and 

hope that you will share with us your ideas about things that we 

can be doing along the lines of some of the things you shared today. 

And I will ask you, if you will, in response to written questions, 

and we’ll keep the record open for a couple of weeks so that Senators on the Committee, some who weren’t here and some who 

were, can follow up with additional questions that they might want 

to put on the record. And if you could get those back to us as quickly as possible, that would be greatly appreciated. 

But thanks again for your testimony. And with that this hearing 

is adjourned. 

[Whereupon, at 11:39 a.m., the hearing was adjourned.] 

(41) 

1http://www.nmfs.noaa.gov/aquaculture/docs/aquaculture_docs/aquaculture_strategic_plan_ 

final.pdf 

A P P E N D I X 

STRONGER AMERICA THROUGH SEAFOOD

Wilmington, DE, Feb. 13, 2018 

Hon. JOHN THUNE, Chairman, 

Senate Committee on Commerce, 

Science, and Transportation, 

Washington, DC. 

Hon. BILL NELSON, Ranking Member, 

Senate Committee on Commerce, 

Science, and Transportation, 

Washington, DC. 

Dear Chairman Thune and Ranking Member Nelson, 

On behalf of the Stronger America Through Seafood (SATS) Campaign, we would 

like to thank you for calling a full Committee hearing on the critical issue of domestic aquaculture on Jan. 30, 2018. We ask that this letter of support for the Committee’s leadership on domestic aquaculture expansion be included in the written record 

of the hearing. 

With support from seafood leaders from across the country, SATS is uniting 

American businesses, consumers, health advocates, and NGOs behind a single, positive message regarding the ecological, societal and economic benefits of U.S. seafood 

production. It was invigorating to hear a diverse panel of witnesses and a bi-partisan panel of Senators all agree on the importance of increasing U.S. production 

of healthful, sustainable, and affordable seafood. With this letter, we ask for your 

continued leadership and partnership in this effort. 

Wild fish harvests are and always will be an important part of seafood supply. 

There is, however, a significant economic and social opportunity for aquaculture to 

supplement wild harvests in both domestic and international markets. Aquaculture 

is one of the fastest growing sustainable forms of food production and has the 

unique potential to improve food security and nutrition, enhance coastal resiliency, 

create quality jobs, help restore species and habitats, and ensure that seafood (both 

wild caught and farmed) continues to be an important part of the global food supply. 

Unfortunately, domestic aquaculture development is currently constrained by disjointed Federal leadership and numerous regulatory hurdles, including overlapping 

jurisdiction of federal, state, regional, county and municipal governments, and the 

absence of a predictable, affordable and efficient permitting process, particularly in 

marine environments. 

To overcome these regulatory hurdles and lay groundwork for strengthening the 

U.S. aquaculture industry, Congress must demonstrate unequivocal willingness to 

streamline the existing bureaucracy and support domestic aquaculture development. 

We strongly recommend legislation to establish the National Oceanic and Atmospheric Administration (NOAA) as the lead agency in charge of overseeing coordination among all Federal partners on U.S. aquaculture interests and on U.S. aquaculture regulation in Federal waters. The legislation should task NOAA with implementing coordinated, consistent and efficient regulatory processes for the marine 

aquaculture sector, like that outlined in Goal #1 of NOAA Fisheries’ Marine Aquaculture Strategy for FY 2016–2020 1 and make funds available for these activities. 

Legislation should also empower NOAA with the authority to remain a strong advocate for all marine aquaculture, facilitate streamlined permitting in Federal waters and increase coordination among agencies with jurisdiction in state waters. 

Further, as with any new industrial venture, the U.S. marine aquaculture industry 

will be hugely capitol-intensive, particularly during the first few decades. As such, 

legislation should provide regulatory certainty and sufficient permit or lease length 

to maximize success while effectively de-risking the project for potential investors. 

Attached, please find a document titled ‘‘Investment Considerations Regarding U.S. 

Offshore Marine Aquaculture’’ prepared by Max Holtzman, a partner at Pontos Aqua 

42 

Advisory and a Board Member of the Stronger America Through Seafood campaign, 

for more background on this topic. 

The Stronger America through Seafood Campaign’s Board of Directors will be in 

Washington, D.C. March 14—15, 2018 and we would like to meet with Members of 

the Committee at that time to discuss these items in greater depth. Please contact 

us at your convenience to arrange for this meeting. By working together, we will 

see the responsible development of commercial-scale, affordable aquaculture become 

a reality for the betterment of our businesses and of our citizens. 

Sincerely, 

KATHRYN UNGER, 

President. 

TONY DAL PONTE, 

Vice President. 

MAX HOLTZMAN, 

Secretary. 

BILL DEWEY, 

Treasurer. 

INVESTMENT CONSIDERATIONS REGARDING U.S. OFFSHORE MARINE AQUACULTURE

There have been many conversations related to the length of time of a permit or 

lease for an offshore marine aquaculture operation contemplated in the proposed 

Senate Bill related to the U.S. Aquaculture industry. This brief summary attempts 

present a view from members of the investment community related to permit or 

lease length and risk assessment in the evaluation of potential investment in an offshore aquaculture operation. 

While there are multiple risk factors that must be fully evaluated and properly 

de-risked in this type of investment analysis, this current discussion is related to 

one sliver of this de-risking process: The length of time of a permit or lease for a 

certain operation. 

There is no ‘‘magic number’’ related to the length of time either a lease or permit 

should be, however the longer this time period the more benefits will accrue to the 

entrepreneurs and companies that wish to start-up this type of operation. A lease 

or permit with a length of time greater than 20 years would provide benefits to the 

borrower/investee that maximize the best chance for success while more effectively 

de-risking the project for potential investors. A brief overview of the reasons for this 

assumption are included herein. 

First, it is helpful to understand the capital intensity of offshore aquaculture operations. Of all of the factors that contribute to this capital intensity, the main drivers 

in offshore operations are the high cost of cages and infrastructure to support these 

operations along with very high working capital requirements. These operations 

typically involve long cycle species which require high amounts of feed, labor and 

depreciation before they reach the market. Below is further detail of the costs associated with these operations, both offshore, and the necessary onshore support: 

Offshore requirements: 

• Offshore equipment including cages, barges and service vessels for feeding, harvest, monitoring and general servicing; 

• Remote monitoring equipment, remote underwater camera systems, pathogen 

detection and monitoring; 

• Harvesting equipment, including fish pumps, insulated bins and other necessary equipment; 

• Labor costs 

» Labor related to construction of site which varies across production methods; 

» FTE’s for operations and maintenance; 

• Insurance, relevant bonding other capital requirements; 

Onshore requirements: 

• Research, development and testing of species suitable for relevant siting; 

• Maintenance of fleet of vessels to move personnel, equipment and feed from 

shore to site; 

• Dockage of vessels; 

• Storage of feed (climate controlled), equipment; 

43 

• Harvesting and processing equipment including industrial ice machinery, adequate equipment to move ice and fish to various locations; 

• If integrated operation with hatchery, full hatchery and recirculating aquaculture system to operate hatchery; 

• Hatchery personnel and equipment; 

• Land, buildings, personnel and equipment necessary for hatchery operation; 

• If integrated operation with feed mill: full feed mill and capex necessary to construct feedmill including land, buildings, personnel and equipment; 

Specific factors related to the need for long lease or permit length: 

1. The highly capital-intensive nature of these operations: Offshore aquaculture 

operations are multi-million-dollar agricultural operations with very high initial startup and working capital requirements. There is an often misunderstanding that these operations are simply cages in the water full of fish, when 

in reality, sustainable modern offshore marine aquaculture relies on cutting 

edge technology, equipment and highly trained personnel to construct, operate 

and maintain these facilities. Equipment and facilities are located offshore, and 

in addition there is a vast land-based network of support infrastructure and 

personnel to run these operations. While these operations create hundreds of 

jobs throughout the supply chain necessary to support these operations, the 

highly capital-intensive nature of start-up and working capital is a major factor 

related to the necessity of a longer lease or permit period. 

2. Long length of grow-out from hatch to harvest: Many species suitable for offshore aquaculture operations can take anywhere from 1–3 years to reach harvest from the time of eggs hatching. This longer than typical harvest times 

compared to terrestrial agricultural protein producers brings additional risk. 

However, just as with our land based producers, the dynamics are the same: 

The longer you are controlling a live animal, the more issues you will need to 

contend with including adverse weather, rising costs of inputs such as feed, 

risk of disease and other unpredictable but known adversaries. Accordingly, investors will rely on longer capital cycles to flatten out this risk curve across 

multiple harvests to reduce risk over increased time and volume of product. 

3. Risk of Price Volatility: Many of the species suitable for offshore aquaculture 

operations have pricing that are based on and behave like agricultural commodities. The cyclical nature of the pricing of these products then demands 

that the investment periods must be longer than the cycles themselves. If not, 

the producer will face much greater risk as you attempt to time your entry and 

exit within these markets. Long lease or permit lengths allow a producer to 

both withstand and manage the cyclical nature of commodities and transform 

unbeatable risk in the short term into manageable volatility in the long run. 

4. Ability to exit the investment and bring new investors: For a multitude of reasons, owners, operators and investors exit or sell operations during the course 

of a business. The value of a business will in part be valued by the length of 

time that remains on a lease or permit. If the initial length of time of the permit or lease is too short, then any subsequent investor will only be able to assign value to the operation based on the remaining time that operation retains 

its certainty to operate, and thus its ability to generate cash flow. 

5. Risk and Return Expectations: Different investors have different appetites for 

risk and return requirements within certain asset classes. Well known in any 

investment is the higher the risk, the higher the expected returns of the investor. If operating within a short time frame, and therefore higher risk, investors 

may rightly seek returns that are not aligned with the intrinsic potential of 

the business. However, if you are able to extend the investment period and decrease the risk, you have the potential to capture investment with more reasonable returns and more aligned with the de-risked intrinsic potential of offshore operations. 

44 

1 National Aquaculture Association, PO Box 12759, Tallahassee, FL 32317; Telephone: 850– 

216–2400; E-mail: naa@thenaa.net; Website: http://thenaa.net/. 2 Rubino, Michael (ed). 2008. Offshore Aquaculture in the United States: Economic Considerations, Implications & Opportunities. U.S. Department of Commerce; Silver Spring, MD; USA. 

NOAA Technical Memorandum NMFS F/SPO–103 3 Nash, C.E. 2004. Achieving Policy Objectives to Increase the Value of the Seafood Industry 

in the United States: The Technical Feasibility and Associated Constraints. Food Policy 29:621– 

641. 4Knapp, G. and M.C. Rubino. 2016. The political economics of marine aquaculture in the 

United States. Reviews in Fisheries Science and Aquaculture 24(3): 213–229. 

PREPARED STATEMENT OF THE NATIONAL AQUACULTURE ASSOCIATION

ACHIEVING SUSTAINABLE SEA FARMING

‘‘We must plant the sea and herd its animals using the sea as farmers instead of hunters. That is what civilization is all about—farming replacing 

hunting.’’ 

∼Jacques-Yves Cousteau 

The National Aquaculture Association 1 is a U.S. producer-based, non-profit association incorporated in 1991 that supports the establishment of governmental programs that further the common interest of our membership, both as individual producers and as members of the aquaculture community. For over 27 years NAA has 

been the united voice of the domestic aquaculture sector committed to the continued 

growth of our industry, working with state and Federal governments to create a 

business climate conducive to our success, and fostering cost-effective environmental 

stewardship and sustainability. 

The NAA offers the following recommendations with respect to drafting U.S. marine aquaculture legislation to support the creation of a commercially viable framework for U.S. aquaculturists to grow, handle, transport and sell marine finfish, 

shellfish (clams, oysters, mussels or scallops) and seaweed from farms located in the 

Exclusive Economic Zone of the United States. 

Advancing Public Health, Food Security and Sustainable Economic Growth 

Offshore marine aquaculture in the Exclusive Economic Zone holds tremendous 

potential for advancing the public health, food security and economic interests of 

Americans, but those interests can only be served if government provides the legal 

authorities for the private sector to fulfill that mission without unwarranted regulatory obstacles. Large-scale marine aquaculture production in the United States 

would create the ability to: 

• Close a significant gap in U.S. food security (availability) through the farming 

of seafood products in U.S. waters rather than relying as the United States currently does on foreign seafood sources for 90 percent of the seafood consumed 

by our citizens. 

• Create ancillary equipment and service businesses and new jobs within coastal 

and inland communities. 

• Accelerate technological development to reduce production costs and minimize 

adverse environmental effects. 

• Maintain working waterfronts and build upon the existing and unique knowledge, skills and abilities possessed by commercial fishers. 

While these projections are well-documented,2 the United States has yet to make 

any significant advances in U.S. marine aquaculture production in the 38 years 

since passage of the National Aquaculture Act of 1980. Aquaculture production is 

approximately 45,500 tons valued at $327 million and supplies about 3 percent of 

U.S. seafood consumption. Federally managed waters beyond coastal state boundaries, termed the Exclusive Economic Zone, encompass 4.4 million square miles 

(11.3 million square kilometers). A U.S. study estimated that 195 square miles (500 

sq. km) of ocean, managed under existing regulations, could produce 1.3 billion 

pounds (600,000 metric tons) or more of high quality seafood.3 Theoretically, the 

farming of 970 sq. miles (2,500 sq. km), an area representing .0002 percent of the 

Exclusive Economic Zone, less than half the size of Delaware, would double U.S. edible seafood production or an area the size of the Pentagon could produce 220 million 

pounds (100,000 MT). A doubling of U.S. aquaculture production to about 1 million 

tons could create an estimated additional 50,000 farm and non-farm jobs.4

45 

5 Be ́ne ́, et al., 2015. Feeding 9 billion by 2050—Putting fish back on the menu. Food Security 

7(2): 261–274 (https://link.springer.com/article/10.1007/s12571–015–0427-z accessed 

February 1, 2018). 6Goldburg, R. and T. Triplett. 1997. Murky Waters: Environmental Effects of Aquaculture in 

the United States. Environmental Defense Fund, New York NY 7 Engle, C.R. and N. M. Stone. 2013. Competitiveness of U.S. aquaculture within the current 

U.S. regulatory framework. Aquaculture Economics and Management 17(3): 251–280. 

Fish Farming is Inherently Efficient 

Farmed and wild-caught fish, shellfish and sea vegetables have been recognized 

as critical components to achieving global food security and nutrition. Farmed and 

wild fish production have been the main contributor to the 61 percent increase in 

world protein consumption, fish are very efficient converters of feed into protein, 

and aquatic animal production systems have a lower carbon footprint, lower nitrogen and phosphorus losses and in the case of shellfish and sea vegetable production 

remove carbon, nitrogen and phosphorus from the environment. The inherent energy and feed advantages of fish are derived from the ‘‘cold-blooded’’ nature, meaning they expend little to no energy to maintain a constant body temperature, and 

the physical support water provides to directs growth to protein and not a bony 

muscular-skeletal structure that is always fighting gravity.5

Current Regulations are Proven and Effective 

Over the last 20 years, rather than acknowledging the many advances in marine 

aquaculture production practices and successful management strategies for adverse 

environmental impacts, many in the environmental community continue to attribute 

a variety of potential adverse environmental effects to aquaculture based on outdated production methods and standards.6 We note that the U.S. Environmental 

Protection Agency (EPA) has held authority to regulate discharges from fish farms 

(nutrients, chemicals and solid waste) under several iterations of the Clean Water 

Act since the 1970s. More recently, environmental groups sought EPA reevaluation 

of the Clean standards applied to aquaculture. During a four-year period, 2000–04, 

the agency completed a detailed technical review of its then current standards, and 

modern aquaculture methods, including those used for marine aquaculture. Formal 

rulemaking was conducted to ensure that Clean Water Act regulations for aquaculture met all standards of environmental protection mandated by Congress. In 

that process, the EPA determined, contrary to the position of environmental groups, 

that the proposed and adopted revised regulations assured environmental protection. 

Other current Federal regulatory authorities, unilaterally or in partnership with 

the states, exist to protect navigation and navigational aids, water and benthic quality, food safety, drug and chemical use, aquatic animal health, endangered species, 

wild fishery stocks (with respect to potential aquaculture impacts to those populations), essential fish habitat, and the opportunity for coastal states to comment on 

proposed Federal permits and leases associated with offshore marine aquaculture. 

Existing law include, but are not limited to, the Animal Health Protection Act, Animal Medicinal Use Drug Clarification Act, Coastal Zone Management Act, Endangered Species Act, Federal Food Drug and Cosmetic Act, Federal Insecticide, Fungicide and Rodenticide Act, Federal Water Pollution Control Act (Clean Water Act), 

Lacey Act, Magnuson-Stevens Fishery Conservation and Management Act, Marine 

Mammal Protection Act, Migratory Bird Protection Act, National Environmental 

Policy Act Outer Continental Shelf Lands Act, and Rivers and Harbors Act. Through 

rulemaking, judicial rulings and an opportunity to comment on significant Federal 

permitting by other Federal agencies, the U.S. Environmental Protection Agency, 

National Oceanic and Atmospheric Administration, U.S. Department of Agriculture, 

U.S. Army Corps of Engineers, U.S. Coast Guard, U.S. Department of Defense, Federal Aviation Administration, U.S. Fish and Wildlife Service, Bureau of Ocean and 

Energy Management, and state agencies (agriculture, natural resources, and environmental protection) have an important regulatory role relative to offshore aquaculture and, in particular, the coastal states are provided an opportunity to comment on proposed Federal permits and leases associated with offshore marine aquaculture.7

Current regulatory authority exists to appropriately protect marine water quality 

and benthic environmental systems, manage fish escapes, require responsible drug 

and chemical use, insure safe navigation, and assure consumers that they will have 

access to safe foods; although, it has been argued, and we agree, that: 

The stringency of the regulatory environment in the United States has increased in recent years in terms of both the number and complexity of regulations that affect U.S. aquaculture. Especially difficult is the common lack of a 

46 

8 Ibid at 274. 

9 Nash, C.E. (editor). 2001. The net-pen salmon farming industry in the Pacific Northwest. 

U.S. Department of Commerce. NOAA Tech. Memo. NMFS–NWFSC–49 (http://www.westcoast 

.fisheries.noaa.gov/publications/aquaculture/noaa_memo_net_pen_salmon_farming_sept2001 

.pdf accessed January 28, 2018). 

Waknitz, F.W., T.J. Tynan, C.E. Nash, R.N. Iwamoto, and L.G. Rutter. 2002. Review of potential impacts of Atlantic salmon culture on Puget Sound chinook salmon and Hood Canal summer-run chum salmon evolutionarily significant units. U.S. Department of Commerce. NOAA 

Tech. Memo. NMFS–NWFSC–53 http://www.westcoast.fisheries.noaa.gov/publications/aquaculture/waknitz.2002.nwfsc_tm53.reviewofpotentialimpacts.pdf accessed January 28, 2018) 10Kumar, G. and C. R. Engle. 2016. Technological advances that led to growth of shrimp, 

salmon, and tilapia farming, Reviews in Fisheries Science and Aquaculture, 24(2): 136–152 11 Ibid at 145. 12Love, D.C., I. Gorski and J.P. Fry. 2017. An analysis of nearly one billion dollars of aquaculture grants made by the U.S. Federal Government from 1990 to 2015. Journal of the World 

Aquaculture Society 48:689–710. 

lead agency at both Federal and state levels to effectively coordinate and 

streamline regulatory and permitting processes that result in timely decisions 

and more certainty for investment in new enterprises and expansion of existing 

operations. The overall cumulative effect has been continued increases in the 

regulatory costs and risk faced by aquaculture growers in the United States.8

Atlantic Salmon in Puget Sound 

The potential environmental effects of the escape of Atlantic salmon in Puget 

Sound on Pacific salmon as a result of a net pen system that collapsed has created 

intense public and media speculation. Fortunately, several publications have examined this risk and other risks and reported that those risks are manageable or unlikely to be realized.9

We believe that when the potential effects associated with this escape are thoroughly analyzed this prior work will be confirmed. We are also hopeful that enough 

time will have passed to then allow a dispassionate discussion and reassessment of 

Atlantic salmon culture to occur. We are confident that this assessment will recognize that potential risks are being adequately managed under existing state and 

Federal regulations. It is also unfortunate, that currently little to no recognition of 

public and private investment to improve Atlantic salmon production characteristics 

(e.g., weight gain, feed efficiencies), human diet and nutrition, fish health, and reduced environmental effects through fish husbandry, domestication and technology 

gained by the global production of Atlantic salmon production has not been made 

known to the public.10

As summarized by Ganesh and Engle (2016) (internal citations deleted): 

The Atlantic salmon industry overcame several biological, ecological, and disease constraints throughout its history. Advanced automated feed monitoring 

systems provided greater resource and environmental management efficiency. 

Commercialization of genetic and vaccination programs improved growth and 

survival while nutritional developments reduced the use of fishmeal and oil 

while improving performance. Such continued technological advances resulted 

in continuous growth in Atlantic salmon production with significant reductions 

in cost of production. The Atlantic salmon industry is one of the leaders in 

terms of biological knowledge and production technology, raising a very resource-efficient species that is often termed ‘‘the super-chicken of the sea.’’ 11

Research with Significant ROI 

Research supported by governmental agencies and the private sector has led to 

continuing improvements in reducing the use of essential fish meal and fish oil components in pelleted aquaculture feeds. Research programs within NOAA and USDA 

that focus on marine aquaculture are critical to U.S. aquaculture and to national 

efforts to reduce our trade deficit, create jobs and increase national security through 

the provision of wholesome domestic food sources. These aquaculture research efforts have benefited U.S. aquaculture by resolving complex biological, environmental, chemical, or public relations constraints to increase aquatic animal or plant 

production or sales. Research funds are not wasted public monies. An independent 

analysis focused on public investment in aquaculture research found an estimated 

37-fold return for each research dollar spent since 2000.12

States Are Managing Aquaculture 

Over the last 20 years, responsible environmental stewardship has become the 

proven business model in the state or territorial waters of Maine, Washington, Hawaii and Puerto Rico where commercial scale net pens have been operated to farm 

Atlantic salmon, Almaco jack or cobia and in the state waters of Alabama, Alaska, 

47 

13 van Senten, J. and C.R. Engle. 2017. The cost of regulations on U.S. baitfish and Sportfish 

producers. Journal of the World Aquaculture Society. 48(3): 503–517. 

California, Connecticut, Florida, Hawaii, Louisiana, Maine, New Hampshire, New 

Jersey, New York, Maryland, Massachusetts, North Carolina, Oregon, Rhode Island, 

Virginia, South Carolina and Washington where shellfish farms have farmed abalone, clams, oysters, mussels or scallops. These farms have been managed in compliance with state and Federal regulations and the provisions of lease agreements with 

the states or territory. All such operations are conducted with regulatory transparency supported by environmental monitoring data and periodic reporting for 

these operations in publicly available documentation required by state and Federal 

agencies. 

Creating Security of Tenure is Critical 

The limited scope of today’s U.S. marine aquaculture industry simply will not substantially expand without access to the majority of offshore waters that are controlled by the Federal Government. However, access alone is not sufficient, and will 

not create the fertile environment for investment in U.S. marine aquaculture. What 

is needed is security for tenure (e.g., a lease) to allow U.S. aquaculture operations 

to operate in the Exclusive Economic Zone in compliance with existing regulatory 

programs that will provide a viable financial model (private investment and insurance) that will survive in the free market. 

Marine aquaculture facilities in the Exclusion Economic Zone must be provided 

security of tenure to occupy a location to the exclusion of other conflicting uses by 

means of a recognized and commercially understood legal agreement such as a lease 

granted by an appropriate Federal agency on behalf of the U.S. Government. Property rights in marine waters are typically available under state laws in state waters 

where marine aquaculture is recognized as a being in the public interest. This is 

typically done by means of a lease. The leasing of a public resource for commercial 

use appropriately requires payment for use of public space (i.e., rental payments). 

However, this use of public trust lands (offshore ‘‘spaces’’) must be not be confused 

with business models for industries that actually consume public trust resources 

(e.g., oil and gas resources that are owned in trust by the U.S. Government for the 

people). 

A viable offshore aquaculture operation will require the same level of commercial 

certainty and property rights available to land-based agricultural enterprises or 

those aquaculture farms located in state waters. Offshore aquaculture operations 

are complex and expensive facilities that require reasonable business planning and 

construction periods and phased development to provide economies of scale necessary to internalize the regulatory and operation costs. Offshore aquaculture leases 

should be renewable and should have initial terms of at least 25 years in order to 

secure financing on commercially-viable terms. Leases should also be transferable 

to support potential sale or other transfer of a farm operation. 

Regulatory Burden and Costs Stifle Small Business Innovation 

The majority of U.S. aquaculture producers are small business entities. The 

USDA Census of Aquaculture conducted in 2012 showed that 86 percent of all aquaculture businesses had sales less than $500,000. The costs of regulatory compliance 

for small businesses are having devastating effects on the ability of these businesses 

not only to exist, but to expand or add capacity. Additionally, these same burdens 

are prohibiting new businesses from starting up, further exacerbating the issue. 

As a specific example, the average total regulatory cost on U.S. batfish/spearfish 

farms was $148,554 per farm, or $2,989 per acre of production.13 The regulatory 

cost burden composed 25 percent of total costs of baitfish/sportfish farms, making 

it one of the largest cost components in their businesses. Total cost to the U.S. 

baitfish/sportfish industry was estimated to exceed $12 million. On 38 percent of the 

farms, the cost of regulations exceeded the value of profits on baitfish/sportfish 

farms. 

The data also revealed that only 1 percent of total regulatory costs were those of 

the fees for permits and licenses. The real burden of the regulatory environment 

was found to be the indirect costs associated with increased manpower costs for 

record-keeping, reporting, and applying for permits, farm changes to remain in compliance, and lost sales (that could not be replaced or re-directed to other markets) 

that were lost directly due to regulatory actions. Environmental management regulations composed 61 percent of the total regulatory cost burden in spite of representing only 17 percent of the total number of regulations with which farms had 

to comply. The regulatory burden was substantially greater on smaller farms 

($5,533 per acre) than on larger farms ($321 per acre), and very likely has contribVerDate Nov 24 2008 09:04 Aug 12, 2019 Jkt 000000 PO 00000 Frm 00051 Fmt 6601 Sfmt 6621 S:\GPO\DOCS\37301.TXT JACKIE
48 

14Gentry, et al., 2017. Mapping the global potential for marine aquaculture. Nature Ecology 

and Evolution 1:1317-1324. 

uted to the 29 percent decline in the number of small baitfish/sportfish farms in the 

United States as compared to no decline in the number of large farms from 2005 

to 2012. 

Seafood Safety from Farm to Plate 

The U.S. domestic aquaculture industry is committed to supplying consumers 

with consistent, high quality, safe products that are produced in an environmentally 

sound manner. Numerous Federal and state agencies are involved with maintaining 

the wholesome attributes of farm-raised seafood. The U.S. Food and Drug Administration works with state departments of agriculture, the Association of Food and 

Drug Officials, and the American Association of Feed Control Officials to regulate 

aquaculture food handling and processing and the manufacture of feeds to ensure 

that they are safe and do not contain contaminants or illegal substances. The U.S. 

Department of Agriculture inspects the processing of catfish and tests catfish products, foreign and domestic, for contaminants. 

The Interstate Shellfish Sanitation Conference in cooperation with the U.S. Food 

and Drug Administration and state agencies administers a certification program requiring all shellfish dealers to handle, process, and ship shellfish under sanitary 

conditions and maintain records that the shellfish were harvested from approved 

waters. State agencies establish standards for shellfish growing areas and regularly 

monitor water quality to make sure that growing waters meet those standards. 

Fish and shellfish packers, warehouses, and processors must comply with the 

mandatory requirements of the Hazard Analysis Critical Control Point (HACCP) 

Program administered by the U.S. Food and Drug Administration. The program 

identifies potential food safety hazards and develops strategies to help ensure that 

they do not occur. New rules by the U.S. Food and Drug 

Administration authorized by the Food Safety Modernization Act have added additional regulations for the processing, handling and transportation of animal feeds 

and human food. All of these controls help to make farm-raised seafood products 

safe and wholesome foods. 

The United States as a World Leader in Marine Aquaculture 

The United States is not a world leader in sustainable aquaculture production by 

volume or value but we are in the thoughtful and rigorous development of regulatory and nonregulatory production practices, animal nutrition and health management, and the efficient processing and distribution of high-quality, wholesome foods. 

A recent global analysis of global marine aquaculture potential concluded with a 

statement that is very relevant to U.S. marine aquaculture in highlights the unlimited potential of the United States to be a global leader in sustainability, technology 

and production (citations deleted): 

Given the significant potential for marine aquaculture, it is perhaps surprising 

that the development of new farms is rare. Restrictive regulatory regimes, high 

costs, economic uncertainty, lack of investment capital, competition and limitations on knowledge transfer into new regions are often cited as impediments to 

aquaculture development. In addition, concerns surrounding feed sustainability, 

ocean health and impacts on wild fisheries have created resistance to marine 

aquaculture development in some areas. While ongoing and significant progress 

has been made in addressing sustainability issues with marine aquaculture, 

continued focus on these issues and dedication to ensuring best practices will 

be a crucial element shaping the future of marine aquaculture. Both the cultural and economic dimensions of development and the management and regulatory systems are critically important to understanding realistic growth trajectories and the repercussions of this growth. Our results show that potential exists for aquaculture to continue its rapid expansion, but more careful analysis 

and forward-thinking policies will be necessary to ensure that this growth enhances the well-being of people while maintaining, and perhaps enhancing, vibrant and resilient ocean ecosystems.14

The National Aquaculture Association requests the U.S. Senate Committee on 

Commerce, Science, and Transportation create, introduce and shepherd national legislation to lead the world and benefit the Nation. It would be our honor and privilege to assist in this effort as fish, shellfish and sea vegetable farmers with the experience, knowledge, skills, scars and persistence to make this happen. 

49 

WRITTEN COMMENTS SUBMITTED BY THE SAN DIEGO UNIFIED PORT DISTRICT

In follow up to the testimony that you heard from our stakeholders and colleagues 

on January 30, 2018, the San Diego Unified Port District (District) would like to 

provide additional comments regarding developing aquaculture opportunities as 

public private partnerships. 

The District serves the people of California as a special district, balancing multiple uses on 34 miles along San Diego Bay spanning five cities. Collecting no tax 

dollars, the District manages a diverse portfolio to generate revenues that support 

vital public services and amenities. 

The District champions Maritime, Waterfront Development, Public Safety, Experiences and Environment, all focused on enriching the relationship people and businesses have with our dynamic waterfront. From cargo and cruise terminals to hotels 

and restaurants, from marinas to museums, from 22 public parks to countless 

events, the District contributes to the region’s prosperity and remarkable way of life 

on a daily basis. 

Background 

As you heard from Mr. Don Kent during oral testimony, on October 8, 2014, Rose 

Canyon Fisheries (RCF) submitted permit applications to the U.S. Army Corps of 

Engineers (ACOE), and the U.S. Environmental Protection Agency (EPA) for a fish 

farm to be located in Federal waters, 4.5 miles off the coast of San Diego, CA. This 

represented the third, but most comprehensive attempt at permitting for an offshore 

fish farm in California since 2002. 

In the ensuing months RCF experienced multiple delays due to a lack of Federal 

agency coordination, including a debate on which agency (ACOE or EPA) should 

take the lead agency role in coordinating the National Environmental Policy Act 

(NEPA), a critical step in moving the applications forward Each agency did initiate 

their own Notice of Intent’s (NOI) to begin processing applications including public 

scoping processes, and the EPA did agree to become the lead agency in February 

of 2015. However, by June of 2016, the EPA had cancelled their agreement to become the lead agency and the ACOE informed RCF that it would deny their Section 

10 Permit application based on concerns about navigation cited in the Navy’s original comments, despite the same comments that suggested the farm location move 

slightly to the north to minimize potential interference with Naval operations. By 

the end of 2016, NOAA Fisheries Regulatory Branch offered to step in and be the 

lead agency on the NEPA review for the RCF permits. While this was a welcome 

and significant step forward, the regulatory quagmire and interagency inaction resulting from the lack of a clear sense of priority and efficiency amongst agencies 

continued. In April 2017 (30 months following application submittal), the District 

intervened and hosted a meeting with the National Oceanic and Atmospheric Administration (NOAA), the U.S. Navy, and the ACOE. The U.S. Navy re-iterated its 

support for the proposal, and while the ACOE was still reluctant, it did agree to 

RCF updating its application materials to reflect the new site location and re-submitting an application package. 

In August 2017, the District hosted the first-ever, interagency pre-application 

meeting for an offshore aquaculture permit application in the U.S. NOAA, now officially the designated lead agency, organized the meeting which included representatives from NOAA, ACOE, EPA, U.S. Coast Guard, U.S. Navy, California Coastal 

Commission, California Department of Fish and Wildlife, Rose Canyon Fisheries, 

and the District. 

Through the District’s Blue Economy Incubator Program, the District is exploring 

a partnership with RCF, which has the potential to be a regional-based model and 

an early proving ground that will provide an invaluable database of information and 

advance the aquaculture industry nationwide. The District has been asked to act 

as a Cooperating Agency, along with NOAA, ACOE, and EPA for the National Environmental Policy Act (NEPA) review for this project. Next steps are currently being 

discussed, along with a draft MOU that outlines each agencies roles and responsibilities. 

The Opportunity for Aquaculture 

There is a clear opportunity and critical need to support development of sustainable domestic marine aquaculture industry. The U.S. currently imports over 91 percent of the seafood it consumes, yet only three percent of U.S. domestically produced 

seafood comes from aquaculture. In economic terms, these imports consistently contribute to a nearly $14 billion domestic seafood trade deficit each year. U.S. based 

aquaculture advocates, however, believe we can reverse that trend and allow aquaculture to flourish right here at home. The U.S. could and should be self-sufficient 

50 

in seafood production with the goal of becoming a net trade exporter of seafood by 

2050. 

The largest opportunity for U.S. aquaculture development lies offshore, but the required Federal permitting process is poorly defined. This has caused domestic investment in aquaculture to be driven to other countries. Besides being the major 

contributor to our trade deficit, this also sends U.S. seafood production and distribution industry jobs to other countries, thereby losing a major economic opportunity 

for the U.S. As you heard during oral testimony, for every one job created on the 

waterfront, two additional indirect jobs are created elsewhere downstream. The import deficit also means that the U.S. is buying seafood that may not be grown to 

our rigorous health and environmental standards. There are numerous examples of 

U.S. investors growing salmon in Chile, red drum, striped bass and yellowtail in 

Mexico and cobia in Panama, simply because those countries welcome their investments. Any one of these companies would rather be working in U.S. waters, but 

they cannot get the permits required from the Federal Government that they need 

to locate and operate U.S. farms. 

The Port of San Diego’s Role 

Aquaculture must be tested and proven to be economically, environmentally and 

commercially viable. This takes time, money, expertise and regulatory wherewithal. 

The District has positioned itself uniquely to supports efforts to advance State and 

Federal policies to increase aquaculture production and deliver a safe, secure and 

sustainable seafood supply for California and the Nation. Ports can and are increasingly playing a critical role in the development of sustainable aquaculture, given 

their familiarity and expertise in the permitting and entitlement process for a variety of coastal and ocean uses; the unique role they often play as a landlord, operator 

and/or regulator, and as champions of the blue economy. As the state-legislated 

trustee of tidelands (i.e., land and water) around San Diego Bay, developing sustainable domestic aquaculture helps fulfill the District’s public trust responsibility to 

promote fisheries and commerce, as well as aligning with its mission to enhance and 

protect the environment. 

As the state-legislated trustee of tidelands (i.e., land and water) around San Diego 

Bay, developing sustainable domestic aquaculture helps fulfill the Port’s public trust 

responsibility to promote fisheries and commerce, as well as aligning with its mission to enhance and protect the environment. 

San Diego could support the development of an offshore aquaculture industry, 

which could become a $1 billion per year industry with only a nominal percentage 

of state or Federal waters leased from the government. A properly constructed and 

managed industry would provide a safe, secure, and stable supply of healthful seafood to the region, alleviate some pressure on wild fish stocks, and help conserve 

the remaining working waterfront, all with acceptable impacts on the environment 

and other ocean uses. Equally as important, an aquaculture facility in our region 

could prove the viability of the domestic aquaculture industry and act as a catalyst 

for growth of the industry nationwide. 

The Pressing Need for Congressional Action 

To address the challenges above, it is essential to have a predictable and systematic approach to permitting and leasing within Federal waters to support and accelerate growth of a domestic aquaculture industry. As our colleagues and stakeholders 

stated during their testimony, the lack of Federal leadership in the permitting process not only slows the process, but hampers access to private investment, research, 

and development of the industry as a whole. The District supports legislation that 

provides NOAA with a leadership role in aquaculture development for our nation, 

including but not limited to: 

• Designating NOAA as the lead agency for aquaculture in Federal waters and 

creating a streamlined regulatory process, 

• Providing support for the National Marine Aquaculture Initiative (NMAI), including a mechanism for long term research and development support, and 

• Facilitating regional projects in support of sustainable offshore aquaculture industry Development 

We have worked with NOAA over the years in support of environmentally and 

economically important issues that affect our region and our Nation and very much 

look forward to engaging with the Department of Commerce to advance sustainable 

offshore aquaculture in our Nation. 

51 

The Time to Act Is Now 

The time is ripe for a forward-thinking strategy that embraces our natural resources. After all, our Nation’s independence depends on our ability to be self-reliant, and not depend on the resources of other nations. We believe that the solutions 

to our challenges are home-grown, and in San Diego, we intend to play a role in 

crafting those solutions. The District stands ready to commit our resources and experience in this area in collaboration with our partners and stakeholders. We have 

the expertise, infrastructure, relationships and marine based regulatory experience 

needed to substantially contribute to this successful venture. We are hopeful that 

the Department of the Interior and the current administration agrees with our assessment on aquaculture and can provide resources and regulatory assistance. 

The District stands ready to work with the Department of Commerce and other 

Federal agencies involved in the permitting process to advance aquaculture in our 

Nation and demonstrate the sustainable development of a domestic seafood industry 

that both creates jobs and lowers our dependence on seafood imports. 

We thank you for your leadership on these issues and look forward to working 

with you on behalf of the United States’ interests and the benefit of all those we 

serve. If you have any questions please do not hesitate to contact the President/ 

CEO, Randa Coniglio at 619–686–6201, or Job Nelson, Vice President, External Relations at jnelson@portofsandiego.org or 619–686–7274 

RESPONSE TO WRITTEN QUESTIONS SUBMITTED BY HON. ROGER F. WICKER TO

MARK LUECKE

Question 1. Is there a link between two reasons for slow domestic growth of aquaculture you identified, namely the ‘‘unavailability of investment capital to construct 

more fish production facilities’’ and ‘‘an inefficient regulatory pathway permitting 

fish production facilities’’? 

Answer. There is a direct link between an inefficient regulatory pathway permitting fish production facilities and the unavailability of investment capital to construct more fish production facilities, leading to slow domestic aquaculture growth. 

Capital sources, such as private equity investors and banks, will only provide capital to projects where there is (1) a clear understanding of risk and (2) a clear plan 

to manage that risk in order to generate a reasonable return on their invested capital. Given the current inefficiency and uncertainty experienced by organizations attempting to permit fish production facilities, capital sources are unable to obtain a 

good understanding of the regulatory risk, much less outline a regulatory management plan, and therefore, they do not place their capital at risk. 

This inefficiency and uncertainty stems from the lack of a clear regulatory pathway to place and retain fish production facilities in service. Without a defined lead 

agency at the Federal level for environmental review and approval of these projects, 

the U.S. will continue to experience a large and growing trade deficit in this critical 

food category. 

Private capital sources will simply not fund projects where there is inefficiency 

and uncertainty. 

Question 2. Should permits or leases for marine aquaculture production facilities 

be of a long enough duration for investors to have the opportunity to see a return 

on their investment? 

Answer. It is imperative that permits and leases for marine aquaculture production facilities be no less than ten (10) years, and preferably twenty (20) years, with 

an opportunity to extend that time period if all conditions of the permit and/or lease 

are being met. 

Quite simply, if permits or leases are not of a long enough duration for capital 

sources to generate a reasonable return on their invested capital, they will simply 

place capital in other projects in other segments of the market. This will cause the 

U.S. to continue to experience a large and growing trade deficit in this critical food 

category. 

Incentives for capital sources to participate in the domestic aquaculture market 

must be established to stimulate its growth, starting with long-term permits and 

leases. 

52 

RESPONSE TO WRITTEN QUESTIONS SUBMITTED BY HON. ROGER F. WICKER TO

DR. KELLY LUCAS

Question 1. What type of assurances—particularly related to permitting—do aquaculture businesses and entrepreneurs require to make offshore aquaculture more attractive to investors? 

Answer. Businesses need regulatory certainty to reduce the risk of investment. 

They need to know they can get a permit. There needs to be a streamlined, transparent, permitting process. They need one agency to take ownership of the permitting process. I would suggest NOAA can lead the process and can lead the necessary 

environmental reviews. Other agencies will still need to supply the permits necessary by law, but it would be efficient to have a designated agency coordinating 

the process. Industry needs permits that are long enough in terms of duration that 

they can not only capitalize the expenses, but they can see a return on their investment. They need certainty that they will be able to renew their permits as long as 

they abide by the regulations, monitoring and reporting requirements. 

Question 2. How can marine aquaculture be compatible with and supportive of the 

commercial fishing industry? 

Answer. First, we need make sure the message is clear that aquaculture is not 

trying to replace commercial fishing. World-wide, wild capture fisheries is stagnant 

and has been since the 1990s. We are fishing at maximum sustainable yield and 

in some cases over sustainable yield. In order to meet the increasing demand for 

seafood, aquaculture will be necessary but it will also be necessary for us to continue to have sustainable wild-capture fisheries. Offshore and nearshore aquaculture shares a lot of the same infrastructure and equipment in terms of working 

waterfronts, processing plants, seafood markets, boats and boat repair with the commercial industry and working together both industries can benefit. 

Question 3. What are the key research areas we ought to invest in to continue 

U.S. leadership in marine aquaculture? 

Answer. We need to invest in larviculture, genetics, aquatic health management, 

feeds, advanced technology and engineering. The development of hatchery capacity 

and refinement of culture techniques is vital to offshore development. Commercial 

operators need a reliable and consistent source of disease free larval fish. Some larval fish species can be reliably supplied, many other species that are high value and 

fast-growing lack sufficient research development. The use of selective breeding as 

a tool to increase production is far behind the plant and farm animal industries. 

Selective breeding of fish using genetics to aid selection can generally be completed 

in less time than breeding of farm animals. Domestication of new species and offshore culture will require monitoring and adaptive health management plans to reduce and prevent disease and outbreaks. Although we have made advancements in 

fish feed and have reduced reliance on forage fish, we should continue to identify 

alternative sustainable feeds for large-scale aquaculture. Improvements in net and 

cage technology have decreased chances of escapes; however, we can continue to improve containment systems with new materials and with remote detection technology. Unmanned systems and artificial intelligence can aid operators in task such 

as cleaning cages, feeding fish and detecting potential problems. 

Question 4. Does regulating marine aquaculture under the Magnuson-Stevens Act 

work? 

Answer. There is great concern among the industry and others that the Magnuson-Stevens Act (MSA) in not the correct tool to regulate marine aquaculture. 

Whereas the offshore aquaculture industry shares some things in common with the 

commercial fishing industry, regulating domesticated fish in a comparable manner 

as wild fish does not work. MSA is not the correct mechanism for regulatory elements such as permitting and aquaculture facility management and monitoring. 

Question 5. Why is genetics research important for marine aquaculture, particularly with respect to fish production, fish health, and interactions with wild fish 

stocks? 

Answer. Genetic level information and genome sequencing is important for wild 

fish stocks and to aid in aquaculture development. Population level genetic research 

has contributed to knowledge of how fish are structured into reproductive populations and how these populations are distributed. At TCMAC we use genetics to 

provide information about local populations of spotted sea trout. We use this information to isolate broodstock, ensure genetic diversity and release hatchery reared 

fish back into their watershed. The genetic markers can also be used to indicate if 

a captured fish was reared in the hatchery. Additionally, we use genetics to help 

assist with selection of species for breeding for commercial aquaculture applications. 

These genetic tools can aid in selecting against a genetic disorder or condition or 

53 

selecting for a value-added trait such as fast growth. These tools can also be used 

to select for entire genomes. The use of selective breeding as a tool to increase aquaculture production is far behind the plant and farm animal industries and selective 

breeding of fish can generally be completed in less time than breeding of farm animals. 

Question 6. Should permits or leases for marine aquaculture production facilities 

be of a long enough duration for investors to have the opportunity to see a return 

on their investment? 

Answer. The duration of the lease and/or permits should be long enough for industry to capture the cost of capital and make a profit on their investment. 

Question 7. Are there environmental benefits to locating marine aquaculture 

farms further offshore, such as in the exclusive economic zone? 

Answer. Open-ocean aquaculture can reduce some environmental concerns that 

we see in nearshore environments by siting farms away from sensitive habitats in 

deep waters with adequate currents the potential pollution would be reduced. 

Question 8. Would a permit to operate a marine aquaculture facility be sufficiently 

secure to provide investors with the certainty to invest in a marine aquaculture operation? 

Answer. There is concern with the industry that a permit only gives an individual 

or company the authority to operate and does not provide the property rights necessary to provide business security. If a company was conducting aquaculture in 

Mississippi state waters, the company would need a lease of the water bottoms and 

would also need a permit to conduct the aquaculture activity. Several states have 

similar models of requiring both a lease and a permit. 

RESPONSE TO WRITTEN QUESTIONS SUBMITTED BY HON. BILL NELSON TO

DR. KELLY LUCAS

Question 1. General Marine Aquaculture: What are your top recommendations for 

building a marine aquaculture industry while preserving our environment and traditional fisheries? 

Answer. Businesses need regulatory certainty to reduce the risk of investment. 

Congress should enact legislation to provide a regulatory framework for offshore 

aquaculture. The regulatory framework should be structured to provide an avenue 

for permit approval. One agency should be the lead for the permit process. I would 

suggest NOAA can lead the process and can lead the necessary environmental reviews. Other agencies will still need to supply the permits necessary by law, but 

it would be efficient to have a designated agency coordinating the process. 

Supporting aquaculture development by similar mechanisms used to support agriculture can help industry grow. The agriculture industry grew tremendously from 

public support of research occurring at universities, state and Federal laboratories 

and research stations spread across the Nation to bring techniques directly to farmers. Aquaculture can benefit from a similar approach of competitive research funding and extension funding to advance research and development. Advancement of 

aquaculture, especially selective breeding, health management and culture techniques can take multiple years for significant gains and long-term funding programs 

will be critical to success. 

Aquaculture can help expand our supply of local, safe, sustainable seafood. Fish 

are more efficient converters of feed to meat and the ability to produce a steady fish 

supply can meet the increasing demand for protein. We have robust environmental 

laws in the United States that help ensure we operate in environmentally safe manner. We also have regulations regarding fish health and treatment of fish for consumption. Open-ocean aquaculture can reduce some environmental concerns that we 

see in nearshore environments by siting farms away from sensitive habitats in deep 

waters with adequate currents the potential pollution would be reduced. We also 

should continue to grow land-based and near-shore aquaculture. Land-based aquaculture in recirculating closed loop systems is advantageous for numerous reasons. 

Some benefits of the controlled environment in recirculating systems is the increased biosecurity and ability to increase production through year-round growth. 

Water reuse through filtration and sterilization also increases the sustainability of 

closed-loop recirculating systems. The ability to locate the facilities in areas of market supply helps create local jobs and supplies safe, fresh, local, seafood for consumers. Near-shore aquaculture in the United States has been increasing. Shellfish 

aquaculture has increased significantly along all United States shorelines and seaweed aquaculture have been increasing in several regions of the United States. This 

54 

un-fed aquaculture in near-shore locations has environmental benefits of improving 

water quality and providing habitat. 

We need to think of aquaculture as diversification and not a replacement for commercial fishing. We need make sure the message is clear that aquaculture is not 

trying to replace commercial fishing. World-wide, wild capture fisheries is stagnant 

and has been since the 1990s. We are fishing at maximum sustainable yield and 

in some cases over sustainable yield. In order to meet the increasing demand for 

seafood, aquaculture will be necessary, but it will also be necessary for us to continue to have sustainable wild-capture fisheries. Offshore and nearshore aquaculture shares a lot of the same infrastructure and equipment in terms of working 

waterfronts, processing plants, seafood markets, boats and boat repair with the commercial industry and working together both industries can benefit. For recreational 

anglers off-shore and near-shore aquaculture creates habitat that attracts fish. Allowing anglers to fish near these structures can provide increased fishing opportunities. In addition to that bait fish can be cultured that benefit both the recreational 

and commercial industries. Both the commercial and recreational communities have 

benefited from stock enhancement and aquaculture-based restoration efforts. 

RESPONSE TO WRITTEN QUESTIONS SUBMITTED BY HON. CATHERINE CORTEZ MASTO

TO DR. KELLY LUCAS

Question 1. Las Vegas receives 42 million annual visitors and has a local population of around two million. We depend on a responsible and clean level of drinking 

water sources. Unfortunately we’re experiencing record-low water levels at Lake 

Mead. How can we ensure a balance of creating more aquaculture opportunities in 

the southwest, while also maintaining the dependable water sources we desperately 

need to survive and thrive? 

Answer. One suggestion I can offer is diversification of aquaculture to include recirculating aquaculture systems. Recirculating aquaculture systems operate by filtering water and cleaning the water to remove waste and reuse the water. Often 

the removed waste products can be used for alternate activities such as growing 

plants. Ponds can also be outfitted in ways to recirculate and filter water for reuse. 

Question 2. Electricity is obviously required for pumps used in aquaculture and 

aquaponics. Are there any studies on the use of renewable sources of energy to help 

maintain the power to these operations? 

Answer. The cost of electricity can be significant for aquaculture operations and 

businesses look for ways to reduce cost. One example of using renewable energy is 

the use of sunlight to grow algae. The algae can be the end product or can be used 

as feed for other aquaculture activities such as feed in a hatchery. Another example 

is the use of the tide to tumble oysters in a bag to create the desired oyster shell 

growth. Also, solar energy can be used for automated fish feeders and monitoring 

systems. There is ongoing research for using renewable energy in aquaculture and 

as renewable energy technology increases so will numerous uses for this technology 

in aquaculture. 

Question 3. Are there opportunities to utilize geothermal technologies specifically 

that you have seen in your work? 

Answer. Geothermal energy is used in aquaculture to heat water for ponds, raceways and tanks. Geothermal energy can also be used to heat greenhouses and aquaculture facilities. 

RESPONSE TO WRITTEN QUESTION SUBMITTED BY HON. ROGER F. WICKER TO

BARTON SEAVER

Question. From your experience in Maine, how can marine aquaculture be compatible with and supportive of the commercial fishing industry? 

Answer. In Maine, as is true in many fishing communities, we have seen the 

proud tradition of wild fisheries atrophy in the wake of mismanagement, foreign 

competition, and changing habitats. And yet these communities somehow remain resilient, finding ways to continue to pursue the iconic profession of fishing on the 

open water. 

Wild fisheries have a long and strong tradition of apprenticeship, where the older 

generation passes its skills and knowledge on to the upcoming generations through 

side-by-side collaboration. But a serious issue facing wild fisheries is the graying of 

the fleets. As rural communities and less profitable fisheries are less able to attract 

young labor the average age of fishermen is increasing. The aquaculture industry 

55 

represents an exciting combination of technology, innovation, environmental stewardship and sustainable food production that can attract younger residents. 

But this does not have to devolve into a competition between the two industries, 

between generations. Rather, it is a perfect opportunity for the experienced fishermen and women to serve as mentors to the budding aquaculturists, sharing their 

knowledge of the local ecosystems, best economic and sustainability practices, and 

navigation of the supply chain. By participating in the growth of a young aquaculture industry, experienced fishermen and women are celebrated for their heritage 

and can serve as catalysts to a new economy, fostering the emerging workforce that 

will settle into coastal communities and maintain their vibrancy. 

In Maine, there are over 4,000 individual, owner-operated lobstermen and women 

who already possess the transportation equipment, have established a sophisticated 

cold storage supply chain, and built the markets to successfully distribute and sell 

seafood. Much of the risk and cost involved in an aquaculture start-up is the creation of these systems beyond the farm itself. The existing support systems, as well 

as the people already working the water could allow rural coastal economies to diversify into farming to augment their wild capture. 

RESPONSE TO WRITTEN QUESTIONS SUBMITTED BY HON. BILL NELSON TO

BARTON SEAVER

Question 1. General Marine Aquaculture: What are your top recommendations for 

building a marine aquaculture industry while preserving our environment and traditional fisheries? 

Answer. It is my belief, and I can point to many examples of collaboration in my 

home state of Maine, that wild fisheries and marine aquaculture not are inherently 

at odds. The existence of one, does not diminish the other in anyway. But to answer 

your question more directly, I do have recommendations that could help both thrive 

at the same time. 

• I recommend the United States heavily invest in the development of modern 

aquaculture much in the same way it invested in the development of the agriculture industry post World War II. Making more seafood available to more 

Americans will raise the consumer confidence in, and the market value of, both 

wild caught and farmed seafood. A made-in-the-USA label is a powerful mark 

of civic and economic virtue. Investing in aquaculture as a national priority will 

send a very clear message calling needed attention to the opportunities for this 

Nation to better utilize our marine resources. 

• I recommend that we as a nation ensure that best fish farming practices are 

followed to protect the environment, wild fisheries and our citizenry. But I also 

recommend that specific regulations in any given region be implemented with 

a firm understanding of that region’s maritime culture and heritage. 

• I recommend the government invest in community and economic development 

programs based on an apprenticeship model through which wild fishery and 

aquaculture participants can find mentorship opportunities in each other and 

create cross-industry collaborations. 

Question 2. Mr. Seaver, as a restaurant owner and chef you have seen first-hand 

the expectation consumers have about the quality, origin, and nutritional value of 

the food they eat. How would consumers benefit from more marine aquaculture? 

Answer. It is important to recognize that seafood is categorically one of the 

healthiest foods humans can eat. As a matter of public health, we must work to increase seafood consumption just to meet our own government’s recommendations for 

twice weekly consumption of fish for every American. A limiting factor in seafood 

consumption to date is a neutral, or often negative, perception of farmed seafood. 

It is not a stretch to say that developing the United State aquaculture industry as 

a trusted source for seafood would lead to increased consumer confidence and consumption. 

Question 3. What kind of regulations or standards for marine aquaculture do you 

see as necessary to preserve the health and safety of consumers and the environment? 

Answer. There are excellent standards for industry best practices that are constantly evolving due to emerging science and technological innovation. While I am 

not an expert and defer to others on specific regulations, I can state with confidence 

that we know how to farm seafood in environmentally friendly ways that produces 

healthy food. 

56 

RESPONSE TO WRITTEN QUESTIONS SUBMITTED BY HON. EDWARD MARKEY TO

BARTON SEAVER

Question 1. Senator Wicker and I worked together to help create the Seafood Import Monitoring Program, which was just fully implemented at the beginning of this 

year. This program will help reduce Illegal, Unreported, and Unregulated (IUU) 

fishing for specific species because it requires importers to include data on where 

and when the fish was landed and who landed it. However, this data is not consumer-facing. In your restaurants, you highly valued traceability and trained your 

staff to tell the story of how each customer’s fish arrived on their plate. How can 

we expand these stories beyond high-end restaurants and make them more accessible to consumers on a daily basis—from fast food to supermarkets? 

Answer. I believe traceability from dock to dish must take many forms, each one 

suited to the particular type of operation in which it is practiced. 

In white table cloth restaurants, we have the luxury of extended customer engagement and the flexibility of daily changing menus that reduce the risk of offering new 

products. We have the time to tell every detail of the fish’s origin, but if it doesn’t 

sell well, we can take it off the menu the next day without too much monetary loss. 

But in the case of a large food service operation—where the customer interaction 

is shorter and purchasing a variety of seafood products comes at a cost. Often there 

is a lower level of culinary skill and thus less ability to adapt to the nuances of variable sourcing. In such operations it is common to find menus that consistently list 

a single species that must be sourced from wherever it is currently available. In 

such cases it is more appropriate to communicate an operator’s commitment to a 

considered set of civic and environmental values regarding the fish being served. It 

is rare in such scenarios that it is feasible to list the specific fishing boat that captured it. The solution is to commit to sourcing from certain regions where the fish 

is sustainably managed and to communicate region or provenance as the best means 

to connect the ingredient back to the producer community. 

The point is to elevate American seafood in general as a trusted seal of quality 

and sustainability. Just as the Magnuson-Stevens Act serves to validate Americancaught seafood as sustainable, so would a robust national aquaculture policy based 

on best practices and the best science provide the same level of confidence in farmed 

seafood. 

Question 2. The Cape Cod Commercial Fishermen’s Alliance in Massachusetts has 

been working with the seafood distribution company Sea to Table to build domestic 

markets for locally caught spiny dogfish. Spiny dogfish is not well known to American consumers, but is delicious in fish and chips, or in tacos. How can we expand 

these sorts of programs so that Americans can enjoy local, plentiful fish that they 

might not currently recognize by name or appearance? 

Answer. Dogfish has long been the bane of fishermen in New England. It was an 

unwelcome catch when the profitable cod was the target. And despite its abundance 

and affordable price it has never enjoyed any significant popularity at market. To 

counter this our government undertook multiple efforts to advertise its qualities, 

even promoting its use as a ‘‘fighting food’’ for those on the home front. It was even 

marketed under a variety of more romantic names such as Harbor Halibut, Mustel, 

and Cape Shark. 

Personally I never have understood the problem with the name dogfish. We eat 

plenty of catfish in this country with no complaint. But these efforts never amounted to any lasting economic impact for fishermen. Although history would suggest 

that there is something less desirable about dogfish, it is simply due to a lingering 

cultural bias that has unfairly regarded this truly delicious fish as a stain upon creation. But as has been proven by the Sea to Table efforts, when stripped of any stigma, consumers find it to be among the tastiest of all the white-fleshed fish varieties 

common to New England. 

And that leads to my recommendation that we educate chefs and consumers about 

seafood by focusing on the culinary qualities of the fish rather than the species 

name. Dogfish cooks the same as cod as haddock as cusk as hake . . . While a consumer might not know what hake tastes like they certainly know what flaky whitefleshed fish tastes like. The best place to implement such education programs is in 

college and university food service operations. Students are often willing to experiment and try new ingredients. And it offers a logistically simple but high volume 

and high impact means to sell product and to influence future consumers. But 

foodservice operators are hesitant to take risks on serving something the students 

will reject and end up wasting. Education initiatives subsidized by state extension 

or Sea Grant programs can help reduce the financial pressure and risk in introducing new fish. And once the students approve, the market is there, and companies 

57 

like Sea to Table and community organizations like the CCCFA are then able to 

supply those markets and connect students with producers. 

Seafood cookery is unnecessarily complicated by our irrational preferences for a 

single species or another. I know too many people who swear by rockfish but swear 

off striped bass (they are actually the exact same fish). When we start with the familiar, say a fish taco, all of a sudden the dogfish inside isn’t so exotic. I by no 

means condone fish fraud. We must always label seafood as the species it is. But 

why try to sell dogfish when you can much more easily sell a fish taco made with 

dogfish. Sell the dish and not the fish. It’s a simple method that allows consumers 

to engage with fisheries in a rational way. Instead of demanding of the oceans and 

of fishermen only cod, we must ask of them what they are able to provide. In doing 

so we shift the entire economy of fisheries from one based on irrational demand to 

one based on sustainable supply. Sustainable meaning that it is often better for the 

environment and it allows fishermen to earn the deserved value of whatever delicious fish they happen to haul up. 

RESPONSE TO WRITTEN QUESTIONS SUBMITTED BY HON. CATHERINE CORTEZ MASTO

TO BARTON SEAVER

Question 1. It is not a stretch to say that developing the U.S. aquaculture industry as a trusted source for seafood could lead to increased consumer confidence and 

consumption, correct? 

Answer. Yes, I believe that to be true. A robust American aquaculture industry, 

regulated for safety and environmental sustainability, would result in increased consumer confidence in and consumption of American seafood. 

Question 2. How we do ensure that low-income individuals and families can still 

have access to this dietary benefit? 

Answer. As the aquaculture industry matures, there will be technological advances made and efficiencies realized that will reduce the cost of American seafood 

to the consumer. It is also important to note that aquaculture isn’t limited to farming fish in the oceans. There are technologically advanced self-circulating systems 

used to farm many species of fish that can be set up in an old warehouse in Detroit 

or in an empty strip mall in rural American. Not only will these aquaculture operations provide increased access to fish in these areas, they could also result in employment opportunities. There are great examples of these systems such as an 

urban farm in Milwaukee where visionary community member Will Allen has proven both nutrition and community benefits result from these efforts. 

Question 3. Furthermore, how can we make it economical enough to allow for its 

viability in food assistance programs and its inclusion in the school lunches that 

often is the main source of nutrition and comprehensive meals for millions of American youth? 

Answer. Given the prodigious potential for aquaculture production, strong governmental support for growth in this industry, much like was done for agriculture commodities, could lead to a scale of production that will enable the farming of healthy, 

nutritious seafood that will fit within the tight budgetary parameters of food assistance and school lunch programs. There are great programs already being implemented for getting more wild-caught seafood at affordable prices into the schools, 

institutions, and food assistance programs in both Massachusetts and Maine. These 

programs, like the Mass Farm to School initiative that embraces seafood as a basic 

tenet of its program (https://www.massfarmtoschool.org/announcement/sea-toschool-takeaways/) could serve as models for farmed fish distribution and consumption in those venue across the country. 

RESPONSE TO WRITTEN QUESTIONS SUBMITTED BY HON. ROGER F. WICKER TO

DONALD B. KENT

Question 1. What type of assurances—particularly related to permitting—do aquaculture businesses and entrepreneurs require to make offshore aquaculture more attractive to investors? 

Answer. As in any enterprise, investors are looking for some assurance of an investment return, and to realize that return, permits are needed to not only allow 

the business to operate, but to also shape the scope of the operation and to define 

operational protocols. Here in the U.S., we have many of the required operational 

protocols understood because of existing laws and regulations for operating in U.S. 

waters and for growing food, but what we lack is any assurance of acquiring the 

permits because the permitting process is not clearly delineated and many years 

58 

and millions in investment can be wasted trying to acquire permits. In juxtaposition 

to this is Mexico, where a very clear permitting path is laid out, and permits can 

be acquired within a six month time frame at a cost of about $50,000. Because of 

this reliability, American investors seek Mexican partners and operate their farms 

in Mexico and then sell the seafood back into the U.S., even though the resulting 

product may not meet our rigorous environmental and public health regulations. I 

do not mean to suggest that imported seafood is unsafe, only that it is more difficult 

to ensure that it meets our standards if we are not growing it ourselves. What is 

needed is a consistent, well-defined permitting pathway that builds upon existing 

U.S. laws and regulatory processes and that can be applied across the Nation so to 

allow investors. This pathway should: 

• Reiterate the authorities assigned by existing law to agencies (e.g., issuance of 

Section 10 permit by U.S. Army Corps of Engineers, issuance of NPDES permit 

by EPA). 

• Require the issuance of an Aquaculture Permit by NOAA Fisheries for any farm 

located in Federal waters outside state coastal jurisdiction. 

• Reaffirm State’s authorities and responsibilities under the CZMA. 

• Establish that NOAA Fisheries should be the lead agency for NEPA review 

based on its aquaculture, marine resource, and NEPA expertise 

• Define the criteria by which the extent of the NEPA review (i.e., Environmental 

Assessment or an Environmental Impact Statement) will be decided. 

Question 2. How would ports and working waterfronts benefit from a growing marine aquaculture industry? 

Answer. Our nation’s marine fisheries are well managed and many that had been 

over-exploited are now harvested sustainably thereby providing longer-term security 

in the supply of those harvested species. But, we all know relying only on domestic 

fisheries isn’t enough, especially if we have had to curtail harvests to ensure longterm sustainability. Aquaculture holds the promise of keeping working waterfronts 

working. 

Much of the infrastructure needed to support commercial fishing (dock space for 

loading/unloading, ice machines, fish processing, fuel, covered storage space, etc.) is 

also needed for farming operations. The primary difference is that commercial fishers harvest wild fish and farmers harvest farmed fish and both need space on-shore 

to support their open ocean operations. By supporting both commercial fishing and 

farming, our Nation’s ports will get a double return on their investment in this infrastructure and realize a far greater economic return as a result of job creation and 

support. 

Question 3. Can you describe in detail the employment opportunities offered by 

an offshore marine finfish aquaculture operation? 

Answer. Marine farms provide a wide range of opportunities for job creation. Direct jobs on the farm represent an opening for commercial fishers who have existing 

skill sets (piloting vessels in rough seas, harvesting fish, managing nets, etc.) that 

are needed for working in the open ocean environment. Besides the direct jobs on 

the farm raising fish, there are jobs associated with processing and distributing the 

farmed product, maintaining vessels, delivering feed and other business support activities. For the farm we propose off the coast of southern California, the San Diego 

Economic Development Corporation predicts that on top of the 72 jobs created by 

farm operations, an additional 300 jobs would be created and supported by the farming operations. This seems consistent with studies conducted in Canada where they 

found that for every thousand tons of salmon production, there are 43 jobs created 

and supported over the long term. Using that rough estimator, a regional increase 

of 100 thousand tons of fish production in the open ocean would support over 4,000 

new jobs in and around the farms’ region of operations. 

Question 4. Would a permit to operate a marine aquaculture facility be sufficiently 

secure to provide investors with the certainty to invest in a marine aquaculture operation? 

Answer. Many industries rely on permits as their primary method of government 

regulation that guides their operations. For example: 

• Business permits issued by a municipality to operate in a given community. 

• Specialty permits for truck drivers to operate long haul vehicles across the Nation. 

• Licenses for certifying the qualifications of doctors, lawyers, CPAs and other 

professionals. 

59 

Permits are the interactive system by which our government regulates industry 

on a day-to-day basis. What is expected in permits from Federal agencies (U.S. 

Army Corps of Engineers, U.S. Coast Guard, EPA) for offshore farms are conditions 

to the permits developed to evaluate, avoid or mitigate and monitor for possible environmental effects and impacts to other users. These would be developed as part 

of the NEPA review and regulatory permitting process. As long as the conditions 

are not unnecessarily restrictive, then the resulting permits are adequate to allow 

appropriate farming operations. 

Question 5. Should permits or leases for marine aquaculture production facilities 

be of a long enough duration for investors to have the opportunity to see a return 

on their investment? 

Answer. Permits or leases HAVE to be of long enough duration to allow profitability. An offshore farming operation is capital intensive and the profit margins, 

like most farming operations, are not that high, so adequate time has to be allowed 

to permit a return on the investment. A typical scenario would require two years 

to acquire permits, a year of mobilization, and at least one year, probably two, for 

product to enter the market. A 2,000 ton farm would likely require and investment 

of at least$15 million, with annual sales not commencing until at least year five 

with profitability realized sometime after that. A ten-year permit would mean that 

a farm would only have three or four years to realize an investment return. 

Permits or leases should act like drivers’ licenses: 

Here is the rule book to go with your license. Don’t break the rules, and we’ll 

let you keep driving. The rules may change, and you will have to adapt to the 

changes, but you need to follow them if you want to keep driving. We may ask 

you to ‘‘renew’’ your license, but as long as you have a good driving record and 

are still capable of driving the car, the State will renew your license. 

A responsible farm operator, even after 20 years of business, should be able to 

continue farming without having to go through the entire permitting process again. 

If it is not significantly impacting the environment and is meeting the Nation’s need 

for seafood, then permits should be renewed. 

RESPONSE TO WRITTEN QUESTIONS SUBMITTED BY HON. BILL NELSON TO

DONALD B. KENT

Question 1. General Marine Aquaculture: What are your top recommendations for 

building a marine aquaculture industry while preserving our environment and traditional fisheries? 

Answer. I feel we have significant existing regulatory safeguards in place to ensure that a use of the EEZ for marine farming will not have adverse impacts on 

traditional fishing communities, the environment or other user groups. What is 

needed is a consistent, predictable, efficient permitting process. This would require: 

• Clearly defining the permits required to operate in the EEZ and reaffirm the 

limits of the legal authorities of permitting agencies to issue permits: 

» U.S. Army Corps of Engineers permit under Section 10 of the Rivers and Harbors Act of 1899 (33 USC 403) which prohibits the obstruction or alteration 

of navigable waters of the United States without a permit. 

» Clean Water Act authorizes the EPA to regulate point sources that discharge 

pollutants into waters of the United States through the National Pollutant 

Discharge Elimination System (NPDES) permit program. 

» The U.S. Coast Guard issues permits for Private Aids to Navigation (PATON) 

which includes lighted structures, lighted and unlighted buoys, RACONs 

(interactive RADAR transponders) and fog signals, which are installed and 

maintained by anyone other than the Coast Guard. Such a permit would 

specify the navigational aids needed for an offshore farm to avoid impacting 

the operations of other vessels in the area. 

• A missing link at this time is a specified lead agency for the requisite National 

Environmental Policy Act review for all federally issued permits. When only one 

Federal permit is required, then the permitting agency is required to conduct 

a NEPA review to ensure that public concerns over prospective environmental 

impacts are addressed. However, when multiple Federal permits are required, 

as with offshore fish farms, then the NEPA review should be combined into a 

single, coordinated NEPA review process that is led by a ‘‘lead agency’’. The resulting environmental review document can then be used to condition the permits issued by the respective agencies. For consistency across all coastlines, it 

is important that a single agency be identified nationally as the lead agency for 

60 

the NEPA review. In my opinion, the lead agency should be NOAA Fisheries 

for the following reasons: 

» The majority of the environmental concerns regarding fish farming are the direct responsibility of NOAA line agencies: 

» Impacts to protected resources like marine mammals, endangered species, 

habitat areas of particular concern, etc. are managed by NOAA Fisheries 

» NOAA’s National Ocean Service is responsible for interactions with state 

coastal resource management agencies under the Coastal Zone Management 

Act and provides resources to coastal zone managers to adequately assess potential impacts. States with approved management plans would have review 

for ‘‘consistency’’ which is best coordinated by NOAA. 

» NOAA’s NOS has developed an extensive array of tools including: 

• GIS based tools that identify potential farming sites by delineating bathymetric 

requirements needs while assessing the potential for interactions with other 

user groups and/or protected resources. 

• Photographic analysis systems that assess visual impacts of farms to coastal 

residents and user groups 

• Water quality predictive models that evaluate site specific characteristics 

(depth, current speed and direction, water temperature, etc.) to assess potential 

impacts to the water column and benthic habitats and mitigate them. 

» NOAA Fisheries has the most comprehensive experience in the subject area 

of aquaculture impacts as well as the most experience in conducting NEPA 

reviews. 

» Collectively, these actions will act to incentivize American investors to keep 

their capital investments here thereby creating a new paradigm for domestic 

seafood production toward higher food security, lower transport costs, more 

American jobs, a larger tax base and rebirth of our working waterfronts. 

Question 2. Aquaculture Facility Siting: Mr. Kent, the ocean is very important to 

my state, especially for fishermen. As industries advance, we continue to see competing demands for the use of our Nation’s waters. Where is the ideal location for 

an aquaculture facility and how should the government sort through competing 

ocean uses? 

Answer. I agree that the health of the ocean environment around Florida is by 

far the State’s most important asset as it contributes significantly to the quality of 

life of Floridians and the millions of annual visitors and ocean health is critical to 

the Florida economy. Tourism, military operations, commercial and recreational 

fishing are all critical components of Florida’s economy and are all reliant on maintaining a healthy ocean ecosystem. 

Relative to where to locate farms off the shores of any of our Nation’s coastal 

states and the Great Lakes, NOAA’s National Ocean Service has developed GIS 

based analytical protocols that can be used to answer that question. Bathymetric 

information exists in databases accessible to NOAA and can be used to identify 

areas where it is presently practical to site farms (e.g., between 100 to 300 feet of 

depth). Much of our Nation’s EEZ is too deep to accommodate the present mooring 

technology used in offshore farming. After determining where farms can be practically located, other databases can be accessed to further refine the locations by 

identifying sites that have adequate, but not excessive, current flows which act to 

maintain water quality for fish health and avoid degradation of the environment. 

These areas can then be reviewed to avoid show sensitive habitats, user groups 

(fishing, energy production, military operations, transportation, etc.), navigational 

conflicts, migratory pathways and other possible conflicts. After this type of vetting 

process all of which could be conducted by Federal agencies (e.g., U.S. Navy, BOEM, 

U.S. Army Corps of Engineers, EPA, U.S. Coast Guard) interacting directly with 

NOS technical staff, the resulting areas should then be available with a far easier 

environmental review since the majority of the potential conflicts would have already been addressed in the site analysis process. 

Question 3. Technology Use: Mr. Kent, I am an advocate for capitalizing on new 

and innovative technology. How is technology being used in the monitoring and inspection of marine aquaculture? What types of systems could be used in Federal waters? 

Answer. Because of the rigors of the open ocean, farms located in Federal waters 

will need to be regularly inspected and maintained. Unlike fish farms located within 

enclosed embayments, offshore farms will need to withstand high wave and wind 

conditions not typically found in near-shore areas. Because of the relative depth (up 

61 

to 300 feet), it would be difficult, hazardous and expensive to rely solely upon 

SCUBA divers to inspect mooring and cage systems on a regular basis. Fortunately, 

over the past few decades there have been significant advances in the development, 

versatility and availability of remotely operated vehicles equipped with high resolution cameras and lighting that are capable of regular use at the required depths of 

operation. These ROVs can replace divers for the majority of the inspections required to maintain operational integrity and safety on offshore farms. 

Large volume cages are now available that can be submerged whenever weather 

becomes problematic. Feed systems are available that can feed multiple cages without wasting feed thereby reducing the potential for adverse impacts. Cleaning systems are available that keep nets clean of fouling organisms which decreases hydraulic drag and improves water flow. New RADAR transponder technologies are 

available for automatic warning and avoidance of potential collisions. 

Question 4. What have been the technological improvements over the last decade 

in reducing the environmental impacts of marine aquaculture? 

Answer. As mentioned above, computer based site analysis can reduce conflict 

with other user groups, minimize interactions with protected resources and ensure 

minimal, if any, impacts on water quality. 

Feeds are no longer completely reliant on fish meal as their primary source of protein and oil. Diets can use vegetative protein, protein from fish processing, bacterial 

protein from agricultural waste fermenters, black fly larvae grown on garbage and 

processing waste from other livestock sources. 

Simulation modeling can be used to site farms in locations where the depth and 

adequate current flow can combine to make the presence of farms chemically 

undetectable and thereby avoid any impacts on water quality. 

Farms can be sited far enough offshore as to make them practically invisible to 

people standing on the shoreline thereby avoiding aesthetic impacts to the coastal 

zone. 

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