NATIONAL AND STATE TRADE ASSOCIATIONS CHALLENGE FRANZ DECISION

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On December 7, a group of leading national and state trade associations sent a letter to Washington Public Lands Commissioner, Hilary Franz, denouncing her political decision to terminate the leases of one of our valued members, Cooke Aquaculture Pacific, and–taking it one step further–ending commercial marine net pen fish farming in the state. Forever.

The text of the letter, with signatories, follows:

Dear Commissioner. Franz:

We, the undersigned, wish to express our collective concern regarding Commissioner’s Order #202211, dated November 17, 2022, directing Department of Natural Resources (DNR) staff to “develop necessary changes to agency rules, policies, and procedures to prohibit commercial net pen aquaculture on state-owned aquatic lands” in the state of Washington, and to demand a third-party review of the science upon which this Order is based.

We represent a broad range of US national, state, and species-specific trade associations whose members either produce or harvest seafood that is destined for both domestic and international markets. Signers also include fisheries scientists, resource economists, veterinary medicine professionals, and other industry stakeholders who —in addition to being concerned about the lack of historical data and peer-reviewed science that would support your Order—are equally concerned about the apparent unilateral and unsupported exercise of government power that does not demonstrate thoughtful, constructive thinking and fairness.

In addition, we find it troubling that the Order:

  1. Fails to cite any credible, peer-reviewed analysis or analyses:
  2. Fails to refer to an independent third-party (or even other State agencies) supporting the Order;
  3. Ignores the recommendations in the April 2022 Washington Department of Ecology document fulfilling a requirement of House Bill 2957 (2018) ordered by the Washington state Legislature, “Commercial Marine Finfish Net Pen Aquaculture in Puget Sound and Strait of Juan de Fuca: Guidance and Risk Management” (Publication number 22-06-008);
  4. Fails to acknowledge the 40+ years of science that federal and state agencies, including the DNR, have conducted regarding marine aquaculture—science which exists to help inform decision-makers on how to strike a balance between environmental conservation and aquatic food production.

We do not argue that aquaculture is without impact or risk. Zero impact or zero risk is an impossible standard that no food production system can live up to. At the same time, however, marine aquaculture from domestic production helps reduce the carbon footprint from imports.

Given the fact that the commercial net pens affected by this Order occupy approximately .0004% of total state-owned aquatic lands, we believe that a third-party review is needed to show that the Order has no basis in scientific fact and is, in essence, an unsupported action by a government agency.

There are several possible candidates for conducting such a review, and we sincerely hope you and your staff have sufficient confidence in either the University of Washington School of Aquatic and Fishery Sciences, the National Marine Fisheries Service, and/or the NOAA National Center for Coastal Ocean Sciences as capable of examining an action that most of the US seafood industry believes to be just plain wrong.

We look forward to hearing from you.

Respectfully,

Jeanne McKnight, Ph.D., Executive Director

Northwest Aquaculture Alliance

Jim Parsons, CEO

Jamestown Seafood

President, Northwest Aquaculture Alliance

Linda A. Chaves, M.S.

Senior Advisor on Seafood and Industry Issues, NOAA (Retired)

NOAA National Aquaculture Coordinator (Retired)

 John Dentler, Esq.

Chairman, Kurt Grinnell Aquaculture Scholarship Foundation

President Emeritus, Northwest Aquaculture Alliance

Walton W. Dickhoff, Ph.D.

NOAA Fisheries Senior Scientist (Retired)

University of Washington Professor of Fisheries (Retired)

John Forster, Ph.D.

Stolt Sea Farm Washington – General Manager (1984-1994)

Columbia River Fish Farms – Co-Owner (1994-2001)

Frederick Goetz, Ph.D.

NOAA Fisheries Biologist (Retired)

Professor Emeritus, University of Wisconsin-Milwaukee

Robert N. Iwamoto, Ph.D.

Northwest Fisheries Science Center – NOAA (Retired)

Don Kent, M.S.

President/CEO – Hubbs Sea World Research Institute

 Hugh Mitchell, M.S., DVM

Aquatic NW Veterinary Services

John Moehl, Ph.D.

Senior FAO Aquaculture Officer (Retired)

Aquaculture Specialist – Realized Expectations/AFFIRM

 Stephen G. Newman, Ph.D.

President/CEO – Aquaintech Inc.

Gil Sylvia, Ph.D.

Professor Emeritus, Department of Applied Economics – Oregon State University

Director, Coastal Oregon Marine Experiment Station (Retired)

US State and National Trade Associations

 Tony Vaught, President

California Aquaculture Association

 Robert Rheault, Ph.D., Executive Director

East Coast Shellfish Growers Association

 Tiffany Conner, Education Coordinator

Florida Aquaculture Association

 Paul Hundley, Founding Director

Florida Marine Aquaculture Coalition

 Brian Perkins, CEO

Global Seafood Alliance

Ronald P. Weidenbach, President

Hawaii Aquaculture and Aquaponics Association

 Sebastian Belle, Executive Director

Maine Aquaculture Association

Dan Vogler, President

Michigan Aquaculture Association

Paul Zajicek, Executive Director

National Aquaculture Association

 Gavin Gibbons, Vice President

National Fisheries Institute

Clinton Bentz, President

Oregon Aquaculture Association

Bill L Lynch, President

Ohio Aquaculture Association

 Fritz Jaenike, Executive Director

Texas Aquaculture Association

Mark Ely, President

US Trout Farmers Association

 Cc:

Governor Jay Inslee

Senator Andy Billig, Senate Majority Leader

Senator John Braun, Senate Republican Leader

Representative Laurie Jinkins, Speaker of the House

Representative Joe Fitzgibbon, House Majority Leader

Representative J.T. Wilcox, House Republican Leader

Senator Kevin Van De Wege, Chair – Senate Agriculture, Water, Natural Resources & Parks Committee

Senator Judy Warnick, Ranking Member

Representative Mike Chapman, Chair – House Rural Development, Agriculture, & Natural Resources Committee

Representative Bruce Chandler, Ranking Member

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