*** ACTION ALERT ***

23 October 2008

The National Organic Standards Board had proposed "organic standards for net pens and fish feed" for farm-raised fish, and is accepting comments on these two proposals until Monday, November 3rd.

The development of U.S. organic standards for aquaculture could potentially help alleviate and reverse the environmental and human health impacts associated with currently used harmful industrial aquaculture methods. In order to realize these benefits, however, any organic aquaculture standards must be stringent, and reflect a primary commitment to developing low impact and sustainable production methods.

Unfortunately, the latest round of the development of Organic Aquaculture standards -- NOSB Livestock Committee Proposed Organic Aquaculture Standards for Net Pens and Fish Feed -- does not comply with organic principles.  CFS opposes both proposals because, if approved, they will fatally undercut any future organic aquaculture standard.

If there is to be a meaningful USDA organic standard for aquaculture, our regulators need to face the reality that some types of fish farming are simply not possible to be made organic because they require environmentally damaging activities.  Farming large predatory fish like salmon in open water net pens will lead to escapes and harm to our oceans' wild fish stocks and biodiversity.  Allowing the use of wild-caught fish to feed "organic" fish is unlawful and misleading to the public, and will also harm our oceans by further depleting forage fisheries.

Send a letter to the following decision maker(s):
NOSB Organic Aquaculture Proposal

Below is the sample letter:

Subject: Proposed Organic Aquaculture Standards

Dear [decision maker name automatically inserted here],

Ms. Valerie Frances
Executive Director
National Organic Standards Board
USDA-AMS-TMP-NOP
1400 Independence Avenue, SW
Room 4008 - So., Ag Stop 0268
Washington, DC 20250-0268

Comments on National Organic Standards Board (NOSB) Livestock Committee

Proposed Organic Aquaculture Standards: Fish Feed and Related Management Issues (September 28, 2008) Net Pens and Related Management Issues (September 28, 2008).

I am writing to urge NOSB to reject the Proposed Organic Aquaculture Standards: Fish Feed and Related Management Issues, and Net Pens and Related Management Issues.

The development of National Organic Standards for aquaculture could potentially help alleviate and reverse the environmental and human health impacts associated with current industrial aquaculture production methods. In order to realize these benefits, however, the resulting organic aquaculture standards must be stringent and reflect a primary commitment to developing low impact and sustainable production methods.

Unfortunately, the latest round of the development of Organic Aquaculture standards -- NOSB Livestock Committee Proposed Organic Aquaculture Standards for Net Pens and Fish Feed -- does not comply with organic principles. Adoption of both proposals would fatally undercut any proposed USDA organic aquaculture standard and I urge the full Board to reject them.

I am specifically concerned about the following issues:

Net pens:

The proposed "organic" fish farming of large carnivorous and migratory fish such as salmon in open-water net pens runs contrary to the letter and spirit of organic food production, which is to produce safe, high-quality foods in an environmentally sustainable fashion.

Fish farming in open water net pens cause a number of environmental harms. Containing escapes is known to be impossible and the large numbers of farmed fish already invading our oceans is having a significant and profound impact on the biodiversity among wild fish species.

There are also significant negative health impacts from pollutants and toxins in open water net pen raised fish. Organic foods, whether from plants or animals, are produced under conditions that can be controlled. This cannot be said for fish grown in the open ocean, where they are exposed to and ingest or absorb many types of industrial and agricultural toxins. Producing fish this way may be a driving force in the fish farming market, but that is not enough reason to mislead consumers by applying to it an organic label.

Fish feed:

Wild caught fish should not be certified as organic and should not be used as food for organic fish. Wild fish are not and cannot be certified "organic," nor can they be certified as "organic" feed.

Using forage fish to grow larger fish is not an environmentally friendly farming method and should not be mislabeled or endorsed as "organic." The practice increases pressure on our ocean's already depleted fisheries. Scientists estimate that producing one pound of farmed fish like salmon requires harvesting more than twice that amount of wild-caught forage fish!

In addition, farmed fish contain much higher levels of environmental contaminants than do wild fish because they are fed a diet that is high in fish oils and fish meal which is primarily obtained from small pelagic fish. There are significant human health risks in consuming toxic environmental contaminants such as these.

If there is to be a meaningful organic standard for aquacultur e, NOSB needs to face the reality that some types of fish farming are simply not possible to be made organic because they necessarily require environmentally damaging activities.

I strongly urge you to reject these proposals.

Sincerely,

on the regulations.gov website, so please be advised not to share any information you do not wish to be publicly posted, such as your street address or phone number. No email addresses will be sent or shared.

Due to the difficulty members have had in submitting comments via the agency website, we will collect your comments and submit them to the agency at the close of the comment period on November 3rd.

Campaign Expiration Date:

November 3, 2008