NOAA to Develop a Work Plan for Federal Regulation of Aquaculture

On October 9, 2019, the National Oceanic and Atmospheric Administration (NOAA) released for public comment a draft outline of a work plan for a Federal Aquaculture Regulatory Task Force. The purpose of the Aquaculture work plan will be “to address the Federal strategic goal of improving regulatory efficiency and predictability for domestic freshwater and marine aquaculture.” Aquaculture will, in coming years, play an increasingly important role in the provision of fish protein to a burgeoning global human population. It is vitally important that the U.S. regulatory structure applicable to this critical industry be based on science-based risk assessments. Interested parties should take the opportunity to comment on NOAA’s draft aquaculture work plan outline to emphasize that the final Work Plan must recognize and emphasize the critical importance of science-based decisionmaking in future regulatory actions related to aquaculture.

According to a 2018 report from the United Nations Food and Agriculture Organization (FAO), in 2016 aquaculture provided 53 percent of all fish protein consumed by humans. The State of the World’s Fisheries and Aquaculture. At the same time, the capture of wild fish is in danger of plateauing, as 33 percent of fish stocks are now being fished at biologically unsustainable levels. Moreover, the number of fish in the oceans almost certainly will decrease as the effects of global warming and increasing discharges of the detritus of humans wreak havoc on marine organisms.

As one consequence of the decreased number of wild fish in the oceans, aquaculture will necessarily take on a more important role in providing fish for human consumption. Interestingly, as noted in a 2019 FAO report, The State of the World's Aquatic Genetic Resources for Food and Agriculture, “[a]quaculture is lagging far behind terrestrial agriculture - both crops and livestock - in terms of the characterization, domestication and improvement of its genetic resources for food production.” Thus, whereas the science of genetic engineering has been utilized to significantly enhance the yields of terrestrial agricultural crops and lessen the ecological impacts of farming, it has not been put to equivalent use for aquaculture. As outlined in the FAO report, there remains great potential for achieving sustainable production gains through the genetic improvement of farmed aquatic resources.

One example of a genetically engineered farmed aquatic resource that will achieve the goal of sustainable and ecologically beneficial production of increased fish protein is the AquaBounty Salmon. In lay terms, the AquaBounty Salmon is an Atlantic salmon that has been genetically engineered with a growth hormone gene from a Chinook salmon that enables the AquaBounty salmon to grow twice as fast as in the wild. Notwithstanding this relatively simple genetic change, regulatory approval for the AquaBounty Salmon took over 20 years and, according to the company, $120 million. It is astounding that this product, which carries a growth gene from an organism within its genus, was subjected to such an overly stringent regulatory ordeal. It’s not surprising that aquaculture has failed to take advantage of the genetic engineering revolution, if this is the kind of unnecessary and impracticable burden that faces aquaculture product developers.

Such an unnecessarily stringent and duplicative regulatory burden has real-world negative impacts on the development of needed food resources. On June 11, President Trump signed an Executive Order that requires EPA, FDA, and USDA to streamline their regulations applicable to agricultural biotechnology. Interested parties should take advantage of this opportunity to submit comments to NOAA to ensure that the agency incorporates the principles outlined in the Ag Biotech Executive Order as NOAA develops the final Work Plan for a Federal Aquaculture Regulatory Task Force. It is vitally important that the benefits of genetic engineering be applied to aquaculture as they have been to terrestrial agriculture.

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