Aura Sustainability EPA Submission to the King Salmon Proposal
Firstly we would like to start by saying we are big fans of Marlborough farmed Salmon and regularly purchase, cook and eat it. It is a world class product and one that Marlborough should be proud of producing. It also goes rather well with our other world renowned product, Marlborough Sauvignon Blanc. We are also advocates of sustainable growth for the Marlborough region and its inhabitants and support sustainable overseas investment.
We have the unenviable task of providing a submission to this proposal by King Salmon from a position of being a well respected and awarded sustainability consultancy operating in Marlborough but not being marine ecologists, not residents of the Marlborough Sounds and currently not working with the aquaculture industry. If that weren’t bad enough our total knowledge of the proposal until rather recently was through what we read in the media.
Because of this we consider we’re not in a position to recommend one outcome from another regarding the proposal. We do though want to make some recommendations as to what we would like to see the EPA consider when making their decision, because all that aside, “Sustainability” is our field.
The thing that most concerns us is the benefit for Marlborough. We base our company here because we like and believe in Marlborough. We call it home and are proud to do so.
The aquaculture industry has the ability to add real value into Marlborough if regulated, marketed and support by the community correctly. Not managed correctly, the added value will be diminished and it also has the ability to diminish the brand value of other produce that Marlborough exports. Bad news travels quickly these days.
It is therefore imperative that the reputation of Marlborough should be paramount when arriving at the decision. In other words: “Is this proposal good enough for the people/ecology/environment of Marlborough.”
Coming at this with considerable knowledge of the sustainability space we found it interesting that the term sustainable was used frequently in the King Salmon proposals and associated reports, as well on one of their brands TV adverts where a former Masterchef winner declares “and it’s sustainable”.
This begged the question to us “what is sustainable?” when it comes to fish farming and of course Salmon farming in Marlborough in particular. If our involvement in the sustainable development space has taught us anything, it is that use of words such as this without the necessary integrity to back them up is very, very dangerous indeed and can be deemed as greenwash by advertising standards authorities around the world.
Although King Salmon helped develop the New Zealand Salmon Farmer’s Association Environmental Code of Practice it is our opinion that if King Salmon, and the broader New Zealand aquaculture industry, wants to use promote its products as “sustainable” it should at the very least be:
“Third party certified to an independently stakeholder designed and managed Sustainability Programme”.
Sustainability is commonly defined as the ability to meet the needs of today, without compromising the needs of future generations to meet their own needs. These needs can be broken down into the pillars of financial viability, environmental management and social equity and therefore this should be the basis that the programme is designed around.
Aquaculture and salmon farming are not currently covered under the world’s largest sustainable fishing certification – the Marine Stewardship Council certification – but a similar scheme was started in 2009 by the World Wildlife Fund (WWF) to fill this gap. This scheme is called the Aquaculture Stewardship Council (ASC) and its goal is as follows:
The ASC will be the world's leading certification and labelling programme for responsibly farmed seafood. The ASC will be a global organisation working with aquaculture producers, seafood processors, retail and foodservice companies, scientists, conservation groups and the public to promote the best environmental and social choice in seafood. The ASC's aquaculture certification programme and seafood label will recognise and reward responsible aquaculture
Earlier this year they launched a final draft standard for the certification of Salmon farms, having noted the major impacts that this standard would need to address through their dialogue with the international Salmon farming industry:
- Benthic impacts and siting - Chemicals and excess nutrients from food and faeces associated with salmon farms can disturb the flora and fauna on the ocean bottom (benthos).
- Chemical inputs - Excessive use of chemicals - such as antibiotics, anti-foulants and pesticides - or the use of banned chemicals can have unintended consequences for marine organisms and human health.
- Disease/parasites - Viruses and parasites can transfer between farmed and wild fish, as well as among farms.
- Escapes - Escaped farmed salmon can compete with wild fish and interbreed with local wild stocks of the same population, altering the overall pool of genetic diversity.
- Feed: A growing salmon farming business must control and reduce its dependency upon fishmeal and fish oil - a primary ingredient in salmon feed - so as not to put additional pressure on the world's fisheries. Fish caught to make fishmeal and oil currently represent one third of the global fish harvest.
- Nutrient loading and carrying capacity - Excess food and fish waste in the water have the potential to increase the levels of nutrients in the water. This can cause the growth of algae, which consume oxygen that is meant for other plant and animal life.
- Social issues - Salmon farming often employs a large number of workers on farms and in processing plants, potentially placing labour practices and worker rights under public scrutiny. Additionally, conflicts can arise among users of the shared coastal environment.
The draft standard can be found here: http://www.worldwildlife.org/what/globalmarkets/aquaculture/WWFBinaryitem26597.pdf
This standard should provide the template for what a Marlborough or New Zealand based scheme should follow for Salmon and to avoid marketplace confusion it is recommended that those that are certified to the national scheme, are also in compliance to the ASC standards and able to use their certification marks, as well as potentially a mark that promotes Marlborough and/or New Zealand.
Local Considerations for the Design of the Financial Viability Component
There is little doubt that the proposal put forward by King Salmon is a long term financial proposition. This should though return financial wealth to all stakeholders in King Salmon supply chain, without compromising the environmental and social equity.
These stakeholders include overseas shareholders, New Zealand based shareholders, King Salmon employees, contractors, other synergistic Marlborough and New Zealand products, suppliers (both direct and indirect), importers, distributors, wholesalers and retailers. It is our opinion that running a successful certified sustainability programme could assist in delivering these financial returns. It should also be considered that a large part of Marlborough’s wine industry is managed under a third party audited sustainability programme and therefore provision of a aquaculture sustainability programme would align itself well with brand Marlborough moving towards being the world’s most sustainable production base.
Local Considerations for the Design of the Environmental Management Component
Consideration should be given to the environmental stewardship of the supply chain, as well as the environmental management of the local environment.
The environmental impact of the Salmon farming and sales supply chain has already been the focus of considerable attention in markets such as the UK, which focused predominantly on the feed stock being used. Attention should be given to the make-up of the feed stock, with particular attention to its environmental credentials. As a minimum fish components of the feed stock should be MSC certified and other components should be given as much rigour surrounding their environmental impacts as is possible.
Fresh salmon which is air freighted to market, will no doubt come under the microscope at some point in the future and consideration should be given to potentially mitigating (offsetting) the carbon impacts of this part of the supply chain. A view on the ability for Marlborough Salmon to reduce transport and refrigeration impacts should be a long term driver as we move towards a world where supply chain carbon is going to be ever increasingly analysed.
The impacts of the farms on the local environment though are the most important aspects to be considered. It seems to the untrained eye that the nutrient evacuation from the farms is an extremely significant environmental impact and could potentially change the eco-system in some form. In fact if this was a land based industry, to comply with the current district plan King Salmon would need 15,000 hectares of land to discharge the nitrogen load to. Of course comparing land based discharge with water based discharge is not apples for apples, but it has to pointed out that if the wine industry proposed to pump 3,000t of nitrogen effluent into the Marlborough sounds (or other waterway) it would have to grow by 200 times its current size and we are sure such a proposal would likely be greeted with considerable derision.
As much as the effluent from Salmon is a threat to the environment of the Sounds, and the reputation they hold as a pristine environment, it is surely also an opportunity. As listed in the King Salmon EAA this nutrient could be harnessed in a manner more in line with permaculture principles to grow co-products that increase the financial return of the operations and also reduce the potential environmental impact from the effluent. This is something that should be considered as a long term sustainable goal for aquaculture in Marlborough.
Also it is now becoming common practice in land cased agriculture sustainability to have in place fallow rotation of farm land, this should also be something that should be considered for fish farming, allowing the sea bed to naturally recover from issues that might arise over time.
Local Considerations for the Design of the Social Equity Component
Often overlooked this is without a doubt the largest potential benefit to Marlborough, the greatest threat to King Salmons ongoing tenancy in the Sounds and the component that is least likely to be covered in consent conditions.
For a start supply chain thinking should be employed once again, ensuring that fair trade principles are employed throughout the chain – but with particular attention to the supply of feed stock.
It is then of great importance that there is ongoing wealth (and not just financial wealth) creation in the Marlborough region and will define whether we and the region are a valued part of the process, or serfs in our own land (or waters as the case may be).
It has been well covered that if the proposal is successful in the Sounds recreational areas, this could impact their ability to be recreational areas. This is a massive threat, as the first person to get attacked by a shark or sick from swimming too close to the farms is going to tarnish not only the reputation of King Salmon but also the entire New Zealand aquaculture sector and the brand image of Marlborough overseas. There should be careful consideration given in the programme to how Salmon farming and recreational activities can co-exist, because if they can’t, or don’t, the damage could be irreparable.
On top of the above it needs to be asked what King Salmon, a company that is overseas majority owned, is going to give back to the community that kindly allows it to be tenants. Of course there is considerable talk about job creation and the trickle down effect of more industry in Marlborough – but there is little talk about the legacy that King Salmon wishes to provide the region with. Things that add wealth into a region such as education, health, the arts and culture, and perhaps not just as sponsorship opportunities for its branded products, but a more holistic benefactor approach. This is something we believe should be strongly considered when setting up a sustainability programme of this sort, especially when the large majority of profits from the enterprise will leave the region. It is also a great marketing story and would act as world leading in a long term sustainability approach to community management where there is give, as well as take.
There is a lot to be considered in setting up a world leading sustainability programme that the aquaculture industry can be proud of and market to the world with integrity. None of it is onerous and from our experience the benefits far out-strip the costs of implementation. If investments, operations, marketing and products are going to be branded as sustainable – it is an imperative that this is the truth.
Our opinion is sustainable growth is good for Marlborough, but it needs to be sustainable and it needs to be for the good of Marlborough as well as the other stakeholders.
Aura Sustainability was formed in Marlborough in 2008 by former Grove Mill employees David Pearce and Roger Kerrison, with the appointment of Gareth Lyne as an independent director. As Marlborough Environmental Award winners in 2011, David and Roger are recognised as local, national and global leaders in the field of sustainability in the wine industry. They have been instrumental in designing and promoting sustainable development and they are specialists in the field of lifecycle carbon accounting. They have been involved in the development of environmental management programmes and systems (such as carboNZero, CEMARS and Sustainable Winegrowing New Zealand) and also the use of these certifications to leverage returns in “The Marketplace”.