Testimony given by Linda Paul, Executive Director for Aquatics, Hawai`i Audubon Society.

Testimony: my name is Linda Paul and I am speaking in behalf of the Hawaii Audubon Society. Since most open ocean aquaculture projects in Hawaii are in State waters, that is, within three nautical miles of shore, they are under the jurisdiction of the State of Hawaii. The regulation of these enterprises needs to involve cooperation between the Department of Land & Natural Resources, the Department of Health, which implements the EPA rules and standards, the Department of Business and Economic Development, which oversees that implementation of the Coastal Zone Management Act in Hawaii, the Department of Agriculture, the Office of Hawaiian Affairs, since most submerged lands in the State are ceded lands, and NOAA's National Marine Sanctuary Office, because of the presence of the Humpback Whale National Marine Sanctuary in our coastal waters.

The Hawaii Audubon Society supports setting enforceable National Open Ocean Aquaculture Standards and Guiding Principles, and a national regulatory framework. However such standards will need to be adaptable to the geological, environmental and cultural requirements of the areas where ocean aquaculture enterprises would be located. The effects of climate change also need to be taken into consideration. Warmer waters and rising acidity levels are already stressing our coral reefs and we do not need any additional stressors.

In addition, where an open ocean aquaculture enterprise in located outside of three miles the Society believes that NOAA should set the terms and conditions of permits, not the regional fisheries management councils, which have little expertise in the area of regulating and managing aquaculture businesses. Neither should the councils be given approval authority for where these enterprises are to be located or what species are to be raised. Aquaculture should never be a substitute for rebuilding depleted wild stocks.

Regarding these species, all aquacultured species should be native to the area and there should be no genetically altered species. It is very difficult to determine conclusively that there will be no long term detrimental impact to the environment from the cultivation of genetically-modified or non native species. And non native algae should never be cultured. All have the potential of becoming invasive.

Only herbivores or omnivores should be raised and their food should come from aquaculture or agriculture sources. Forage fish or fish meal should not be used since most forage fish stocks around the world are fully exploited and in many of the areas where such feed comes from the local people need these fish to feed their families. The harvesting of forage fish also alters the food chain in these areas. Soy products should not be used because of the natural estrogen in soy beans. We are also opposed to any grow-out pens for tuna; it takes 20 tons of forage fish to raise a single ton of tuna. And all proposed ocean aquaculture projects should be required to do an EIS.