On February 9, 2011, the Department of Commerce (DOC) and the National Oceanic and Atmospheric Administration (NOAA) published in the Federal Register for comment complimentary draft national aquaculture policies (Draft Policy or Policies) for the purpose of supporting sustainable marine aquaculture.

Full Comments

April 8, 2011 Submitted Electronically The Honorable Gary Locke Secretary of Commerce Room 5858 United States Department of Commerce 1401 Constitution Avenue, N.W. Washington, DC 20230 The Honorable Dr. Jane Lubchenco Under Secretary of Commerce for Oceans and Atmosphere and Administrator National Oceanic and Atmospheric Administration 1401 Constitution Avenue, N.W. Room 5128 Washington, DC 20230 RE: Draft DOC and NOAA Aquaculture Policies On February 9, 2011, the Department of Commerce (DOC) and the National Oceanic and Atmospheric Administration (NOAA) published in the Federal Register for comment complimentary draft national aquaculture policies (Draft Policy or Policies) for the purpose of supporting sustainable marine aquaculture. The Food Marketing Institute (FMI) appreciates the opportunity to respond to the request of DOC and NOAA for comments on their Draft Policies. FMI is the national trade association that conducts programs in public affairs, food safety, research, education and industry relations on behalf of its 1,500 member companies – food retailers and wholesalers – in the United States and around the world. FMI’s members in the United States operate approximately 26,000 retail food stores and 14,000 pharmacies. Their combined annual sales volume of $680 billion represents three-quarters of all retail food store sales in the United States. FMI’s retail membership is composed of large multi-store chains, regional firms, and independent supermarkets. Our international membership includes 200 companies from more than 50 countries. FMI’s associate members include the supplier partners of its retail and wholesale members. FMI Comments DOC and NOAA Draft Aquaculture Policies April 8, 2011 Page 2 of 4 FMI believes that DOC and NOAA should consider the following recommendations as they work to develop final aquaculture policies: April 8, 2011 Meeting Consumer Demand Submitted Electronically Fish consumption is on the increase around the world. The latest United Nations State of the World The Honorable Gary Locke 1 Fisheries and Aquaculture Report indicates that per capita consumption of fish is at an all time Secretary of Commerce high. Aquaculture accounted for 46 percent of the total food fish supply and is set to overtake Room 5858 2 capture fisheries as a source food fish. Aquaculture continues to be the fastest-growing animal United States Department of Commerce producing sector. 1401 Constitution Avenue, N.W. Washington, DC 20230 The U.S. has one of the highest seafood consumption rates in the world and it is likely to rise. The recently released 2010 Dietary Guidelines for Americans doubled the recommendation in the 2005 The Honorable Dr. Jane Lubchenco Guidelines for weekly seafood consumption. As consumer demand increases, cultured seafood will Under Secretary of Commerce for Oceans and Atmosphere and Administrator undoubtedly play an increasing important role in helping Americans achieve dietary goals. National Oceanic and Atmospheric Administration 1401 Constitution Avenue, N.W. DOC and NOAA aquaculture policies should anticipate the increase in demand both domestically Room 5128 and abroad and contemplate how best to balance expansion of aquaculture with the maintenance Washington, DC 20230 and restoration of wild fisheries. RE: Draft DOC and NOAA Aquaculture Policies Complementing Wild Fisheries On February 9, 2011, the Department of Commerce (DOC) and the National Oceanic and It is essential that any aquaculture policies be crafted in such a way as to complement wild fisheries, Atmospheric Administration (NOAA) published in the Federal Register for comment not diminish them. Cultured fish and shellfish should provide consumers with greater choices, but complimentary draft national aquaculture policies (Draft Policy or Policies) for the purpose of not supplant wild seafood in the marketplace. Aquaculture should not displace wild populations. supporting sustainable marine aquaculture. NOAA should prioritize the development of alternative feeds to forage fish so as not to threaten wild stocks. Aquaculture should not be conducted in a manner which damages estuaries or other The Food Marketing Institute (FMI) appreciates the opportunity to respond to the request of DOC environments essential to wild stocks. and NOAA for comments on their Draft Policies. FMI supports NOAA’s commitment to “Ensure agency aquaculture decisions protect wild species FMI is the national trade association that conducts programs in public affairs, food safety, research, and healthy, productive, and resilient coastal and ocean ecosystems, including the protecting of education and industry relations on behalf of its 1,500 member companies – food retailers and 3 sensitive marine areas.” wholesalers – in the United States and around the world. FMI’s members in the United States operate approximately 26,000 retail food stores and 14,000 pharmacies. Their combined annual sales volume of $680 billion represents three-quarters of all retail food store sales in the United States. FMI’s retail membership is composed of large multi-store chains, regional firms, and independent supermarkets. Our international membership includes 200 companies from more than 50 countries. FMI’s associate members include the supplier partners of its retail and wholesale members. 1 http://www.fao.org/docrep/013/i1820e/i1820e00.htm 2 Id. 3 http://www.nmfs.noaa.gov/aquaculture/docs/noaadraftaqpolicy.pdf FFMMII CCoommmmeennttss DDOOCC aanndd NNOOAAAA DDrraafftt AAqquuaaccuullttuurree PPoolliicciieess AApprriill 88,, 22001111 PPaaggee 23 ooff 44 FFMreIe bTerliaedvee s that DOC and NOAA should consider the following recommendations as they work t o develop final aquaculture policies: April 8, 2011 A component of the DOC policy is to: Meeting Consumer Demand Submitted Electronically Promote a level playing field for U.S. aquaculture businesses to engage in international trade. Work to ensure that countries exporting culture seafood products to the United States are meeting Fish consumption is on the increase around the world. The latest United Nations State of the World 4 The Honorable Gary Locke requirements relating to fair trad1e, food safety, and international agreements. Fisheries and Aquaculture Report indicates that per capita consumption of fish is at an all time Secretary of Commerce high. Aquaculture accounted for 46 percent of the total food fish supply and is set to overtake RImopoomrt 5ed8 5c8u ltured fish and shellfish is an essential part of the marketplace. It has been responsible 2 capture fisheries as a source food fish. Aquaculture continues to be the fastest-growing animal for increased consumer interest and consumption of seafood. Cultured seafood imports have United States Department of Commerce producing sector. provided Americans with a greater variety of fresh, affordable fish and shellfish than ever before. 1401 Constitution Avenue, N.W. WDOasCh isnhgotuolnd, nDoCt i2m0p2l3e0m ent protectionist policies for purposes of reducing competition to U.S. The U.S. has one of the highest seafood consumption rates in the world and it is likely to rise. The producers. Protectionist policies would lead to higher prices and less choice, significantly harming recently released 2010 Dietary Guidelines for Americans doubled the recommendation in the 2005 Tcohnes Humoneorsr.a bAles Dder.m Jaannde fLourb scehaefonocod continues to rise in the United States, the marketplace will not Guidelines for weekly seafood consumption. As consumer demand increases, cultured seafood will be able to respond to it absent imported cultured fish and shellfish. The Dietary Guidelines have Under Secretary of Commerce for Oceans and Atmosphere and Administrator undoubtedly play an increasing important role in helping Americans achieve dietary goals. recommended significantly greater levels of fish and shellfish consumption and imported cultured National Oceanic and Atmospheric Administration 1se4a0f1o oCdo inss etistsuetinotnia lA ivne hneulep,i nNg. WAm. ericans meet their dietary goals. DOC should coordinate with the DOC and NOAA aquaculture policies should anticipate the increase in demand both domestically RUonoitmed 5 S1t2a8te s Trade Representative to ensure that all policies are consistent with trade obligations and abroad and contemplate how best to balance expansion of aquaculture with the maintenance iWncalsuhdiinnggt oWn,o DrlCd T2r0a2d3e0 O rganization rules. and restoration of wild fisheries. Consumer Education RE: Draft DOC and NOAA Aquaculture Policies Complementing Wild Fisheries OFMn IF seubprupaorryts 9 N, 2O0A11A,’ tsh peo Dliecpya trotm “Aendtv oafn Cceo mpumbleircc eu n(DdeOrsCta)n adnidn gt hoef Nsuasttiaoinnaalb Olec aeqanuiacc uanltdu re It is essential that any aquaculture policies be crafted in such a way as to complement wild fisheries, 5 Aprtamctoicspesh.e”ri c A A sdimgninifiisctarantti oanm (oNunOtA oAf m) pisuibnlfiosrhmeda tiino nth eex Fisetds erreagla Rrdeignigs taeqr ufoacr uclotumrem pernatc tices and not diminish them. Cultured fish and shellfish should provide consumers with greater choices, but production. Educating consumers on the environmental and economic benefits of aquaculture is complimentary draft national aquaculture policies (Draft Policy or Policies) for the purpose of not supplant wild seafood in the marketplace. Aquaculture should not displace wild populations. critical. It is essential to advance public understanding of the safety, quality and freshness of supporting sustainable marine aquaculture. NOAA should prioritize the development of alternative feeds to forage fish so as not to threaten cultured seafood. FMI members have played key roles in educating consumers about sustainable wild stocks. Aquaculture should not be conducted in a manner which damages estuaries or other Tsehaef oFoodo dan Md athrkee itnindgu sItnryst iwtuetlec o(FmMesI )t haep porpepcoiarttuesn itthye t oo pppaorrtntuenr iwtyi ttho NreOspAoAnd a tnod t hDeO rCeq tuoe satd ovfa nDcOe C environments essential to wild stocks. apnudb lNicO uAndAe rfsotra ncdoimngm oefn tssu ostna itnhaebirl eD arqaufta Pcuolltiucriees. . FMI supports NOAA’s commitment to “Ensure agency aquaculture decisions protect wild species Responding to the Marketplace FMI is the national trade association that conducts programs in public affairs, food safety, research, and healthy, productive, and resilient coastal and ocean ecosystems, including the protecting of education and industry relations on behalf of its 1,500 member companies – food retailers and 3 sensitive marine areas.” Iwt hiso leesssaelnetrisa l– t ihna tt haen yU fneidteedr aSl taaqteusa caunldt uarreo upnodli cthye r ewsoprolndd. tFoM thIe’s d mememanbdesr so ifn t hthee m Uanrkiteetdp lSatcaet.e s NopOeAraAte aanpdp rDoxOimC astheolyu l2d6 w,0o0r0k rteot asiul pfpooordt ssteoarfeoso adn sdp 1ec4i,e0s0 0th paht aarrme aatctireasc.t i Tveh etoir ccoonmsubmineerds .a nPnruicael points on cultured fish and shellfish must make them competitive with existing products. NOAA sales volume of $680 billion represents three-quarters of all retail food store sales in the United should also contemplate that the form in which cultured items are sold to consumers must be States. FMI’s retail membership is composed of large multi-store chains, regional firms, and cinodnevpeenniednetn ta nsudp aeprpmeaarlkinegts. . T Ohuer a ignetenrcnya tsihoonualld m aelsmob ceornshsiidpe irn hclouwd ecso 2n0su0m coerm tpaastneise sa nfrdo dme mmaonred tvhaarny b50y rceoguinotnr iteos .r e FgMioIn’ sin a sthsoe cUianteit emde Smtabteerss. include the supplier partners of its retail and wholesale members. 1 http://www.fao.org/docrep/013/i1820e/i1820e00.htm 42 Ihdtt.p ://www.nmfs.noaa.gov/aquaculture/doc_policy/ 53 hhttttpp::////wwwwww..nnmmffss..nnooaaaa..ggoovv//aaqquuaaccuullttuurree//ddooccss//nnooaaaaddrraaffttaaqqppoolliiccyy..ppddff FFFMMMIII CCCooommmmmmeeennntttsss DDDOOOCCC aaannnddd NNNOOOAAAAAA DDDrrraaafffttt AAAqqquuuaaacccuuullltttuuurrreee PPPooollliiiccciiieeesss AAAppprrriiilll 888,,, 222000111111 PPPaaagggeee 432 ooofff 444 FFEMrsetaIe b bTleirlsiahedivneeg s Gthoata Dls O C and NOAA should consider the following recommendations as they work t o develop final aquaculture policies: April 8, 2011 AN OcoAmAp aonnde nDt OofC t hseh oDuOldC c rpaoflti cayq uisa ctuol:t ure policies that establish clear and measurable goals. The Mageenetciinegs sChoonusldu mpeerrio Ddiecmalalyn de xamine if they are meeting these goals and reassess aquaculture Submitted Electronically Promote a level playing field for U.S. aquaculture businesses to engage in international trade. Work policies if necessary. to ensure that countries exporting culture seafood products to the United States are meeting F ish consumption is on the increase around the world. The latest United Nations State of the World 4 The Honorable Gary Locke requirements relating to fair trad1e, food safety, and international agreements. FRiesshoeurirecse asn d Aquaculture Report indicates that per capita consumption of fish is at an all time Secretary of Commerce high. Aquaculture accounted for 46 percent of the total food fish supply and is set to overtake IRmopoomrt 5ed8 5c8u ltured fish and shellfish is an essential part of the marketplace. It has been responsible 2 NcaOptAuAre afinsdh eDriOesC a ssh ao usoldu rwceo rfko owdi tfhis Ch.on gArqeussa ctou letunrseu rceo nthtiant uaedse tqou abtee tfheed fearsatle rsets-goruorwceisn ga raen imal for increased consumer interest and consumption of seafood. Cultured seafood imports have United States Department of Commerce dperoddicuactiendg tsoe acqtoura. culture research. provided Americans with a greater variety of fresh, affordable fish and shellfish than ever before. 1401 Constitution Avenue, N.W. WDOasCh isnhgotuolnd, nDoCt i2m0p2l3e0m ent protectionist policies for purposes of reducing competition to U.S. The U.S. has one of the highest seafood consumption rates in the world and it is likely to rise. The producers. Protectionist policies would lead to higher prices and less choice, significantly harming Trehcaennktl yy oruel efoars ecdo n2s0i1d0e rDinige toauryr cGoumidmeleinntess ofno rt hAemsee irmicpanosrt adnotu ibslseude sth. e recommendation in the 2005 Tcohnes Humoneorsr.a bAles Dder.m Jaannde fLourb scehaefonocod continues to rise in the United States, the marketplace will not Guidelines for weekly seafood consumption. As consumer demand increases, cultured seafood will be able to respond to it absent imported cultured fish and shellfish. The Dietary Guidelines have Under Secretary of Commerce for Oceans and Atmosphere and Administrator undoubtedly play an increasing important role in helping Americans achieve dietary goals. recommended significantly greater levels of fish and shellfish consumption and imported cultured National Oceanic and Atmospheric Administration Sincerely, 1se4a0f1o oCdo inss etistsuetinotnia lA ivne hneulep,i nNg. WAm. ericans meet their dietary goals. DOC should coordinate with the DOC and NOAA aquaculture policies should anticipate the increase in demand both domestically RUonoitmed 5 S1t2a8te s Trade Representative to ensure that all policies are consistent with trade obligations and abroad and contemplate how best to balance expansion of aquaculture with the maintenance iWncalsuhdiinnggt oWn,o DrlCd T2r0a2d3e0 O rganization rules. and restoration of wild fisheries. Consumer Education RE: Draft DOC and NOAA Aquaculture Policies Complementing Wild Fisheries Erik R. Lieberman FOMn IF seubprupaorryts 9 N, 2O0A11A,’ tsh peo Dliecpya trotm “Aendtv oafn Cceo mpumbleircc eu n(DdeOrsCta)n adnidn gt hoef Nsuasttiaoinnaalb Olec aeqanuiacc uanltdu re It is essential that any aquaculture policies be crafted in such a way as to complement wild fisheries, 5 Regulatory Counsel Aprtamctoicspesh.e”ri c A A sdimgninifiisctarantti oanm (oNunOtA oAf m) pisuibnlfiosrhmeda tiino nth eex Fisetds erreagla Rrdeignigs taeqr ufoacr uclotumrem pernatc tices and not diminish them. Cultured fish and shellfish should provide consumers with greater choices, but production. Educating consumers on the environmental and economic benefits of aquaculture is complimentary draft national aquaculture policies (Draft Policy or Policies) for the purpose of not supplant wild seafood in the marketplace. Aquaculture should not displace wild populations. critical. It is essential to advance public understanding of the safety, quality and freshness of supporting sustainable marine aquaculture. NOAA should prioritize the development of alternative feeds to forage fish so as not to threaten cultured seafood. FMI members have played key roles in educating consumers about sustainable wild stocks. Aquaculture should not be conducted in a manner which damages estuaries or other Tsehaef oFoodo dan Md athrkee itnindgu sItnryst iwtuetlec o(FmMesI )t haep porpepcoiarttuesn itthye t oo pppaorrtntuenr iwtyi ttho NreOspAoAnd a tnod t hDeO rCeq tuoe satd ovfa nDcOe C environments essential to wild stocks. apnudb lNicO uAndAe rfsotra ncdoimngm oefn tssu ostna itnhaebirl eD arqaufta Pcuolltiucriees. . FMI supports NOAA’s commitment to “Ensure agency aquaculture decisions protect wild species Responding to the Marketplace FMI is the national trade association that conducts programs in public affairs, food safety, research, and healthy, productive, and resilient coastal and ocean ecosystems, including the protecting of education and industry relations on behalf of its 1,500 member companies – food retailers and 3 sensitive marine areas.” Iwt hiso leesssaelnetrisa l– t ihna tt haen yU fneidteedr aSl taaqteusa caunldt uarreo upnodli cthye r ewsoprolndd. tFoM thIe’s d mememanbdesr so ifn t hthee m Uanrkiteetdp lSatcaet.e s NopOeAraAte aanpdp rDoxOimC astheolyu l2d6 w,0o0r0k rteot asiul pfpooordt ssteoarfeoso adn sdp 1ec4i,e0s0 0th paht aarrme aatctireasc.t i Tveh etoir ccoonmsubmineerds .a nPnruicael points on cultured fish and shellfish must make them competitive with existing products. NOAA sales volume of $680 billion represents three-quarters of all retail food store sales in the United should also contemplate that the form in which cultured items are sold to consumers must be States. FMI’s retail membership is composed of large multi-store chains, regional firms, and cinodnevpeenniednetn ta nsudp aeprpmeaarlkinegts. . T Ohuer a ignetenrcnya tsihoonualld m aelsmob ceornshsiidpe irn hclouwd ecso 2n0su0m coerm tpaastneise sa nfrdo dme mmaonred tvhaarny b50y rceoguinotnr iteos .r e FgMioIn’ sin a sthsoe cUianteit emde Smtabteerss. include the supplier partners of its retail and wholesale members. 1 http://www.fao.org/docrep/013/i1820e/i1820e00.htm 24 Ihdtt.p ://www.nmfs.noaa.gov/aquaculture/doc_policy/ 53 hhttttpp::////wwwwww..nnmmffss..nnooaaaa..ggoovv//aaqquuaaccuullttuurree//ddooccss//nnooaaaaddrraaffttaaqqppoolliiccyy..ppddff