Factory-Fed Fish: How the Soy Industry Is Expanding Into the Sea

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    Factory-Fed

    Fish

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    About Food & Water Europe

    Food & Water Europe is the European programof Food & Water Watch, a nonprofit consumer

    organization based in the United States that

    works to ensure the food, water and fish we

    consume is safe, accessible and sustainable.

    So we can all enjoy and trust in what we eat

    and drink, we help people take charge of where

    their food comes from, keep clean, affordable,

    public tap water flowing freely to our homes,

    protect the environmental quality of oceans,

    force government to do its job protecting citizens,and educate about the importance of keeping

    shared resources under public control.

    Food & Water Europe

    Rue dEdimbourg, 26

    1050 Bruxelles

    Belgium

    [email protected]

    www.foodandwatereurope.org

    Copyright June 2012 by Food & Water Europe.

    All rights reserved.

    This report can be viewed or downloaded at

    www.foodandwatereurope.org.

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    Factory-Fed FishHow the Soy Industry Is Expanding Into the Sea

    Executive Summary 2

    Findings 3

    Introduction 3

    Why Should We Be Concerned? 4

    Fishy raditions 5

    State o the Soy Industry 6

    Who is lobbying or the soy industry? 6

    How much soy is genetically modifed 6

    How much soy is in our ood now? 6

    What Does Soy Have to Do With Fish Feed? 7

    Te soy industrys championing o soy diets or actory armed fsh 7

    Cargill and Monsanto: Corporate interest in soy or armed fsh 8

    Impacts o a Soy Diet on Fish and Teir Environment 8

    Issues o indigestibility and nutrient defciency 8

    Potential impacts on the marine environment 9

    Impacts on Consumers 10

    Missing omega-3s 10

    General impacts o soy consumption 10

    Environmental and Human Rights Inringements in Soy Consumption 11

    Other Alternatives 12

    Conclusion 13

    Recommendations 14

    Endnotes 14

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    2 Food & Water Europe www.foodandwatereurope.org

    Executive SummaryIn 2010, the CEO o the American Soy Association

    reported that the organization has been closely

    monitoring progress in the development o oshore

    sh arming legislation and meeting with congres-sional sta on the topic1 In March 2011, it endorsed

    a controversial plan that would allow such sh

    arming or aquaculture in the Gul o Mexico2

    In September 2011, a press release was issued

    announcing a new marine sh arm project that

    would revolutionize sustainable agriculture3 Te

    source o the release? Te Illinois Soybean Associa-

    tion4

    Why are trade associations or an agricultural

    commodity that is grown on land involved in poli-

    cies and marketing that aect the use and steward-

    ship o our oceans?

    Seaood is one o our last wild ood sources Fish

    are a vital part o many peoples diets because

    o potential health benets, resh taste and the

    connection that sh give us to our oceans and

    coasts Around hal o the worlds seaood, however,

    now comes rom arms rather than rom the wild5

    In some o these arms, sh are grown in crowded,polluting cages and may be attened on commer-

    cially prepared diets6

    Feed has been one o the aquaculture industrys

    greatest challenges Many o the species grown

    by the ocean nsh industry are highly valued

    carnivorous sh,7 which have typically been ed

    diets consisting o shmeal and oil made rom

    smaller, wild sh8 Te excessive use o wild sh to

    grow armed sh can make aquaculture inecient9

    Further, aquaculture has been accused o spurring

    the depletion o these small sh, which is problem-

    atic not only or their own populations, but also to

    the other animals that rely on them or ood10

    With little public scrutiny, soy has been hailed by

    some as a sustainable alternative to eed based on

    wild sh, thus supposedly solving some o the sh

    arming industrys sustainability problems11

    In this report, the rst to address the relationship

    between the soy and actory sh arming indus-

    tries, Food & Water Watch reveals that, while the

    soy industry stands to make large prots rom

    the expansion o actory sh arming,12 there is

    no guarantee that soy-based aquaculture eed

    can consistently produce healthy sh or promote

    ecological responsibility In act, by causing sh toproduce excess waste,13 soy could lead to an even

    more polluting sh arming industry

    By supporting actory sh arming, the soy industry

    could not only help to expand an industry that

    degrades marine environments, threatens wild sh

    populations and damages coastal communities, it

    could also extend its own negative impacts Already,

    industrial soy production has led to the prevalence

    o genetically modied crops on US armland14

    and in consumer ood products,15 caused massive

    deorestation in South America16 and displaced

    indigenous communities living in areas now used to

    grow soy17

    Rather than actually promoting sustainability in a

    developing industry, the involvement o soy associ-

    ations in aquaculture could spur the growth o two

    industries that have extremely negative impacts

    on our land, our oceans and the communities that

    depend on them

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    Factory-Fed Fish: How the Soy Industry Is Expanding Into the Sea 3

    Findings I the soy industry succeeds in helping the

    aquaculture industry meet the annual produc-

    tion goals or marine nsh set by the ederal

    government, and in getting a substantial portion

    o soybean meal included in the diets o these

    armed sh, it could net an additional $201million each year; this doesnt include revenue

    it may earn rom supplying soy as a eed

    ingredient or other types o sh arming in the

    United States or abroad

    Although the soy industry claims that soy is an

    environmentally riendly alternative or sh

    eed, sh that are ed soy have been shown to

    produce more waste; thus, an increase in the

    amount o soy ed to sh in sh arms could

    increase the pollution load on the environment

    surrounding these arms

    In open ocean sh arming, uneaten eed fows

    directly rom the cage into the environment

    Because 94 percent o the soy grown in the

    United States and much o the soy grown inter-

    nationally is genetically modied, eeding soy

    to armed sh means that genetically modied

    ood will enter the environment and diets o

    other marine organisms

    Te rising use o soy in sh arming industries

    will mean that notorious agribusinesses like

    Monsanto, which has sponsored eed trials

    with genetically modied soy and salmon, and

    Cargill, which has an aquaculture eed division,

    will play a hand in seaood production

    Deorestation to clear land or soy arms, which

    is already a problem in South America, could

    increase given the large quantity o soy thataquaculture would require to meet US targets

    or nsh production

    A growing number o researchers has noted

    that the potentially negative impacts o the

    increasing amount o soy in our diets are under-

    researched, and it is even less apparent what

    the long-term human health impacts could be

    o consuming soy secondarily, through sh and

    meat raised on soy

    IntroductionAs you take your rst bite o a reshly grilled sh

    llet, you may be imagining the weathered boat that

    reeled it in or the seaside town where it was brought

    to shore Perhaps you are contemplating the lie it

    led in the seas and eeling content that you chose a

    healthier, resher alternative to the mass-producedhamburger you considered ordering But what you,

    along with most people, are probably not picturing

    is a deorested plantation in Argentina, the dead

    zone growing in the Gul o Mexico or a US soy

    industry executive signing o on a press release to

    promote actory sh arming

    Around hal o the seaood consumed in the world

    is now produced through aquaculture, or sh

    arming18 Tere are various types o sh arming,

    including production in coastal ponds, near-shorecages, or cages placed arther o the coast Open

    ocean actory sh arming, also known as oshore

    aquaculture, is the practice o growing nsh in

    huge, oten overcrowded cages miles o the coast-

    line Tis method o arming can be problematic or

    both the environment and the economy

    Te waste ecal matter, uneaten ood and the

    chemicals or drugs used in these operations

    fows directly into the ocean, where it has thepotential to damage ecological equilibrium19 Fish

    tend to escape rom cages, and once in the wild

    they can interbreed with or outcompete wild sh,

    leading to decreased genetic viability and access

    to resources20 Even beore escape, sh can spread

    diseases and parasites which may be prevalent on

    some arms due to crowded conditions to nearby

    wild sh21 I arms damage wild populations, shing

    communities and local coastal economies could be

    seriously threatened

    A variety o concerns also come into play with

    regard to eed or armed sh Farmed sh have

    generally been raised on eed that is ormulated

    with shmeal or oil made rom small, wild sh22

    But now, both ecological and nancial obstacles to

    this practice are arising23 As a result, the industry is

    seeking out potential alternative ingredients to eed

    armed sh, and the soy industry has positioned

    itsel as a viable option Te American soy industryis powerul It has been able to und many studies

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    on using soy or sh eed24; it has built relationships

    in the aquaculture industry25; and it has publicly

    supported ederal policies in avor o oshore

    aquaculture26

    Supporters o the soy-aquaculture alliance claim

    that using soy or sh eed could allow or a new,

    more environmentally riendly type o aquacul-

    ture27 Soy does not have the ull array o nutrients

    demanded by sh, however28; nor is it a natural sh

    ood or substance in the marine environment In

    act, using soy may cause some sh arms to pollute

    more by producing extra waste29

    Further, the negative ramications o the soy

    industry on the environment and potentially on

    our health are reasons to resist the allure o soy as

    a savior o the aquaculture industry Te cultiva-

    tion o soy is associated with agricultural runothat is contributing to the dead zones in the Gul o

    Mexico,30 with deorestation in Latin America31 and

    with the displacement o many indigenous peoples

    rom their homes and work32

    As soy becomes increasingly ubiquitous in our diets

    in processed oods and the meat rom animals

    that have been raised on it33 we must ask what

    health impacts this high level o soy consump-

    tion may have on us Scientists are beginning toquestion claims about the benets o eating soy

    and to suggest that the plant-based estrogens that

    occur naturally in soy, many o which are endo-

    crine disruptors, could potentially have adverse

    impacts34 In light o these concerns and unan-

    swered questions, it is troubling to know that much

    o our sh one o our last wild oods could be

    attened on this crop

    Why Should We Be Concerned?People who are looking to sh or a lighter,

    healthier or more sustainable ood option may have

    no idea that mega-industries rom both land and

    sea are wielding infuence on the types o seaood

    that we can consume35

    US policy and much o the research and develop-

    ment on aquaculture, however, is currently ocused

    on the development o actory-style oshore sh

    arms and on soy as an ingredient in sh eed36

    In 1999, the US Department o Commerce (DOC)

    released a policy calling or a quintupling o the total

    value o the nations annual aquaculture production

    by the year 2025 rom $900 million a year to $5

    billion37 Te policy listed DOC objectives including

    osetting the seaood trade decit, creating more

    jobs and bringing more high-quality seaood to US

    consumers38

    o completely oset the seaood trade decit

    through open ocean aquaculture would require

    producing an almost unimaginable 200 million sh

    in oshore cages each year39 But the seaood decit

    is more complicated than simply producing more

    sh Te United States exports 74 percent o the

    seaood caught or grown domestically and, in turn,

    imports 85 percent o the seaood available in the

    United States, primarily rom Asian countries40 Tis

    problem could be better met by increasing import

    inspections in order to keep cheaper, lower-quality

    seaood out, and keeping more US-produced

    seaood in the country41

    Te likelihood that open ocean aquaculture

    would produce a signicant number o jobs is also

    dubious i Kona Blue Water Farms, a prototypical

    open ocean arm in Hawaii, is taken as a potential

    indicator o what an expanded US industry might

    look like Although the company once employed 49

    people, it projected in 2009 that it would eventuallyemploy only 14 Te company said that sta reduc-

    tion would be necessary to achieve protability42

    Further, a large-scale oshore sh arming industry

    could cause major environmental damage Placing

    sh arms in the open ocean has been pitched as a

    way to minimize pollution by diluting or dispersing

    waste43 Tere is not enough inormation available

    yet to know what the long-term eects o these

    arms will be,44

    and research rom Italy indicatesthat pollution rom oshore arms may aect the

    marine ecosystem well beyond the local scale45

    Te ecosystems around arms could also be

    disrupted by chemicals and drugs used on arms,

    potentially leading to negative health consequences

    or people One study ound that the use o antimi-

    crobials on sh arms can lead to the development

    o drug-resistant genes in sh pathogens genes

    that could be transerred to bacteria that inect

    humans Tis could make human illnesses moredicult to treat46

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    Factory-Fed Fish: How the Soy Industry Is Expanding Into the Sea 5

    Despite indications that oshore sh arms are

    economically uneasible, environmentally unsound

    and unlikely to provide major benets to US

    consumers or the regional economies that could

    most benet rom a revitalized seaood industry,

    the National Oceanic and Atmospheric Administra-

    tion (NOAA) has hung on to it as a pet project and

    continued pushing or it47

    Various environmental, consumer-interest and

    shing groups, as well as many individual citizens,

    have raised concerns about NOAAs aquaculture

    policy48 But the agency has held on to allies in the

    soy industry, who are interested in new markets

    Fishy TraditionsFeeding sh is one o the central challenges in

    the sh arming industry o grow and producemarketable quantities or seaood, sh must be ed

    a sucient diet On arms, carnivorous nsh are

    typically ed commercial diets containing shmeal

    and/or oil, which can be produced rom smaller

    sh species or, in some cases, rom shermens

    unwanted catch49

    Te use o shmeal and oil in sh arming began in

    Europe and North America in the early 19th century

    as a way to utilize excess herring catch50 Unor-

    tunately, what started as a creative way to utilize

    extra catch has now become a motivation to exploit

    small, orage sh populations and a burden on

    marine ood webs On average, it takes one to two

    pounds o wild sh processed into shmeal or oil

    and included in commercial eed to produce one

    pound o armed sh (rates vary between species;

    or some it takes much more)51 Tereore, as aqua-

    culture production increases, so does the demand

    or shmeal and oil Between 1995 and 2010, the

    aquaculture industrys use o shmeal increased75 percent, and its use o sh oil has risen by 62

    percent52

    Te growing demand or shmeal and oil does not

    appear to be without consequence Some species

    o the small sh used to create these products are

    considered to be ully exploited or overexploited,

    which, according to the Food and Agriculture

    Organization o the United Nations, means that no

    sustainable increases in catches rom these species

    can be expected53 Exploitation o these species can

    threaten not only their own populations, but also

    those o the predatory nsh,54 marine birds and

    mammals that depend on them or survival55

    In addition to these ecological problems rom using

    increasing amounts o shmeal and oil in the sh

    arming sector, nancial impediments have arisen

    As demand has gone up and supply has been

    squeezed, the price o shmeal has risen sharply It

    doubled between 1995 and 2010, and now consti-tutes the sh arming industrys largest production

    expense56

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    State of the Soy IndustryIn light o the burden that actory sh arming

    places on the marine ood web, any alternative

    plant-based sh eed may seem like a welcome

    alternative But beore soy is accepted as the savior

    o the sh arming industrys sustainability, the state

    o the soy industry and soy productions impacts onthe environment and our diet must be analyzed

    Who is lobbying for the soy industry?

    Te soy industry is well organized and represented

    in Washington, DC and other parts o the world57

    Te American Soybean Association (ASA) repre-

    sents 32,000 soybean producers and is primarily

    concerned with policy development and infuencing

    the legislative process in avor o soy growers58 In

    addition to the national association, 26 aliated

    Soybean Associations represent various states or

    regions o the United States,59 and the US Soybean

    Export Council has nine international oces60

    Te ASA states in a policy resolution that it

    supports expansion o the domestic aquaculture

    industry, including oshore aquaculture, and

    encourages ederal unding or research that

    would optimize the use o soybean protein and oil

    in aquaculture eed61 It even has included a resolu-

    tion that it supports the recommendation o theGul Coast Fishery Management Council to allow

    oshore sh arms in the Gul o Mexico,62 reer-

    ring to a controversial actory sh arming plan that

    was challenged in ederal courts63

    How much soy is genetically modified?

    According to the 2007 Census o Agriculture, the

    number o soy arms in the United States, at 279,110,

    was second only to the number o corn arms64 In

    the 2008 Organic Survey, only 1,336 soybean armswere reported as certied organic65 Te standards

    or certied organic ood do not allow the use o

    genetically engineered crops

    I arms arent producing or the organic market,

    there is a good chance that they are using geneti-

    cally modied seeds, and that they are whether

    intentionally or not looped into the major transna-

    tional companies that control large portions o our

    current ood system While the seed industry oncerelied on universities or most o its research and

    development, a ew major chemical and pharma-

    ceutical giants now dominate66

    Between 1996 and 2007, Monsanto acquired more

    than a dozen smaller companies67 Te company

    controlled approximately 625 percent o soybean

    seeds and seed trait licenses in the United States

    by 201068 By 2009, because o this dominance,

    93 to 94 percent o the soybeans produced in the

    United States are genetically modied according

    to Monsanto patents69 Te increase in geneti-

    cally engineered soybeans, which are resistant

    to Monsantos herbicide Roundup, has led to an

    increase in herbicide use70

    How much soy is in our food now?

    From 1996 to 2009, the sales o oods containing

    soy increased rom approximately $1 billion to

    almost $45 billion71 Soybeans are a key ingredient

    in many oods that Americans eat every day, even

    though they may not know they are eating them

    Soybeans are a key eed ingredient or cattle, hogs

    and chickens, and products known as textured

    soy protein and soy protein isolate are used in a

    wide variety o processed oods including hot dogs,

    hamburgers, baked goods, cereal, pasta and snack

    oods72 Soybean oil is also commonly used to ry

    rench ries at ast ood restaurants73 According to

    various estimates, soy is ound in 60 to 70 percent o

    our processed oods74

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    Beyond the soy that we consume directly, large

    amounts o soy are entering our ood chain indi-

    rectly, through our consumption o meat rom

    animals that have been raised on soy An estimated

    47 percent o the soy produced in the United States

    is consumed by livestock75

    What Does Soy Haveto Do With Fish Feed?Te US soy industry is powerul and successul at

    expanding its markets Te American Soy Associa-

    tion testies beore and lobbies Congress,76 and

    counts many successes in encouraging Congress

    and ederal agencies to enact policies in its avor77

    The soy industrys championingof soy diets for factory farmed fish

    In 2002, the United Soybean Board and the Illinois,

    Indiana and Ohio State Boards unded the Soy in

    Aquaculture Initiative, with the goals o increasing

    the use o soy in sh eed and developing a program

    or international marketing o soy-based aquacul-

    ture eed78 Under this initiative, the industry has

    unded many research projects to investigate the

    inclusion o soybeans in diets or salmon, marine

    shrimp and marine nsh Tese studies have

    been carried out by researchers at numerous US

    universities, and with commercial armers in Latin

    America, Asia and the Mediterranean79 In China

    alone, where the ASA began work in 1989,80 the

    industry has successully increased the volume o

    soy used annually in aquaculture eed rom close to

    zero to approximately 6 million metric tons81

    Although the industry has also given some support

    to the inclusion o soy in the diets in more sustain-

    able means o sh production, such as re-circu-

    lating land-based aquaculture, it has ocused mucheort on oshore cage-based aquaculture82 In

    2004, the Soy in Aquaculture Initiative began an

    Ocean Cage echnology Project to experiment with

    eeding soy to sh raised in oshore cage proto-

    types For the next two years, trials were completed

    o the coast o Hainan, China Although the study

    ound that these sh, which were kept at densities

    o 9,600 sh per cage, perormed as well on soy-

    based diets as on the sh meal-based control, the

    author concluded that growth rates were at leastpartially caused by the eects o antibiotics that the

    sh were given ater contracting a parasitic inec-

    tion83

    Te industry appears eager to bring this type o

    oshore arming to the United States as well Te

    ASA gives support to policies that will encourage

    the development o a US oshore aquaculture

    industry, and it has stated not merely that it

    applauds the release o a national aquaculture

    policy that includes the controversial plan or

    oshore aquaculture in the Gul o Mexico, but also

    that it will work toward [the policys] implementa-

    tion84

    Further, both the Illinois Soybean Association (ISA)

    and Indiana Soybean Alliance are members o the

    Ocean Stewards Institute, a trade organization that

    advocates or the open ocean sh arming industry

    and provides testimony and public comments toCongress and ederal agencies on policies regarding

    oshore aquaculture85 Te Director o the ISA has

    been vocal in the organizations support o NOAAs

    aquaculture plans, stating: We want to see aqua-

    culture grow and fourish Economic activity within

    the industry would be the best driver or economic

    opportunity or soybean armers, too, and we hope to

    see that86

    Te ISA has also worked closely with KampachiFarms, ormerly known as Kona Blue Water Farms,

    in Hawaii In August 2011, the ISA recognized

    Kampachis Neil Sims with an Excellence in Market

    Development award or research on soy inclusion

    in the diets o the companys sh87 Te ollowing

    month, a press release listing the ISA as a source

    announced Kampachis new project to test oshore

    cage technologies in which sh would be ed a

    diet with signicant portions o shmeal and oil

    replaced by soy and other agricultural proteins88

    In the past, the Kona Blue Water Farms has also

    listed the United Soy Board, Nebraska Soy Board

    and mega-agribusiness Monsanto as partners in its

    research89

    Te soy industrys enthusiasm or expanding open

    ocean aquaculture is not surprising given the

    potential market it oers soybean producers Te

    ederal government has estimated that marine

    nsh production could be raised to 590,000 tons

    annually by 202590 Te ISA has said that soy may

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    8 Food & Water Europe www.foodandwatereurope.org

    be able to comprise 35 percent o shes diets91 I

    the ederal governments goal is reached, and each

    o these sh is ed on a 35 percent soy diet, the

    soy industry could stand to net an additional $201

    million each year by supplying eed or marine

    nsh armed in the United States92 Tis does not

    include additional revenue that could be made

    supplying soy-based eed or reshwater sh, likecatsh, or anadromous sh like salmon and trout

    Nor does it include earnings made by supplying

    soy-based eed to rapidly expanding aquaculture

    industries in other countries93

    Cargill and Monsanto:Corporate interest in soy for farmed fish

    It isnt only soybean trade associations that have a

    stake in supporting the development o open ocean

    sh arming Other large corporate soy interestshave a role to play, too For instance, Monsanto

    supported a study on incorporating soy into sh

    diets by providing both genetically modied and

    non-genetically modied soy or the researchers to

    give salmon in eed trials94

    Cargill, the worlds largest trader in agricultural

    commodities and the third largest soybean-

    crushing rm,95 is also extending its role in the sh

    eed business Cargill created a team dedicated to

    aquaculture eed products in the 1990s96 In April

    2001, Cargill acquired Agribrands International,

    Inc97 Combined, the two companies control 178

    animal nutrition acilities/ actories98 Agribrands

    Purina, owned by Cargill, is now producing several

    lines o sh eed,99 and in May 2004 Cargill acquired

    another sh eed production company, Burris

    Mill100 According to the vice president o Cargill

    Animal Nutrition, Aquaculture is the primary ocus

    o Burris Mill, and Cargill intends to increase its

    presence in this industry101

    Impacts of a Soy Dieton Fish and Their EnvironmentDespite the industrys best eorts, there are still

    serious limitations and challenges to eeding soy

    to armed sh which is not entirely surprising

    considering that it is not a ood that sh would ever

    encounter naturally Even the America SoybeanAssociation has stated that, despite years o

    research unded both by government and industry,

    there are still unidentied actors in plant eedstus

    that limit its use in diets or carnivorous species,

    including most marine species o commercial

    importance, as well as salmon and trout102

    Issues of indigestibility and nutrient defi-ciency

    Various inherent qualities o soybeans make thema less-than-ideal ood source or sh Although,

    as the ASA and researchers have said, there are

    unidentied soybean meal components limiting its

    use, there are also many diculties that have been

    identied A review article o studies on plant-based

    eeds or sh indicates that soy is not easily digest-

    ible or sh, a problem that can lead to reduced

    growth rates and inecient eed use103

    Soybeans contain lower levels o some o thenutrients that sh need, and excessive concentra-

    tions o others Tey are lower than shmeal in nine

    o the 10 essential amino acids, crude at and ash104

    Crude at and ash can be made up or through

    supplementation, and amino acid concentrations

    could be increased by processing soybeans into soy

    protein concentrate or isolate, but these products

    are relatively expensive compared to shmeal105

    On the surplus side, soybeans contain high levels o

    carbohydrates, including two types that are indi-

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    Factory-Fed Fish: How the Soy Industry Is Expanding Into the Sea 9

    gestible or sh106 One o these types, non-starch

    polysaccharides (NSPs), intereres with the ability

    o sh to digest eed, thus making it dicult or the

    sh to obtain the energy they need107

    Additionally, soybeans contain protease inhibitors,

    natural components that help make the bean more

    resistant to pests but that damage the enzyme

    balance in sh digestive tracts, also impeding their

    ability to digest and utilize soy108

    o make things worse, when the raction o

    soybeans in sh eed is too high, sh may develop

    an infammation o the lower intestine called

    enteritis109 Tis infammation may be sparked by

    immunological ood intolerance essentially, like

    some people, sh may be allergic to soy110 rout and

    salmon that are ed soy, or example, sometimes

    mimic the human allergic reaction, suering skinlesions, alterations o the digestive tract and exces-

    sive mucus in the eces111

    Potential impacts on the marine environment

    Because certain characteristics o soy make it

    dicult or sh to digest, eeding sh soy and other

    plant-based eeds causes them to produce higher

    levels o excrement112 Even without unusually high

    waste production, waste fowing directly through

    sh arms into the ocean can damage the ecologicalequilibrium o the sea foor and cause habitat

    destruction or disrupt the ecology in the area113

    In addition, soybeans contain phytoestrogen, an

    estrogen-like chemical produced by plants Tere

    is inadequate research on what the impacts are o

    introducing phytoestrogen to the marine environ-

    ments around arms Various research has conrmed

    the [o]estrogenic activity o soybeans in sh114 In

    other words, the phytoestrogens in soybeans havebeen shown to produce physical eects on sh that

    are ed soy or injected with phytoestrogens in clinical

    settings

    Tere is insucient evidence to understand how

    severe these eects can be, but one study ound

    that when eels were ed one type o phytoestrogen

    present in soy, 11 times more eels became emales

    than in the control group115 Tere is inadequate

    research to know whether levels o soy eed being

    released into the aquatic environment are harmul

    to the reproduction o native sh species in the

    surrounding areas But this lack o understanding

    should give regulators and the open ocean aquacul-

    ture industry pause beore the wholesale adoption

    o soy diets or armed sh

    Dj vu?Fish are certainly not the first animal to

    be fed an unnatural diet on factory farms.

    Ninety-eight percent of soybean meal in the

    United States goes to livestock feed,116 and

    either corn, soybeans or a combination is

    the main ingredient of most feed mixtures

    for factory farmed cows, chickens and pigs.117

    Soy and corn became cheap feed options for

    livestock operations after a series of policy

    changes culminating with the 1996 Farm Bill,

    which marked the end of policies designed to

    stabilize farm prices.118 Change in farm policy

    eliminated requirements that some land be

    kept fallow and resulted in large increases in

    the amounts of soy and corn produced, thus

    leading to price decreases for these crops.119

    Rather than addressing the root cause of

    this problem in the 1996 Farm Bill, Congress

    issued emergency payments for farmers to

    offset their losses.120 These subsidies have

    continued to encourage overproduction,

    and livestock producers can often buy corn

    and soy feed below the cost of production.121

    Unfortunately, these farm animals arent

    naturally suited to corn and soy diets. Cows,

    for instance, are ruminants their four-part

    stomachs are made specifically to digest

    grass. When they eat other foods, their gut

    health may be impaired. Studies show that

    artificial diets increase the amount of time

    that E. coli strains live on in the manure of

    cows, which can be passed on to the meat

    itself.122 Increased antibiotic use to counter

    E. coli contributes to the development

    antibiotic-resistant bacteria strains.123

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    Impacts on ConsumersEvidence indicates that soy-based aquaculture

    eeds may not be the best option or the sh that eat

    them or the marine environment into which they

    are released But what about the people who eat the

    sh?

    Unortunately, there are lots o unanswered ques-tions about both eating soy in general, and eating

    sh raised on soy However, several potential health

    problems associated with soy consumption, as well

    as concerns about the nutrient prole o sh that

    are ed soy, indicate that we should proceed with

    caution

    Missing omega-3s

    Consumers increasingly preer ood products that

    are high in omega-3 atty acids124 Omega-3 attyacids are thought to promote human health and

    lessen the likelihood o various diseases, including

    coronary heart disease125 Tere are three types o

    omega-3 atty acids, which all into two general

    categories One, -linolenic acid (ALA), is a plant-

    based atty acid, and the other two, eicosapentae-

    noic acid (EPA) and docosahexaenoic acid (DHA),

    are marine atty acids We get these by consuming

    sh, which become enriched with them by eating

    algae126 Te American Heart Association recom-mends that adults eat sh at least twice a week in

    order to gain the positive benets o EPA and DHA,

    which it says are more potent than ALA127

    Unortunately, substituting the sh oil used in

    eed or armed sh with terrestrial plant oils, like

    soybean, reduces the concentration o these omega-

    3s in eed128 I sh armers do not want to produce

    a nal product low in omega-3s, they must switch

    their sh o o a soy diet and on to a high-sh oildiet shortly beore harvest129 Doing so, however,

    means that the industry will continue to consume

    small, wild sh the very problem that soy use was

    intended to avoid Researchers have also explored

    genetically engineering soy and other plants to

    increase the amount o omega-3s in them130 Tis

    would be a troubling proposition, however, or

    those who turn to sh or a more natural, sustain-

    able ood product, and it may bring other unin-

    tended consequences

    General impacts of soy consumption

    Perhaps more complicated is the issue o increasing

    soy in human diets Although eating sh that are ed

    soy is a less direct way to consume soybeans than

    eating soy products or snacks made with soybean

    oil, it needs to be questioned whether some compo-

    nents o soy such as the phytoestrogens could

    also be passed on to human consumers through

    their consumption o sh

    Soy is oten associated with healthy eating131 A

    central component in some Asian diets, such as the

    Japanese cuisine, soy has been associated with the

    historically lower rates o cardiovascular disease,

    menopausal symptoms, breast cancer, diabetes and

    obesity in these populations than in Western popu-

    lations132 However, some researchers are calling

    this linkage into question,133 or suggesting that theselow rates may be caused by dierent actors134

    Moreover, the soy in these diets may not be equiva-

    lent to the soy now present in the American diet

    due to diering levels o isofavones organic

    compounds that have been associated with some

    o the potentially negative impacts o soy135 New

    Zealand-based toxicologist Dr Mike Fitzpatrick

    has pointed out that the soy in traditional Asian

    diets is typically ermented, a process that lowersits levels o isofavones136 Additionally, the strains

    o soybeans grown in Asia are lower in isofavones

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    Factory-Fed Fish: How the Soy Industry Is Expanding Into the Sea 11

    even beore ermentation than those grown in

    North America, which have been bred to be higher

    in isofavones to make them more pest resistant137

    Te debate over soys impacts on human health

    has been contentious and complicated Although

    researchers have connected consumption o the

    phytoestrogens in soy to potential lowered risk

    o osteoporosis, heart disease and breast cancer,

    scientists Heather Patisaul and Wendy Jeerson

    have pointed out that phytoestrogens are also

    endocrine disruptors with a range o potential

    negative impacts that likely depend on a persons

    age and health status138 Tey state: While the

    potentially benecial eects o phytoestrogen

    consumption have been eagerly pursued, and

    requently overstated, the potentially adverse

    eects o these compounds are likely underappreci-

    ated139

    In addition, the jury is still out on whether the

    phytoestrogens in soy are helpul or harmul in

    protecting against breast cancer Although many

    studies have been conducted in both humans and

    animals, the results have been conficting140 For

    instance, a meta-analysis supported by the Susan

    G Komen Breast Cancer Foundation ound that the

    risk o developing breast cancer decreased as soy

    intake increased among Asian women, but that soyintake was unrelated to breast cancer risk in studies

    conducted in Western populations141

    Another study that looked at the eects o soy

    consumption on pre-existing cancers suggested

    that highly processed soy, like the sort commonly

    consumed in the United States, may be harmul

    to post-menopausal women with breast cancer

    Te study ound that mice that were ed minimally

    processed soy four, like that typically consumed inAsian diets, had no tumor growth, whereas tumors

    in mice that were ed more processed orms o

    soy grew Te study concluded that the benecial

    impacts o soy may be eliminated during certain

    types o processing, and cautioned against the

    common practice o natural hormone replacement

    therapy via increased soy intake or menopausal

    women, particularly those with breast cancer142

    Tere is also evidence that phytoestrogens could

    potentially be harmul or males A study geared

    at determining the negative impacts o eeding

    soy ormula to male human inants ound that

    eeding soy ormula to monkeys reduced the

    typical neonatal rise in testosterone expected at a

    certain age, an eect that they expected would be

    equal, or perhaps more marked, in human inants

    under the same conditions Although researchers

    are not sure what the impacts o suppressing thisneonatal rise in testosterone are, they write that

    it would seem prudent to avoid eeding inants

    with SFM [soy ormula milk] whenever alternatives

    are possible143 Another researcher has suggested

    that the isofavones present in soy reduce sperms

    mobility, thus having a great impact on male

    ertility144

    While the potential health impacts o soy consump-

    tion are yet to be ully understood, it appears that,

    as Patisaul and Jeerson state, moderation is likely

    key145

    Environmental and Human RightsInfringements in Soy ProductionRather than provide a sustainable eed or armed

    sh, soy-based eed simply shits the burden and

    potential risks onto other ecosystems Ninety-our

    percent o soy grown in the United States is geneti-

    cally modied,146 as is the majority grown in Argen-tina and Brazil147 Monsanto introduced genetically

    engineered soy in the mid 1990s Te companys

    Roundup Ready soy plants are designed to be

    resistant to Roundup, a herbicide that the company

    also sells, so that armers can chemically control

    weeds without damaging crops148 Increased use

    o herbicide has been shown to lead to herbicide-

    resistant weeds, which can in turn lead to even

    heavier herbicide use in a vicious cycle Tis intense

    chemical application raises concerns about poten-tial environmental and human health impacts149

    As the soy industry has expanded into South

    America, most notably in Argentina and Brazil,

    but also in Paraguay, Uruguay and Bolivia,150 it has

    led to deorestation and corresponding reduc-

    tion o tropical biodiversity and soil erosion151 An

    estimated 10,000 hectares (24,711 acres) o orest

    is lost in Argentina each year to expanded soy

    production152 Tis is damaging not only to plantsand animals,153 but also to human populations

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    12 Food & Water Europe www.foodandwatereurope.org

    As soy arms take over, indigenous people have

    been pushed rom their homeland154 An estimated

    300,000 peasant and indigenous amilies have

    been displaced in the last decade as a result o soy

    expansion in Argentina, and our out o ve previ-

    ously existing arming jobs have been lost

    In response, groups o small armers and peas-

    ants, such as La Via Campesina and the National

    Indigenous Campesino Movement o Argentina,

    have organized against the monoculture-based soy

    industry155 Even more shocking, there have been

    documented instances o orced labor on soy plan-

    tations in Brazil In 2004, the government created

    a registry o agricultural rms ound to have used

    slavery156 According to an October 2011 search o

    the governments database, six soy operations have

    been cited or enslaving a total o 241 workers157

    I the US governments estimation that the country

    can increase marine nsh production to 590,000

    tons a year by 2025 is achieved, and an average o

    35 percent o soy is included in the shs diets, as

    the Illinois Soy Association says is possible,158 then

    the industry would need to utilize an entire 456,292

    tons o harvested soy a year to eed these sh It

    would take approximately 172,838 hectares o land,

    or around 427,000 ootball elds, to produce this

    much additional soy each year159 Tis is over twotimes the size o greater New York City,160 and is 173

    times the amount o orest already lost to soybean

    cultivation in Argentina each year161 It is unclear

    what land would be used to meet this growing

    need will it be ound through additional tropical

    deorestation?

    Soy production in South America can also be

    problematic or national ood security Even the

    Argentine government has blamed the soybeaneconomy or diverting agricultural capacity toward

    soy exports, which have orced the country to

    import crops that it used to produce domestically162

    Te environmental eects o soybean production

    are by no means exclusive to South America In Illi-

    nois, Iowa, Ohio and southwest Minnesota, under-

    ground drainage pipes are used to make the land

    dry enough to plant corn and soybeans Te water

    that these pipes collect rom arms, which is mixed

    with nitrogen ertilizers, drains into tributaries that

    eventually eed into the Gul o Mexico163

    Te nitrogen ertilizer rom these pipes is possibly

    the largest source o nutrient pollution in the Gul164

    Tese pollutants eed harmul algae blooms that

    take oxygen out o the water, and can cause sh,

    shrimp, crabs and other marine lie to suocate i

    they cannot swim quickly enough to a more oxygen-

    rich area o the water Tese oxygen-depleted

    areas are known as dead zones, and in 2011 the

    dead zone in the Gul o Mexico equaled and likely

    exceeded the size o New Jersey165 I aquaculture

    were to create a demand or much more soy, it could

    potentially lead to more harmul runo rom soyarms, and more destruction o wild sh

    Other AlternativesTere are other options or working toward seaood

    sustainability On the most basic level, consumers

    can restrict their consumption to wild seaood rom

    well-managed sheries or sustainable arming

    operations Research, government unding and

    private entrepreneurial eorts can be shited away

    rom open ocean actory sh arming and toward

    other alternatives, such as land-based recirculating

    sh arms Because conditions in these closed-loop

    systems can be careully controlled, growth rates

    can be higher in closed-containment sh arms

    than in others166 Plus, sh convert eed eciently

    when the water they are in is at the optimum

    temperature,167 so the ability to control temperature

    in recirculating systems could potentially lead to

    lower overall eed requirements Instead o being

    ed wild sh or soy, these sh could be ed alterna-

    tive ingredients such as algae

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    Factory-Fed Fish: How the Soy Industry Is Expanding Into the Sea 13

    Because algae are rich in omega-3s and oils168 and

    are produced in marine environments, they seem

    likely to be a better option or sh eed than soy

    Whereas soybeans contain only 18 percent oil, algae

    contain as much as 70 percent by weight169 Tey

    can also be ecient to grow, with some species

    able to double their population in only 24 hours170

    Several researchers around the world, includinga team at the University o Maryland, which also

    houses a demonstration closed-loop recirculating

    sh arm, have been studying possibilities or using

    algae as sh eed171 For algae to be a good option,

    however, water use will need to be monitored and

    genetically engineered varieties avoided

    ConclusionTe soy industrys involvement in aquaculture is

    a tale o how ar-reaching the infuence o a large,powerul, well-organized agribusiness can be

    Although soy is an unexpected and unnatural ood

    or sh to eat, the research and outreach unded by

    the soy industry has propelled it to the oreront

    o alternative eed research in the aquaculture

    industry Because o the widespread concern about

    sh armings reliance on small, wild sh or eed,

    the industry has been able to position soybeans as

    an answer to aquacultures sustainability problems

    Unortunately, however, eeding soy to sh is ar

    rom sustainable Increasing the global demand or

    soy through the aquaculture industry could exac-

    erbate the negative ramications that already exist,

    including pollution to the Gul o Mexico, deoresta-

    tion in South America, displacement o indigenous

    peoples, and an increase in genetically modied

    crops It also raises questions about the rising ubiq-

    uity o soy in the ood chain and concerns about

    potential human health impacts

    Even i soy alleviates the eed problem in aquacul-

    ture, open ocean actory sh arming would still be

    plagued with the burden o potentially spreading

    disease to wild sh, threatening many types o

    marine mammals, birds and sh, and disrupting

    coastal shing communities Even worse, soy eed

    could increase some o the pollution impacts o

    ocean sh arming by increasing the amount o

    waste that sh produce

    Rather than a partnership or innovation, therelationship between the soy and aquaculture

    industries is one that could spread damage on both

    land and sea

    RecommendationsConsumers:

    Choose local or domestic seaood that is rom

    sustainable, wild sheries or rom conscientious

    land-based arms Tis helps you get better sh,protects the environment rom the damage

    caused by sh arming and supports economies

    in coastal communities

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    14 Food & Water Europe www.foodandwatereurope.org

    Look beyond the label Not all sustainable

    schemes are as helpul as you might think See

    De-Coding Seaood Eco-Labels: How the Euro-

    pean Commission Can Help Consumers AccessSustainable Seaood or more

    Oppose expansion o commercial sh arming

    operations Tey promise clean, green jobs, but

    they dont deliver See No Jobs Hereor more

    Policymakers:

    Support research and eorts to sustainably

    manage wild sh stocks, and explore other

    methods o aquaculture, such as land-basedrecirculating systems

    Shit research unding away rom soy into

    investigating alternative sh eeds like algae

    Support communities eorts to prohibit expan-

    sion o commercial sh arming operations in

    avor o jobs and industries with a genuinely

    sustainable uture

    Shit arming policies toward research intoalternative breeds and eeds to help break

    Europes dependence on imported soy that

    enables industrial meat and sh production and

    exports our environmental damage to other

    countries

    Support moves or the European Union to with-

    draw its soybean commitments under the Blair

    House Agreement and the current WO Agree-

    ment on Agriculture Te EU should be able to

    reassess and reestablish arm programs without

    the limitations posed by agreements designed

    to suit industrial armers in other countries

    See Te Perils o the Global Soy rade: Economic,

    Environmental and Social Impacts or more

    Endnotes1 AmericanSoybeanAssociaon.CEOReporttotheBoardandStates.

    March2010.

    2 AmericanSoybeanAssociaon.ASAPolicyResoluons.March5,2011at

    2.23.09.

    3 IllinoisSoybeanAssociaon.[PressRelease].VelellaResearchProject

    PromisestoRevoluonizeSustainableAquaculture.September14,2011.

    As reprinted in The Sacramento Bee.

    4 Ibid.

    5 FoodandAgricultureOrganizaonoftheUnitedNaons(FAO).TheState

    oftheWorldsFisheriesandAquaculture2010.2010atForeword.

    6 Weber,MichaelL.SeawebAquacultureClearinghouse.WhatPriceFarmed

    Fish:Areviewoftheenvironmentalandsocialcostsoffarmingcarnivo -

    roussh.2003at18and43;Rana,KrishenandMohammedHasan.FAO.

    ImpactofRisingFeedIngredientPricesonAquafeedandAquaculture

    Producon.(FisheriesandAquacultureTechnicalPaper541.)2009ativ.

    7 Naylor,RosamondandMarshallBurke.AquacultureandOceanResources:

    Raisinggersofthesea.Annual Review of Environmental Resources,vol.

    31.2005at185to218.

    8 Shamshak,GinaandJamesAnderson.FutureAquacultureFeedsandFeed

    Costs:TheRoleofFishMealandFishOil.InNaonalOceanicandAtmo -

    sphericAdministraon(NOAA).Oshore Aquaculture in the United States:

    Economic Consideraons, Implicaons and Opportunies.2008at73to96.

    9 Inthatitresultsinanetlossofproteinifitrequiresmorethanoneunitof

    wildshtoproduceoneunitoffarmedsh.SeeWeber(2003)at24.

    10 Sles,Margotetal.Oceana.HungryOceans:Whathappenswhentheprey

    isgone?Undatedat2,4,9and18;Cury,Philippeetal.GlobalSeabird

    ResponsetoForageFishDepleonOne-thirdfortheBirds.Science,vol.

    334,iss.6063.December2011at1703to1706.

    11 Forexample,theMarineAquacultureTaskforcerecommendedin2007thataenontoalternavefeeds,suchassoy,wouldbeadvisablefortheaqua -

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    Factory-Fed Fish: How the Soy Industry Is Expanding Into the Sea 15

    cultureindustry.See:MarineAquacultureTaskforce.SustainableMarine

    Aquaculture:FulllingthePromise;ManagingtheRisks.January2007at

    95and99.

    12 Basedon2011pricesforsoyofapproximately$12abushel,anaverage

    feedconversionrateof1.75andstascalconversionsoftheSoybean

    ExportCouncil,weesmatethatthesoyindustrycouldpotenallynet

    $201millionannuallybysupplyingsoyasaningredientforthefeedofthe

    590,000tonsofmarinenshthatNOAAhasesmatedcouldbeproduced

    annuallyby2025.MethodologyonlewithFood&WaterWatch.

    13 Gatlin,Delbertetal.Expandingtheulizaonofsustainableplantproducts

    inaquafeeds:Areview.Aquaculture Research,vol.38.2007at557,558and

    566.

    14 Duetothefactthat94percentofsoygrownintheUnitedStatesisgene-

    callymodied.See:UnitedStatesDepartmentofAgriculture(USDA),

    EconomicResearchService.AdoponofGenecallyEngineeredCropsin

    theU.S.:SoybeanVariees.July1,2011.

    15 Barne,Anthony.TheyHailedItasaWonderfood.The Guardian(Lon-

    don).November7,2004.

    16 Ibid.

    17 Wallace,Sco.LastoftheAmazon.Naonal Geographic,vol.211,iss.1.

    January2007at40to71.

    18 FAO(2010)atForeword.

    19 Alston,DallasE.etal.EnvironmentalandSocialImpactsofSustainable

    OshoreCageCultureProduconinPuertoRicanWaters.FinalReport

    SubmiedforNOAAFederalContractNumber:NA16RG1611.April2004at

    12.

    20 NaylorandBurke(2005)at202.

    21 Upton,HaroldandEugeneBuck.OpenOceanAquaculture.Congressional

    ResearchService.August9,2010at12to13;NaylorandBurke(2005)at

    203.

    22 UptonandBuck(2010)at11.

    23 Tacon,AlbertandMarcMean.Globaloverviewontheuseofshmeal

    andshoilinindustriallycompoundedaquafeeds:Trendsandfuture

    prospects.Aquaculture,vol.285.2008at154;FAO.Fishmeal.Globesh.

    March2010;Slesetal.(undated)at2,4,9and18;Curyetal.(2011)at

    1703to1706.

    24 U.S.SoybeanExportCouncil,UnitedSoybeanBoardandAmericanSoybean

    AssociaonInternaonalMarkeng.SoyProteinConcentrateforAqua -

    cultureTechnicalBullen.2008at8;AmericanSoybeanAssociaon.Com-

    mentsSubmiedtotheUnitedStatesDepartmentofAgricultureinregards

    totheResearchEducaonandEconomicsOceRoadmap.May2009;Hart,

    Steven.SoyAquacultureAlliance.PresentaonatAquacultureCoalion

    Meeng.March2012.

    25 Forinstance,asillustratedbytheIllinoisSoybeanAssociaonworkingwith

    andcommemorangtheworkofKonaBlueWaterFarms:KonaBlueWa-

    terFarmsCo-founderWinsAward.Pacic Business News.August2,2011;

    alsobythesameorganizaonspartnershipwithaquaculturistsinIllinois:

    IllinoisSoybeanAssociaon.[PressRelease].IllinoisAquacultureSurfaces

    asNewSoybeanPartner.September9,2010;andbytheU.S.SoyExport

    CouncilandtheIndianaSoybeanAlliancesmembershipintheGlobalAqua -

    cultureAlliance:GlobalAquacultureAlliance.AssociaonMembers.2011.

    26 AmericanSoybeanAssociaon.ASAPolicyResoluons.March5,2011at

    2.23.09.

    27 AmericanSoybeanAssociaon.[PressRelease].ASAOutlinesPotenalofOshoreAquacultureforSenateCommiee.April6,2006.

    28 Gatlinetal.(2007)at553to554.

    29 Naylor,RosamondL.etal.Feedingaquacultureinaneraofnitere-

    sources.Proceedings of the Naonal Academy of Sciences,vol.106,iss.36.

    September8,2009at15106.

    30 Marder,Jenny.FarmRunoinMississippiRiverFloodwaterFuelsDead

    ZoneintheGulf.PBS.May18,2011.

    31 Barne(2004).

    32 Wallace(2007)at40to71.

    33 Pasaul,HeatherB.andWendyJeerson.Theprosandconsofphytoes-

    trogens.Froners in Neuroendocrinology,vol.31.March2010at402;

    Barne(2004);InstuteforAgricultureandTradePolicy.Below-CostFeed

    Crops:AnIndirectSubsidyforIndustrialAnimalFactories.June2006.

    34 PasaulandJeerson(2010)at400.

    35 See,forexample,Food&WaterWatch.WhosBenengfromFactory

    FishFarming.September2011.Availableatwww.fwwatch.org

    36 Asevidencedbythevariousbillsregardingoshoreaquacultureintroduced

    inthepast15years,theGulfFisheryManagementPlanforOshoreAqua -

    culture,andthediscussionofsoyintheNOAA/USDAFutureofAquafeeds

    report,whichstatesthattheexpertpanelconvenedtodiscussalternave

    feedingredientsforaquacultureendorsesthestrategicresearchplanlaid

    outbythePlantProductsinAquafeedsWorkingGroupwithsponsorship

    fromtheUnitedSoybeanBoard.See:S.1192,104thCong.(1995);S.1195,

    109thCong.(2005);S.1609,110thCong.(2007);H.R.2010,110thCongress

    (2007);H.R.4363,111thCongress(2009);H.R.2373,112thCongress

    (2011);GulfofMexicoFisheryManagementCouncil.FisheryManagement

    PlanforRegulangOshoreMarineAquacultureintheGulfofMexico.

    January2009at18to19;Rust,Michaeletal.TheFutureofAquafeeds,

    NOAA/USDAAlternaveFeedsIniave.November2010at45;Plant

    ProductsinAquafeedWorkingGroup.StrategicResearchPlan.November

    2005at2;UptonandBuck(2010).

    37 U.S.DepartmentofCommerce.AquaculturePolicy.1999.

    38 Ibid.

    39 CalculaonsconductedbyandonlewithFood&WaterWatch.Formore

    informaon,seeFood&WaterWatch.FishyFarms:TheGovernments

    PushforFactoryFishFarmsinOurOceans.October2011.

    40 NaonalMarineFisheriesService.FisheriesoftheUnitedStates.NOAA.

    2010at50and63.

    41 Forfurtheranalysisandinformaon,seeFood&WaterWatch.Import

    Alert.May2007;Food&WaterWatch.LaboratoryError.December

    2008.

    42 KonaBlueWaterFarms,LLC.FinalSupplementalEnvironmentalAssess-mentforaModicaontoNetPenDesignsWithintheExisngProducon

    CapacityandFarmLeaseAreaforKonaBluesOshoreOpenOceanFish

    FarmoUnualohaPoint,Kona,Hawaii.April21,2009at10,22and23.

    43 Forinstance,anarcleinScienc Americanwrites:Atoshoresitessuch

    asKonaBlueWaterFarms,polluonisnotanissue,Sims[companypresi -

    dent]explains.Thesevensubmergedpaddocks,eachoneasbigasahigh

    schoolgymnasium,areanchoredwithinrapidcurrentsthatsweepawaythe

    waste,whichisquicklydilutedtoharmlesslevelsintheopenwaters.See

    Simpson,Sarah.TheBlueFoodRevoluon:Makingaquacultureasustain -

    ablefoodsource.Scienc American.February7,2011.

    44 MarineAquacultureTaskForce.SustainableMarineAquaculture:Fullling

    thePromise;ManagingtheRisks.January2007at6.

    45 Sar,G.etal.Impactsofmarineaquacultureatlargespaalscales:

    evidencesfromnandpcatchmentloadingandphytoplanktonbiomass.

    Marine Environmental Research.AcceptedFebruary24,2011.

    46 Heuer,Ole.E.etal.HumanHealthConsequencesofUseofAnmicrobial

    AgentsinAquaculture.Clinical Infecous Diseases,vol.49,iss.8.2009at

    1248to1253.

    47 Formoreinformaonsee,forexample,Food&WaterWatch(2011).

    48 Asdemonstratedbypubliccommentssubmiedin2011inregardto

    NOAAsDraAquaculturePolicyincluding:Commentssubmiedby2,325

    individualsandbySarahAlexanderonbehalfofFood&WaterWatch

    supporters;Raney,Dave.SierraClub.SierraClubCommentsonNOAA

    andDepartmentofCommerceDraAquaculturePolicies.April11,2011;

    Keever,MarcieandEricHoman.FriendsoftheEarth.NOAAsDraAqua-

    culturePolicy.April11,2011;Witkowski,JillM.SanDiegoCoastkeeper.

    CommentsonNOAAsDraAquaculturePolicy.April11,2011;Coastal

    ConservaonAssociaon.CommentsontheNOAADraAquaculturePol -

    icy.April11,2011;Vinsel,Mark.UnitedFishermenofAlaska.Comments

    onNOAADraAquaculturePolicy.April11,2011;Kelley,Dale.Alaska

    TrollersAssociaon.DOCandNOAADraAquaculturePolicies.April10,

    2011;Kimbrell,Andrew.TheCenterforFoodSafety.CommentstoDepart-

    mentofCommerceandNOAADraNaonalAquaculturePoliciesonthe

    NeedforaProgrammacEnvironmentalImpactStatement.April11,2011;

    Mitchell,JamesandMarianneCufone.Food&WaterWatch.Comments

    ontheFebruary2011NaonalOceanicandAtmosphericAdministraon

    DraAquaculturePolicyandtheDepartmentofCommercesDraNaonal

    AquaculturePolicy.April11,2011.

    49 NaylorandBurke(2005)at194.

    50 FAO.Theproduconofshmealandoil.(FAOFisheriesTechnicalPaper

    142.)1986at1.

    51 UptonandBuck(2010)at14.

    52 TaconandMean(2008)at146to158.

    53 FAO.Reviewofthestateofworldmarinesheryresources.(FAOFisheries

    TechnicalPaper457.)2005at6to7.

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    16 Food & Water Europe www.foodandwatereurope.org

    54 Upho,J.H.Jr.Predator-preyanalysisofstripedbassandAtlancmenha-

    deninupperChesapeakeBay.Fisheries Management Ecology,vol.10,iss.

    3.2003at313to322.

    55 Cury(2011)at1703to1706;Bearzi,Giovannietal.Ecology,statusand

    conservaonofshort-beakedcommondolphinsDelphinus delphisinthe

    MediterraneanSea.Mammal Review,vol.33,iss.3.2003at236.

    56 U.S.DepartmentofCommerce,NOAA,NaonalMarineFisheriesService.

    BudgetAcvity:NaonalMarineFisheriesService.FiscalYear2012at117

    and118.

    57 TheAmericanSoybeanAssociaonisrepresentedinWashington,D.C.by

    thermGordleyAssociates.See:DelaneyMovestoAmericanSoybean

    Associaon.The Hagstrom Report,December19,2011;CenterforRespon -

    sivePolics.OpenSecrets.AmericanSoybeanAssociaon.Availableat

    www.opensecrets.org.AccessedFebruary2012.

    58 AmericanSoybeanAssociaon.StatementtotheUnitedStatesDepartment

    ofAgricultureResearch&PromoonProgramsJointTaskForce.Wash-

    ington,D.C.March9,1999;AmericanSoybeanAssociaon.ASASoybean

    Success.2008.

    59 AmericanSoybeanAssociaon.FirmlyRootedinSuccess:2011Soybean

    SuccessReport.AnnualReport.2011at11.

    60 U.S.SoybeanExportCouncil.AnnualReport.2009.

    61 AmericanSoybeanAssociaon.ASAPolicyResoluons.March5,2011at

    2.23.07

    62 Ibid.at2.23.09.

    63 GulfRestoraonNetwork,Inc.etal.v.NaonalMarineFisheriesServiceetal.730F.Supp.2d157(D.D.C.2010).

    64 USDA.FarmNumbers,Demographics,Economics.2007CensusofAgricul-

    ture.2007.

    65 USDA.2008OrganicSurvey.2008atTable7,OrganicFieldCropsHar-

    vestedfromCeredandExemptOrganicFarms.

    66 Howard,Phil.MichiganStateUniversity,AssistantProfessor.SeedIndustry

    Structure,1996-2008.2009.OnleatFood&WaterWatch;Fernandez-

    Cornejo,Jorge.TheSeedIndustryinAgriculture.USDAEconomic

    ResearchService,AIB-786.January2004at25to26and36(Table18).

    67 Fernandez-Cornejo(2004)at33to34.

    68 See:Moss,DianaL.TheAmericanAntrustInstute.TransgenicSeedPlat-

    forms:CompeonBetweenaRockandaHardPlace?Addendum.April

    5,2010at5;Moss,DianaL.TheAmericanAntrustInstute.Transgenic

    SeedPlaorms:CompeonBetweenaRockandaHardPlace?October23,2009at13to14.

    69 AdoponofGenecallyEngineeredCropsintheU.S.:SoybeanVariees.

    DataSet,EconomicResearchService,USDA;Whoriskey,Peter.Monsantos

    dominancedrawsantrustinquiry.Washington Post.November29,2009.

    70 Benbrook,Charles.GenecallyEngineeredCropsandPescideUseinthe

    UnitedStates:TheFirstNineYears.BioTechInfoNet,Paper7.October2004

    at2,4,22and34.

    71 Soyatech,LLCandSPINS.SoyfoodsAssociaonofNorthAmerica.TheU.S.

    Market2010.OnlewithFood&WaterWatch.

    72 PasaulandJeerson(2010)at402.

    73 Jahren,A.HopeandRebeccaA.Kra.Carbonandnitrogenstableisotopes

    infastfood:Signaturesofcornandconnement.Proceedings of the Na-

    onal Academy of Sciences,vol.105,iss.46.2008at17859.

    74 PasaulandJeerson(2010)at402;Barne(2004).75 InstuteforAgricultureandTradePolicy(2006).

    76 See:AmericanSoybeanAssociaon.ASASoybeanSuccess.2008;Censky,

    Stephen.AmericanSoyAssociaon.CEOReporttotheBoardandStates.

    July2011.

    77 AmericanSoybeanAssociaon.FirmlyRootedinSuccess:2011Soybean

    SuccessReport.AnnualReport.2011at4.

    78 Hart,Stevenetal.Soybeanannutrionalfactorsandtheirrelave

    importanceinlimingtheuseofsoybeanmealinsalmoniddiets.Funded

    byIndianaSoybeanAlliance,IllinoisSoybeanAssociaon,IowaSoybeanAs -

    sociaon,OhioSoybeanCouncilandtheUnitedSoybeanBoard.Undated.

    79 Hart,Steven.SoyAquacultureAlliance.PresentaonatAquacultureCoali-

    onMeeng.March2012.

    80 AmericanSoybeanAssociaon.StatementtotheUnitedStatesDepartment

    ofAgricultureResearch&PromoonProgramsJoinTaskForce.Washing-

    ton,D.C.March9,1999.

    81 AmericanSoybeanAssociaon.Aquaculture.PosionPapers.Onleat

    Food&WaterWatch;Gatlinetal.(2007)at552.

    82 See,forexample:VirginiaCobiaFarms.IndustryExperienceinGood

    PracceRecirculaonSystems.PresentedattheWWFsSeriolaandCobia

    AquacultureDialogues(SCAD)II,Veracruz,Mexico.September25,2009at

    31;BellAquacultureandIndianaSoybeanAlliance.[PressRelease].Bell

    AquacultureTeamswithIndianaSoybeanAlliance,VirginiaCobiaFarmsand

    theConservaonFundsFreshwaterInstute.January25,2012.

    83 Hsiang,PinLan.GrowthPerformanceofPompano(Trachinotus blochii)

    FedFishmealandSoyBasedDietsinOshoreOCATOceanCages.Results

    of2007OCATCageFeedingTrialinHainan,China.

    84 AmericanSoybeanAssociaon.Aquaculture.Undated.

    85 Sims,Neil.OceanStewardsInstute.TesmonytotheHouseSubcom-

    mieeonInsularAairs,OversightHearingonOshoreAquaculture.

    September9,2009;OceanStewardsInstute.Commentssubmiedduring

    publiccommentperiodondrapolicy.CommentsontheNaonalDra

    DOCNaonalAquaculturePolicy.NOAA,DepartmentofCommerce,2011.

    86 IllinoisSoybeanAssociaon.[PressRelease].ISAEncouragesU.S.Aquacul-

    tureIndustrytoMoveForward.June6,2011.

    87 KonaBlueWaterFarmsCo-founderWinsAward.Pacic Business News.

    August2,2011.

    88 IllinoisSoybeanAssociaon(September14,2011).

    89 Sims,Neil.KonaBlue,andtheFutureofFish.PresentaonattheAmeri-

    canSoybeanAssociaonAquacultureInvestmentSeminar,Miami,Florida,

    August24,2010.

    90 NOAA,U.S.DepartmentofCommerce.NOAA10-YearPlanforMarine

    Aquaculture.October2007at12.

    91 IllinoisSoybeanAssociaon(June6,2011).

    92 Basedon2011pricesforsoyofapproximately$12abushel,anaverage

    feedconversionrateof1.75forthisproduced,andstascalconversions

    oftheSoybeanExportCouncil.MethodologyonlewithFood&Water

    Watch.

    93 AccordingtotheFAO,aquacultureisdeveloping,expandingandintensify-

    inginalmostallregionsoftheworld,exceptinSub-SaharanAfrica:FAO.

    StateofWorldAquaculture2006.(FisheriesTechnicalPaperNo.500.)

    2006.

    94 Sissener,N.H.etal.AlongtermtrialwithAtlancsalmon(Salmo salar

    L.)fedgenecallymodiedsoy;focusinggeneralhealthandperformance

    before,duringandaerparr-smolttransformaon.Aquaculture,vol.294,

    iss.12,September2009at108to115;Sissener,N.H.etal.AnAssessment

    oforganandintesnalhistomorphologyandcellularstressresponsein

    Atlancsalmon(Salmo salar L.)fedgenecallymodiedRoundupReady

    soy.Aquaculture,vol.298,iss.12,December2009at101to110.

    95 Blas,Javier.CargillBuysAgriumsGrainTradeUnit.The Financial Times

    (London).December15,2010;Hendrickson,MaryandHeernan,William.

    ConcentraonofAgriculturalMarkets.UniversityofMissouri.April2007.

    96 Whiy,Gerry.SmallPondsServeaBigFish.Feed & Grain.June/July2007.

    97 AgribrandsShareholdersApproveMergerwithCargill.PR Newswire.April

    26,2001.

    98 Grainnet.CargilltoAcquireAgribrands.December8,2000.

    99 Cargill.AgribrandsPurina(JiaXing)FeedmillCo.,Ltd.AccessedonJune10,

    2011.OnlewithFood&WaterWatch;CargillBuysStakeinPurina.Food

    Navigator.May22,2001.

    100 CargilltoacquireBurrisMills&FeedInc.TheFishSite.

    101 Ibid.

    102 AmericanSoybeanAssociaon.[PressRelease].ASAOutlinesPotenalof

    OshoreAquacultureforSenateCommiee.April6,2006.

    103 Gatlinetal.(2007)at557,558and566.

    104 Ibid.at553.

    105 Ibid.

    106 Chou,R.L.etal.Substungshmealwithsoybeanmealindietsofjuve-

    nilecobiaRachycentron canadum,Aquaculture,vol.229,iss.14.2004at

    325to333.

    107 Gatlinetal.(2007)at557and558.

    108 Ibid.at559.

    109 Ibid.110 Bakke-McKellop,etal.Changesinimmuneandenzymehistochemical

    phenotypesincellsintheintesnalmucosaofAtlancsalmon, Salmo salar

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    Factory-Fed Fish: How the Soy Industry Is Expanding Into the Sea 17

    L.,withsoybeanmeal-inducedenteris.Journal of Fish Diseases,vol.23.

    2000at115to127;Gatlinetal.(2007)at559.

    111 Gatlinetal.(2007)at559.

    112 Nayloretal.(2009)at15106.

    113 Alston,DallasE.etal.EnvironmentalandSocialImpactofSustainable

    OshoreCageCultureProduconinPuertoRicanWaters.FinalReport

    SubmiedforNOAAFederalContractNumber:NA16RG1611.April2004at

    12.

    114 Gatlinetal.(2007)at560to561.

    115 Ibid.at561.

    116 Ash,Mark.SoybeansandOilCrops:Background.USDA,EconomicRe-

    searchService.May7,2010.

    117 Starmer,E.,andT.A.Wise.FeedingattheTrough:IndustrialLivestock

    FirmsSaved$35BillionfromLowFeedPrices.GDAEPolicyBriefNo.07-03.

    GlobalDevelopmentandEnvironmentInstuteofTusUniversity.Decem -

    ber2007.

    118 Eand,AnneB.W.USDA,EconomicResearchService.U.S.FarmPolicy:

    TheFirst200Years.AgriculturalOutlook.March2000at25.

    119 Beitel,Karl.U.S.FarmSubsidiesandtheFarmEconomy:Myths,Realies,

    Alternaves.FoodFirst/InstuteforFoodandDevelopmentPolicy.Sum-

    mer2005.

    120 Ray,Darrelletal.AgriculturalPolicyAnalysisCenter,UniversityofTennes-

    see.RethinkingUSAgriculturalPolicy:ChangingCoursetoSecureFarmer

    LivelihoodsWorldwide.September2003at9.

    121 Ibid. at13.;StarmerandWise(2007).

    122 Franz,Eelcoetal.EectsofCaleFeedingRegimenandSoilManage-

    mentTypeontheFateofEscherichiacoliO157:H7andSalmonellaenterica

    SerovarTyphimuriuminManure,Manure-AmendedSoil,andLeuce.

    Applied and Environmental Microbiology,vol.71,iss.10.October2005at

    6165and6172;Callaway,T.R.etal.Foragefeedingtoreducepreharvest

    Escherichiacolipopulaonsincale,areview.Journal of Dairy Science,

    vol.86,iss.3.2003at858.

    123 Schroeder,CarlM.etal.AnmicrobialResistanceofEscherichiacoliO157

    IsolatedfromHumans,Cale,Swine,andFood.Applied and Environmental

    Microbiology,vol.68,iss.2.February2002.

    124 Nayloretal.(2009)at15103.

    125 Li,MengheH.etal. EectsofDriedAlgaeSchizochytriumsp.,aRichSource

    ofDocosahexaenoicAcidonGrowth,FayAcidComposion,andSensory

    QualityofChannelCaishIctalurusPunctatus.Aquaculture,vol.292.2009at232.

    126 Jenkins,DavidandAndreaJosse.Fishoilandomega-3fayacids.Cana-

    dian Medical Associaon,vol.178,iss.2.January2008at150.

    127 Kris-Etherton,PennyM.etal.AmericanHeartAssociaon.Omega-3Fay

    AcidsandCardiovascularDisease:NewRecommendaonsfromtheAmeri -

    canHeartAssociaon.Arteriosclerosis, Thrombosis and Vascular Biology,

    vol.23.2003at151to152.

    128 Nayloretal.(2009)at15107.

    129 Ibid.

    130 Ibid.

    131 Lawrence,Felicity.ShouldWeWorryAboutSoyainOurFood?The Guard-

    ian(London).July25,2006.

    132 PasaulandJeerson.2010at400.133 Ibid.

    134 Lawrence(2006).

    135 Ibid.;Barne(2004).

    136 Lawrence(2006).

    137 Ibid.

    138 PasaulandJeerson(2010)at400.

    139 Ibid.at413.

    140 Ibid.at406to407.

    141 Wu,A.H.etal.Epidemiologyofsoyexposuresandbreastcancerrisk.Brit-

    ish Journal of Cancer,vol.98iss.98.2008at9to14.

    142 Allred,ClintonD.etal.Soyprocessinginuencesgrowthofestrogen-

    dependentbreastcancertumors.Carcinogenesis, vol.25,iss.9.2004at

    1649to1657.

    143 Sharpe,RichardM.etal.Infantfeedingwithsoyformulamilk:eectson

    thetessandonbloodtestosteronelevelsinmarmosetmonkeysduring

    theperiodofneonataltescularacvity.Human Reproducon,vol.17,iss.

    7.2001at1692,1699and1701.

    144 Barne(2004).

    145 PasaulandJeerson(2010)at414.

    146 AdoponofGenecallyEngineeredCropsintheU.S.:SoybeanVariees.

    DataSet,EconomicResearchService,USDA.

    147 AlmostallofArgennassoybeancropisnowfrombiotechnologyseeds:

    Mergen,DavidandAndreaYankelevich.USDA,ForeignAgriculturalService.

    ArgennaAgriculturalBiotechnologyAnnual.July15,2011at2;In

    2007/08anesmated5261percentofBrazilssoycropwasgenecally

    modied:EuropeanCommission,Health&ConsumersDirectorate-General,FinalreportofamissioncarriedoutinBrazilfrom22Aprilto30April2009

    inordertoevaluateocialcontrolsystemsforfood,feedandseedconsist-

    ingoforproducedfromgenecallymodiedorganisms(GMOs)intended

    forexporttotheEU.(DG(SANCO)/2009-8301-MRFINAL.)2009at4.

    148 Paarlberg,Robert.Food Polics: What Everyone Needs to Know.Oxford:

    OxfordUniversityPress.2010at163.

    149 Binimelis,Rosaetal.Transgenictreadmill:Responsestotheemergency

    andspreadofglyphosate-resistantjohnsongrassinArgenna.Geoforum,

    vol.40,iss.4.July2009at623to633.

    150 AmericanSoybeanAssociaon.SoyStats,AReferenceGuidetoImpor-

    tantSoybeanFacts&Figures.2011at30;Garca-Lpez,GustavaA.and

    ArizpeNancy.ParcipatoryprocessesinthesoyconictsinParaguayand

    Argenna.Ecological Economics,vol.70,iss.2.December2010at196to

    206.

    151 Nepstad,Danieletal.TheEndofDeforestaonintheBrazilianAmazon.

    Science,vol.326.December2009at1350to1351;Grau,H.Ricardoand

    MitchellAide.GlobalizaonandLand-UseTransionsinLanAmerica.

    Ecology and Society,vol.13,iss.2.2008atarcle16(onlinepublicaon).

    152 Barne(2004).

    153 vanSolinge,TimBoekhout.DeforestaoncrimesandconictsintheAma-

    zon.Crical Criminology,vol.18,iss.4.December2010at263to277.

    154Wallace(2007)at40to71.

    155 Garca-LpezandArizpe(2010)at196to206.

    156 ReporterBrasil.SlaveLabourLaundryList.AccessedOctober23,2011.

    157 InternaonalLabourOrganizaon,EthosInstuteandReprterBrasil.Slave

    LabourLaundryList.AccessedOctober23,2001.

    158 IllinoisSoybeanAssociaon.(June6,2011).

    159 CalculaonsconductedbyandonlewithFood&WaterWatchbasedon

    averagefeedconversionraosof1.75.

    160 CalculaonsconductedbyandonlewithFood&WaterWatch.

    161 Anesmated10,000hectaresoflandarelostinArgennaeachyear,and

    weesmate172,838hectaresoflandwillbeneeded.172,838/10,000=

    1.73.Barne(2004).

    162 Lewis,Steven.SouthAmericansoybeanboomposeslogiscalchallenges.

    Food Chemical News.March1,2010.

    163 Marder(2011);David,MarkB.,etal. SourcesofNitrateYieldsintheMis-

    sissippiRiverBasin.Journal of Environmental Quality,vol.39.September

    October2010.

    164 Ibid.

    165 Ibid.

    166 Timmons,M.B.andJ.M.Ebeling.RecirculangAquaculture.CayugaAquaVentures.2007at7.

    167 Masser,Michaeletal.SouthernRegionalAquacultureCenter.Recirculat-

    ingAquacultureTankProduconSystems:ManagementofRecirculang

    Systems.No.452.March1999.

    168 Li,MengheH.,etal.EectsofDriedAlgaeSchizochytriumsp., aRich

    SourceofDocosahexaenoicAcidonGrowth,FayAcidComposion,and

    SensoryQualityofChannelCaishIctalurusPunctatus.Aquaculture,vol.

    292.2009at232to236;Mata,Teresaetal.Microalgaeforbiodiesel

    produconandotherapplicaons:Areview.Renewable and Sustainable

    Energy Reviews,vol.14.Spring2010at221.

    169Mata(2010)at221.

    170 Chis,Yusef.Biodieselfrommicroalgae.Biotechnology Advances,vol.25.

    February2007at126.

    171 Block,Ben.WorldwatchInstute.NewFishFarmsMovefromOceantoWarehouse.May2008.

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