FAO’s vision for aquaculture is clearly presented in its “Blue Transformation roadmap”: the objective is the “intensification and expansion of sustainable aquaculture,” so that it “continues to meet the global demand for aquatic foods.”
The expectation is that, through this blue transformation, aquaculture will supplement what fisheries cannot provide while reducing pressure on wild fish stocks. Some experts, however, are calling for caution about “aquaculture over-optimism”. According to a recent report, the growth rate of aquaculture cannot be maintained in the future. The authors contend that, “the notion that fish farms alone could supply most of the fish that the world needs seems unrealistic,” and that even if it was feasible, “its socio-economic cost to low-income coastal countries could be devastating.”
On its side, the FAO insists on the fact aquaculture must be “sustainable.” To define what this means in practice, it is developing Guidelines for Sustainable Aquaculture (GSA). Ahead of the 12th session of the COFI Sub-Committee on Aquaculture, which will take place in May 2023 in Mexico, the draft GSA have been published for comments.
As the preface rightly points out, the rapid expansion of aquaculture in the last decades has brought “undesirable social and environmental impacts in several parts of the world, often leading to social conflicts between users of land, water, and living aquatic resources, and negatively affecting the aquatic environment.” The Guidelines aim at addressing these concerns, enabling the “aquaculture sector to participate effectively in the implementation of the 2030 Agenda” for sustainable development.
However, there are issues both with the process of drafting as well as with the content. Key stakeholders, especially civil society, including small-scale fisheries organisations, have not been involved in the drafting exercise. This may be one of the reasons why the draft guidelines do not address properly contentious issues in aquaculture production.
From a small-scale fisheries perspective, by taking a one-size-fits-all approach to aquaculture, the Guidelines fail to tackle the main challenges posed by industrial intensive aquaculture to coastal fishing communities, including land/sea use conflicts, pollution of the environment, and the increased pressure on fish stocks they depend on for their livelihoods, caused by the larger demand for fish feed.
1. The shortcomings of the current draft FAO Guidelines on Sustainable Aquaculture
a) A matter of form: clarity around the challenges
Presently, the draft Guidelines are rather vague, and do not reflect the key challenges facing the future of the sector, which include: spatial interactions with other sectors, including small scale fisheries; the use of carnivorous species that rely on fish feed derived from wild fish stocks like West Africa small pelagics; the sustainability of the fish feed production; the global inequalities of accessibility to fish.
The Guidelines should highlight the challenges more clearly in its structure, so that users can quickly identify and refer to them.
B) Acknowledging current (and potential) space conflicts
One of the main problems is that the guidelines do not yet address sufficiently the interactions with other sectors, especially small-scale fisheries. Sea food farms generally compete for space with other users of coastal and marine areas. In many developing countries, these spaces have been traditionally occupied and used by small-scale fisheries.
Beyond land conflicts, though, intensive aquaculture also causes widespread destruction of coastal ecosystems, such as fjords, deltas, estuaries, marshes, wetlands, or mangroves. While some aquaculture can be restorative of ecosystems, such as oyster farming, the pollution brought by the placement of a fixed structure in these waters, like salmon pens, can affect reproductive cycles of marine species and bring adverse genetic, disease and other effects on the wild local species. The impact on these ecosystems has a ripple effect on those small-scale fishers that depend on a healthy environment for their livelihoods.
While the Guidelines address aquaculture spatial planning, they seem to approach planning to “make space for aquaculture” rather than upfront acknowledging the needs of original users aquaculture will displace. The latest developments in marine planning processes show there is a tendency to grant concessions to fixed-structure industries (farms, windmills, offshore exploitation) which exclude in practice other industries that require vast spaces to carry out their activities (especially fisheries). In many cases, marine planning processes are not inclusive and these concessions are granted without a proper environmental impact assessment undertaken in consultation with local communities.
Furthermore, the concession of these areas effectively close or restrict access to these public domain spaces. There are cases where human rights activists have been harassed for protesting around those areas, with the police or other enforcing authorities acting as “private security for private firms.”
The Guidelines should address these conflicts in a way that acknowledges the tenure rights of coastal communities, by citing best practices and cross-referencing other relevant documents such as the Tenure Guidelines, and the Small-Scale Fisheries Guidelines, which are currently not referenced at all.
C) Choosing the right species: moving to aquatic species from lower trophic levels
Last September, at the 35th session of the Committee on Fisheries (COFI), small-scale fishers expressed their concerns about the current model of intensive farming of carnivorous species, such as salmon. This requires vast amounts of fish feed produced in developing countries, like West Africa, where it deprives local populations of fish. This model is neither sustainable nor can be made sustainable.
Even though the draft guidelines recommend to “avoid” fishmeal and fish oil sourced from over-exploited stocks (see 16.2.3.), to “reduce dependency on wild caught fish” (16.2.4.) and see opportunities for investment and research in plant-based feed (see 15.4.3. and 7.3.11.), this is not enough. “Even if improvements are made to reduce the amount of wild fishmeal needed to produce one kilo of farmed fish,” stated the African Confederation of Artisanal Fisheries Professional Organisations (CAOPA), “the expected development of the sector - an increase of 22% by 2030 - will lead to an ever-increasing demand for fishmeal, and ever-increasing competition with our fishermen, and especially our women processors, who will be left empty-handed.”
And even if fishmeal is replaced by plant-based feed, fish oil – which requires a higher proportion of fresh wild caught fish in its production – is still required in fish farming. There are also other sustainability considerations with plant-based feed, such as the deforestation and displacement of small-scale farmers caused by the expansion of soy production particularly in Brazil.
The guidelines need to address the choice of species in aquaculture and the impact those farmed species will have on other sectors and on the environment.
D) Prioritizing direct human consumption
FAO argues that “for all its faults, fish farming helps relieve pressure on the oceans; it is, overall, more efficient than landbased animal production systems; and it generates fewer emissions.” Yet, with more than 20% of wild caught fish being processed into fishmeal, and with 90% of the fish used in fishmeal good for human consumption, this statement raises eyebrows.
A caption of FAO’s publication on fish receipes. In an “interview” with a salmon, the response to whether it is farmed or wild, is “I do wish the world would stop creating these divisions […] we are all people.” Humour apart, there are divisions to be drawn between wild or farmed fish and it is not useful to bury one’s head in the sand.
Aquaculture of carnivorous species does not relieve pressure on the oceans and should not be considered fish production, as it is just a conversion of wild fish into fish feed into carnivorous fish. And whereas it is true that fish farming generates fewer emissions than pork or beef rearing, it certainly does not generate less emissions than wild caught fisheries, the products of which should be rendered more accessible to hungry populations.
The figures speak by themselves: It just simply does not make sense to reduce 25 kg of fresh sardinellas into 5 kg of fishmeal, to feed 1 kg of salmon in Norway, Scotland, or China… “When we think sardinella is accessible to West African populations, and we want to fight against poverty, then we realise it is not possible to develop an aquaculture that is based on fishmeal,” stated Gaoussou Gueye, president of CAOPA at an event organized by the German Ministry of Cooperation in Lisbon during the UN Ocean Conference in June 2022.
A recent report has shown that the yearly intake of sardinellas – a staple food – in Senegal has drastically declined, due to the reduced catches. The overfishing of sardinellas is driven mostly by the booming fishmeal and fish oil industry in West Africa. This is causing a food security crisis in the region.
The former special rapporteur on right to food, Olivier De Schutter, pointed at the fish feed industry endangering the food security of the poorer : the “use of the industry to produce farmed fish […] may come at the expense of poorer populations who could benefit from improved availability of and accessibility to wild fish.”
The Guidelines should openly dismiss intensive aquaculture of farmed fish that is reliable on fish feed and mark this model as unsustainable. Direct fish consumption should always come first.
E) A healthy and sustainable yearly intake
Recommendations for fish intake vary between 5 to 20kg/capita/year. [Note: Several sources cite 1-4 portions of fish per week, 1 portion being 100g, to prevent risks of coronary heart disease and stroke. Fish is also a source of micronutrients, fatty acids, and enhance the availability of minerals from cereal-based foods.] With 24,17kg/person/year, fish consumption in the EU surpasses the recommended yearly intake, with similar figures in many other high and middle-income countries. So, the current model which offers aquaculture products to wealthy consumers is not about food security or nutrition.
A recent report, pointed out that while the “aquaculture industry regularly uses the narrative of ‘food security,’” there is a continued lack of evidence “that aquaculture directly feeds the world’s poor.” Ten years ago, the UNSR De Schutter was already questioning whether aquaculture products are mostly for wealthy consumers: “it remains difficult, in the absence of adequate data, to assess whether aquaculture is genuinely supporting food availability and accessibility for people living in poverty.”
The EU, for example, is the biggest market for sea food in the world, and proposes a vast offer to its consumers. In a previous publication, we asked ourselves whether the current EU consumption of sea food was sustainable. As the Food Policy Coalition pointed out, food environments have an impact on how consumers make their decisions about food, and therefore, also on food demand.
Policies and guidelines should take into account these global dynamics and inequalities, and should encourage a production and a consumption wired to more sustainable options and production models: Privileging the direct consumption of wild fish coming from sustainable, low-impact and preferably local fishing, encouraging sustainable and little known – yet quite nutritious – species, and promoting low-impact or restorative aquaculture, such as mussels, oysters, or algae.
2. What kind of aquaculture will help African coastal communities?
At the occasion of the International Year of Artisanal Fisheries and Aquaculture, CAOPA held a workshop in Mbour (Senegal) to start a conversation on what model of aquaculture would be compatible with small-scale fisheries. Even more, could small-scale aquaculture complement small-scale fisheries activities? This workshop included African artisanal fisheries professionals (fishermen, fishmongers, and smokers), research institutions, civil society organisations (CSOs), as well as representatives of the FAO and the Senegalese authorities.
One of the hotly debated topics was the fishmeal production in the region and its impact on the fishing communities. The participants enunciated recommendations to their governments and FAO, such as regulating and limiting the fishmeal production capacity and prioritizing human consumption. Social and environmental considerations were included, such as the prohibition of toxic waste discharge and the settlement of these factories “outside built-up areas to avoid adverse effects on the population.” Finally, they called on decision-makers to assist small-scale producers in “designing and producing alternative feeds.”
More significantly, the outcomes of this workshop highlight the importance of an alternative model being developed, one that privileges small-scale productions, in a way that it is complementary to small-scale fishing. This complementarity would help this vulnerable (yet key for food security and livelihoods) sector by allowing for diversification and providing alternative raw materials in the low fishing seasons: “Artisanal aquaculture can provide women [fish processors] with an alternative income-generating activity that also improves their supply of fish for processing.”
The Guidelines should include proposals for alternative models of aquaculture in developing countries, such as those suggested by African artisanal fishing communities.
CAOPA’s workshop press release cites examples. In DRC, tilapia and catfish farming has helped address malnutrition and ensure food security. In Mali, where overfishing has caused a reduction in the amount of fish available, women fish processors have developed small-scale aquaculture coupled with off-ground market gardening. This model complementary to artisanal fisheries “has advantages in terms of food security and economics, with little negative impact on the environment,” CAOPA argues.
However, CAOPA continues, the model “faces constraints related to the availability of water, land, fish feed and training in fish farming.” In a letter to FAO, in view of its discussions on the Guidelines for Sustainable Aquaculture, they propose the following recommendations:
Promote alternative activities for small-scale fishers such as fish farming with an integrated market gardening system:
o Allocate land to women processors by local authorities to develop alternative activities;
o Encourage and popularize family fish farming above ground integrated with other plant and animal production activities;
o Develop new income-generating activities such as seaweed farming and spirulina culture; and
Supporting artisanal fisheries actors in:
o Strengthen the technical capacities of artisanal fisheries and aquaculture actors; make good quality fingerlings available;
o Support actors in financing their projects;
o Promote the use of local equipment and infrastructure accessible to all; and
o Facilitate the integration of women and men from artisanal fisheries who wish to develop fish farming activities.
Conclusion
The FAO Guidelines on sustainable aquaculture should include the considerations of those stakeholders that are currently facing the negative impacts of unsustainable aquaculture, and are looking at alternative models of small-scale aquaculture. The GSA, instead of feeding over-optimism, would benefit from openly addressing the points of contention which were the reason of drafting the guidelines in the first place.
As a recent report pointed out, a really sustainable aquaculture should “move away from the intensive, feed-based production” of seafood. There are alternatives: they mean moving to lower trophic aquaculture, such as low trophic fish, seaweed, or bivalve farming. In countries where aquaculture is still incipient, governments should be asking the right question: how to develop an aquaculture that brings the most social and environmental benefits to its populations.
In Africa, small-scale fisheries in Africa provide food for more than 200 Million people. This can be complemented by a well-developed small-scale aquaculture that helps these same communities face the current challenge of access to raw materials. A low impact and small-scale aquaculture can complement small-scale fisheries in a way that is respectful of the ecosystems and continues providing livelihoods and healthy nutritious food for coastal communities and beyond.
Banner photo: Salmon farming, by Michael Fousert.
In a position paper, APRAPAM questions the government's proposal to support the production of fish feed and insists instead on the importance of a management plan for small pelagics and the prioritisation of human consumption.