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Inclusion of EPA 



The U.S. Environmental Protection Agency (EPA) should be given a greater role 

 in developing strategies for aquaculture. EPA's programs and regulations related to 

 the environmental impacts of aquaculture, including impacts on water quality, in- 

 stream flows and aquatic ecosystems, mean that this agency already has consider- 

 able responsibilities concerning aquaculture. Ignoring the importance of EPA's role 

 would be shortsighted, particularly if a major goal of aquaculture legislation is to 

 promote the development of an environmentally sound industry. 



One section of S. 1288 where EPA clearly should be included with other agencies 

 is proposed new Section 7, National Policy for Private Aquaculture. As it is now 

 written, this section now mandates that the Secretary of Agriculture, in consultation 

 with the Secretary of Commerce, the Secretary of the Interior, and the heads of 

 other agencies, as appropriate, coordinate and implement a national policy for pri- 

 vate aquaculture. EPA should be specifically included in the list of agencies to de- 

 velop this policy. In addition, for the reasons discussed in the previous section, the 

 responsibility for developing the national policy should be distributed among all four 

 participating agencies, rather than assigned primarily to USDA. 



Coordination by the Joint Subcommittee on Aquaculture 



As mentioned above, federal agencies coordinate their aquaculture activities 

 through the Office of Science and Technology Policy's Joint Subcommittee on the 

 Secretary of Agriculture. 16 U.S.C. 2805. The Subcommittee has been highly suc- 

 cessful at increasing communication and coordination among those federal agencies 

 which are members of the Subcommittee. In addition, the Subcommittee has even 

 initiated several interagency projects to address pressing problems in aquaculture, 

 such as a lack of available drugs licensed for administration to fish. 



Given that a number of federal agencies will continue to have important respon- 

 sibilities concerning aquaculture, we urge that a major problem of the Subcommit- 

 tee — the lack of a budget — be remedied. To achieve Subcommittee goals staff from 

 various agencies must now voluntarily assume Subcommittee responsibilities, in ad- 

 dition to their regular duties. The Subcommittee would benefit greatly from an ade- 

 quate budget that allowed agency staff to be detailed to work on Subcommittee ini- 

 tiatives and allowed the hiring of other necessary experts. Aquaculture legislation 

 should authorize a minimum of several hundred thousand dollars per year to sup- 

 port the Subcommittee's critical functions. 



PUBLICLY OWNED FISH AND SHELLFISH STOCKS 



We are troubled by provisions in the National Aquaculture Act of 1980 that en- 

 courage use of aquaculture technology in the rehabilitation and enhancement of 

 public fish and shellfish stocks, and in particular, by the Act's encouragement of 

 such efforts by private entities. The Act includes a finding that "the rehabilitation 

 and enhancement of fish and shellfish resources are desirable applications of aqua- 

 culture technology." 16 U.S.C. 2801(aX5). The Act also mandates that the Secretar- 

 ies of Agriculture, Interior, and Commerce "encourage the implementation of aqua- 

 culture technology in the rehabilitation and enhancement of publicly owned fish and 

 shellfish stocks (including rehabilitation and enhancement by private nonprofit en- 

 terprises), and in the development of private commercial aquacultural enterprises." 

 16 U.S.C. 2804(aX3). 



As discussed above, the introduction of nonnative fish spjecies and large numbers 

 of cultured native fish can cause serious harm to aquatic ecosystems. 16 U.S.C. 

 2801(aX5) and 16 U.S.C. 2804(aX3) appear to encourage such harmful introductions. 

 Private involvement in such introductions is especially worrisome because a private 

 enterprise may have interests inconsistent with those of the public. Involvement of 

 private commercial enterprises is the most worrisome. These enterprises by defini- 

 tion are motivated primarily to maximize their own economic profits and are there- 

 fore especially likely to take actions inconsistent with the public's interest in pro- 

 tecting natural ecosystems and preserving native fish and shellfish populations. 



A specific problem with 16 U.S.C. 2804(aX3) is that it is ambiguous and under 

 one interpretation encourages the involvement of commercial aquaculture enter- 

 prises in wild stock enhancement. This section could be read simply to "encourage 

 the implementation of aquacultural technology * * * in the development of private 

 commercial aquacultural enterprises." More troubling, the section can also be read 

 to "encourage the implementation of aquacultural technology in the rehabilitation 

 and enhancement of publicly owned fish and shellfish stocks * * * in the develop- 

 ment of private commercial enterprises." The Act should at the very least be amend- 

 ed to remove the ambiguity and eliminate the second possible interpretation. 



