Over the past year or so, striped bass fishermen have been
focused on efforts to
rebuild the currently overfished striped bass spawning stock biomass back to
its target level by the 2029 deadline specified in the fishery management plan;
on the Atlantic States Marine Fisheries Commission’s Atlantic Striped Bass Management
Board’s
failure to adopt a 12% harvest reduction, to make such rebuilding more likely,
last October, and on the
past seven years of record-low striped bass recruitment in the Chesapeake Bay,
as well as the possibility that 2026 will become the eighth straight year of
poor spawns.
Thus, they might be excused if they failed to notice another,
stealthier threat to the health of the Atlantic migratory stock of striped
bass, and that is the federal government’s efforts to initiate striped bass aquaculture
in federal waters more than three miles from shore.
The issue has been rattling around the Commerce Department,
and the National Marine Fisheries Service, for a few years, but it
finally entered the public consciousness at the February meeting of the Management
Board, where Danielle Blacklock of NOAA Fisheries Office of Aquaculture explained
the administration’s interest in farming striped bass offshore:
“…we know we have a marketplace that is needing more seafood. This has been acknowledged by the Trump
administration in two executive orders.
On the right-hard side, we have Executive Order 1391…
“This came out in 2020, it called for a whole host of
aquaculture-related activities, and we have done them. There is one that is still underway, which is
identification of aquaculture opportunity areas…
“We anticipate that we will continue to move around the
country. The Executive Order on the
left, Executive Order 14276 calls for restoring America’s seafood
competitiveness. This has a lot of wild
harvest drivers in it, but it also calls for an America First seafood strategy,
which asks us to increase domestic aquaculture production and create more
marketing and export opportunities.
“Those are backdrop drivers that bring us to today. Why striped bass? Well, there are a number of reasons. One is that we know a lot about striped bass…It
is a species that has been farmed for a long time, and we have great
information feeding into the knowledge base.
We also at NOAA have been doing over the past eight years a process of
identifying top marine candidate species…
“…Through voting and process of prioritizing all of those
species, Atlantic striped bass has consistently risen to the top as a candidate
species of interest…
“We are now in generation 8 of selective breeding, and it
grows significantly faster than hybrid [with white bass] striped bass…Well,
Atlantic striped bass has a higher price point.
It has a different marketplace, because hybrid striped bass is typically
sold as a whole fish, and Atlantic striped bass farmed or wild is typically
sold as a fillet.
“But the market value is so much higher that we are watching
hybrid striped bass farms switch to Atlantic striped bass…What I flagged in
2024 is still true, that Atlantic striped bass is being farmed and it’s
entering our markets today. It’s just
not coming from the Atlantic seaboard, it’s not coming from the federal waters
along the Atlantic, or course, because of the moratorium on possession.”
So up to that point, Ms. Blacklock made a purely economic
argument for farming striped bass, which was fine, particularly if folks who
are currently farming hybrid striped bass on their inland ponds and aquaculture
facilities think that they can make some more money by raising pure-strain
striped bass instead.
But what Ms. Blacklock didn’t demonstrate is why striped
bass ought to be farmed in the federal waters of the Exclusive Economic
Zone. After all, if folks can grow them
out inland, or in the Gulf of Mexico, there’s no need to start introducing some
sort of genetically manipulated “generation 8” fish into the striped bass’
natural range, where those fish could—and almost certainly would—escape and
threaten the genome of the native population.
But then, Ms. Blacklock uttered the words that ought to put
everyone on high alert, and make them understand that aquaculture’s threat to
native fish is very, very real:
“The goal here is to balance aquaculture
development with protection of wild striped bass populations and the fisheries
they support. [emphasis added]”
Because as soon as the aquaculture promoters start talking
about “balance,” it’s a clear signal that they’re planning to increase the risk
to the wild striped bass population, removing some existing protections in
order to make it easier to successfully develop striped bass farms,
What sort of risks might the striped bass face?
Ms. Blacklock herself mentions
“concerns about illegal harvest and enforcement; Ocean use
conflicts, economic feasibility, market competition, aquatic animal health and
disease, environmental impacts and escapement and genetics.”
She was quick to offer solutions for the some of the first
issues on that list, but when it came to disease, escapement, and genetics, the conversation as to why they
weren’t a problem began to become far more hypothetical than concrete.
“Disease, when it comes to disease in fish nobody wants
it. It is the nightmare of the farmer,
it is the nightmare of the regulator, it is very scary to everyone
involved. The way that in the United
States typically we deal with disease is prevention. We have a lot of rules and regulations about
stocking density, overcrowding, water flow.
“All of these things are managed to make sure that the fish
have the highest level of ability to stay healthy. In addition, we create vaccines…We are an
agency of prevention and that is where I would anticipate
anything goes with Atlantic striped bass.
“There are very few therapeutants available…It is extremely
rare to use antibiotics. But it is still
something that we would have to work on for Atlantic striped bass. [emphasis added]”
So from a disease perspective, offshore striped bass farms
remain a work in progress.
The same seems to hold true about genetic concerns.
“A lot of farms currently are applying, not for striped bass
but in other species, are applying for just F-1s, right having wild broodstock.”
That doesn’t seem to be the case with striped bass, where specially-bred
strains of fish are being used to populate the farms. As Ms. Blacklock noted,
“selective breeding is critical to be able to grow fish
faster, having them be meatier, lighter skeletons, all of that, lower food
intake.”
But those sort of custom-designed fish aren’t necessarily
fish fit to survive in the wild, which can be a problem should farmed striped
bass escape and their artificially selected genes enter the genome of the wild
population.
“The way that we can protect the wild population, there is a
whole host of tools in the toolbox. We
have everything from many salmon farms are female only. That is not 100% right, females
can still put off eggs. There are tools
like triploidy, where you make a fish have three chromosomes so that they are
sterile.
“That has a 99% effectiveness rate. It’s not 100. But now there is new technology that has come
online that we are using with other species.
It has not been applied to striped bass yet, which is 100%
effective. Through genetic knockdown
G-knockdown technologies, we have the ability to just make them not grow
gonads, 100% effectiveness.
“Now again, we have not done that for Atlantic striped
bass yet. That research would take 4 to 7
years maybe, but the tool is there.
Another tool that we have is better understanding of what the potential
impact would be through genetic risk assessments.
“…We again can put a farm in the water, know what kjnd of
species it is, you need to know what the population outside is. Is it a big population, a small population? It’s actually arithmetic, not just big or
small that we use. You can model
how much risk there is…
“If you have a small population and a net, and a huge population
outside, the risk is probably not very high of there being
any challenges or changes in the external population. On the converse of that, if you have a
big farm and a small wild population, the genetic risk becomes much higher,
if you’re not putting in sterile fish…
“In the final piece on genetics is, genetics become a
risk not only from gametes, potentially, but also from escapes,
right? We don’t want any escapes. We don’t want spillage, which is just a
couple of fish every time you are feeding or treating or anything like
that. You also don’t want a
catastrophic event where the whole population is released at once.
“We have also heavily invested in, as has the industry, in
engineering for offshore, to make sure that you are building things in a robust
nature, so that they can handle extreme weather. We’re seeing sinking cages as becoming more
of the norm. Things aren’t staying on
the surface the way they used to, so that you can get under the waves and under
the swell…
“Finally, a lot of that backdrop of the science tools
was not striped bass specific.
But it started with, we know a lot about Atlantic striped bass… [emphasis added]”
So yes, the risks offshore striped bass farming poses to the
wild population are very real, and come in many different forms. Ms. Blacklock admitted that
“There are applications in the Gulf of [Mexico] for Atlantic
striped bass that will use their eighth generation, ninth generation by the
time they get there. There is also a
number of farms on land that are farming Atlantic stripe [sic] bass….
“A number of farms in Texas that farm red drum are seeing
mortalities, because it is so cold. But
a number of them have already switched to farming Atlantic striped bass, and
the stripers are surviving.”
The fact that bass can be and are being farmed in existing on-shore
facilities, and in farms located outside the range of the coastal migratory
stock, raise questions about why it is necessary to consider farms on the
Atlantic coast, which could cause some level of harm to the wild
population. That’s particularly true
when one considers Ms. Blacklock’s comments that few farms would likely be located
north of North Carolina, because water temperatures would probably be too low
to support robust year-round growth.
“For offshore operations, it is useful to distinguish between
chronic, low-level seepage of escapees and rare, high magnitude catastrophic
releases, because these pathways differ in detectability, dispersal potential,
and the timing of exposure that drives genetic risk. Seepage most often results from small holes,
net abrasion, predator related tearing, and routine activities such as handling
and lifting, creating a persistent trickle of escapees that can be
difficult to detect directly yet still sustain contact with wild conspecifics. Catastrophic events are more commonly linked
to structural failure or mooring failure, collisions, and extreme weather, and
they can release large numbers of fish over short periods, overwhelming
recapture capacity and increasing the likelihood that mature escapees enter
migratory corridors or spawning habitats during sensitive windows.
“Escape events are among the most widely recognized
ecological risks associated with marine finfish aquaculture, with
outcomes shaped by species behavior, farm design and durability, siting and hydrodynamic
conditions, operational practices, and interactions with predators such as
sharks, marine mammals, and seabirds. Ecological consequences have been well
documented across freshwater, estuarine, and marine systems, including competition
with conspecifics, habitat displacement, disease and parasite transmission, and
genetic introgression. Although
domesticated fish often show reduced individual fitness and survival compared
to wild stocks, even limited interbreeding can erode local adaption,
homogenize genetic structure, and reduce the long-term resilience of wild
populations.
“For offshore aquaculture of native striped bass, these
risks warrant particular attention.
Striped bass are highly mobile and migratory, with populations ranging
from the Gulf of St. Lawrence (Canada) to the St. John’s River (Florida). Resident populations occur in southern systems
such as Albemarle Sound, North Carolina, while northern populations migrate
extensively along the Atlantic coast. Escaped
individuals could therefore disperse widely, interact with multiple genetically
distinct subpopulations, and introduce risks of maladaptation or loss of
genetic structure… [emphasis
added, references omitted]”
Given those very real and very significant risks, and give
the fact that alternative siting of striped bass farms is available on land and
in the Gulf of Mexico, far from the Atlantic coastal migratory stock, the
administration’s efforts to establish striped bass farms in federal waters off
the East Coast seem to make very little sense.
Certainly, members of the Management Board expressed some
concerns about the proposal.
For Virginia fisheries manager Joeseph Grist, it was a
matter of fish farms potentially squeezing out traditional commercial
fishermen. He expressed concern that
“this almost sounds like we’re popping up the next Walmart in
the ocean versus all of our generational traditional inland fisheries and
families, the mom and pops that depend on striped bass harvest and the price
point they get to survive through the year.
“…This could be a huge risk to the individual watermen that
are out here in the various states that depend on this as part of their
business plan during the year…once one of these gets up and running and they
start making the profit, I can see the price of striped bass going down at a
point they could take it out to compete [sic] everybody else.”
Ms. Blacklock assured Mr. Grist that NOAA doesn’t plan on
that sort of thing happening, but never suggested that it wouldn’t. And reality doesn’t always stick to the plan.
Dr. Jason McNamee, the Rhode Island fishery manager, made a supposedly
tongue-in-cheek comment, saying
“I had a thought. It’s
funny to me, I don’t know if it’s going to be funny to anyone else. But when you offered a comment about 100%
effectiveness of some of the genetic, you know manipulation that you can do on
these animals, I was just wondering if you saw Jurassic Park. It’s a joke, sorry.”
And maybe it was a joke, but in the movie
Jurassic Park, the “100% effective” genetic safeguards weren’t
100% effective, and that led to all sorts of problems. I suspect that Dr. McNamee’s “joke” contained
a deeper message.
Emerson Hasbrouck, Governor’s Appointee from New York, was
also a skeptic of offshore striped bass aquaculture, saying,
“My concerns are very similar to what Joe and Jay just voiced. You know all morning here we’ve been talking
about rebuilding a wild stock of striped bass.
It may not be officially the intent of NOAA to compete with wild
harvest.
“But the reality is that once all these additional striped
bass, if they come into the market or when they come into the market, they are
going to compete with wild harvest striped bass, and they are going to compete
with our commercial fishing industry…There is going to be a market impact here.
“Is there kind of a hidden message here that we don’t need to
rebuild striped bass wild stock for commercial harvest, because we’re queuing
up aquaculture to replace wild harvest in the marketplace. That doesn’t sit very good with me. The offshore culture that we’re talking about
here is going to have an impact on markets and market conditions…”
Again, Ms. Blacklock denied any hidden messages, and denied
any intention to undercut the commercial fishery in the marketplace. But as
the old saying goes,
“The road to Hell is paved with good intentions.”
Other Management Board members raised other concerns, but
the discussion soon reached its end, only to be continued
at the May Management Board meeting, where some sort of response to NOAA’s
presentation and technical memo was contemplated. The discussion began with Toni Kerns, the
ASMFC’s Fisheries Policy Director, making some suggestions for items that the
Management Board might want to include in a comment letter.
“I just want to point out a couple of areas where I think the
Board may want to go back and reread the memo and focus potential comments on…
“Then I’ll propose a timeline for receiving those
comments. In terms of economic analysis,
the Board did request an economic analysis from NOAA. I’m not sure at this time they’re prepared to
do an economic analysis, unless they know they are going to be moving forward
with some sort of plan.
“But the report doesn’t have any published U.S. production
costs and economic analysis that they do have in there relies on cost estimates
that have been extrapolated from other species like red drum, greater amberjack
and salmon operations. But we don’t
have any cost study for striped bass.
“The report talks about using sterilization technologies, in
order to make sure the popuations that are in the net pens aren’t breeding with
wild fish, but the report also states that the technologies have not been
tested…If those technologies haven’t been tested then what types
of risk does that put on the wild stock with possible escapement?
“The report looks at thermal modeling, but it only uses data
from 2020 to 2023, so four years of ocean temperature data is a pretty short
baseline for a long-term [siting] decision, especially given our known
uncertainty with climate…especially when those [siting] areas are mostly off
our southern states.
“…Some of the disease therapy information that is being
suggested, in terms of what would be put into the water has not been tested by
the FDA in marine striped bass…
“Then lastly is the habitat and protected species. For some of the areas that are being suggested
for [siting], it is critical right whale habitat that overlaps along the Atlantic
coast, so offshore permitting processes may face a lot of scrutiny under Section
7 consultations, as well as containment risks…
[emphasis added]”
“Enforcement Concerns
“Enforcement capacity in the EEZ is currently limited, and
aquaculture sites would create additional enforcement responsibilities, either
increasing costs or diverting resources from other enforcement priorities. Since the EEZ is currently closed to striped
bass fishing, there is potential for offshore aquaculture to be used as cover
for some illegal fishing. The memorandum’s
discussion of traceability, monitoring, compliance, and enforceability lacks
sufficient detail to evaluate whether these programs would be practical or
effective…
“The memorandum does not clearly identify which agencies
would be responsible for carrying out these monitoring and enforcement
activities or how they would be funded.
Historically, federally permitted activities often result in states and
interstate commissions assuming substantial administrative, regulatory, enforcement,
and financial responsibilities without corresponding federal resources. Additionally, there is the question of
whether all states on the Atlantic coast have the authority to enforce and
monitor striped bass aquaculture operations…Many states’ enforcement
capabilities are already stretched very thin with limited resources. These implementation burdens must be fully
evaluated before advancing any offshore striped bass aquaculture program…
“Economic Concerns
“The memorandum does not adequately address or consider the
economic consequences of potential offshore aquaculture on the wild
fishery. Increased production of aquaculture-raised
striped bass has the potential to flood seafood markets, reducing the value of
wild-caught striped bass—a premium product that supports commercial fishermen
throughout the Atlantic coast—and directly impacting the wild-caught striped
bass harvest fisheries (the mom-and-pop businesses)…
“Rather than creating new economic opportunities, offshore
striped bass aquaculture may shift economic benefits from traditional fishing
communities to private aquaculture operations…
“User Conflicts
“User conflicts must be addressed in greater detail. The memorandum downplays user conflicts that
offshore aquaculture for striped bass would present, especially at a time when
user conflicts due to other ocean uses (e.g., offshore wind) are at the
forefront. Access to traditional fishing
grounds would be reduced for commercial and recreational fisheries, particularly
for mobile gear users and for year-round fisheries in warmer waters…
“To inform this issue, more details are needed regarding what
offshore farms would look like in practice, and which uses would be allowed or
restricted within these shared-use areas.
NOAA should clarify whether exclusion zones would be established around
farm infrastructure, and if farms are expected to aggregate pelagic finfish
species, whether recreational or commercial fishing would be prohibited in the
surrounding area. Regarding vessels,
available data on the frequency or risk of vessel collisions with offshore aquaculture
infrastructure should be considered…
“Project Siting
“The current description provides limited detail beyond
general, high-level considerations, and appears to underestimate the
engineering and operational challenges associated with locating striped bass
net pens in offshore environment…
“The areas identified are also highly susceptible to severe
weather events, including hurricanes and winter storms. Notably, the strongest hurricanes often stay
offshore, which could result in aquaculture facilities taking a direct hit. NOAA should evaluate and describe the expected
resilience of offshore aquaculture operations under extreme storm conditions,
including the measures that would be implemented to minimize infrastructure
damage, fish escapes, and environmental impacts.
“Aquaculture Industry Specifics
“Additional information is needed regarding the level of industry
interest in offshore striped bass aquaculture and the basis for pursuing this
initiative. It is unclear whether there
is currently an interested party seeking to develop an offshore striped bass
aquaculture operation, or whether the interest is to establish a regulatory
framework for potential future applicants…
“Ecological Concerns
“The memorandum does not address one of the longstanding
concerns associated with farming high-value carnivorous marine fish species: dependence on fish-based feeds. Although feed technology continues to evolve,
forage fish remain an important component of diets used to optimize growth and
product quality. The ecological
tradeoffs associated with diverting forage resources into aquaculture deserve
careful consideration. Maintaining healthy
forage fish populations benefits not only wild striped bass but also numerous
marine mammals, seabirds, and other ecologically and economically important
species.
“Regarding habitat, offshore units/structures tend to act as
fish ‘attractor’ devices through complex structure, food availability or prey
availability and could have unforeseen effects on essential fish habitat (EFH)
in close proximity to other bottom structure or pelagic species…Management
plans for any offshore facility should require permittees to have adequate funds
(e.g., assurance bond) committed to ensure removal of fish and decommissioning
of the facilities that are abandoned, obsolete, or storm-damaged or had their
permits revoked…
“Protected Species
“Offshore aquaculture operations create the potential for
entanglement and other interactions with species protected under the Endangered
Species Act (ESA) and Marine Mammal Protection Act (MMPA). The current information in the memorandum is
limited on this issue and remains a potentially significant ongoing concern…
“Biological Risks:
Escapement, Genetic Concerns, and Disease
“Significant biological risks remain unresolved. Disease transmission, parasite transfer, escape
of cultured fish, and genetic interactions with wild striped bass populations
continue to present legitimate concerns.
Likewise, questions remain regarding the adequacy and consistency of
federal oversight related to therapeutants, antibiotics, and other chemicals
that may be used in commercial aquaculture operations. Wild fish in close proximity to facilities
could be exposed to therapeutics environmentally or through excess feed escapement
and potential parasitic infection with unknown effects. This also applies to therapeutics used to
prevent parasitic infections, which can be a problem in culture
facilities. These issues warrant
additional scientific evaluation before large-scale offshore production is
considered.
“The memorandum should explain how genetic tracking would be
implemented in practice. If ‘pure-strain’
stocks are non-interbreeding (e.g., sterile), NOAA should evaluate whether this
would affect the economic viability of production, particularly if such fish
are considered genetically modified…If pure-strain stocks are not sterile, there
are concerns regarding the risk of escapement and potential impacts on wild
striped bass populations and information is needed on average escapement rates
from similar net-pen aquaculture systems…
“Information should also be provided regarding how disease
events would be managed given the apparent lack of approved antibiotics for
striped bass…
“The memorandum notes that there may be some small losses
(escapements) that may mingle with the wild population, but that risk should be
given more weight and consideration, as well as the risk of a catastrophic
failure (which would be a real risk considering weather events and potential
vessel interactions). There is no way to
guarantee that aquaculture striped bass would not mix with the wild population,
and these risks are much greater in open water systems. Containment rules as well as genetic
modification of cultured fish (triploids and diploids) or potential
sterilization techniques are not necessarily validated for striped bass in
large-scale production culture situations.
“Policy and Regulatory Roles
“Strong regulatory barriers for starting these types of
operations exist, as they should if they are to be done properly. Many of the regulatory concepts presented in
the memorandum remain vague with respect to implementation. There appears to be limited direct regulatory
authority by NOAA or the Commission over offshore aquaculture operations…
“The memorandum notes that the Commission may wish to
consider whether existing authorities could be used to develop monitoring and
enforcement programs specific to striped bass aquaculture. However, it is indicated that such actions
would serve primarily to ‘influence’ federal partners rather than to establish
mandatory requirements…
“Conclusion
“In summary, offshore net pen aquaculture of striped bass has
a very limited operational history and no demonstrable record of large-scale,
long-term success in the United States.
The Commission has substantial concerns including risks to wild striped
bass populations, commercial fisheries, seafood markets, marine ecosystems, and
protected species, enforcement concerns, as well as the potential for
significant regulatory and financial obligations for states. Based on the information currently available,
those risks are not adequately balanced by the potential public benefits
described in the memorandum. Given
these risks and unresolved issues described above, the Commission does not
support moving forward with consideration of offshore striped bass aquaculture
at this time… [emphasis in
original sector headings, added to text]”
NOAA and the current administration clearly want to move
forward with offshore striped bass aquaculture, although it is not clear that
anyone has yet applied for permission to engage in such activities off the U.S.
Atlantic coast. The ASMFC has responded with
appropriate caution, acting as a responsible steward for the striped bass
resource, and as a responsible representative for existing striped bass
fisheries.
It is not at all clear how NOAA will respond to the ASMFC’s
letter to Ms. Blacklock. However, we can
only hope that the ASMFC will continue its present, risk-averse approach to offshore
striped bass aquaculture, and continue to protect the interests of the striped
bass and striped bass fishermen, whether commercial or recreational.
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