§ 4. Commercial uses and arguments about the meaning of "aquaculture."

§ 4.1. Failing to come to terms. There is general agreement on the significance of the threat from ballast water (although other shipping vectors, particularly hull fouling, need to be better addressed), no one is in doubt about what we are talking about when we talk about ships, and the shipping industry has been involved in a very professional manner, from the beginning, in formulating policy about exotics in ballast water. The world of "commercial uses," meaning aquaculture, baitfish, and commercial importation of exotics for aquaria and ornamental ponds, seems to be rather different. As discussed in § 4 of the white paper, there is disagreement about how to even define "aquaculture," and about whether or not various forms of it constitute a significant threat. As evidenced at the workshop, moreover, there is a noticeable lack of a good working relationship between government regulators concerned about exotics and proponents of the aquaculture industry. My use of the term "commercial uses" as a general category - with "aquaculture" in the form of fish farming for food, baitfish transportation, and importation of exotics in aquaria and ponds framed as separate subcategories - was deliberately chosen in an effort to get beyond semantic arguments. The effort failed. When the discussion turned to this topic, it immediately degenerated into vehement arguments about how one defines "aquaculture," about the supposed misrepresentation of the different sorts of activities covered by that term in the white paper, and accusations that the white paper was therefore an unfair attack on the industry, all delivered in a rather acrimonious manner. At that point, I asked the most vehement speaker to please follow up with some written comments on where he thought the white paper was misleading and did not attempt to press that discussion further in the workshop. It was simply not productive. It was obvious that representatives of the industry had not come prepared to have the same sort of substantive discussion which the shipping industry representatives were prepared for

§ 4.2. Intergovernmental coordination. We had representatives from various state and provincial agencies, including both some of those responsible for regulation and promotion of aquaculture, on one hand, and several of those responsible for control of exotics, on the other. There was a noticeable difference in approach towards the issue evident in the comments of those different agencies, and an apparent lack of communication among them. I would submit that this is in itself is a significant piece of information which should be given consideration. In the white paper, and in more detail in the Michigan report which provided the basis for the summary comment on this issue in the white paper, I pointed out that there is a general lack of coordination on policies for the regulation of these commercial uses among the eleven different jurisdictions and multitude of separate agencies within jurisdictions in the Great Lakes region. This failed attempt at consultation at the workshop only emphasized the nature of the problem.

§ 4.3. Some comments on the nature of the threat. We did manage to have some preliminary discussion at the level of a very rough threat evaluation. We had an academic expert who had conducted a study of the threat from various forms of aquaculture. He, in fact, had taken care in his morning presentation to stress the fact that "aquaculture" covered a broad range of activities presenting different kinds and levels of threats. He proposed that one needs to look, specifically, at (1) the type of facility (discussed in the white paper), (2) its water source, (3) the type or species of organism, (4) what it is being raised for (such as food or bait), and (5) how it is sold, among other factors. In his opinion, the greatest threat was from the wild harvest of baitfish, because this had the definite potential to involve the accidental collection of non-target species. One of those speaking for industry who vehemently objected to my whole analysis in the white paper did agree with this idea that there was a threat from wild bait harvest, but emphasized his view that "aquaculture" in the sense of fish-farming for human food consumption was not a problem. Other participants raised concerns about a new industry for the sale of live food fish, and about the problem of disease in aquaculture generally.