The underlying environmental implication of "paper or plastic?" is enormous enough. Building and operating a large-scale, land-based fish farm has a complexity of ecology that has so far taken Nordic Aquafarms 1,800 pages to begin to address. Citizens scrutinizing Nordic's Draft Environmental Impact Report on the implications of the fish factory produced their own volumes Feb. 18 for the county planning department to consider and respond to.
Some responses simply deemed Nordic's analysis defective. For instance, critics argue the company is using flawed data to estimate greenhouse gas emissions. In another, some noted Nordic was using information from a water testing point that doesn't reflect the project's true intake and outfall.
Humboldt Baykeeper, the Coalition for Responsible Transportation Priorities, Surfrider Foundation, the Northcoast Environmental Center, 350 Humboldt, the Environmental Protection Information Center, Friends of the Eel River, Save California Salmon and the Sierra Club Redwood Chapter North Group collectively proposed what the environmental nonprofits call a "roadmap" for Nordic to follow in order to build a factory that they expect would pass legal and local muster.
Here are some of the highlights of the analysis and a distillation of public response.
Against the current — energy and climate
Nordic's data on energy triggered the most criticism. It would use 21 percent of the county's total electric demand — as much as the cities of Eureka and Fortuna combined. And while Nordic intends to build a 4.8-megawatt solar installation of its own, it would only contribute a figurative flashlight's worth (3 percent) of the fish farm's estimated electricity demand.
Environmental groups suggest a legal commitment by the company to purchasing 100 percent renewable energy by increasing its own solar construction and buying local renewables when feasible. That may not be a problem if plans for an offshore wind farm are completed. But if that project does not come to fruition, transmission constraints currently prevent Nordic from importing enough renewable energy to meet its needs.
Nordic project manager Scott Thompson said committing to certain energy sources would disarm the company's ability to negotiate future prices. He added that the electricity required, mostly for pumping and cooling, would be about two offshore wind turbines' worth of power. But that offshore wind power is far from guaranteed. In part, it's a bit of a "chicken and egg" problem — wind developers don't want to bid on costly new wind turbine leases and infrastructure unless they can sell it locally; local industry, like the fish factory, meanwhile, can't promise to use the electricity until it's built.
Nordic's draft takes the position that no significant greenhouse gases will be generated from the development. That's "totally anomalous," according to 350 Humboldt. Nordic relied on PG&E data to reach its conclusion and the utility's information is flawed, 350 Humboldt and other organizations stated.
Another greenhouse gas impact is refrigerants. Fish need to be cold, and the resulting greenhouse gas emissions from refrigerants are glossed over in Nordic's plans, environmental groups say.
Murking it up
Once the fish are done with their H2O, the factory is set to discharge 12 million gallons of treated wastewater a day. That discharge would also be warmer with lower pH and salinity than the receiving ocean waters. While Thompson said the warmer water would cool to sea temperature within 10 feet of being discharged out the outfall pipeline and ocean temperatures are warming anyway, environmentalists worry this combination has the potential to exacerbate toxic algae blooms. Critics also note there could be antibiotic — and potentially chemically toxic — effluent from the factory.
The environmental groups and others, including the Salmonid Restoration Federation, say modeling using data from ocean waters near the discharge point would be more accurate than what is in the DEIR, and that unspecified protective actions should be triggered before another algae bloom creates unsafe levels of domoic acid.
"Exposure to viruses, loss of habitat (including food and cover), timing of exposure to toxic chemicals, disruption of migration, thermal pollution and localized domoic acid proliferation all deserve a harder look in the final EIR," commented wildlife biologist Alison Willy. "This is especially true for vulnerable species such as green sturgeon, Chinook salmon, coho salmon, steelhead, eulachon, longfin smelt and Dungeness crab. Adverse effects to local fisheries are reasonably certain to occur as a result of the project. These adverse effects would come at a time when our fisheries and local wildlife are already stressed from climate change, marine warming and harmful algal blooms."
Fish without bicycles
There is no question vehicle traffic will increase if the factory is built. Shipments of harvested fish to market are expected to cause 95 truck trips per week. The environmental groups contend the total number of vehicle trips would be at least twice that, noting it doesn't include other increased traffic accessing the facility, like deliveries. The groups suggest using electric vehicles as they become available to reduce greenhouse gases, as well as vanpools for workers. Some neighboring residents say increased traffic is intolerable.
Sucking it up
Tiny fish that feed the food chain can be inhaled into the facility's uptake system, according to The National Marine Fisheries Service and the Wiyot Tribe, which argue that sucking in 12 million gallons of water a day from Humboldt Bay is bound to catch a few stray life forms.
"Although the screen size and maximum approach velocity are designed to have minimal impacts," the Wiyot wrote, trapping "culturally important and endangered fishes [are] likely unavoidable."
Thompson said that the Harbor District is still analyzing the proposed intake system's effect on teeny creatures, like long-finned smelt, and will use that to create "compensatory mitigation" measures, like preserving other fisheries' environments.
Farm to table
Nordic's land-based fish factory is set to grow 25,000 tons of edible Atlantic salmon per year. The fish is intended for local distribution hubs and then on to the supply chain, with 40 percent sold retail and the rest going to wholesale markets. If it's on your shopping list, the company said in an email, its farmed Atlantic salmon is intended for the "high end" of the farmed fish price range, now at about $15 per pound, "but not as high as wild-caught fish."
Many advocate eating their proteins low on the food chain for higher environmental sustainability. Producing legumes for sustenance, for instance, creates far less impact on the land than cattle feedlots because it takes more protein, and related energy, to make that pound of hamburger than it does for a pound of beans. Because of that, what Nordic's farmed fish are fed creates levels of impact. Fish feed has its own greenhouse gas emissions, the environmental groups noted. According to data, they say fish food production drives more than 90 percent of aquaculture's energy use and greenhouse gas emissions. They say the company "ignores the carbon footprint of the food" in its DEIR, asking that the final EIR "quantify the carbon intensity of various feed stocks," including using vegetable proteins and insect meal.
For instance, 350 Humboldt proposes that the feed for Nordic's fish be of the same protein content or less than the fish themselves, so it doesn't take more resources to create the fish than the fish offer. Thompson said he expects the feed conversion ratio to be about 1-1, that is, slightly more protein will go in than is in the fish, but a far lower ratio than, say, chickens. Nordic, however, is still looking for sustainable and local sources of feed at this time.
Working for scale
Operating Engineers Union Local 3, educational institutions and real estate companies sent in dozens of letters in support of the potential for 150 or so well-paying positions that the facility aims to fill with full-time employees.
Locovore — no project, no way
The Humboldt Fishermen's Marketing Association leads this category. The people who depend on wild-caught fish for a living believe that the Pacific Coast is no place for Atlantic salmon. They are concerned that Atlantic salmon eggs cannot be proven to be without viruses, which could contaminate the wild Pacific salmon fisheries. They also fear potential job displacement.
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