Cooke Aquaculture Pacific was very disappointed to receive the Washington Department of Natural Resources (DNR) notices not to renew our two steelhead fish farming leases in Rich Passage off Bainbridge Island and off Hope Island in Skagit Bay.

Regulators and policymakers must responsibly follow the science and judicial precedents in making key decisions regarding marine aquaculture, which we do not believe was the case in this instance.

We were surprised by Commissioner of Public Lands Hilary Franz’s decision. Over the past five years, Cooke has worked to foster productive working relationships with Tribes, DNR staff, and other state agencies. A recent Federal Biological Opinion and a recent Washington Supreme Court decision both reaffirm the state of the science that fish farming does not have an adverse impact on the environment. All of these factors are contrary to DNR’s decision to not renew our leases.

• In 2018, the Washington State Legislature explicitly allowed the continued farming of fish in Washington, banning non-native fish such as Atlantic salmon but allowing farming of native fish such as steelhead to continue. DNR is now acting contrary to that legislative directive.
• In a landmark opinion filed in January 2022, the Washington State Supreme Court unanimously rejected the arguments of a group of environmental organizations and upheld a permit granted to Cooke Aquaculture Pacific by Washington Department of Fish and Wildlife (“WDFW”) for the farming of Pacific Steelhead trout.
• Further, the Washington State Supreme Court ruling found that farming of steelhead would not have probable, significant adverse impacts on the environment. The Court upheld WDFW’s years of careful analysis and permit conditions that it found would be protective of the environment. This finding is in stark contrast to the purported concerns of DNR as the rationale for its two decisions.
• In March 2022 the National Oceanic and Atmospheric Administration’s (NOAA) National Marine Fisheries Service released a 210 page biological opinion regarding marine finfish aquaculture in Puget Sound, finding little to no negative impact on native species such as endangered salmon, Orcas, or their habitat.
• In its analysis, NOAA found that EPA’s approval:
  • Is “not likely to jeopardize the continued existence” of Puget Sound (PS) and/or Georgia Basin (GB) species, including Chinook salmon, PS steelhead, Hood Canal summer-run chum, PS/GB yelloweye rockfish, or PS/GB bocaccio.
  • Is “not likely to result in the destruction or adverse modification of the designated critical habitats for any of the listed species.”
• Washington State has been a leader in developing and implementing permit requirements for fish farms. Over the past five years, Cooke has worked cooperatively with regulators, including DNR, to implement independent engineering review of its facilities, enhanced monitoring of water and sediment quality, and increased transparency regarding its operations. All these requirements that have been implemented at Cooke’s farms in Washington show the lack of impact to the environment of its operations.
• Cooke has continued to listen and do tribal outreach including hosting tribal tours on our Washington farms to understand their concerns. Through listening, we understand better than ever the importance of salmon to tribes in Western Washington and believe fish farming can be compatible with and supportive of the tribal goal of having wild fish for harvest for generations to come.
• Cooke was engaged in dialogue with tribes in Washington regarding integrating wild salmon enhancement into its farm operations. Wild salmon survive to adulthood at extremely low rates. Delayed release—holding wild fish in pens so they are released as older and larger fish–is a proven method to increase that survival rate. Those efforts, if they had been allowed by DNR, would have had immediate and meaningful positive impacts on wild fish survival for tribal fishers to harvest.
• As farmers and wild fishers, we understand that the natural environment and ensuring its health is fundamental in sustainably producing quality, healthy food. We have a vested interest in the waters we farm in and, as shown by our close work with agencies in Washington and elsewhere, welcome a well-regulated environment to operate in.

Environmental organizations and Commissioner Franz are choosing to ignore the fact that farm-raised fish is one of the healthiest and most efficient ways to feed the global population with a minimal environmental impact and the lowest carbon footprint of any animal protein. Farmers work closely with world-renowned scientists from academia, government, and the private sector to develop rigorous standards and implement best practices for fish health and environmental protection.

The science does not support the statements made by Commissioner Franz that the removal of these fish farms will save wild fish and natural habitat. There are many known factors contributing to wild salmon population decline including hydropower dams, growing seal populations as predators, habitat loss due to development, continued commercial fishing in migratory routes, municipal waste treatment plants releasing untreated pollutants and contaminants which affect juvenile salmon and more. Fish farming can mitigate these harms by reducing pressures on wild stocks and also by directly applying the expertise of companies like Cooke to better hatchery and wild salmon recovery efforts.

From an animal welfare perspective, with this decision, Commissioner Franz is forcing Cooke Aquaculture Pacific to kill 332,000 juvenile steelhead that were planned to be stocked at Rich Passage and Hope Island in 2023. This is a tragic outcome for fish that should have been healthy, sustainable, food for our communities.

Cooke Aquaculture Pacific acquired the Cypress Island fish farm in 2016 from a previous owner on the brink of bankruptcy. Regrettably, a year later the steel cage system collapsed. Prior to the collapse, Cooke had applied to replace the cage system that was in operation by the previous owner almost 20 years.

The compliance issues relied upon by DNR as the reason not to renew our two steelhead fish farming leases in Rich Passage and Hope Island stem from our assuming ownership of farms that fell into disrepair by the previous owner. After the collapse of that farm, Cooke focussed on improving the operations in Washington, working with regulators to increase transparency of its operations, implementing third party engineering review of its facilities, implementing enhanced environmental monitoring, and transitioning the farms early to all female, sterile trout.

DNR’s action ignores all of this effort and improvements. DNR’s own staff has repeatedly commended Cooke, in both internal and external correspondence, for the strides it had taken in working with DNR, the Washington Department of Ecology and WDFW. The actions by DNR’s leadership are perplexing at best, and punitive at worst. As a Canadian family company investing significantly in Washington State and creating local jobs, this is very disheartening. As a steward of Washington’s lands, DNR is sending a very clear message to others: “Do not come to Washington, do not invest here.”

We have been and continue to be focused on improvement including responding through technological and science advancements where nature presents us with events beyond our control. We are committed to listen, learn, and adapt to ensure we are always focused on sustainable outcomes.

At this time, we are focused on our employees in Washington State, who are best-in-class multi-generational fish farmers whose livelihood has been put in jeopardy by Commissioner Franz. We intend to explore available options for our operations and investments in Washington with the best interest of our employees, and their families at top of mind.

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Joel Richardson
Vice President Public Relations
Cooke Aquaculture Inc. / for Cooke Aquaculture Pacific LLC
40 Wellington Row, Saint John, NB, Canada  E2L 3H3
+1-506-694-4939 office / +1-506-721-1093 mobile
Joel.Richardson@cookeaqua.com
www.cookeseafood.com