FISH

The False Promise of Ocean

Aquaculture in Hawai`i
Backgrounder • February 2010

F or the past 10 years, Hawai`i’s state-controlled waters have been a testing ground
for the industrial ocean fish farming industry. But after a decade and an investment
of millions in taxpayers’ dollars, it is clear that the industry has not lived up to its
promises of both economic and environmental sustainability. Instead, industrial fish
farming has damaged ocean ecosystems, infuriated native Hawaiian rights groups and
contributed little to the local economy.

Viable alternatives to open-ocean aquaculture exist, Ocean Aquaculture in Hawai`i

including local and culturally appropriate methods such as
traditional fish ponds (loko i`a) and land-based recirculating
aquaculture systems (particularly aquaponics). Legislators
should consider prohibiting the expansion of commercial
open ocean aquaculture to conserve state resources and
protect them for future generations. Resources should be
redirected to the restoration of loko i`a and development of
land-based recirculating aquaculture.
The United States Department of Commerce promoted
development of an open-ocean aquaculture industry as
a priority in the 1990s, and Hawai`i became the nation’s
testing ground. As part of the experiment, in 1998,
the federal government financed the Hawai`i Offshore
Aquaculture Research Project (HOARP) off Ewa Beach,
O`ahu.1 After only one year of experimentation and much
lobbying from industry enthusiasts, Hawai`i amended its
oceans leasing laws to allow commercial development of
ocean fish farms. Shortly thereafter, despite documented
negative environmental impacts, HOARP was sold to a
private, for-profit venture and became the nation’s first
commercial ocean fish farm.2 It is now owned by Hukilau
Foods, LLC — a subsidiary of Grove Farm Fish & Poi LLC
— which plans to increase the site from 28 to 61 acres and
quadruple its production of moi (Pacific threadfin) from 1.5
million pounds to 5 million pounds by 2013.3,4

The second existing commercial ocean aquaculture

Ocean fish farming, also known as open-ocean aquaculture and
other, similar terms, is the mass production of fish in large float-
ing net pens or cages in ocean waters. Photo courtesy of NOAA.
operation is Kona Blue Water Farms Inc. (KBWF) which
recently transferred lease ownership and operation of the
offshore aquaculture aspects of its business to a newly
formed company, Keahole Point Fish LLC. 5 The 90-acre site
is located off Unualoha Point, Hawai`i Island, and visible
from the International Kailua-Kona Airport.6 KBWF’s
facilities are in “Class AA” waters — determined by state
law to be kept in their “natural pristine state. ”7,8 Although
“the support and propagation of shellfish and other marine
life” is an allowed use under the law, it is doubtful that
lawmakers had intended such facilities to be factory fish
farms. 9

Pacific threadfish off the Hawaiian coast. Photo courtesy of
NOAA.
Three further ventures are in the works for Hawaiian
waters, including: Hawai`i Oceanic Technology Inc. (HOT),
Indigo Seafood (IS) and Maui Fresh Fish LLC (MFF). Both
HOT and IS are proposing operations off of the north Kohala
Coast, Hawai`i Island. 10,11 MFF requested a lease for a site
off of Lana`i Island in 2007 but met with resistance from
local fishermen and it is unclear at this time if the venture
will move forward. 12 HOT’s goal is the production of 12
million pounds of yellowfin and big eye tuna annually at
a 247-acre proposed ocean lease site, using 12 enormous
cages.13 Two contested cases filed by native Hawaiians
against the Board of Land and Natural Resources decision
to award HOT a Conservation District Use Permit are
awaiting judgment.14,15
Should the HOT operation move forward, it would expand
the industry’s current overall production by 530 percent.16
Factoring in the projected increase in production at
Hukilau Farms, industry production would increase by
780 percent.17 Given the demonstrated negative impacts
of operations at the current production capacity, such
a drastic increase is cause for great concern and should
be addressed by the legislature. But, because permitting
is done on a case-by-case basis, the overall cumulative
impacts of increased production on ocean ecosystems are
not being considered.
Economics
The ocean fish-farming industry in Hawai`i has been the
recipient of much government investment and promotion
at both the state and federal level. Unfortunately, it is
questionable whether the return to the local Hawaiian
economy is comparable to the costs paid by taxpayers
and the environment, especially when weighed against
alternative fish farming methods such as land-based
recirculating aquaponic systems.
Public money for private profit
KBWF (now owned by Keahole Point Fish LLC) and Hukilau
Farms combined plan to create 39 jobs by 2013. These
jobs will cost taxpayers more than $84,000 each when
factoring in over $3.3 million in public subsidies that the
companies have benefited from directly or indirectly — not
including Hawai`i Act 221 High Tech tax credits.18,19, 20,21 The
state derives only a small percentage in rent from ocean
leases — with a base around $2,000 per year or 1 percent
of revenue, whichever is greater, that is funneled back into
the administrative costs of the aquaculture development
program. 22,23,24 But despite ongoing financial support and
low lease costs, both of the ocean fish farms in Hawai`i have
been delinquent in rent payments. 25,26
Economically unsustainable
KBWF has demonstrated that its model of commercial
aquaculture is not profitable. In January 2010, KBWF sold
its ocean fish farm to Keahole Point Fish LLC. 27,28 Despite
$1.8 million in funding from NOAA, nearly $200,000 in
federal stimulus grants and contracts, Hawai`i high-tech
tax credits, nearly $10 million from investors and a product
sold only in high-end restaurants and retailers, KBWF did
not achieve a level of profitability to sustain its grow-out
operations.29,30,31,32,33 On January 8, 2010, the Board of Land
and Natural Resources unanimously approved the transfer
of KBWF’s lease for 90 acres of Hawaiian waters to a
company registered just two months prior as a foreign LLC
in Delaware — Keahole Point Fish LLC. 34,35 The board failed
to question the applicants who were present at the meeting
about their experience and how they proposed to turn the
failing KBWF into a profitable enterprise.36 KBWF will
continue to manage sales and marketing of Kona Kampachi
as well as conduct research at their land-based hatchery at
Natural Energy Laboratory of Hawai`i Authority.37
Economic comparison between ocean fish farming
and land-based aquaponics
Because the existing ocean fish farms in Hawai`i are private
ventures, their financial records are not accessible to
the public. Therefore, the total amount required to fund
one farm is unknown. However, what is known is that
$13 million is being invested in the expansion of Hukilau
Foods.38 This number does not account for the money
invested in starting HOARP or Cates International.
Viable alternatives such as recirculating aquaculture
systems could provide a better investment. A comparison
between the Premier Organic Farms’ recirculating
aquaponic system in Memphis and Hukilau Foods shows
that the ventures expect to have similar sales in fish
products (with Premier Organic expecting 9 percent more
in sales).39 However, Premier Organic Farms will provide
11 times as many jobs and more than twice the amount
of fish — plus 43 million pounds of produce. It will also
be far more profitable, recuperating start-up costs within
the first year and perhaps achieving over 11 times the
revenue that Hukilau Foods will in year one.

Hukilau Foods1 Premier Organic Farms — Memphis2

Ocean Fish Farming Recirculating Aquaponics
Sales in fish
$20 million (projected) for moi $22.3 million (projected) for tilapia
(per year)
Jobs 25 for hatchery and administration 282 full-time operations and production jobs
Fish production
5 million pounds 11.44 million pounds
(per year)
7.7 million pounds of Boston lettuce/arugula
Additional 16.9 million pounds of baby greens/spinach/mixed greens
products None
(per year) 6 million pounds of herbs

12 million pounds of tomatoes

Additional sales $114.5 million in vegetables

None
(per year) (Total sales $136.8 million, fish and produce)
$4.2 million to build fish production unit and tilapia
$13 million now being invested (from fingerlings and fish food
Initial capital private investors and federal fisheries
investment loans) to scale up from 1.25 million pound $50 million total costs (including land, greenhouse
production levels.3 construction, cafeteria and daycare facility for employees’
children)
$78 million in first year (earnings before tax, depreciation
Potential profit Less than $7 million in the first year4
and amortization)
61.59 acres of seafloor plus the water
Space used 100 acres of land
column
15.9 million gallons will be constantly
40 million gallons of captured rainfall (for tilapia and
Water used flowing through the cages at a rate of 0.5-
plant production)
2.0 kts
Zero-impact operation — the system is in alliance with
other industries. It will provide heated rain/wastewater for
Energy used Numbers unavailable
energy plants to use and will get excess energy from the
plants to use for its operation

1
Information drawn from: Aquaculture Planning & Advocacy, LLC. “Final Environment Assessment: Proposed Expansion of Hukilau Foods Offshore Fish
Farm, Mamala Bay, Oahu, Hawai`i.” July 29, 2009. Sales, Jobs, Fish Production and Initial Capital Investment at p. 22; Space Used at 8; Water Use at 3
(volume of cages) and 28 (current speeds) with calculations conducted by Food & Water Watch for gallons of water based on volume of cages. 1 cubic
meter = 264.172052 U.S. gallons

2
Information provided by Susan Bedwell, CFO, Premier Organic Farms, September 15, 2009. Information on file at Food & Water Watch.

3
The company plans to invest $13 million, as quoted in Aquaculture Planning & Advocacy LLC, Op cit. This figure does not include the money that
was invested in starting up the Hawaiian Offshore Aquaculture Research and Demonstration Project or Cates International, the predecessors of Hukilau
Foods. $13 million does not necessarily represent the money that would be needed to start Hukilau Foods from scratch.

4
This is a generous calculation. Hukilau Foods projects a total wholesale value of $20 million when the operation is at full capacity, but it does
not actually plan to reach full production until year three. $7 million would be the maximum revenue possible after recuperating the $13 million
investment if the company did reach $20 million in sales that first year (a lower revenue is actually expected). Plus, because financial figures prior to
this expansion were not available, this calculation does not figure in the financial status, or debt, Hukilau was in prior to this expansion.
The “Real Costs” of Ocean Fish Farming
Ocean fish farming is heavily dependent on natural
resources. Because of this, any economic discussion
of the industry needs to also account for the costs of
environmental pollution and resource extraction. In other
words, in addition to the basic financial comparison of costs
and revenues, we must also consider other environmental
and social externalities without an easily quantifiable
price. For example, what is the cost of ocean pollution?
What are the economic effects of fish escapes on wild fish
populations? How are ocean fish farms impacting cultural
resources and the rights of native Hawaiians? The public
bears the burden for these hidden costs of industrial ocean
aquaculture in Hawai`i.
Conflicts with marine mammals and other sealife
The state has documented cases of deliberate interference
with bottlenose dolphins associated with KBWF
operations40; six or seven dolphins are believed to frequent
the site daily in search of food.41 Their numbers are
increasing over time.42 The dolphins began appearing
when the cages were first installed.43 According to the
Hawai`i Department of Aquatic Resources (DAR), the
animals have begun to exhibit “unnatural behaviors.”44
Conditioning of the dolphins is a major concern. The
alteration of feeding and social behaviors and the increased
potential for entanglement or foreign-body ingestion can
all be detrimental to dolphin survival. At KBWF, the DAR
warned that dolphin conditioning could “be occurring, or
soon occur, at levels that constitute “take” as defined under
the Marine Mammal Protection Act.”45 This could put the
facility in violation of federal law.
Like dolphins, sharks are drawn to aquaculture cages
because of the large number of fish in a confined area
and the accumulation of wild fish that frequent the sites
to take advantage of excess feed. This poses an extreme
hazard to employee safety, the safety of other ocean users
near and around the site, and the safety of the shark.
Additionally, it is problematic due to the significant role
that sharks play for culturally practicing native Hawaiians
who revere them as aumakua, a family guiding spirit.46 In
2005, KBWF killed a 16-foot tiger shark that repeatedly
visited the site.47 The incident sparked outrage in the native
Hawaiian community. In September 2009, a Galapagos
shark was documented to have bitten through and entered
one of KBWF cages, releasing farmed fish into the wild.
Hundreds of the escaped fish were reportedly eaten quickly
by a resident dolphin and school of ulua.48 The shark was
removed with the help of local fishermen by using a seine
net. 49
Use of antibiotics
Captive fish, held in unnatural, crowded and stressful
conditions, are more likely to fall ill than they would in the
wild. Indeed, documented cases of stress-related illnesses
requiring in-situ antibiotic treatment50 and parasites51 have
occurred at KBWF. The use of antibiotics in aquaculture
has gained attention as a public health concern and
ecological threat. Antibiotics can alter the composition of
marine and freshwater bacteria. Evidence suggests that
these antibiotic-resistant bacteria can, in turn, pass on
their antibiotic resistant genes to other bacteria, including
human and animal pathogens.52 Antibiotic use is a cause
for concern for consumers because they, in turn, ingest the
drugs when they eat treated fish. This can lead to allergic
reactions and increased resistance to antibiotics.
Stress-related disease and parasites documented at the
KBWF site include streptococcus and skin flukes. 53,54
The United States Fish and Wildlife Services of Montana
gave KBWF a permit to use the antibiotic florfenicol,
which is explicitly approved only for catfish or freshwater
salmonid aquaculture, as an experimental drug used to
treat streptococcus. 55,56 What is particularly troubling
is that the decision to introduce antibiotic-coated feed
directly into Class AA Hawaiian waters at the company’s
site in 2007 was not made by Hawaiian officials or even
overseen by Hawaiian veterinary counsel. 57 The impacts
of florfenicol on unique Hawaiian marine flora, fauna and
other organisms are unknown. In addition to impacting
the environment, the use of antibiotics in seafood poses
a threat to consumers who may experience unexpected
allergic reactions after consuming fish with antibiotic
residues, or as previously mentioned, through the public
health implications of creating drug-resistant pathogens.
Impacts on coral reefs
In Hawai`i, the 100- to 300-foot depth that ocean
aquaculture operations require often occurs directly
adjacent to the shoreline, and operations may be less than
a mile out. 58 For example, KBWF (now operated by Keahole
Point Fish) is less than a half-mile off the Kailua-Kona
shore.59 This poses a unique problem for Hawai`i, because
many Pacific coral reef habitats are characterized as
occurring in deep waters and often extend well beyond 100
feet. 60 Ocean aquaculture sites are likely to be near these
unique coral reef habitats or other native flora and fauna
protected under state law (such as live rock). Unfortunately,
according to DAR, offshore aquaculture corporations have
often failed to “adequately address potential impacts on
[these resources] for areas under consideration which
would be necessary for a resource trustee to evaluate
possible concerns …”61
Aquatic invasive species
“…Alien species issues as they relate to [ocean aquaculture
cages] in nearshore waters serving as a major colonization
refuge, are real, and a threat to Hawai`i’s nearshore natural
marine ecosystems.” – Dan Polhemus, Director of Department
of Aquatic Resources 62
The cumulative effects of excessive nutrification of reef
sites from fish feed and feces over the years are not fully
known. According to DAR, “nutrification of coral habitats
often results in an ecological shift from coral to fleshy algal
structure resulting in a decrease in reef species’ diversity,
populations, and trophic complexity.”63 In fact, there have
been documented cases of phase shifts at the site currently
owned by Hukilau Farms located off of Ewa Beach, O`ahu,
characterized by the growth of alien soft coral underneath
the cages. 64 Requests by DAR for KBWF to report the
findings of similar, unknown fauna growing on and around
the cages to prevent such a reoccurrence was dismissed by
the company as “ludicrous” and that the company’s intent
was “controlling biofouling, rather than identifying it.” 65
With known problems of invasive species and phase shifts
occurring at other sites, KBWF’s response demonstrates
neglect and an unwillingness to work with state agencies
to address environmental impacts before they get out of
hand.
In 2006, a research team found that the facility now owned
by Hukilau farms had “grossly polluted” the seafloor and
“severely depressed” certain types of sealife. “Despite the
open ocean location and alongshore currents, the effect
of fish feed and waste on the [seafloor] community were
evident.” The ecosystem had been “drastically changed,”
leaving the researchers to wonder whether the seafloor
could ever return to normal.66
Fish food concerns
KBWF has used a feed ingredient that most consumers
wouldn’t expect the fish on their dinner plate had
eaten: chicken byproducts such as ground feet, heads
and undeveloped eggs.67,68 Using these ingredients in
aquaculture feed could inadvertently introduce the
hormones and other chemicals originally consumed by
industrially raised chickens into Hawai`i Class AA waters.69
The use of preventative antibiotics and the injection of
hormones are widespread in land-based concentrated
animal feeding operations and researchers do not know
the impact poultry byproducts from such farms could have
when introduced into marine waters.
biggest catch out of respect. By killing one of these sacred
animals, Kona Blue has disrespected us and infringed on
our religious freedom.” – Kale Gumapac, Alaka`i, Kanaka
Council73
The ocean fish farming industry has been opposed by
many in the native Hawaiian community on cultural
grounds. Those bringing contested cases against new
operations and challenging proposals for expansion of
existing operations have often been members of the native
Hawaiian community. Killing animals revered as aumakua,
the misappropriation of cultural terms, impacts on natural
resources needed for cultural and medicinal uses, impacts
on traditional fishing grounds and ceded land issues are all
concerns with offshore aquaculture in Hawai`i.
Despite this, the industrial ocean fish farming operations in
Hawai`i consistently misappropriate the idea of traditional
Hawaiian fishponds (loko i`a) to validate using Hawai`i as a
testing ground for ocean aquaculture. KBWF, for example,
has an entire section on its Web site claiming that they are
located on the site of King Kamehameha’s favorite fishpond
and continuing the tradition.74 Given the lack of native
Hawaiian involvement in KBWF’s farming operations and
the fact that some native Hawaiians oppose them,75 such
a statement is an irresponsible portrayal of broad native
Hawaiian support for the open ocean aquaculture industry.

Raising large numbers of fish in captivity requires huge

amounts of feed, made largely from fishmeal and oil. These
ingredients are derived almost exclusively from small
ocean fish, such as sardines, anchovies, herring, menhaden
and krill. Due to its tremendous growth, aquaculture is
now the world’s largest user of these products, consuming
53 percent of the world’s fishmeal and 86 percent of the
world’s fish oil each year.70 In some cases, it can take about
two to six pounds of wild fish to produce just one pound of
farmed fish.71 Such a reliance on wild fish as a food source
is one reason labeling ocean aquaculture as sustainable is
questionable at this time.

Native Hawaiian rights

“The ocean has enormous historical, cultural and religious
importance for native Hawaiian communities, which could
be infringed upon by this new type of ocean use.” – Mike
Kumukauoha Lee, Cultural Practitioner72

“Kanaka Maoli recognize the ocean as the domain of the

mano (shark) and traditionally offered them the first or
Conclusions and Recommendations
The past decade has shown that the Hawaiian open-
ocean aquaculture industry should be considered a failed
experiment. Less risky methods of aquaculture should
be explored and promoted to increase food security and
decrease the state’s reliance on imported food. The
restoration of loko i`a could provide both the impetus for
a cultural revival and meet community food needs. It is
estimated that when Europeans arrived in 1778, there
were 360 fishponds producing nearly 2 million pounds of
fish per year.76 Initiatives are already underway across the
islands to restore a number of historic fishponds.77,78 Land-
based recirculating systems — including aquaponics — are
other alternatives that are successfully in use on the islands
and could be expanded to meet seafood demand.79 An
investment in these technologies could provide real returns
to Hawai`i — not just empty promises.
For everyone:
• See our Smart Seafood Guide for sustainable seafood
choices
• Take action and learn more about the expansion of
industrial fish farming in Hawaiian waters by going to
www.foodandwaterwatch.org/hawaii
For policymakers in Hawai`i
• Oppose House Bill 2409 introduced by Representative
Tsuji which would increase the length of leases for
ocean fish farm sites, up to 45 years!
• Encourage the reestablishment of loko i’a (traditional
coastal fishponds) and the development of recirculating
aquaculture systems and aquaponics
The following bills that could have helped protect Hawai`i
from problems associated with ocean fish farming did
not make it to the hearing stage in the legislature. Next
year, similar pieces should be introduced, discussed and
reviewed for passage.
• Support Senate Bill 2486 introduced by Senator
Galuteria to require full Environmental Impact
Statements for all ocean aquaculture applicants
and requires a royalty payment by aquaculture
corporations
• Support House Bill 2958 introduced by Representatives
Hanohano and Carroll to halt the expansion of commer-
cial ocean fish farming, or transfer and expansion of
existing leases, except for research purposes.
For federal policymakers
• Look to Hawai`i to understand the difficulty in
regulating open ocean aquaculture and the massive
environmental and cultural ramifications it may cause.
• Do not support legislation that would promote the
expansion of offshore aquaculture in the United States,
such as H.R. 4363, which would streamline regulation
of the industry in federal waters.
Endnotes
1 Alessi, Michael D. Grassroot Institute. “Catching the Aquaculture Wave.”
Reason Policy Study 327. Grassroot Study 1004. December 2004. P. 5
2 Cates, John R. Hukilau Farms, LLC. March 31 2006 Written Testimony
on National Ocean Policy Study. Committee on Commerce, Science
and Transportation. United States Senate. March 31, 2006. < http://com-
merce.senate.gov/pdf/cates-040606.pdf>
3 “Final Environmental Assessment for Proposed Expansion of Hukilau
Foods Offshore Fish Farm, Mamala Bay, O`ahu, Hawai`i.” Prepared for
Office of Conservation and Coastal Lands, Hawaii Department of Land
and Natural Resources by Aquaculture Planning & Advocacy LLC. July 24
2009. p. 8.
4 Minutes of Board of Land and Natural Resources, Hawai`i Department
of Land and Natural Resources. Minutes. Item D-11. February 9, 2007.
<http://www.state.hi.us/dlnr/chair/meetings/minutes/070209-minutes.
pdf>
5 Miller, Erin. (2009) Kona Blue Close to Changing Hands. West Hawai`i
Today. January 7 2010.
6 “Final Supplemental Environmental Assessment for a Modification to
Net Pen Designs within the Existing Capacity and Farm Lease Area for
Kona Blue’s Offshore Open Ocean Fish Farm off Unualoha Point, Kona,
Hawai`i.” Prepared for Office of Conservation and Coastal Land Division,
Department of Land and Natural Resources by Kona Blue Water Farms.
Kailua-Kona, HI. April 21, 2009. p xxii.
7 Notice of Proposed Water Pollution Control Permit for Kona Blue Water
Farms NPDES Permit No. HI 0021825. Hawai`i Department of Health
Clean Water Branch. October 1, 2009.
8 Hawaii Administrative Rules §11-54-3
9 Hawaii Administrative Rules §11-54-3
10 “Final Environmental Impact Statement for the Ahi Aquaculture Project,
Kohala Coast, Hawai`i.” Prepared for Office of Coastal and Conservation
Lands, Hawaii Department of Land and Natural Resoures by Tetra Tech
on behalf of Hawai`i Oceanic Technology Inc. May 25, 2009. Page i.
11 McVey, Jim. “Informal Presentation: Indigo Seafood.” Kohala Ranch,
Hawai`i, May 23, 2009. On file at: Food & Water Watch.
12 Maui Fresh Fish LLC. www.mauifreshfish.com Accessed 17 January
2010.
13 “Final Environmental Impact Statement for Ahi…”, p. i.
14 Gumapac, Kale. Kanaka Council Moku `O Keawe. Contested case peti-
tion filed with Board of Land and Natural Resources, Hawaii Department
of Land and Natural Resources. October 23, 2009. On file at: Food &
Water Watch.
15 Lee, Michael Kumukauoha. Kanaka Council Moku `O Keawe. Contested
case petition filed with Board of Land and Natural Resources, Hawaii
Department of Land and Natural Resources. October 23, 2009. On file
at: Food & Water Watch.
16 12 million lbs/2,271,600 million lbs (Hukilau current + KBWF once they
are up and running again) = 5.3. Data for Hukilau from Aquaculture
Planning & Advocacy LLC. Final Environmental Assessment Proposed
Expansion of Hukilau Foods Offshore Fish Farm, Mamala Bay, O`ahu,
Hawai`i. Prepared for Office of Conservation and Coastal Lands, Depart-
ment of Land and Natural Resources. 24 July 2009. Page 8. Data for
KBWF from Kona Blue Water Farms, LLC Final Supplemental Environ-
mental Assessment for a Modification to Net Pen Designs within the
Existing Capacity and Farm Lease Area for Kona Blue’s Offshore Open
Ocean Fish Farm off Unualoha Point, Kona, Hawai`i prepared for Land
Division, Department of Land and Natural Resources. Dated April 21,
2009. Page 23.
17 17,771,600 million (Hukilaus additional 3.5 million + HOTs 12 mil-
lion)/2,271,600 million = 7.8 Data for Hukilau Data for Hukilau from
Aquaculture Planning & Advocacy LLC. Final Environmental Assessment
Proposed Expansion of Hukilau Foods Offshore Fish Farm, Mamala Bay,
O`ahu, Hawai`i. Prepared for Office of Conservation and Coastal Lands,
Department of Land and Natural Resources. 24 July 2009. Page 8.
Data for Hawai`i Oceanic Technology Tetra Tech Inc. Final Environmental
Impact Statement for the Ahi Aquaculture Project, Kohala Coast, Hawai`i.
Prepared for Hawai`i Oceanic Technology Inc. Submitted to Office of
Coastal and Conservation Lands, Department of Land and Natural Re-
sources. 25 May 2009. Page i.
18 Food & Water Watch. Fishy Farms: The Problems with Offshore Aquacul-
ture. October 2007. P. 9
19 “Final Supplemental Environmental Assessment for a Modification…”
2009. p 23.
20 “Final Environmental Assessment Proposed Expansion of Hukilau…”
2009. p. 22.
21 The High Tech Tax Incentive gives an 80 percent tax credit (previously
100 percent) against Hawai`i State taxes for equity investments for Quali-
fied High Tech Companies, which include aquaculture facilities. Investors
are able to receive the credit front-loaded over five years.
22 State of Hawai`i Department of Land and Natural Resources submittals
GL S-5721, January 8, 2010. P. 4.
23 State of Hawai`i Department of Land and Natural Resources submittals
GL S-5654, February 9, 2007.
24 “Final Supplemental Environmental Assessment for a Modification…” p
14.
25 State of Hawai`i Department of Land and Natural Resources submittals,
GL S05721, August 28, 2009.
26 State of Hawai`i Department of Land and Natural Resources submittals
GL S-5654, February 9, 2007.
27 Agenda. Board of Land and Natural Resources Agenda, Hawai`i Depart-
ment of Land and Natural Resources. January 8, 2010. Available http://
Hawai`i.gov/dlnr/chair/meeting/index.html. Accessed 15 January 2010.
28 Parsons, Rob. Food & Water Watch, Personal communication, January
11 2010. On file at: Food & Water Watch.
29 Pro-publica. Recovery Tracker, Hawai`i County. Available at: http://
projects.propublica.org/recovery/locale/Hawai`i/Hawai`i Accessed 30
January 2010.
30 Food & Water Watch. Fishy Farms. October 2007. p. 11
31 Durst, Sidra. “Problem No. 6: Overfishing Kona Blue’s deep-ocean
aquaculture could help save declining fish populations.” CNNMoney.
com 26 January 2007. Available at: http://money.cnn.com/2007/01/24/
magazines/business2/Prob6_Overfishing.biz2/index.htm
32 “Final Supplemental Environmental Assessment for a Modification…” p.
23
33 Ibid p 9.
34 Agenda. Board of Land and Natural Resources, Hawai`i Department of
Land and Natural Resources. January 8, 2010. Available http://Hawai`i.
gov/dlnr/chair/meeting/index.html. Accessed 15 January 2010.
35 Hawaii Department of Commerce. Business Registration Database.
“Keahole Point Fish LLC” Available at http://hbe.ehawaii.gov/documents/
search.html, accessed January 29, 2010
36 Parsons, Rob. 2010
37 Miller, Erin. “Kona Blue Close to Changing Hands.” West Hawai`i Today.
January 7 2010.
38 See: “Final Environmental Assessment Proposed Expansion of Hukilau
Foods Offshore Fish Farm, Mamala Bay, O`ahu, Hawai`i.” Prepared for
Office of Conservation and Coastal Lands, Hawaii Department of Land
and Natural Resources by Aquaculture Planning & Advocacy LLC. July 24
2009. p. 22.
39 Aquaponics is the practice of raising both fish and plants in a mutually
beneficial, land-based, closed looped system.
40 Polhemus, Dan. Division of Aquatic Resources. Memorandum to Sam
Lemmo, Office of Coastal and Conservation Lands, Hawaii Department
of Land and Natural Resources. February 20, 2008. On file at: Food &
Water Watch.
41 Yates, Chris E. Protected Resources Division of National Marine Fisheries.
Public comment re: Draft EA/CDUA HA-3443 for the Expansion of Kona
Blue Waters Farms Offshore Aquaculture Facility. 4 February 2008. On
file at: Food & Water Watch.
42 Ibid.
43 Ibid.
44 Polhemus, Dan. 2008.
45 Ibid.
46 Gumapac, Kale et. al. (2009). Letter to Monterey Bay Aquarium regard-
ing “Good Alternative” ranking for US Farmed Yellowtail. Available at:
http://foodandwaterwatch.org/fish/fish-farming/Hawai`i-1/KanakaCouncil-
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47 Lucas, Carolyn. “Fish farm seeks second location.” West Hawai`i Today,
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48 Note from Office of Conservation and Coastal Land. Titled “Follow Up
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49 Viezbicke, Justin P. to Neil Sims, Kona Blue Water Farms. Personal com-
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50 Sims, Neil Anthony to Kris Potentis, Engineering Branch of Clean Water
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51 Kona Blue Water Farms LLC. Land submittal to Board of Land and Natural
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52 Heuer, Ole. E. et al. “Human Health Consequences of Use of Antimicro-
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53 Sims, Neil Anthony to Kris Poentis. 2007.
54 Kona Blue Water Farms LLC. Land submittal 2007 p 2.
55 Storey, Susan. Aquaculture Drugs Team, FDA-CVM, Office of New
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to Neil Anthony Sims, President, Kona Blue Water Farms. Personal com-
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56 Approved Drugs for Use in Aquaculture, poster produced by USFWS
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57 Sims, Neil Anthony to Dr. Allen Riggs, Aquaculture Development
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58 Polhemus, Dan. 2008. Page 9.
59 Sustainability. Kona Blue Water Farms. Available http://www.kona-blue.
com/sustainability.php Accessed 10 February 2010.
60 Polhemus, Dan. 2008. Page 9.
61 Ibid p. 1.
62 Ibid p 3.
63 Ibid p 3.
64 Ibid pp. 5-6.
65 “Final Supplemental Environmental Assessment for a Modification…”
2009. p xiii.
66 Lee, Han W. “Temporal changes in the polychaete infaunal community
surrounding a Hawaiian mariculture operation” Marine Ecology Progress
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67 Loews, Chris. “Kona Blue seeks to improve sustainability score.” Seafood
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seafoodsource.com/newsarticledetail.aspx?id=4294975807 >
68 Food and Agricultural Organization of the United Nations. Animal Feed
Resources Information System. “Poultry by-products meal.” Available at
http://www.fao.org/ag/aGA/AGAP/FRG/AFRIS/Data/325.htm, accessed
February 2010.
69 Polhemus, Dan. 2008. p 10-11.
70 Tacon, Albert et al. “Use of Fishery Resources as Feed Inputs to Aqua-
culture Development: Trends and Policy Implications.” FAO Fisheries
Circular No. 1018, Food and Agriculture of the United Nations, Rome, p.
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71 Hungry Halibut. Food & Water Watch. April 2007.
72 Lee, Mike Kumukauoha. 2009.
73 Gumapac, Kale et. al. (2009).
74 Kona Blue Water Farms. “Hawaiian Fish Farming & Kona Blue.” <http://
www.kona-blue.com/Hawaiianaquaculture.php>.
75 Gumapac, Kale et. al. (2009).
76 Alessi, Michael D. Grassroot Institute. “Catching the Aquaculture Wave.”
Reason Policy Study 327. Grassroot Study 1004. December 2004. P. 5
77 Maui Fish Pond Association. http://www.mauifishpond.com/ Accessed
27 January 2010.
78 He`eia Fish Pond. Kamehameha Schools. 2009. Website. http://ksdl.ksbe.
edu/heeia/index.html Accessed 27 January 2010.
79 Whitton, Kevin. “Liquid Engineering” Green Magazine. Hawai`i. Avail-
able http://greenmagazineHawai`i.com/food_v1-3.html Accessed 27
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