One of the many net-pen salmon operations in Alaska; this one in Bear Cove in northern Southeast Alaska/NSRAA

Salmon ranch waste reported piling up

Update: This story was updated on April 8, 2024 to specify the more than $10.3 million the state of Alaska in fiscal year funneled to the five state hatchery organizations protesting regulations requiring they monitor their net pens for pollution from fish waste and excess feed.

In filings submitted to a state administrative law judge, the Alaska Department of Environmental Conservation has indicated there might be a good reason the state’s ocean-farming salmon hatcheries want to be exempted from newly proposed requirements that they monitor the waters beneath the nets pens in which they fatten hatchery fish before sending them to sea.

The reason, in one word, is “sludge.”

Sludge is the mine tailings of the industrial salmon farming business – the unwanted byproduct that inevitably must go somewhere in the process of producing the valuable product. Sometimes nature can be used to help alleviate or possibly even solve the problem of disposing of this sort of waste.

The state allows so-called “mixing zones” for “municipal wastewater treatment facilities, seafood processors, oil and gas wastewater discharges, mining activities, and cruise ship wastewater discharges.”

These mixing zones are permitted in areas where tides, such as in Cook Inlet, or currents, such as in the Yukon River, so quickly mix waste into the water that any pollution is minimal. As chemists long ago observed, the solution to pollution is dilution.

The problem facing Alaska’s ocean-farming hatcheries is that they apparenlty didn’t pay enough attention to the need for mixing zones when siting their net pens and now the shit is quite literally piling up beneath them.

“The (Environmental Conservation) Department’s regulations tolerate zero deposits on the seafloor for any length of time,” Alaska Senior Assistant Attorney General Cody Doig wrote in a court brief summarizing the DEC’s view of the problem. “The hatcheries deposit feed, excrement, and other sludge on the seafloor – sometimes inches deep, sometimes 90 percent of the seafloor under a pen.

“The Water Transfer Rule, a rule promulgated by Environmental Protection Agency, does not provide safe refuge for intervening uses, like when thousands of fish hatch, are fed, die,
decay, defecate and live in the water for years at a time. (The full state filing is attached to the end of this story)”

Net pens here, there, everywhere

That Alaska has an environmental problem with salmon in net pens might seem a little incongruous to those familiar with the state ban on net-pen salmon farming imposed in 1990. But even before lawmakers began debating that legislation, which was primarily and foolishly believed to be a way to limit the global production of farmed salmon then only hinting at blowing up a market dominated by Alaska’s wild salmon, state fishery biologists had begun experimenting with net pens to improve the success of a state-driven, open-ocean salmon farming program.

That program began in 1968 after Alaska voters approved $3 million (approximately $31.4 million after correction for inflation to 2024) in bonds to build hatcheries. It was the first of several voter-backed bond packages aimed at building hatcheries to “rehabilitate and enhance” flagging salmon return.

“The basic idea behind the state hatchery program was to supplement the existing wild
salmon stocks in the state with hatchery fish which would be available for harvest by
commercial, sport and subsistence fishermen,” as a history written for the now-extinct Fisheries Rehabilitation and Enchantment Division (FRED) of the Alaska Department of Fish and Game recounts.

“The legislature planned for a long-range goal of increased commercial harvest from the 30 million fish level (of the early 70s) to a steady supply of 100 million ( +) salmon to provide a long-term source of employment and economic activity.”

The hatcheries long ago met that goal at least in numbers if not value. The 10-year, average annual harvest is now over 180 million salmon per year, though the bulk of them are low-value pink salmon. Of the 234 million salmon caught in Alaska in 2021, approximately 161 million or 69 percent of the catch were pinks – nearly a third of them hatchery fish – but they accounted for only 28 percent of the value of that year’s salmon harvest, according to state data.

The state led the charge into this low-value, ocean-farming business after the establishment of FRED in 1971. That division within Fish and Game, according to the history, “was modeled after the agriculture industry and covered many disciplines. So, from the beginning fish pathology, fish genetics, fish culture, biometrics, limnology, biology, engineering and a coded wire tag processing lab were all part of the overall development.

“Between 1974 and 1980, the legislature passed an additional 74.3 million dollars (approximately $400 million when corrected for inflation) of general obligation bonds, approved by the public, to build a state hatchery system.

“During the next six years, the public and private hatchery programs expanded at a rapid pace and by 1980, there were 25 hatcheries in operation, taking a total of 290 million eggs.” (The permitted egg take now stands at at 2.6 billion, according to Fish and Game.)

Most of the hatcheries, the FRED history recounts, “were producing pink salmon. This was because pink salmon do not require fresh water rearing and they are the fastest maturing salmon with a life cycle of just two years. Therefore, pink salmon could be added to the commercial fishery quicker than any other species.”

But as the state continued to promote the farming of the ocean, another 13 hatcheries were built between 1980 and 1985 either with state funds or with loans made to commercial fishing groups by the state, and the production of chum salmon along with pink salmon saw a big jump.

“Chum salmon are the only other salmon besides pink salmon that don’t require fresh water rearing,” the history recounts. “Now that the annual commercial harvest numbers had begun to rise, fishermen were interested in a more valuable species.”

To increase the number of these more valuable fish, state hatchery operators also began experimenting with net pens and by 1987 FRED’s Phil Rigby was telling a hatchery workshop that net-pen rearing of pink and chum salmon could significantly boost hatchery returns.

Follow the money

“Hatchery-reared pink salmon survived to adults at about 2.6 and 1.9 times the rate of fry released unfed from Kitoi and Tutka Hatcheries, respectively,” he said. “Reared chum salmon released from Hidden Falls Hatchery survived to adult at about 6.0 times the rate of fry released unfed.

“The value of additional adult fish produced by releasing fed juveniles exceeded the cost of
feeding by factors ranging from 4.4 to 12.8.”

Thus, three years before Alaska banned net-pen salmon farming, the die was cast and the state was headed into the net-pen business. Nearly all Alaska hatchery fish now spend some time fattening in net pens before going to sea to give them a better chance at ocean survival than the state’s wild fish.

All of this helps maximize the financial returns for the commercial fishermen who make up the “aquaculture associations” to which the state granted control of the hatcheries in 1995 after deciding, according to Fish and Game, that the facilities were too costly to operate.

At the Tutka Bay hatchery south of Anchorage, the Cook Inlet Aquaculture Association now says, its pink salmon “are reared in the facility until they reach the fry stage and then they are temporarily reared in net pens in front of the hatchery. On average the time in the net pens is two months before they are released to the open ocean.”

Hatchery chums spend even greater lengths of time in pens before release. And while these fish are in the pens, their waste, some of their carcasses and all of the food they didn’t eat is settling to the seabed beneath the pens.

Too costly

The hatchery operators, who got a great deal on the formerly state-owned hatcheries when they took them over,  are now arguing it would be too costly for them to monitor what is going on beneath their pens and, if necessary, clean it up.

After years of both the state and federal governments treating them as if they were a special industry beyond reproach, it would be understandable to find them shocked that DEC wants to make them meet environmental standards. This is a big change from where things started in 1982 when the state tried to gift the associations state hatcheries worth tens of millions of dollars.

The office of then-state Attorney General Will Condon vetoed that idea, but ruled that “if the associations are unable to purchase the facilities, the state may lease them for a nominal fee and provide that the associations shall operate and maintain them.

KBBI public radio in Homer reported in 2019 that “hatchery organizations that currently run state-owned facilities are responsible for all maintenance and operating costs, (but) they lease the properties for next to nothing – typically $1 for 50-to-90-year leases.”

This is not something state officials normally talk about. Neither do they say anything about the subsidization of hatcheries by the Division of Sport Fisheries and some local communities in order get them to provide fish for other than commercial fishermen.

When Alaska voters agreed to pay to build the hatcheries, they were promised the facilities would provide salmon for all Alaskans. The hatcheries have since been given outright ownership of a portion of their production in the form of exclusive, so-called “cost-recovery” fisheries that allow them to catch enough salmon to cover their operating costs and pay those “nominal fees” to the state for the takeover of state facilities.

Meanwhile, the state, plus some local communities, have to pay the hatcheries to raise salmon for the sport and subsistence fisheries that were originally supposed to have benefitted from the bonds along with the commercial fisheries

CIAA brags that “the recreational users in Seward also benefit from Trail Lakes Hatchery’s coho salmon program. On average, CIAA releases 450,000 coho salmon fry each year into Bear Lake. In cooperation with the Seward Chamber of Commerce, CIAA releases 50,000 to 75,000 additional coho salmon smolt into Bear Creek. The returning adult cohos are the prized target species of Seward’s Silver Salmon Derby.”

But those fish don’t come free.

‘When (Seward Salmon) derby anglers bring their salmon back to the derby weigh-in station,” according to CIAA, “they are given the option of donating or buying back their salmon for $5 a fish. The donated salmon are sold to a local fish processor and all the money collected through the buy-backs and donations is used for the Seward Chamber of Commerce Salmon Restoration Fund.

“This fund helps to pay for Cook Inlet Aquaculture Association for the raising of silver (coho) salmon,” as in pay CIAA to raise the fish. In fiscal year 2024, records indicate, the state paid CIAA another $68,243 to rehabilitate and enhance salmon fisheries for non-commercial fishermen.

The Kenai Peninsula community of Homer has had to come up with funds to pay CIAA to keep producing salmon for part of a project begun by the state to create a king (Chinook) salmon tourist attraction on the Homer Spit. 

State records indicate Fish and Game in fiscal year 2024 paid the five commercial-fishermen associations protesting the environmental rules more than $2.3 million, mainly to raise fish for non-commercial fishermen. Another more than $468,000 went to Douglas Island Pink and Chum, a Juneau-based private business the state allowed to take over its Snettisham hatchery.

The Sport Fish Division has admitted to “working with hatchery operators to collaboratively fund enhancement opportunities for sport anglers – mostly for king salmon, but also some coho salmon and trout. The sources of the funds have varied over the years, but include: angler license revenues (Fish and Game funds); Sport Fish Restoration funds (Dingell-Johnson); Pacific Coastal Salmon Recovery Act funds (AKSSF); and most recently, the Sport Fish Enterprise Account funds generated by the sport fishing license surcharge approved by the Alaska Legislature under SB147 in 2005.”

The Dingell-Johnson funds come from an unnoticed, 10 percent, federal excise taxes anglers across the country pay when they buy fishing gear. This tax is then shared with the states, which must raise a 25 percent match to collect their share. Alaska, which gets about $20 million per year from the fund, is the biggest beneficiary of the money and generally provides the match by using the revenue generated by sales of non-resident fishing licenses.

Outside sport fishermen thus end up being among those helping to subsidize the operation of hatcheries producing salmon for Alaska’s commercial fishermen as do U.S. taxpayers. The state’s Department of Commerce, Community and Economic Development reported passing through to the hatcheries another approximately $8 million in taxes collected from commercial salmon fishermen, some of whom benefit from the hatcheries and some who don’t, bringing the entire state support to the hatcheries to more than $10.3 million.

We’re special

These are the hatcheries now say it would be too costly to monitor the seabed beneath their net pens for pollution and arguing that they shouldn’t be required to do so because state water quality standards (WQS) only ban “deposition that interferes with the protected use of the bottom.

“It is apparent that the WQS does, indeed, tolerate de minimis or transient deposition, so long as it does not make the water (or seafloor) unfit or unsafe for the protected use,” they argue.

Doig labeled that a “straw man argument,” and noted that state regulations specifically spell out the requirement that “human activities…may not, alone or in combination with other substances, cause a film, sheen, or discoloration on the surface of the water or adjoining shorelines; cause leaching of toxic or deleterious substances; or cause a sludge, solid, or emulsion to be deposited beneath or upon the surface of the water, within
the water column, on the bottom, or upon adjoining shorelines.”

The documents filed in the case to date do not get into the issue of where net pens are sited in Alaska, but many appear to be at the heads of bays where tidal flushing of waste is the least.

Leroy Seafoods, one of Norway’s largest salmon-farming companies, is now experimenting with sludge collection systems on some of its farms because of problems with waste in these situations.

“The natural ecosystem on the seabed benefits from a little discharge of organic materials from the cages; it acts as fertilizer,” the company says on its website. “The problem arises when the amount of sludge exceeds nature’s own tolerance, which can happen in threshold fjords with low oxygen levels.”

In such situations, Leroy says, “the sludge from the fish is collected in a fine-mesh groove installed at the bottom of the cage. It is then pumped up through a filtration system and into a tank located on the surface. The sludge is then transported away from the facilities in boats. The sludge is then converted into biogas.”

Salmon-farm sludge is one of the problems that have led some environmentalists to attack the business of salmon farming for years.

“In the industrial-scale farms in coves and bays off the coasts of Norway, Scotland, Chile, and Canada, the only barrier between the cages that harbor millions of salmon and the environment is a net that allows the ocean to flush the pens. Excess feed, chemical residue, and fecal matter form a layer of slime on the seabed below the farms, smothering marine life and plants,” the authors of  Salmon Wars: The Dark Underbelly of Our Favorite Fish reported in Natural History magazine in 2022.

“Sewage and other waste cause far-reaching damage to the environment, contaminating the seabed and nearby marine life,” reported Douglas Frantz and Catherine Collins. “A city must treat its sewage, but the farms dump the excrement and excess feed on the seabed. Waste beneath farms turns the ocean floor toxic, consuming oxygen needed by marine life and dispersing contaminants through the water. A 2014 study in Scotland found a reduction in biodiversity up to two hundred yards away from salmon cages; other studies described wider impacts on marine life and wild salmon.”

Somehow, however, Alaska’s hatcheries have long escaped the wrath of environmentalists opposed to salmon farming, apparently because of the state’s 1990 declaration that it had banned net-pen farming in the style of Norway, Chile, Scotland and other countries; partly because Alaska has always pitched its ocean-farming business as “ranching” as if this were somehow different than farming; and partly because major environmental groups have wanted the support of Alaska’s commercial fishermen when trying to block development projects, most notably those involving mining or oil and gas.

The latter have ignored hatchery issues despite the fact the state has flooded the ocean pastures with pink and chum salmon, as if those pastures were limitless, without a single environmental impact statement ever being written to attempt to ascertain what this manmade boosting of pink and chum salmon might do to other species of salmon such as – sockeye, coho and giant Chinook salmon – that compete with pinks and chums for food.

There is increasing evidence that the hatchery fish reduce returns of those salmon. Scientists involved in the latest research concluded that ” in the present era hatchery releases represent a classic ‘zero-sum’ game.”

Hatchery releases, they said, now result “in some loss of growth and productivity of wild salmon through increased competition at sea.”

In January, the Seattle-area-based Wild Fish Conservancy, a smallish environmental group, cited this problem in a petition to the U.S. federal government asking that it list Alaska Chinooks as a threatened species under the terms of the Endangered Species Act.

“The major causes of the region-wide declines in Chinook productivity and abundance are predominately due to factors in the marine rearing and migratory environment. Global warming and climate change along with massive releases of hatchery pink and chum salmon from Japan, Russia, and Alaska adversely impact marine food webs,” the organization claims.

Fish and Game, which has for more than 50 years been a big backer of industrial-scale ocean farming to produce revenue for commercial fishermen and salmon processors, has so far refused to admit that this could even be a possibility. But its sister agency, DEC, now appears committed to taking on at least some of the environmental problems connected to hatcheries.

55. ADEC, Division of Water’s Response Brief