The 350 Humboldt general meeting for July will focus on organizing our response to the Nordic Aquafarm conditional use permit hearing at the Planning Commission on July 28. We meet Thursday (tomorrow, the 21st) at 6 PM on Zoom: https://us02web.zoom.us/j/82309119608?pwd=NmRBVjVWM1hEUHRhNEdMc3ZhSTRrQT09

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Also on the agenda for the meeting is a presentation by EPIC intern Juan Giovanni Guerrero.

Below is a draft of the formal letter we will send the Planning Commission.  We need to decide on the specific requests we are making and organize volunteers to speak live or on zoom at the meeting on the 28th. Please take a few minutes to read the letter before the meeting.

Thanks!

Steering Committee: Diane Ryerson, Laura Simpson, Dan Chandler


Nordic Aquafarm Issues Remaining After the Final EIR

Will the Nordic Aquafarm aggravate the climate crisis or help reduce greenhouse gases?

a.     Common sense perspective: Humboldt County faces sea level rise, drought, and wildfires and numerous smaller impacts. As the Climate Action Plan and the state law says, we need to decrease emissions by at least 40% by 2030.

b.     Scientific perspective:

i.     The Paris Accord committed us to trying to keep global warming to no more than 1.5°C. It is at 1.1°C now and the IPCC projects that we have to reduce emissions by 50% by around 2030 to have a chance

ii.     Going over 1.5°C is likely to let loose a series of tipping points that make it impossible to control global warming

iii.     The United States alone has contributed 20% of all greenhouse gas emissions. We are the second largest emitter still today. California is the second largest state emitter.[1]  If the world is going to meet the overall 50% reduction, the US and California are going to have to do more than 50%.

c.     So the crucial question is whether the Nordic Aquafarm will contribute to the problem or help solve it. As we will see, the Nordic facility will be adding large amounts of greenhouse gases not included in the final EIR, rather than helping reduce the 50+ percent needed in the next 10 years and 100% by 2050.

Overall role of land-based aquaculture in a warming world

a.     Aquaculture has many pluses. If done correctly it doesn’t deplete the world’s fisheries and it produces much less greenhouse gases than most sources of food protein.

b.     However, the advantages depend on the fish being farmed and the fish feed being used.

Because salmon is a predator fish it must be fed at least as much fish in its feed as is produced. This is called the Fish In Fish Out ratio. This ration has dropped over the last ten years, but basically it is now 1 kg of other fish must be put in fish feed to produce 1 kg of salmon. The fish that go into salmon feed are “forage” fish that predators eat, such as sardines and anchovies. These are fish that can be and are eaten in areas where they are caught, such as off the coast of Africa. So poor countries, some of which are already facing food shortages, have their fish fed to Atlantic salmon that are sold to upper middle class people in developed countries in violation of economic and climate justice. This makes it hard to say that the benefits of a land-based Atlantic salmon aquafarm outweigh the disadvantages, considered globally.

c.     We know that the advantage Nordic claimed, that it would reduce greenhouse gases by replacing salmon air shipped from Norway or Chile with local salmon, is not true. This is both because the amounts of air shipped salmon are much less than what Nordic will produce and because anything not sold in this market will be flown to another.[2]  Reference to this supposed savings has been dropped from the final EIR in recognition of the error.

The global warming effect of fish feed

a.     Fish food is viewed by virtually all fish biologists as a major source of greenhouse gas emissions. Using data from many different scientific studies that estimate the CO2 equivalent emitted by fish food for Atlantic Salmon, the average emissions at the Nordic aquafarm are likely to be 150,000 metric tons per year, at least six times the amount needed to meet a threshold of environmental significance under CEQA.[3] What we did not know when we summarized these scientific studies is how much the industry as whole has adopted the scientific methods used in these studies.

b.     The major organization responsible for certifying quality in the land-based growth of Atlantic Salmon, the Aquaculture Stewardship Council (ASC), includes greenhouse gases as part of their certification and requires each aquafarm farm to do a greenhouse gas inventory each year, which includes the greenhouse gases attributable to the fish food consumed. It also requires fish feed manufacturers to state on their product the greenhouse gases released in their manufacture. Here is the ASC statement to this effect as it applies to aquafarms such as the facility Nordic seeks to permit:[4]

GHG accounting for feed –
[R]equires the calculation of the GHG emissions for the feed used during the prior production cycle at the grow-out site undergoing certification. This calculation requires farms to multiply the GHG emissions per unit of feed, provided to them by the feed manufacturer, by the amount of feed used on the farm during the production cycle. The feed manufacturer is responsible for calculating GHG emissions per unit feed….
The scope of the study [by feed manufacturers] to determine GHG emissions should include the growing, harvesting, processing and transportation of raw materials (vegetable and marine raw materials) to the feed mill and processing at feed mill. Vitamins and trace elements can be excluded from the analysis. The method of allocation of GHG emissions linked to by-products must be specified. The study to determine GHG emissions can follow one of the following methodological approaches:

1. A cradle-to-gate assessment, taking into account upstream inputs and the feed manufacturing process, according to the GHG Product Standard

2. A Life Cycle Analysis following the ISO 14040 and 14044 requirements for life cycle assessments.”

These are the same methods used by the scientists we cited in our DEIR comments.

c.     One of the three biggest fish feed manufacturers, Cargill, notes that fish farming contributes 250 million metric tons of CO2e per year, and salmon contributes 10 million metric tons of CO2e per year. Cargill says: “Feed contributes significantly to the carbon footprint of seafood farming, and feed producers hold the key to achieving large emissions reductions throughout the value chain. Using that key to its full effect depends on seafood farmers and retailers sharing the same drive for sustainability.”[5]

d.     To summarize:  ASC, the certification agency, requires food manufacturers to calculate GHG emission using the methods fish biologists do; and ASC requires the aquafarms themselves to count these feed emissions in the GHG emissions inventory they are required to report to ASC. So all three components of the industry are on the same page with how to calculate greenhouse gases from fish food. Nordic will be reporting every year to the ASC the greenhouse gases attributable to their fish feed. Yet, at the same time the FEIR argues that none of those greenhouse gases should count in the CEQA analysis! So everyone except the people who prepared the FEIR buys into the idea that greenhouse gases from fish foods have to be calculated and reported using a life cycle or carbon footprint method. Why is this?

e.     The difference is that the FEIR says only greenhouse gases produced in California count, and the life cycle method used by scientists and the aquaculture industry is “not commonly” used in CEQA analyses. We agree that CEQA does not require this method but it does not preclude it, and all parties agree that with respect to aquaculture it is appropriate and it is required by the certification Nordic touts. After all, greenhouse gas emissions are a global problem; they don’t just affect California as the FEIR argument implies. So the FEIR should  be changed to require mitigation of fish feed greenhouse gases.

f.      We used the “sustainability reports” that fish food manufacturers Skretting[6] and Cargill[7] produce annually  to calculate what the Nordic aquafarm greenhouse gas emissions would be. On their website, Skretting lists the values for the tons of CO2e per ton of feed in their four Canadian and four Norwegian factories: they range from 2.05 at a minimum to 5.28 for the maximum (t CO2e/t feed).[8] Cargill, instead of providing figures for different factories, provides an average for salmon fish food of 2.67t CO2e/t of feed.[9] We can calculate the greenhouse gas emissions if we know how much fish food will be used. The Staff Report to the Planning Commission says: “At full scale operations, NAFC expects to use approximately 36,300 metric tons of feed per year.” To get the range of fish feed greenhouse gases attributable to Nordic at full build-out using Skretting’s data, we multiply respectively the 2.05 and the 5.28 of CO2e t/t of fish food by the 36,300 tons of fish food. For the low figure it is 74,415 and for the high figure it is 191,664. For Cargill’s factory average it is 2.67 * 36,300 or 96,921 metric tons of greenhouse gases per year.

g.     These are huge figures. For illustration, California’s cap and trade program applies if a source emits 25,000 metric tons of CO2e a year.

Refrigerants

a.     Here is why refrigerants are important: They warm the atmosphere from a few hundred times more than CO2 itself to thousands of times more.

b.     Nordic plans to use 25% of their electric power (which in total is equal to all that used by Eureka and Fortuna combined) for refrigeration.[10] They will use refrigerants to make the ice that they pack the fish in for shipping, and they will use refrigerants in “chillers” that will keep the water cool enough for the fish. The DEIR also says: “Use of water to water-heat exchangers and heat pumps will be maximized to reduce energy demands.” Heat pumps also use refrigerants.

c.     They say they will follow all laws and regulations and will have full time staff working on the cooling systems. However, they say they cannot specify the actual refrigerants and the global warming potential of them because their design team hasn’t designed the system. In short, instead of describing the potential greenhouse gas emissions from refrigerants they say they don’t know what they are, but offer up as mitigating circumstances that they will follow the law. Is there any other source of greenhouse gas emissions that this would be an acceptable answer for? Suppose they said, we don’t know how much electricity we will use but we’ll follow all applicable laws and regulations. Would that be acceptable?

d.     In emails to Marianne Naess we asked that Nordic commit to using natural refrigerants. These are refrigerants that have a minimal effect on the climate. There is refrigeration equipment that uses natural refrigerants for chillers and virtually every other heating or cooling use. They refused to commit to this.

e.     We asked for information that would allow us to judge how much refrigerants with a high global warming potential  they will use (the law in 2025 will allow them to use HFC refrigerants with up to 2,200 times more global warming potential than CO2). Namely, what do they use in their Norwegian factory? They refused.

f.      We have calculated how much greenhouse gas emissions there might be based on adapting data from other uses and information on leaks from chillers. Our detailed methodology is in the Appendix. It comes out to 6,224 metric tons a year. Over thirty years that would be 186,720 metric tons of CO2.

g.     Refrigerants is an area that can go drastically wrong. The following quotation is from the shareholder statement of Atlantic Sapphire’s facility in Florida:

“The increase [in costs] is mainly explained by the $11 million in temporary chiller and generator rental costs  in the U.S. following the breakdown of the chiller plant…in Q1 2021.”

h.     Chillers is another element that have never been proved to work in aquaculture even at a scale of less than half what Nordic proposes.

In summary, the EIR does not meet the legal requirement to identify and describe the potentially significant impacts of refrigerants and Nordic has refused to adopt the mitigation measure of using very low global warming potential refrigerants, which are readily available.

Sources of greenhouse gases from electric power.

a.     Nordic has committed to either buy its electricity from RCEA or buying renewable or low carbon electricity from another provider, presumably a solar provider outside the county. As a result the final EIR incorrectly states: “A more appropriate carbon intensity factor would be zero pounds of carbon dioxide equivalent per megawatt hour (0 lbs. CO2e/MWh).”

b.     We are very appreciative that Nordic has decided to go with renewable energy. However there are two sources of greenhouse gas emissions that will still exist – it will not be zero emissions from power.

i.     First, all forms of energy emit some greenhouse gases, including solar and wind. For solar, for example, the electricity is generated by the sun activating two layers of silicon semiconductor chips.[11] Carbon is emitted in the manufacturing process, in operation and in decommissioning and recycling. The National Renewable Energy Laboratory recently reviewed 400 estimates of the carbon footprint of solar and came up with 45 grams of CO2 per kilowatt hour. This compares to 450 for natural gas, so it is ten times less. However, Nordic will be using 195 gigawatt hours of electricity. A gigawatt hour is one million kilowatt hours. The CO2 emitted by one gigawatt hour is 45 million grams or 45 metric tons (since there are a million grams in a metric ton). We multiply the 45 metric tons by 195 and get an annual emission of 8,775 metric tons of CO2e – not zero.

ii.     The second source is due to the intermittency of renewable power. Even if one buys 195,000 gigawatt hours of solar, that doesn’t mean that 24/7 the Nordic facility will be powered by solar.[12]“24/7 Carbon-free Energy (CFE) means that every kilowatt-hour of electricity consumption is met with carbon-free electricity sources, every hour of every day, everywhere.”[13] The United Nations has a 24/7 Energy Compact that lays out the principles of such energy systems. Microsoft and Google are two of the firms that have signed on. We can get an idea of the extent to which 24/7 is going to be available in northern California by using the figure for Google’s Oregon operations: 88% of their energy will be 24/7 carbon free energy.[14] This is among the highest in the many places where Google operates facilities, for example it will only be 21% in Nevada and 40% in Texas. So if we apply the 88% to what is available for Nordic and assume the other 12% is made up of power from the Humboldt Generating station, in 2030 the actual greenhouse gas emissions from times when renewables are not available will be 12% of 195 gigawatt hours or 23.4 gigawatt hours.  Since gas emits 450 metric tons (NREL intensity of natural gas) per gigawatt hour, the total will be: 10,450 metric tons of CO2e in a year.[15]

iii.     So rather than zero the actual amount of CO2e released in 2030 from energy usage will be 19,305 metric tons. Some of this will decline over time as the 24/7 percentage increases.

What could go wrong?

c.     The Nordic information has focused on stability and sustainability but there is actually a lot that can go wrong. In the past the county has gotten stuck for corporate failures. The land the aquafarm would go on is poisoned by many years of pulp mill pollution which the county did not adequately regulate or require be cleaned up.

d.     The Nordic facility is experimental. It is approximately 17 times the size of the Norwegian plant the company runs (1,500 metric tons vs 25,000 metric tons of fish product) so there is actually not much assurance to be found in their prior experience.

e.     The largest operating Atlantic Salmon aquafarm today is that of Atlantic Sapphire in Florida. It is only 40 percent of the size of the facility planned for Humboldt. In the last year it had a fish die off of 500,000 fish. It had a refrigeration failure so that they are now using rented chillers at a cost of $11 million a year. And there was a fire at its Norwegian plant that destroyed most of the facility. So there is a lot that can go wrong. It lost $121 million in 2021. It’s CEO was quoted as saying: Atlantic Sapphire had a 121 million dollar loss in 2021. The CEO offered this advice to a Maine RAS facility that is just starting up: “”Don’t underestimate the task. It’s very complicated and takes a lot of time.”[16]

f.      On an aquaculture pod cast, in the context of the die-off, Brian Vinci, director of a non-profit called The Freshwater Institute—which supports sustainable aquaculture — said the following about Atlantic Sapphire: “It’s clear to me that scale is a huge issue and a challenge they have had to face. Johann (the CEO) was on the news media recently warning that there are massive challenges with growing Atlantic Salmon at scale. Although we at Freshwater Institute proved out land-based salmon from egg to grow-out back in 2008, we were only doing it at a small scale of 20 tons per year head and gutted. What’s going on at Sapphire at 10,000 tons is just another beast entirely.” [17]

g.     The founding CEO of Nordic, Erik Heim, met with a group of environmentalists. When asked about the problems of other companies he said, “We never had any of those problems in our Norwegian facility.” However, that facility, besides being only 1/16th  the size of the Humboldt plan, has only been in operation a short time. In 2021 the firm reported: “Fredrikstad Seafoods has successfully harvested salmon on a weekly basis for almost a year now.”

h.     However, Nordic has already had two organizational difficulties, though neither involved fish die offs, fires, or refrigeration breakdowns:

i.     Erik Heim, the founder of Nordic, and his wife Marianne Naess who was the public face of Nordic here in Humboldt quit in June with no explanation

ii.     In April the Nordic corporation was split in half, with one corporation now owning the Norwegian and Danish factories, and the unbuilt American factories being in another separate corporation. Also in April, the company decided to convert the Atlantic Salmon factory in Norway to Yellowtail Kingfish.[18]

iii.     This does not sound like a stable business we can count on for over 30 years.

i.      In effect, Humboldt County is an investor in Nordic. But here is what an investment advisor for aquaculture says: “They aren’t asking the basic question: ‘Has your pilot facility performed according to your target bio-plan with three continuous cohorts? Is it a spreadsheet bio-plan or is it based on science or actual results? If you can’t do it at a pilot scale, how do you propose to do it at large scale?”[19] Nordic only did it for one cohort before switching away from Atlantic Salmon,[20] so it does not meet this basic standard.

j.      What happens if offshore wind doesn’t come through? We certainly hope it will, but if it doesn’t Humboldt County is left with a factory using as much electricity a year as Eureka and Fortuna combined. Nordic has committed to clean electricity, but if the wind farm falls through where would it come from? We will only get upgraded transmission lines if the wind farm goes through. The electricity Nordic uses will be needed for the conversion of our transportation and housing to electricity so that we can do our share of reducing greenhouse gas emissions.

k.     There are actually many specific things that can go wrong. Comments on the draft EIR spelled them out. A small number of them is listed below. The FEIR assured us all was taken care of. Experience in the aquaculture industry leads us to doubt that these paper guarantees can be counted on.

·      Contamination of the fish eggs with viruses

·      Viruses in the effluent

·      Antibiotic resistant bacteria from fish feed associated with aquafarming

·      Uncontrolled algae growth where the effluent is sent out into the ocean (no studies were conducted there)

·      Hazards in case of a 9.5 earthquake or a tsunami

·      “Impingement” of juvenile salmonids on the bay intake systems

Transportation

The EIR estimates 2,268,907 VMT, most of which is driving loaded trucks. The EIR estimates these trips to emit 2,371 metric tons of CO2e. The modeling tool did not include important variables, particularly the tonnage expressed in “ton-miles” as is usual. The EPA publishes a calculator that could be used for this purpose.[21]

What we ask for

a.     The final EIR should be redone to meet legal requirements and recirculated. It should include all of the above sources of greenhouse gas that it omitted, especially the greenhouse gas emissions that Nordic will be certifying to the ASC each year.

b.     All greenhouse gas emissions should be offset by purchase of offset credits from the Yurok tribe. Offsets are widely used, for example by airlines, when greenhouse gas emissions cross state or national borders. Offsets can also be directly proportionate to the emissions. It will take several years for the facility to reach full production, so offsets for fish food or energy usage should be calibrated to the actual emissions.

c.     The EIR must either specify the refrigerant leakage and offset it or Nordic must commit to using ultra-low (<10 GWP) refrigerants. If the design really can’t be done until after certification we request “adaptive management” for the heating/cooling system.

d.     The conditional use permit should specify that all hauling out of county be done using electric or hydrogen powered trucks.

e.     Because of the currently unmitigated emissions attributable to Nordic’s electricity use (due to emissions from renewable energy sources and to intermittency), Nordic should install solar microgrids to equal their unmitigated energy. These would be installed at at hospitals, fire houses, community centers, schools, assisted living and nursing homes, waste treatment plants, and water districts. EV chargers would be another community benefit that would mitigate this unmitigated electricity use.

f.      Nordic must put up a $500 million dollar bond to ensure that the county, its taxpayers, and its wildlife are not left holding the bag if any of the many things that could go wrong do so.

 

[1] Our World in Data. https://ourworldindata.org/co2-emissions. US historical contribution from: David Wallace-Wells, May 24: https://messaging-custom-newsletters.nytimes.com/template/oakv2?productCode=DWW&te=1&nl=david-wallace-wells&emc=edit_dww_20220524&uri=nyt://newsletter/71f82874-6fe2-5287-932f-f921132e7f0b  World Resources Institute. https://www.wri.org/insights/8-charts-understand-us-state-greenhouse-gas-emissions California’s own methdology differs. These data use an EPA methodology that offers comparability across states

[2] See the joint response to the DEIR by several environmental organizations, which were not addressed in the FEIR

[3] A number of these studies were cited in detail in our joint response to the DEIR

[4] https://www.asc-aqua.org/wp-content/uploads/2019/12/ASC-Salmon-Standard_v1.3_Final.pdf

[5] https://www.cargill.com/doc/1432196768685/cargill-aqua-nutrition-sustainability-report-2020.pdf

[6] https://www.cargill.com/doc/1432196768685/cargill-aqua-nutrition-sustainability-report-2020.pdf;https://www.skretting.com/en/sustainability/sustainability-reporting/sustainability-report-2020/

[7] https://www.skretting.com/en/sustainability/sustainability-reporting/sustainability-report-2020/climate–circularity/the-carbon-footprint-of-feed/

[8] https://www.skretting.com/en/sustainability/sustainability-reporting/sustainability-report-2020/climate–circularity/the-carbon-footprint-of-feed/

[9] https://www.cargill.com/doc/1432196768685/cargill-aqua-nutrition-sustainability-report-2020.pdf

[10] See the graph on page 3.5-4 of the DEIR

[11] https://www.energy.gov/eere/solar/solar-photovoltaic-cell-basics

[12] A very understandable explanation of this issue has been written by David Roberts at: https://www.canarymedia.com/articles/clean-energy/google-and-others-have-committed-to-24-7-carbon-free-energy-what-does-that-mean

[13] UN 24/7 Carbon Free Energy Compact. https://www.un.org/en/energy-compacts/page/compact-247-carbon-free-energy

[14] https://sustainability.google/progress/energy/

[15] This is a very conservative figure since it is unlikely RCEA will be close to 88% for some time.Although RCEA has no specific plans to deliver 24/7 carbon free power (private communication), Penninsula Clean Energy does. They purchase as much renewable energy as their consumers use, but fall short of 24/7 matching. On their website, they have an excellent description of why this is important; it includes a graph showing how much of the time there is a mismatch between demand and the renewable supply. https://www.peninsulacleanenergy.com/our-path-to-24-7-renewable-power-by-2025/ Here is a summary of how different their electricity is depending on using annual accounting vs. 24/7 accounting:

[16] https://www.intrafish.com/aquaculture/atlantic-sapphire-ceos-advice-to-land-based-rival-dont-underestimate-scale-of-the-task/2-1-1197991

[17] The Freshwater Institute, a program of The Conservation Fund, focuses on the sustainability of the domestic seafood supply by providing solutions to enable the growth of environmentally-responsible aquaculture. Vinci’s statement is on a recording is available at https://www.rastechmagazine.com/ras-talk-hard-path-to-innovation-with-johan-andreassen-of-atlantic-sapphire/, starting at 1 minute 35 seconds.

[18] https://www.intrafish.com/aquaculture/nordic-aquafarms-confident-on-land-based-kingfish-salmon-farming-permits/2-1-1246458

[19] https://www.intrafish.com/finance/the-biggest-land-based-salmon-skeptics-companies-actually-producing-salmon-on-land/2-1-986934

[20] https://www.nordicaquafarms.com/fredrikstad-seafoods-strong-biological-performance-from-the-first-generations-of-land-raised-salmon/

[21] https://nepis.epa.gov/Exe/ZyPDF.cgi/P1013TIJ.PDF?Dockey=P1013TIJ.PDF