CAFOs of the Sea

Last week EPA finalized its NPDES effluent limitations guidelines and standards rule governing wastewater discharges from Concentrated Animal Feeding Operations (CAFOs). The rule was originally finalized in 2003, was challenged by environmentalists, and portions of it were set aside by the Second Circuit in Waterkeeper Alliance et al. v. EPA, 399 F.3d 486 in 2005. EPA made changes to address the issues that were vacated or remanded by the Court, and last week's final rule is the result.

This article on salmon farming brought to mind that rule. Although salmon farms are not CAFOs, they are attempts to produce healthy protein in a cost-efficient manner, like terrestrial CAFOs. The article, and some of the commenters, point out some of the problems that are posed by large-scale farming operations - the concentration of pollution, the use of antibiotics, and the possibility of disease spreading to wild stocks. There is a place for the government to step in and regulate these concerns. But these problems should be weighed against the growing demand for fish protein, and the likelihood that commercial fishing has almost depleted tuna and other high-end fish stocks. Large scale farming, properly regulated, is a middle course that can relieve some pressure on wild stocks until they can rebound.