In an article in the September 1997, Mr. RJ Nolan writes that a shrimp aquaculture project in the Rufiji Delta area of Tanzania is "eco-friendly" since it:

1. will be situated behind the mangroves on salt flats,
2. is an area local people do not use for traditional gathering of wood, hunting, and fishing,
3. has given a commitment to the local community of no loss of mangrove or displacement of people due to the project,
4. will be using semi-intensive methods,
5. will bring benefits to the people of Tanzania,
6. will follow the "Guidelines on Sustainable Development in Aquaculture" as presented to the United Nations Commission on Sustainable Aquaculture by various NGOs in 1996.

States Mr. Nolan, "Environmentalists do not have the monopoly on caring for the planet and we are confident that this project will bring employment and social development to the area without harming it's unique environment."

RJ Nolan, Chair, African Fishing Company, Dar-es-Salaam, Tanzania.

ITEM # 2

On November 26, 1997, Yoshi Hirono, a shrimp farming consultant and general manager of the African Fishing Company’s shrimp farming project in Tanzania, reported:
 
On 19th of November the Cabinet of the Tanzanian Government met and unanimously voted to support the Integrated Prawn Project without any conditions except the monitoring program organized by the environmental gurus. The Integrated Prawn Project was approved to develop 6,000 hectares growout ponds and a hatchery on Bwejuu Island, as described in the environmental impact assessment.

We did what it took to convey to relevant ministries that the sustainable prawn aquaculture could be undetaken in Tanzania.  The Government of Tanzania was set back by malicious critics from environmental organizations and some NGOs.  In spite of strong opposition from the donor countries against our project, the Government made a historical but wise and gutsy decision.  According to our PR officer, we have to wait for the official letter of the decision to approve the project by the Cabinet from the Ministry of Natural Resources and Tourism before proceeding with further surveys and investigations.

The first major obstacle was cleared.  Now it is essential to set up orderly preparation of the project to minimize the lost time.

Information: Yosuke Hirono, Manager, Tannol Holdings, Ltd., NIC Building, 14th Floor, Samora Avenue, Dar Es Salaam, Tanzania, (phone 255-51-44889, fax 255-51-44622, email tannol@twiga.com).
 
 Background
 
On October 9, 1997, Yosuke Hirono, general manager of the African Fishing Company’s (AFC) integrated shrimp farming project in Tanzania, reported: “With regard to the African Fishing Company’s integrated shrimp project, we face strong opposition from international environmental groups and various international nongovernment organizations (NGOs), but the strongest opposition often comes from some of the donor countries.  In July 1996, the Management Council discussed the project, but the developer was not allowed to participate. Consequently, in November 1996, the developer held a forum to explain the project to government officials and NGOs, and he submitted a complete environmental impact assessment, compiled by internationally recognized aquaculture experts and ten local experts, to the government.  The developer
is still waiting for approval from the Government of Tanzania.

The proposed project is located in the Rufiji Delta (100 kilometers south of Dar es Salaam) and ponds will be constructed beyond the mangroves. It’s a semi-intensive project designed to be environmentally friendly and socially responsible.  It will include a hatchery and maturation facility, 6,000 hectares of growout ponds, a processing plant and feed mill.  The feed mill
will not be constructed immediately, so feeds will have to be imported. Indigenous monodon will be stocked at the rate of 10 postlarvae per square meter.  After completion in 8 years, the project projects exports of $200 to $300 million a year.  The project will employ more than 6,000 people.

Transmitted by Mr. Bob Rosenberry, 10 December 1997 to "Ocean Farmers of America" Discussion List

Response by Mangrove Action Project, 12 December 1997  (Alfredo Quarto, Co-Director, Mangrove Action Project)
 

    I would like to comment on the recent announcement of the decision by the Tanzanian government to approve the large shrimp farm development on the Rufiji Delta. I will comment on a few points made in this announcement:

1. "The proposed project is located in the Rufiji Delta (100 kilometers south of Dar es Salaam) and ponds will be constructed beyond the mangroves. It's a semi-intensive project designed to be environmentally friendly and socially responsible.

Comment: What we design "to be" may not "be" in actuality! How can the proponents of this project ensure in Tanzania what has not worked elsewhere? The track record for the shrimp aquaculture industry elsewhere is not something to be proud of, and is definitely not reassuring! Without strict guidelines and constraints firmly in place and enforceable, how will this quality control be sustained? Will the important concept of the "ecological footprint" be incorporated in this project from start to finish? Who will do the actual monitoring and regulating of this new project? And what of new, unplanned for shrimp aquaculture projects which will inevitably follow?

2. "Tanzania does not have guidelines for the aquaculture industry and, consequently, in their absence AFC took the precaution of following the Guidelines on Sustainable Development in Aquaculture as presented to the United Nations Commission on Sustainable Aquaculture by various non-government organizations in 1996.

Comment: The admission that Tanzania does not have guideines for aquaculture industry is clearly stating an obvious fault in the regulatory system necessary to properly direct and regulate the industry. Who will enforce regulations that do not yet exist? And who will ensure that those regulations, once drawn up, are enforced, when this seldom happens elsewhere in other
nations which do have regulatory bodies in place? Concerning the NGO guidelines, I personally took part in this meeting of NGOs referred to here, and I can assure you that this project does not adhere to those guidelines we drew up in New York at the UN CSD meeting. I list these guidelines below for your reference, and point out here some examples of non-conformance to these stated principles:
 
NGO Statement Concerning Unsustainable Aquaculture To The United Nations Commission On Sustainable Development, May 1996

    In recent years, aquaculture development has been repeatedly promoted as a solution to meet growing world food needs from fish.  Traditional forms of aquaculture can and have made substantial contributions to food supplies in areas of the world where food needs are most acute.  However, recent patterns of aquaculture development have emphasized the production of high value species for export markets.  In particular, the rapid development and expansion of intensive aquaculture for shrimp has resulted in widespread degradation of the environment, displacement of coastal fishing and farm communities, and a negative impact on local food supplies and food security.

Comment: Has this global industry history really been taken into account in the design and planned implementation of this massive 6000 ha project?

    The FAO Code of Conduct for Responsible Fisheries in Article 9 urges responsible aquaculture development.  National and regional implementation of the FAO Code, the Convention on Biological Diversity and other existing laws and policies, must be pursued in a manner which ensures that unsustainable aquaculture is prohibited before there is irreversible damage, loss of
 biodiversity, or harm to coastal communities.

     The undersigned Non-governmental Organizations (NGOs) urge governments to agree to:
 
 1. Ensure that artisanal fisheries and dependent coastal communities, and their access to community resources, are not adversely affected by aquaculture development or operations, including extensive and semi-intensive as well as
 intensive aquaculture methods.

Comment: What assurance can the developers give that the pond effluents emmanating from this large industrial operation will not [enter] with sea water in the ponds? If so, how will this affect the fresh water supplies? What is the rate of water exchange during operation? These are just some of the important factors needing careful considration to ensure environmental sustainability.

2. Ensure the use of environmental and social impact statements prior to aquaculture development and the regular and continuous monitoring of the environmental and social impacts of aquaculture operations.

COMMENT: Who will do this monitoring and then who will act on the recommendations made by this monitoring process? Also, an independent environmental impact assessment should not involve the interested investor, but should be done independent of that investor.

3. Ensure the protection of mangrove forests, wetlands, and other ecologicallysensitive areas.

Comment: Again, even if these ponds are placed beyond the actual mangrove forest, can it be asssured that no harmful effects will follow?  For instance, when ponds are built in such a way that natural patterns of fresh water flow are disturbed or diverted, this can cause problems for the affected mangroves. These natural aquifers and streams help provide replenishing nutrients and
mineral deposits important for a healthy mangrove ecosystem. How much fresh water will be required from a 6000 ha operation? How much pesticide, antibiotics and other regularly used pond chemicals will find their way out of the ponds and into the nearby mangrove forest? Is this healthy for the mangrove forest in the long run?

4. Prohibit the use of toxic and bioaccumulative compounds in aquaculture operations.

Comment: Is this principle going to be adhered to? Will the developers use no chemicals such as pesticides in the pond water, no antibiotics or medicines in the feeds? After all, this type of regular chemical input is "usual farm practice."

5. Apply the precautionary approach to aquaculture development.

Comment: I would venture to suggest that the application of this precautionary approach in Rufiji Delta would have to entail building much smaller shrimp farm operation, for isn't it a bit overzealous to aim at a 6000 ha farm as a beginning venture in a place where even small-scale shrimp farms have not previously existed? When one gambles on a so-called "sure bet,"  the
gambler might be tempted to bet with high stakes, but this itself violates the precautionary principle. Why not at first attempt to run a one or two hectare farm, just to work out the unforseen bugs? The sheer size and scope of this project throws such precaution to the vagrant winds of an errant gambler.

6.  Prohibit the pollution of surrounding areas resulting from the excessive discharge of organic wastes.

Comment: Again, how is this being assured? What amount of effluent will be involved, and what type of waste discharge will occur? Elsewhere in the world of industrial shrimp farming, large-scale operations produce massive amounts of pollution.

7.  Prohibit the development and use of genetically modified organisms.

 8.  Prohibit the use of exotic/alien species.

 9.  Prohibit the use or salinization of fresh water supplies, including groundwater, important for drinking or agriculture.

Comment: How will this be assured? Will there be any use of ground water or nearby stream water? What will happen to the salt water content of the effluent? Will it all be safely deposited at sea, or will some leach into the adjacent lands? How will these ponds affect nearby agriculture if any exists in the area?

10. Prohibit use of feeds in aquaculture operations consisting of fish that can be consumed by people.

Comment: The developer states that at first imported feeds will be utilized, which leads one to suspect that sooner or later locally produced feeds will follow. Is this true, and if so, what pecentage of shrimp feed will come from "fish that can be consumed by people?" For that matter, what percentage of imported feeds still consist of fish which people could consume? This is an important point of non-conformance.

11.  Prohibit the wholesale conversion of agricultural or cultivable land aquaculture use.

12.  Ensure that the collection of larvae does not adversely affect species biodiversity.

Comment: How will these ponds be stocked? If this shrimp facility is dependent upon the capture of wild larvae to stock its ponds, then serious questions arise as to its sustainabilty and adverse affect on surrounding biodiversity. In other nations where capture of wild larvae occurs, for every one shrimp larva captured there are nearly 100 other shrimp and fish larvae thrown away as by-catch, most of which dies, thus resulting in serious depletion of the future nearby coastal fishery.

13. Ensure that abandoned or degraded aquaculture sites are ecologically rehabilitated and that the companies or industry responsible bear the costs of rehabilitation.

Comment: What real assurances, other than mere promises, will ensure that environmental damages will be repaired and paid for by those responsible?

14.  Ensure that aquaculture and other coastal developments are addressed in integrated coastal zone management planning which includes the meaningful participation of all coastal user groups.

Comment: Does this shrimp farm venture really address the need for an pre-existing and accepted integrated coastal zone management plan?Are all user groups really participating in this plan? Since I have heard that a majority of the local populace are not in agreement on this issue, I doubt that "all coastal user groups" are being heard on this issue which may affect them most.

15. Ensure the development of aquaculture in a manner which is compatible with the social, cultural and economic interests of coastal communities, and ensure that such developments are sustainable, socially equitable and ecologically sound.

COMMENT: Based on my above questions, I do not see how this can be assured.

16. Ensure that multi-lateral banks, bilateral aid agencies, and the UN Food and Agriculture Organization and other relevant national and international organizations or institutions do not fund or otherwise promote aquaculture development consistent with the above criteria.

This statement has been endorsed by the following NGO’s:  Accion Ecologica, Ecuador, Christian Aid, UK, Coalition of Environmental NGOs, Bangladesh, Consumers Association of Penang, Malaysia, CODDEFFAGOLF, Honduras, Dessarrollo
Ambiente y Sociedad, Mexico , Earth Island Institute, USA, Environmental Defense Fund, USA, Greenpeace International, Indigenous  Community Rights Forum, Papua New Guinea, International Collective in Support of Fishworkers, Mangrove Action Project, Movimiento Nacional Pescadores Riberenos, Mexico, Nijera Kori, Bangladesh, Ocean Advocates, USA, Orissa Krushak Mahasangh, India, Peoples Action Against Shrimp Industry, India, PREPARE, India, Sahabat Alam Malaysia, Sierra Club Canada, Sea Turtle Restoration Project , USA, Swedish Society for Nature Conservation , Third World Network, Yadfon Association, Thailand
 
 "AFC's detractors insist on equating one hectare  of shrimp farm land with the loss of one hectare of mangrove.  This is  patently untrue.  We will be using the semi-intensive method of farming and are confident that our project will be one of the most controlled and environmentally caring in the world."

Comment: I sincerely doubt that the developer can assure this, as this has not occurred elsewhere on this planet. Both intensive and semi-intensive operations have had their problems with disease and pollution, improper pond siting, acid-sulfate soils, improper feed ratios, effluent buildup, etc., etc.Why does this developer believe that he will escape all  such problems
unscathed, when the industry's short history can not help but prove otherwise.
 
"AFC stands by this project.  It will bring enormous benefits...and we are just as committed to the protection of the environment as those who oppose us.

Comment: "Enormous benefits" for whom, and at what costs to those most dependent upon a healthy coastal environment for their livelihoods and futures? What percentage of the projected profits produced by this development will be ?? (garbled) do not have a monopoly on caring for the planet.."

Comment: I wholeheartedly agree! In fact, we try to ensure that equal shares are distributed to all living creatures, great and small.
 
    Your optimistically stated projection of long-term employment for nearly 6000 people is questionable in the light that semi-intensive shrimp farm operations do not often last more than 10 to 20 years before disease and pollution
problems close them down. And what kind of employment are we talking about here--mainly low-paid positions such as shrimp processors and larvae collectors. Around the world, where shrimp farming has taken root, the majority of affected people remain poor, or actually become impoverished. The boom comes to a few astute investors, but the imminent bust affects the majority. Show me the rich affected populace along the coasts of Thailand, India, Bangladesh, Honduras or Ecuador, for we all know that they do not exist! Prove to me that this purported glorious industry is something more than an instigator of human misery and a despoiler of land and sea! Just visit those affected places, talk to the people there, and you will know the truth that this is not so.