WANTED: your input on proposed regulation of aquaponics in California

[Paul Trudeau]

As you know, aquaponics has all sorts of potential to benefit society and our environment.  At the same time, the practice of aquaponics has the potential to contribute to the risk of fish disease and proliferation of invasive species that may threaten commercial aquaculture and natural resources.   In California, the state Department of Fish and Wildlife (CDFW) is considering how to minimize those risks while promoting the beneficial aspects of aquaponics.  One aspect of that effort involves developing appropriate regulations for the practice of aquaponics.   A group of aquaponics practitioners, state agency personnel, and academic personnel, together comprising the Aquaponics Subcommittee (APS) of the Aquaculture Development Committee (ADC) that advises the CDFW’s Aquaculture Coordinator, has come up with an initial proposal for regulation of aquaponics in California.  The ADC wants input on the proposal from the aquaponics community between now and their next meeting on January 8, 2015, at which time they plan to discuss the proposal and any input received.  A number of members of the aquaponics community, including myself, have volunteered to solicit input from aquaponics folks.

The initial proposal is posted here.  However, I think a discussion of terminology is necessary before you read it.  The proposal makes a significant distinction between aquaponics operations that sell fish and those that do not.  Unfortunately, the proposal uses the terms “commercial” and “non-commercial” to describe those two different categories, which is potentially confusing because an aquaponics operation that sells only vegetables and does not sell fish would be categorized as non-commercial in this context, even though in any other context, it would be considered commercial.  So, I have taken the liberty of inserting the alternate terms “fish-selling” and “non-fish-selling” into the text of the proposal below.  

Similarly, at one point the proposal describes an aquaponics operation that “produces” fish.  “Produces” could be interpreted to mean a breeding operation to produce fry/fingerlings/juveniles, but according to the APS member who submitted the proposal, that is not the intended meaning.  As such, I have taken the liberty of inserting the alternate term “utilizes,” which is more accurate.

PLEASE READ AND THINK ABOUT THE PROPOSAL AND SUBMIT YOUR COMMENTS BY DECEMBER 31, 2014.   You can submit your comments by posting a reply on this forum, or you can send comments directly to me at [e-mail].  I will forward all comments received by December 31 to the APS prior to their January 8 meeting.  Feel free to contact me with any questions as well.  

Paul

Paul Trudeau

Southside Aquaponic Farm

Sacramento

916-533-5268 mobile

PS:  If you are a member of a local group on this or another forum, please notify your group members of this issue and direct them to the discussion posted here, as opposed to re-posting this announcement or the proposal in your own local group - I think it will be less confusing to have this single central thread where people comment.  Thank you.

[Paul Trudeau]

There is now a specific online site for submitting comments on the California aquaponics regulation proposal (as announced on the home page of this forum now):

Click HERE.

I will forward prior comments made here to the ADC as well, but feel free to submit those prior comments of yours directly at the above link too.

Paul

[Michael Hall]

Hi Paul and Everyone,

First of all Happy New Year,

However I have several problems with the proposal  and I would wish to have some comments from you, and the members of this community before I give a more proper response to the proposal.

specifically,

2) Non-Commercial Aquaponics: Aquaponic operation that does not sell fish, but produces fish that fall under the jurisdiction of the CDFW.

Caveats to Non-Commercial Aquaponics  

• Non-commercial aquaponics operation must follow the CDFW Code

What is the CDFW Code (I can't find the code)

• Registration (permit, license) required for all non-commercial operations. This may require a minimal fee to cover cost of paperwork.

So anyone wanting to even start and aquaponics system will have to get permitted.

• Non-commercial aquaponics operation would be limited to non-restricted fish species.

I  don't necessarily have a disagreement with this.

• Personnel of non-commercial aquaponics operation may grow and consume the fish produced. If fish are given away, the fish must leave the property dead.

So we will be not be able to give away fish. I thought the above addressed the fact the the fish are non-invasive.

 So in short.

Anyone wanting to start an aquaponics system will have to 

1. get registered. (stifle innovation) 

2. cannot give away any extra fish (I thought the fish we we using were non-Invasivive)

Not to mention

Who are these people

I do not remember there names being on my last election ballot.

(bureaucrats will take your (rights) away and then sell them back to you) through permits and fees 

[MikeH]

After reading all the replies, reading for numerous hours via the web, although still being new to aquaponics. Well, maybe I am missing something here but why would I volunteer to be regulated.? Why create a situation where I can be fined for doing something that feeds my family.? What is next; We volunteer to start paying fee's & have to register to grow in soil.? Pay a fee (Tax) on every fish we have or eat.?

If I am missing something here, please reply and set me straight because I am not understanding this. I CAN see how it would benefit companies / Commercial growers, but not the private home grower that just wants to provide a healthy alternative for his wife and kids as I am doing.

[Paul Trudeau]

Hi Mike,

I don't speak for the State or anyone else other than myself, but my own personal thoughts about the issues you raise are these:  I think the remarkable growth of aquaponics in recent years (and hopefully continuing into the future) does pose legitimate concerns about increased risk of fish disease and proliferation of invasive species that may threaten commercial aquaculture and natural resources that we all share.  Just because a personal aquaponics operation is used only for feeding one's family does not mean it does not contribute to these risks.  By way of analogy, Burmese pythons were brought into the southeast US as pets, but that activity led to them being released and becoming an awful problem in the environment there.  It may be that regulation could prevent a similar problem from occurring with aquaponics, without unnecessarily impeding aquaponics practice.  It's certainly worth considering, and I think that's what the State is doing at this point.

[MikeH]

Well, I can see how it can benefit the state to regulate the commercial growers although don't see how it benefits a hobbyist as myself.
I like your analogy with the snakes although I can't see a comparison between an investment of a hundred dollars versus a couple thousand. If the general public put in as much research into raising reptiles as in there is involved in aquaponics then that wouldn't have happened.
I just see all this as another way for the state to collect money for their coffers and to control the average person from doing something good, and that they enjoy.
I guess I may have to head to this meeting if it is open to the public to voice my opinion.

[Fishy McFisherson]

I was unable to attend the meeting as I'd hoped. Can anyone report back on the discussion and results?

[Michael Hall]

MikeH said:

Well, I can see how it can benefit the state to regulate the commercial growers although don't see how it benefits a hobbyist as myself.
I like your analogy with the snakes although I can't see a comparison between an investment of a hundred dollars versus a couple thousand. If the general public put in as much research into raising reptiles as in there is involved in aquaponics then that wouldn't have happened.
I just see all this as another way for the state to collect money for their coffers and to control the average person from doing something good, and that they enjoy.
I guess I may have to head to this meeting if it is open to the public to voice my opinion.

I agree with MikeH on this, 

Aquaponic growers are already have regulations on the type of fish we can have, so you burmese python analogy doesn't hold up, since the Pythons were not on an invasive species list, or the regulation was not enforced.

All that having the CDFW involved in small time home aquaponics systems is going to do is have us go underground.

Paul, you talk about disease control, is the CDFW going to come out and inspect our fish for diseases?, or are they just going to make up get registered and pay a fee.

If we do have to get registered and pay a fee then we should be able to call them with any fish problems and the should send someone out to help us.

IMHO, this is just another way for a CA State agency to expand, even more, into our lives.

[Paul Trudeau]

Couple things:

I understand that a number of key people were unable to attend ADC meeting last week so issue was tabled to next meeting, which I think will be in a few months.

Secondly, the unofficial impression I get is that the State realizes there's no way they can or should physically police the gazillion home aquaponics practitioners out there.  I suspect they will rely more on education and the good sense of home practitioners.  I think their regs re home aquaponics should reflect what makes sense environmentally and then I think most folks will have the good sense and will to follow those.  I think it would make more sense for them to focus more attention on larger/commercial operations.

[Fishy McFisherson]

Thanks for the update Paul!

[Averan]

I'm pretty sure that pond owners aren't limited by regulations like these! People trade, give away or sell koi and goldfish all the time.

[Jim Edmunds]

This seems to be an old post. Can anyone update me on the status of this proposed legislation.

[Paul Trudeau]

Good question!  I will inquire and report back any findings.