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Eco-Justice Notes
The E-mail Commentary from Eco-Justice Ministries

Recipe for Exploitation
distributed 1/18/13 - ©2013

Start with a salmon -- an Atlantic salmon, to be precise. Mix in some genetic material from a Chinook salmon, then give a boost to the mix with a gene from the ocean pout, "an eel-like fish." Simmer through a drawn-out process of review by the Food and Drug Administration, then sear briefly with the hot flames of a 60-day public comment period.

A Massachusetts company, with operations in Canada and Panama, has done the genetic work combining characteristics of Atlantic and Chinook salmon, and using a gene from an unrelated fish species, to create a new kind of fish. We're now about half-way through the FDA comment period about whether to allow commercial production of the fish.

The fish created through a process of genetic engineering is named "AquAdvantage® Salmon" by the corporation that created it. It is called "Frankenfish" by some of the activists trying to block its approval. Both sides focus on the genetic changes that cause the modified fish to grow to market size about twice as fast as unmodified salmon.

The corporation offers assurances that their salmon-variant is perfectly safe as a food, and for the environment. Opponents list concerns about health risks and (more importantly, in my reading) a number of environmental concerns.

I have three sets of ethical qualms about the AquAdvantage® fish, only some of which are directly germane to the FDA approval process. Within the next few days, I will be filing formal comments asking that the fish not be approved for sale in the US. I invite to study the issue and submit comments of your own. (Options for commenting are below).

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I am opposed to the propagation of this genetically engineered animal on three fairly distinct grounds. One is explicitly theological, the other two are more practical ethics.

(1) Theological ethics. The website for the company that developed the fish speaks of it as "advanced-hybrid" (that is, genetically modified in a way that could never be achieved through breeding), and they say that the fish that they are working on are "designed to grow faster than their conventional siblings." The corporate website appears to be deceptive (at the least) when it does not mention the use of genes from the ocean pout.

Theologically, I have real problems with "designing" animal species to conform to the desires of businesses. This is creating a new species that is convenient and efficient for our exploitation. It is designed to be raised in captivity, and manipulated for economic purposes. The interests of the fish have been given no consideration. They are treated solely as objects, as resources for human use alone.

Certainly, modern forms of agriculture already use technology to modify and exploit animals. (Turkeys, for example, are bred to the point where they can hardly stand on their own, and concentrated animal feeding operations -- CAFOs -- follow horrible practices with chicken, hogs and cattle.) The genetic tinkering that combines two kinds of salmon and the ocean pout is the farthest extension of such exploitation. This is not just using other animals -- these salmon are designed and created specifically to be used.

Ethically, the manipulation and abuse of other species is a violation of our shared identity as creatures. It is a contradiction of the theological principle of "the integrity of creation", and a violation of what I see as humanity's appropriate participation in the web of life.

(2) Practical dangers. This new kind of fish has been designed to grow at exceptional rates. Its creator stresses that the fish will be (mostly) sterile, and raised in captivity, because it is abundantly clear that the release of these fish into natural environments would be -- will be -- an ecological disaster. The company downplays the possibility of the fish escaping into the wild. Opponents believe that such a release is inevitable.

If, or when, the modified salmon are present in unconfined waters, their rapid growth rate would allow them to out-compete other fish for food and habitat. They would become a highly-successful invasive species, joining the list of other plants and animals that disrupt and degrade environmental communities. If the modified salmon inter-bred with natural salmon stocks, the genetic changes would spread rapidly, leading to the corruption of naturally evolved salmon genetics.

The high potential for the modified salmon to become invasive in the wild, and the serious repercussions of those impacts, will be the primary element of my comments to the FDA.

(3) Direct and certain environmental costs. Almost all of the meat raised for human consumption comes from animals low on the "food chain." Cattle, sheep and chicken are not high-level predators. It is only with fish that we seek out the long-living species at the top of the food-energy pyramid. Salmon, tuna, swordfish eat astonishing amounts of other critters as they grow to maturity. What we often do in our preferences for fish is similar to eating predators like wolves and tigers instead of herbivores like cattle.

There is a remarkable stupidity in creating a fish species that requires huge quantities of other fish as food. It is economically and ecologically inefficient to farm-raise a top predator, whether they are natural species or genetically engineered. To live more lightly and responsibly on the planet -- if we're going to be eating fish at all -- the emphasis should be on those with a much lighter ecological impact, such as catfish and tilapia. The creation of a new kind of fast-growing salmon simply continues the widespread use of the wrong kind of fish.

Farming salmon in inland ponds -- required to reduce the chance that they'll escape -- will, by definition, require the use of massive amounts of fish meal created from other fish harvests. It will require extensive use of antibiotics that will pollute local waterways. And the waste from the fish ponds will require substantial and ongoing water treatment. Whether GMO or not, farming salmon has unacceptably high environmental costs.

(To provide a bit of balance, an article in Slate encourages approval of the GMO salmon, and says that the fast-growing characteristics would reduce some environmental impacts.)

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In the regulatory system of the United States, the approval of this animal for food falls under the jurisdiction of the Food and Drug Administration, which is concerned primarily with whether the thing is safe to eat, and the FDA is recommending approval. The FDA's evaluation of environmental and economic impacts has not been as robust as would have been the case with a review by the Environmental Protection Agency.

I suggest two ways that you might file an official comments with the FDA about the genetically modified salmon.

The AquAdvantage® Salmon would be the first genetically-modified animal to be approved as food in the US. This is a question of significant moral, environmental and economic importance. Please consider it prayerfully, and file a comment.

Shalom!

Peter Sawtell
Executive Director
Eco-Justice Ministries

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