The Salmon Dialogue: What’s the future of sustainable, genetically engineered foods?

What we eat has become embroiled in politics. The opposing sides in today’s fiercely contested debate over the ‘future of food” often talk past each other. Vegetarians call meat “murder” while meat producers maintain that animal protein is a healthy and necessary part of the modern diet. Locavore fans of Michael Pollan and Mark Bittman argue vociferously that industrial monoculture is destroying soil, water and the ‘soul’ of American agriculture while those who toil in the farm belt maintain that the industrial-scale production of key commodity crops has allowed the US to feed a growing and hungry planet.

And so it goes with the debate over one of the newest biotechnology innovations, AquaBounty Technology’s AquAdvantage salmon. The AquAdvantage fish is an Atlantic salmon that carries a growth gene from a Chinook salmon, which is under the control of a genetic “switch” taken from the ocean pout. All of the scientific studies have been completed and reviewed. Despite claims that the FDA has engaged in a ‘rush to judgment’ over AquaBounty’s application, the company’s almost 20 year joust with regulatory authorities for a decision is one of the longest, if not the very longest, review period ever placed on a company seeking approval of a food or medical product.

The salmon received preliminary approval from the Food and Drug Administration earlier this year. The extended public comment period is now concluded, thousands of viewpoints have been weighed and the FDA’s response is presumably organized. Sometime in the next 60 to 90 days, it is likely that the quest to obtain FDA approval for the first genetically modified animal will come to a final resolution.

Whether the FDA will approve or disapprove of the company’s application—or whether the White House will intervene and slow or block an approval as it did once before (read the investigation by GLP’s Jon Entine in Slate: —is still unknown. But whatever the decision, it will spark an outpouring of heated discussion among the public and media, including predictable outrage by NGOs and radical environmentalists who are ideologically—almost religiously—opposed to the genetic engineering of our food.

Anticipating a media frenzy, earlier this year the Yale School of Forestry & Environmental Studies and Yale University asked Elliot Entis, founder of AquaBounty, and Paul Greenberg, author of the best selling Four Fish: The Future of the Last Wild Food and a critic of genetic engineering, to debate the issues surrounding Aqua Bounty’s fast growing salmon. Both the published debate and the comments it received are good indicators of the fierce national conversation that is likely to occur in the very near future when the FDA announces its decision. As a public service, we at the GLP believe it is important for a broader audience to get a taste of the debate to come.

The Yale Environment 360 website posted an edited version of this debate here.

We at the GLP have decided to post the entire unedited transcript of the debate:

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The GE Salmon Dialogue

PAUL GREENBERG: Elliot, when we first spoke on the phone to set up this discussion you made the point that you are every bit as much as a fish lover as I am, that you come from a fishing family that you “love fish”.  Can you tell me a bit about your family background and what led you to want to create a better salmon?

ELLIOT ENTIS: I grew up in Boston where my father was a wholesale seafood dealer. Though I always loved both eating and seeing fish, I never thought I would be involved in that business. But after a few years working in DC I moved back to work for my dad. It was adventurous; it had a material reality. My ideas in DC might never get traction, but in the fish business, at the end of each day I could say that somebody ate something that I helped to provide. It was also fun. I prided myself on looking for species not yet on the local market. That included farm raised salmon from Norway – an unknown beast in 1982. I was entranced with the idea of fresh, farm raised fish and decided that this really was the future of seafood.

From there, it was a couple of steps to the biotech company I founded in 1992, based on a brief article in the NY Times. The article described work by scientists on a so-called “antifreeze protein” produced by arctic fish that allows them to survive the cold that would otherwise kill them. Their first effort was to transfer the antifreeze gene from a species in which it occurred naturally to salmon – which do not have it – and which were being farmed for the first time in Canada. While that work did not succeed, by the time I met them, they had paired instructional DNA from the antifreeze gene with a salmon growth hormone gene, in an attempt to have the salmon grow more quickly by encouraging growth in the winter, something that does not naturally happen in cold winter water.[1] Their discovery resulted in reducing the time required for an Atlantic salmon to grow from hatch to harvest by 50%, from almost 3 years to 16 to 18 months.

I thought that this was truly a remarkable advance in food production, one that could change fish farming. And it was very shortly after that that I coined and defined the term “Blue Revolution”, thinking of course of Norman Borlaug. My original definition, which is unchanged was: “The Blue Revolution”: Bringing together technology from the biological sciences and engineering to produce an aquaculture industry capable of large scale, low-cost production independent of proximity to the oceans and less invasive to the environment. Increased growth rates, enhanced resistance to disease, better food conversion rates, alteration of breeding cycles, more efficient use of indoor water recycling plants are all aspects of this revolution.”

PAUL GREENBERG: It’s of course always exciting when we see some law of nature that can be tweaked with human know how. Some hidden efficiency that can be added to make a system better. And I’ve certainly written over the years about the importance of reforming aquaculture to have more efficient systems. Aquaculture in its early years was extremely wasteful. Those first farmed Norwegian salmon you saw in your father’s market ate a great deal of wild fish to come to market –sometimes it took six pounds of wild fish to make a single pound of salmon. But I have to admit I don’t really see the point of a genetically modified salmon at this time. The non-modified salmon industry has greatly improved its feed efficiency down to less than 1.5 pounds of wild fish for 1 pound of salmon. You’ve often made the point that traditional salmon farmers grow their crops in sea cages that pollute the marine environment and that we’d be better off farming in tanks on land. You’ve further argued that only a modified fish would meet the costs of growing fish on land because of its added efficiency. Meanwhile several growers seemed to have figured out containment growing fish closely related to the Atlantic salmon without tampering with genes. Your colleague Per Heggelund at Sweet Spring in Washington State says he can grow a Coho salmon in containment in 9 months. And Arctic char, very salmon-like in taste and provenance seems to take well to containment growing. Char farming is booming in Iceland and Canada. If we have these possibilities, even if the risks are low for the ABT salmon why even introduce it into the food system?

Finally a point that is overlooked is that in this country we have abundant wild salmon in Alaska two-thirds of which we send abroad. While some of those salmon fisheries are propped up by hatcheries (a practice I don’t endorse) a lot of them aren’t (c.f. sockeye salmon). We seem to be sending all our wild fish abroad and then importing farmed fish in their place. Your fish would just further supplant American use of American wild fish.

ELLIOT ENTIS: Paul, I have to disagree with you here on several points. While strides are being made to grow salmon in land-based facilities, it is far from proven to be economically feasible. While the industry has made great improvements in feed efficiency, the amount of fish to produce one pound of salmon is still about 2 lbs, and growth rates are much lower than you might believe. Because of these remaining hurdles, unfortunately, two of Per’s recirculation plants are now closed, bankrupt mainly due to an inability to meet the projected production of 3 kilo fish in 12 months. As for Arctic char, in contrast to your suggestion that Char are easy to grow and rapidly increasing in production, the last statistics I have seen indicate that worldwide there are about 5000 tons grown per year: – about 0.02% of the Atlantic production and they are not increasing in number also due to husbandry issues.

So while hopes for indoor systems grow, it is apparent that greater economic efficiencies are needed. These efficiencies can be created by economies of scale, more efficient feeds and more efficient fish, e.g., the AquaBounty salmon. Not only have eight generations been raised in an indoor facility with a now proven growth rate, the latest 3^rd party analyses of the AquAdvantage salmon’s sustainability is even more exciting than we ever knew: these fish consume 25% less feed than their standard Atlantic Salmon brethren to achieve the same growth, and even better, they are able to efficiently utilize a much higher percentage of plant protein in their feed than the others. In a recently concluded trial, plant protein was substituted for 50% of the fish meal in the industry diet and the result was that the AquAdvantage salmon not only tolerated this, but grew more quickly than any of the standard salmon and still retained the same nutrient content. In sum, the amount of fish needed to grow one pound of AquAdvantage Atlantics is reduced from the industry standard of about 2 pounds to roughly one pound.

As for the risks from the AquAdvantage salmon, what are they?

Studies conducted by independent researchers in the US, Canada and Australia have come to the conclusion that even the release of fertile AquAdvantage Salmon would pose virtually no risk to the ocean environment. Fast growing AquAdvantage salmon are not suited to life in the wild, and all indications are that they would rapidly disappear in the event of an ocean release. The AquAdvantage salmon is truly the “disadvantaged” salmon when it comes to going out to the wild waters of the ocean.

As my recitation of factual evidence shows, AquAdvantage salmon are more sustainable, have less of an environmental impact, and cost less to produce than any other Atlantics raised in similar conditions. Having spent a year analyzing construction bids for a large indoor facility, I can also say with assurance that a facility capable of producing roughly 1000 tons of Atlantics per year will cost between $15 and $25 million to build. If that same capital cost can produce 2000 tons, and the running costs remain relatively constant, the economic calculus changes completely and taking salmon farming out of the ocean becomes a reality, not the dream it has so far been. Economic analysis of the resulting reduction in per unit costs coupled with the effective doubling of production per unit of time can dramatically lower the costs of production, resulting in lower costs to the consuming public. Creating land-based water-recirculating facilities would, as we agree, reduce water pollution, antibiotic use on fish, prevent escapees and locate grow-out facilities nearer to markets, saving fuel and transportation costs.

Finally, despite pockets of abundance that periodically appear, the supposition that there is an abundance of wild salmon is one that I can find no support for in the scientific literature. There is a trend of population decrease in the Pacific trending from south to north over time: first felt in California, then Oregon, now in Washington. I suspect very soon in Alaska.

Now if you still don’t see the point of using transgenic technology, then I assume you just don’t like the technology because you don’t like the technology.

PAUL GREENBERG: On the question of wild salmon abundance, I don’t quite agree with you. We’ve lost most of our wild salmon in the lower 48, but we’ve lost it not due to overfishing but rather to habitat destruction–dams, loss of water quality, logging, etc. Alaska remains good salmon country because it is largely undisturbed territory. And I worry by undercutting the value of wild salmon, by producing a cheaper farmed product, we undercut the necessity for the continued existence of wild salmon habitat.

But back to the AquAdvantage salmon itself. If the AquaBounty fish is safe for consumption, if it poses, in your opinion very few risks why then the resistance to labeling the AquaBounty salmon as being the product of genetic modification? Why not call a GE fish a GE fish on its labeling?

ELLIOT ENTIS: The reasons for the disappearance of wild salmon are complex, including overfishing human habitat destruction, and changes in ocean temperatures as a likely result of climate change. In addition to good husbandry, however, the reason the Alaskan salmon fishery remains strong in no small measure is due to the hatcheries you don’t like that release well over billion smolt a year – including nearly 30 million sockeye per year! I am not sure why you don’t like the hatchery program – perhaps because you are an incurable romantic?

You do raise another point that I find interesting: farming as a disincentive to valuing wild things. I think that there is some truth in the idea that once we can farm an animal rather than hunt it, we lessen the economic incentive to preserve it in the wild. But the alternative in the case of the fisheries is to solely rely on hunting/gathering, and that has not really worked out too well. So if we wonder what is more destructive to the existence of wild fish, fishing or aquaculture, I would have to say the evidence is strongly in favor of fishing and that aquaculture is and will continue to be the critical lynchpin. Jacques Cousteau recognized this back in 1973 when he wrote, “we must turn to the sea with new understanding and new technology. We need to farm it as we farm the land.”

So we are back to the core point: if aquaculture, then we have an obligation to make it as efficient, as sustainable as possible. Given that it is now proven that we can significantly reduce the feed inputs, particularly the fish-based portion, as well as the time and other scarce resources required to raise Atlantics by using biotechnology-based hybridization, do you still object to its use? That is the real question in our conversation

Finally, I want to put in a good word for labeling.

I am now, and have been on written record for 20 years as in favor of labeling foods produced with the help of modern biotech. And based on my conversations with its management, AquaBounty continues to favor labeling, with the caveat being that labeling is supported as a voluntary marketing tool, not as a skull and crossbones warning, which is what the opponents of biotechnology want. I want to follow in the footsteps of the organic farming associations who also developed their labeling plans as a marketing tool. So I propose that the food industry develop a consistent, informative and accurate label for all foods that are developed with the help of modern methods of hybridization, a label that indicates the health and environmental benefits of these foods.

PAUL GREENBERG: I would agree with your take on labeling. That seems fair. But to your other points — my responses circles around the question of carrying capacity. On the question of why I object to stock supplementation of wild Alaskan salmon. I believe that there is a carrying capacity for salmon in the ocean. There is a reason why historically there have been a certain number of wild salmon feeding off the west coast and in the Bering Sea. By forcing the system to produce more salmon I believe eventually there will be a crash of prey or some other element that keeps the salmon system going. My second reason for objecting to supplementation was actually brought to my attention by an AquaBounty employee who noted that even though we are now using the same river stock to re-stock Alaskan rivers, by introducing smolts into the environment at an advanced age we are removing the selection pressure that happens in the wild when an egg in a redd (nest) emerges and eventually grows into a smolt. A whole lot of mortality happens during that period and by cutting out that aspect of natural selection I worry that we are shifting the overall genetic make up of salmon populations and making them less fit. And I would point out again that the pretty healthy runs of Alaskan sockeye have virtually no supplementation whatsoever.

To your main points about improved efficiency of ANY species be it Atlantic or Coho or tilapia. Yes, obviously it would be better to have more efficient less impactful animals for our food. But it’s also clear to me that the diet of the future is going to contain less animal protein. It simply makes more sense. The loss of energy that happens when you feed an animal and then eat that animal instead of what you’re feeding it will not be economically acceptable in a few more decades even if animals are more efficient. Greater efficiency is a distraction from the larger problem of humans and our unsustainable over-reliance on animal protein.

I’m reminded of something told to me by the writer Anna Lappé (daughter of France Moor Lappé who you will remember wrote Diet for a Small Planet). Anna’s essential issue with GE crops be they salmon or corn or pigs was the open-ended way they formulate our response to population growth. If we continue to bend the rules of nature so that we can provide more and more food for an open-ended expansion of humans on the planet something eventually will have to give. Would you like to live in a world of 15 billion people? 20 billion. I would not. And while it’s possible you will label my response as New Age-ish or even compare what I write to Swift’s Modest Proposal (i.e. let them starve rather than eat GE food) I feel that GE food distracts us from the real question of the carrying capacity of the planet.

ELLIOT ENTIS: While consistency may be the hobgoblin of small minds, I think that in the context of this discussion it has some merit. Paul, you cannot with credibility applaud and encourage increasing the efficiencies of aquaculture through the use of indoor systems as you have often done, while simultaneously disparaging efficiencies if they come from better understanding of fish genetics. And while I understand and share your concern for the potential degradation of our habitat and our lifestyles if population growth is unchecked, it is not clear to me that you have set forth a coherent message. It seems that personally you want to be able to continue to eat meat protein, but not have it so available that everyone can afford to have it. Kind of a Romney approach to the masses, no? Now if you are a vegan then I take this all back.

PAUL GREENBERG: I’m not a vegan and I drive a car and I live in a modern American city with all the electricity and running water I could want at my fingertips. Do I think that’s right or fair? No. But honestly speaking I don’t believe that making a faster growing salmon, already a luxury product for 99% of the world will mean that people in South Sudan will suddenly be feasting upon lox and bagels every Sunday. To my mind it’s really about improving profit margins for AquaBounty, which markets to the West and hopes to sell to the West.

While were on the subject of costs and marketing, could you indeed set the record straight on how much funding you’ve received to date? How does it compare to other areas of aquaculture research? I ask because while perhaps the investment was small, there is the potential of a huge pay off for you and one with which I take issue.

ELLIOT ENTIS: This discussion is not just about AquaBounty’s salmon, it is about the acceptance and use of a technology that can help all of us attain goals we hold in common, like producing more food with less use of scarce resources, be it water, fish meal, or land that could be left wild. And focusing only on AquaBounty’s use of this technology, perhaps you will be pleased to know that it has successfully been applied to tilapia, a fish that subsists on vegetable matter and makes up much of the meat diet of poorer countries. A variation of the technology has also been used in China so that carp, a diet mainstay in Asia, can be produced more quickly with less feed.

As for economics, it is a matter of public record that AquaBounty raised about $30 million (net) on the London stock exchange in 2006, and two million more since then. Prior to 2006 the company raised about $5 million. All of this is private capital, of course, and over the course of 20 plus years, not very much money. I do not have comparable figures for aquaculture research as a whole, but I am quite sure that worldwide it is orders of magnitude more. But the point is that the transgenic research of ABT was privately financed, so there should be no question of redirecting funds willingly invested by the private sector. Yes, there is some amount of R&D for transgenic research from government sources, as there should be if you value scientific research. But if you look at the public US expenditure on R&D associated with genetic modification of agriculture animals, you will find it is as close to zero as you can get. Public financing of this type of research is actually forbidden in most US agricultural programs.

If you added up all the money spent on fish-related transgenic research, it’s such a small amount that in the immortal words of one-time VP John Nance Garner, “it wouldn’t be “worth a warm bucket of spit.” I would love to have been the head of a company with serious resources, but the fact is that we have gotten by with few dollars, bad PR but pretty good science.

Now about the “huge payoff” that you object to. Why? It seems that you object to a company making a profit if they develop a faster growing, more sustainable fish hybrid, but not if they develop a better facility in which to grow it. To quote your earlier writing: “Let the fittest, most closed system survive and reap the economic benefit inherent within that victory.” Since you appear to be pleased if a hi-tech plumbing company gets a huge payoff but not a biotech company, I assume you are not an anti-capitalist, just an anti-biotech capitalist. If your concern is that the genetic technology would disenfranchise lots of fish farmers, I need to point out that recirc systems are far more likely to eliminate the small farmer than would the genetic technology: After all, every fish farmer has to afford to buy eggs, but few will be able to raise north of $10 million to build a recirc facility. The biggest drawback to recirc facilities, if you value the small farmer, is that this undoubtedly will lead to an even greater concentration of the industry, while improving the genetics of the fish is size-neutral. (By the way: you would not absolutely need a recirc facility to grow AquaBounty fish, you just need to be inland.)

PAUL GREENBERG: I’ve actually heard rumors from some of your critics that getting approval for inland or recirc farming of the fish is just the first step. Are there forces within AquaBounty that would indeed like to put the AquAdvantage fish in net pens and farm them in the sea with all the damaging effects we’ve discussed?

ELLIOT ENTIS: Paul, I can say with assurance that the idea of putting AquAdvantage salmon in ocean net pens has never been discussed or considered by the company. Regulatory approvals for the long foreseeable future will, I am certain, be available only for land-based systems. And that is as it should be. While we are on the subject of critics, there are two kinds: those who begin with a reasonable understanding of the science and have made AquaBounty prove that its products are safe, and those who simply make up baseless charges and promulgate myths. Unfortunately, we have far more of the latter. I am all for mythmaking, but mostly in the form of Arthurian legends

PAUL GREENBERG: One criticism I’ve often heard of the AquAdvantage fish is that underlying this more efficient animal is a bid to privatize the Atlantic salmon itself. Just as farmers of corn and soy are caught in a relationship with the large seed companies where they must purchase seed from a handful of firms that own the genetic material of their seed, isn’t it true that should the AquAdvantage fish come to be grown in the States won’t you then have something a monopoly?

ELLIOT ENTIS: Aren’t the salmon raised by farmers already “privatized”, as are all agriculture products? And as far as having a US monopoly, I think you are putting too little faith in the powers of competition and diversity of taste. While I do believe AA salmon present noteworthy economic and environmental advantages to users, I also have no doubt that as soon as that becomes commercially apparent, there will be others with equally inventive technologies that will lead additional improvements in fish farming genetics. I am sure you do know that currently the US does not have a salmon farming industry: we import 97% of our farm-raised salmon, so anything we can do to change that paradigm and help create a domestic industry will be a boon to our economy and a plus for our workforce.

Your broader comment about farmers being forced to buy seeds from a few companies is off the mark: no one forces farmers to buy seeds from Monsanto, DuPont or any other company that sells them. I give more credit to farmers than you seem to: they buy these seeds because they are more productive.  If it were not the case, the farmers would certainly go elsewhere, and many do, including of course, organic farmers. There are always commercial choices in seed buying.

What I really believe you are referencing is the fact that seeds from these companies are patented. If your objection is to US Patent law, you should take a broader view and not assume it is genetic engineering that is differentially protected to the exclusion and detriment of more traditional seed and plant producers. At last count, there were thousands of seed and plant patents issued since the first one in 1930, and only recently have they been protective of GMO seeds and plants. Plant patents are allowed in keeping with Jefferson’s philosophy that “ingenuity should receive a liberal encouragement”. Without patent protection no doubt there would be no AquAdvantage salmon, and few or any genetically modified plants. But there would also be no Burpee’s Beefmaster and Big Boy tomato, no Celebrity Golden Boy and Viva Italia vegetables. The fact is that without patent protection, there is little incentive to invest the enormous amount of time and money needed to make significant crop improvements, either the old fashioned way or especially by using the newer methods that are expensive, but capable of greater improvements in shorter amounts of time. For example, the AquAdvantage salmon.

PAUL GREENBERG: But what about the fact that traditional growers who may not want to farm with modified stock will find themselves at a competitive disadvantage. That they may in fact be obliged to buy salmon juveniles exclusively from AquaBounty. Is that ethical? Is that good for the world?

ELLIOT ENTIS: I am confused by your raising the question of ethics. Are you really suggesting that improving a product so that people will prefer it is unethical because people with an inferior product will be disadvantaged? Is that what you would have written when the first Model T rolled off the line and the horse and buggy industry cried foul? Your “ethical” objection can be raised against any new invention or product. Do I hope salmon farmers will buy the AA eggs? Of course, and then the farmers, consumers and the environment will benefit. I think that is pretty ethical. And good for the world as it spurs even greater efforts by more people and companies to improve upon what is.

PAUL GREENBERG: I suppose it depends on what your definition of an “inferior product” would be. I know you have absolute faith in the safety of your salmon but others would rather take a longer-range view and wait and see if it is truly safe. DDT and PCBs were once considered “safe” in the general marketplace. We only saw their profound impact on the environment decades later.

ELLIOT ENTIS: Paul how long is the long range? 10 years? A hundred? This argument is the refuge of those who would prefer that this fish and any product of biotechnology never see the commercial light of day.

Very little in our world is perfectly knowable, but over the years, I believe that the systems for judging knowable risk have improved in quality and comprehensiveness. I also know that analysis of DDT, PCBs and other chemical agents used in the past did not undergo 15 or more years of safety research, as has the AquaBounty salmon. I also note that since AquaBounty’s salmon contain only proteins, minerals, nutrients and even DNA found only in salmon and other edible fish, and in the same concentrations, we have extremely good reason to believe that the analyses of our salmon have been as thorough and accurate as any science-based inquiry into safety can be. I can also point out with no fear of contradiction that no fish – salmon or other species, wild or farmed – has undergone as much testing and analysis as the AquAdvantage Atlantic.

So, Paul after our lengthy and perhaps discursive conversation, has any of this allowed you to see things a little differently?

PAUL GREENBERG: I think the points you make are often valid and I do see some validity in a genetically engineered more efficient fish if indeed AquaBounty’s true and stated goal is to end net-cage culture and get fish farms out of the sea. But I don’t believe that will happen.  I think that somewhere along the line someone will realize that they can make even more money growing genetically modified fish in the open ocean. Maybe it won’t be AquaBounty. Maybe it will be one of your future American competitors. Maybe it will a competitor in a place like China, where environmental safeguards are much less stringent. And since modified salmon will be cheaper there will be more demand and then more salmon farms in the ocean. The load and burden on the environment will increase not decrease. So I respectfully say that I stand opposed to modified salmon until the industry can on an international basis agree and enforce standards that keep modified fish out of the sea.

[NOTE: Paul – AquaBounty’s goal is not to end net-cage culture. ABT’s goal is to produce safe, sustainable salmon in a manner that is not harmful to the environment. For ABT that does mean land-based facilities, but there are many other companies with acceptable ocean-based farming technologies and it is not ABTs goal to stop them. That would be reading more into my statements or ABTs goals than are meant.]