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As Final U.S. Decision Nears, a Lively Debate on GM Salmon by Staff Yale Environment 360, May 29, 2013

In an online debate for Yale Environment 360, Elliot Entis, whose company has created a genetically modified salmon that may soon be for sale in the U.S., discusses the environmental and health impacts of this controversial technology with author Paul Greenberg, a critic of GM fish.

Few businessmen would relish promoting a product dubbed the "Frankenfish," but the challenge does not seem to daunt Elliot Entis, co-founder and former CEO of a company, AquaBounty Technologies, that is on the verge of selling a rapidly growing, genetically altered farmed salmon. The company's AquAdvantage Atlantic salmon -- modified with a gene that enables it to reach harvesting weight in half the time of a regular salmon -- received preliminary approval from the U.S. Food and Drug Administration (FDA) last December. A public comment period ends April 26, after which the fish could win final FDA approval and become the first transgenic animal product ever sold as food in the U.S.

To explore the environmental and human health impacts of the AquAdvantage salmon, author Paul Greenberg, author of Four Fish: The Future of the Last Wild Food and an outspoken critic of GM salmon, invited Entis to engage in a written online debate for Yale Environment 360. Entis, who has spent two decades and raised roughly $50 million to bring his fish to market, readily agreed:

Paul Greenberg: It's 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. 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. 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 of 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 nine months. If we have these possibilities, even if the risks are low for the Aqua Bounty Technologies (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. We seem to be sending all our wild fish abroad and then importing farmed fish in their place. Your fish would 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. And though the industry has made great improvements in feed efficiency, the amount of fish to produce one pound of salmon is still about 2 pounds, 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-kilogram fish in 12 months.

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 third-party analyses of the AquAdvantage salmon's sustainability shows that these fish consume 25 percent 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 percent 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 U.S., 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.

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.

Greenberg: 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 [genetically engineered] fish a GE fish on its labeling?

Entis: I want to put in a good word for labeling. I am now -- and have been on written record for 20 years -- 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 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 that 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 developed with the help of modern methods of hybridization, a label that indicates the health and environmental benefits of these foods.

We have an obligation to make aquaculture 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 Atlantic salmon by using biotechnology-based hybridization, do you still object to its use? That is the real question in our conversation.

Greenberg: To your main points about improved efficiency of ANY species, be it Atlantic salmon 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 Lappe (daughter of France Moor Lappe, who 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, I feel that GE food distracts us from the real question of the carrying capacity of the planet.

Entis: 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. While consistency may be the hobgoblin of small minds, I think that in the context of this discussion it has some merit. 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.

Greenberg: Honestly speaking, I don't believe that making a faster-growing salmon, already a luxury product for 99 percent 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 we're on the subject of costs and marketing, could you 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 payoff for you and one with which I take issue.

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 $7 million more through 2012. Prior to 2006 the company raised about $25 million. All of this is private capital, of course, and over the course of 20-plus years, not very much money. 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 and 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 high-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.

Greenberg: I've actually heard rumors from some of your critics that getting approval for inland 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?

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.

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 United States won't you then have something of a monopoly?

Entis: Aren't the salmon raised by farmers already "privatized," as are all agriculture products? And as far as having a U.S. monopoly, I think you are putting too little faith in the powers of competition and diversity of taste. While I do believe AquAdvantage 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 to additional improvements in fish farming genetics. I am sure you do know that currently the U.S. does not have a salmon farming industry: We import 97 percent 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 U.S. 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. Without patent protection there would be no AquAdvantage salmon, and few or any genetically modified plants. But there would also be no Burpee's Big Boy tomatoes, 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.

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?

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 AquAdvantage eggs? Of course, and then the farmers, consumers, and the environment will benefit. I think that is pretty ethical.

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.

Entis: Paul how long is the long range? Ten 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 can also point out with no fear of contradiction that no fish has undergone as much testing and analysis as the AquAdvantage Atlantic salmon.

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

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 aquaculture 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 be 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.