MAP has recently learned that Wal-Mart, the world's largest retailer, and Darden Restaurants, parent company of Red Lobster, intend to, starting in early 2006, "begin certifying all of their imported farm-raised shrimp to ensure it is grown in a sustainable way, with minimal impacts on the environment." The certifying organization chosen for third-party review is the Aquaculture Certification Council (ACC), www.aquaculturecertification.org, which is utilizing a description of Best Aquaculture Practices (BAP) developed by the Global Aquaculture Alliance (GAA), itself a powerful shrimp industry consortium.

MAP is familiar with the BAP standards and similar sets of standards established over the years, and have found these to be inadequate in ensuring ecological sustainability and social equity. After reviewing the BAP standards promoted by the GAA, MAP and the Environmental Justice Foundation, www.ejfoundation.org, have both provided detailed comments to Wal-Mart and GAA about their inadequacy. Similar comments have been provided in the past to GAA, as the BAP standards have been in place for several years. (See the attached Appendix for a position statement by Redmanglar International, the Latin American Mangrove Network currently headquartered in Ecuador. We are largely in support of their stated position).

Several examples of the problems inherent in the BAP standards:

BAP Standard #4 - Environment - Mangrove Conservation and Biodiversity Protection

1. In reading Standard 4, one encounters immediate serious discrepancies. This troubled standard advises that wetlands are to be avoided, but also states that shrimp farms SHOULD be located on salt flats, a widely recognized, inter-related coastal wetland type. It also says that care should be taken to insure that hydrologic conditions are not altered, which cannot be done if farms are built in salt flats, which lie landward of mangroves and channel freshwater flows through them into mangroves. Invariably, hydrologic conditions are modified and mangroves suffer. There is no mention of the need for the shrimp pond certification applicant to supply proof of prior site conditions. How is a certifier supposed to really know what happened on site? It is not just a matter of "delineating wetland areas by the type of vegetation present." 'Accurate aerial photography and accurate vegetation maps, of the site both before and after development, are essential to any verification process. 'The certification process should be transparent, and certification documents and reports should be freely available for review and critique.

2. The standard does not say that FORMER wetlands are to be avoided. In many parts of the world, mangroves and other wetlands have been degraded by over-harvesting for wood or by hydrologic modifications; these degraded sites can be restored, but with Standard 4 in place they can be further degraded to become shrimp ponds.

3. The statement that "mangroves removed for allowable purposes shall be mitigated by the replanting of an area of mangroves three times the size of the area removed" is the single most egregious part of the standard. It does not say that there needs to be a "successful restoration." In other words, all one needs to do is plant mangroves on a mudflat or inside an abandoned shrimp pond, where we know they will not grow successfully, and the investor is off the hook. The failure of simple replanting to really establish a successful mangrove restoration area without considering restoring the hydrology has been repeatedly documented. There is also no requirement for follow-up or actual application of Best Management Practices for mangrove restoration.

What is proposed is wetland mitigation, a concept that has been tested in the USA for 20 years. But mitigation, even under the most strict review involving legally issued permits with requirements for successful mitigation was not working, and was not even close to achieving the goal of "no net loss" of wetlands. How then can such a failed policy in the USA come even close to being effective in foreign countries with no legally binding requirements or monitoring for success? The answer is simple, it won't.⁴

Thus, the Wal-Mart, Darden and GAA certification scheme will actually further the loss of mangroves and other wetlands because it provides no satisfactory requirement that it works, no requirement that those who develop mangrove restoration plans know what they are doing, nor follow-up to ensure successful mangrove restoration occurs.

4. Another example of the gaps between reality and these flawed standards is that these standards were developed without input from those most affected by shrimp aquaculture expansion — the countless subsistence farming and fishing communities which lie in the path of industrial shrimp aquaculture, and whose members' lives and livelihoods have been repeatedly disrupted by this same industry that now makes claims to certify itself via self-set "standards." However, these standards do not include the local populations in their development nor in their implementation or monitoring to really determine their social and environmental impacts on the surrounding communities whose quality of life is too often adversely affected.

5. Finally, the list of approved certifiers is a list of consultants that are paid by the farms seeking certification. Without a truly independent third-party review, where money is not a factor, none of the proposed standards will likely be enforced to any great degree.

Conclusions

The adherence to these so-called BAP standards with which the GAA purports to resolve these issues will fall far short of their stated expectations. Working with Wal-Mart itself is quite a challenge, as Wal-Mart does not have a great reputation for its own ethical business practices — both in the US orabroad. Wal-Mart, after all, is accused of supporting sweatshop labor in the Developing World and union busting and lack of benefits for its employees. Red Lobster's "all you can eat" menu could well be reworded as "all you can stomach," because of the mounting associated problems of shrimp farming in the Developing countries.

Most of the GAA standards for a Code of Conduct are technical solutions that aim to better ensure a longer-term production of shrimp, but do not address the many pressing social and environmental concerns raised by the shrimp aquaculture industry.

Simply put, the Wal-Mart/Darden certification scheme will not work, but instead will engender more societal disruption in the affected regions, more mangroves and other wetland areas will be lost, and proven unsuccessful methods of restoration will be applied in attempts at wetland mitigation. In consideration of the 2004 Indian Ocean tsunami, or the 2005 hurricane season records, this is quite troublesome, as vital protective coastal greenbelts will be further lost and more local communities put at serious risk...and all for the love of shrimp!

¹ Position statement prepared by Board of Directors of MAP, a largely volunteer non-profit organization dedicated to the proper management, protection, and restoration of mangrove ecosystems worldwide. MAP has been actively involved with the issue of aquaculture and its impacts on mangrove ecosystems and local fisherfolk for 14 years.

² Based on 30 years of international experience working in mangrove ecosystem management and restoration, MAP's chief scientific advisor, Roy R. "Robin" Lewis III, www.RoyRLewis.com has estimated that shrimp aquaculture may have been responsible for between 9% and 7.6% of mangrove loss worldwide (16,300 to 13,700 km2). In some countries, however, this contribution to loss may be as high as 30%. Other causes of mangrove ecosystem loss include: ports, airports, and other industrial developments, urbanization, and deforestation from lumber and fiber harvests.

³ Current estimate of existing mangrove forest coverage is 146,530 km, representing a decline from 198,000 km (1980), and 157,630 km (1990). These losses represent about 2%/yr from 1980-1990, and 1%/yr from 1990-2000, and an approximate 50% loss from the best estimates of historical cover.

⁴ See conclusions of several major studies, including the recent GAO review, www.gao.gov/cgi-bin/getrpt?GAO-05-898, and the report of the Committee on Mitigating Wetland Losses of the Board on Environmental Studies and Toxicology of the National Research Council, www.nap.edu, Compensating for Wetland Losses Under the Clean Water Act, 2001.

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