Architectural mock-up of the land-based fish farm Nordic Aquafarms plans for the Samoa Peninsula.


PREVIOUSLY: Nordic Aquafarms Lays out Next Steps After Planning Commission Gives the Thumbs-Up to Their Samoa Fish Farm Plans


Two weeks after the Humboldt County Planning Commission certified the Final Environmental Impact Report (FEIR) for Nordic Aquafarms’ planned land-based fish factory on the Samoa Peninsula, the decision is being appealed to the Board of Supervisors.

On Thursday, leaders of three local nonprofits — the Redwood Region Audubon Society Chapter, the Humboldt Fishermen’s Marketing Association and 350 Humboldt — submitted a letter to the supervisors and to John Ford, the county’s director of planning and building, initiating the appeal.

The letter alleges that the environmental report, which was prepared for the county by local engineering firm GHD, violates the California Environmental Quality Act (CEQA) by understating several of the project’s impacts, including its greenhouse gas emissions, its energy use and the threats it poses to commercial fisheries and coastal and bay ecosystems.

“We collectively believe that the FEIR has fatal flaws that make it inadequate for final certification,” the letter says.

In all, the letter identifies 14 “issues” with the FEIR. Among these, the signatories argue that the report should have accounted for greenhouse gas emissions produced in the manufacture of fish feed, which they say will amount to between 80,000 and 190,000 metric tons of carbon dioxide annually. 

They also challenge the report’s claim that the project’s energy consumption will produce zero carbon emissions because Nordic has committed to buying 100 percent renewable energy. “[T]he way such purchases are calculated (annually rather than 24/7) means that approximately half the electricity actually used on an hourly basis will be generated by natural gas,” the letter states.

Over the course of nine pages, the letter goes on to identify other alleged shortcomings in the environmental document, saying it should have considered a smaller project or multi-phased modular build out as less-impactful alternatives. It also says the authors of the report should have done more research and formal consultation regarding impacts to threatened species via the intake of up to 10 million gallons of saltwater per day.

However, permitting for the project’s saltwater intake component is being pursued separately by the Humboldt Bay Harbor, Recreation and Conservation District, which owns the Redwood Marine Terminal II property, a former pulp mill site where the project is slated to be built.

The letter-writers argue that this “piecemeal” permitting is not allowed under CEQA.

As for the concerns from the fishermen’s association, the letter says the environmental report arbitrarily concludes that there’s no risk to local wild salmon populations. 

“The risk of pathogens escaping the facility and affecting wild salmonids remains high,” the letter says. More specifically, it says the environmental report doesn’t adequately address the risk of viral accumulations in the farmed fish’s blood or abdominal fluids, arguing that the project’s filtration and ultraviolet treatment may not prevent the release of this “fish-killing wastewater” into the ocean.

You can read the full letter via the link below. We’ve reached out to Nordic for comment and will update this post if and when we hear back.


UPDATE, 11:10 a.m.: Nordic Aquafarms Public Relations Manager Jacki Cassida emailed the following statement:

At Nordic Aquafarms, we have always considered and continue to consider our work with local organizations and the community to be open and transparent. 

Thursday’s combined filed appeal from the Redwood Region Audubon Society (RRAS), Humboldt Fishermen’s Marketing Association and 350 Humboldt provides an avenue to continue a dialogue, as well as work with the County and Harbor District through the appeal process. 

We believe the certified Environmental Impact Report to be a comprehensive and robust document. Nordic sees remediation and reuse of a defunct Superfund site to be of great value to the community and stand by our commitment to creating economic benefits for Humboldt County. 

On the whole, Nordic will become a great asset in the County, with continued environmental sensitivity and community partnership, while displacing imported Atlantic Salmon in the market.


DOCUMENT: Nordic Appeal Letter

Diagram via the Planning Commission’s executive summary.