Note: Shrimp Farming Is Destroying Shark Habitat & Nursery Grounds

AN OPEN LETTER TO THE GENERAL STEERING COMMITTEE OF THE

WWF SHRIMP AQUACULTURE DIALOGUE

4th May, 2011

Dear ShAD/GSC members,

After careful and considered reflection on the draft standards and the

whole WWF-ShAD (Shrimp Aquaculture Dialogue) process, we the undersigned

Conscientious Objectors -- NGOs working with local communities in the

shrimp producer-nations and consumers in the shrimp-importing nations --

have unanimously decided that we cannot support the ShAD General Steering

Committee (ShAD/GSC) and the Aquaculture Stewardship Council’s (ASC)

intentions or actions towards establishing standards for shrimp aquaculture

certification. Many others who have added their names and organizational

affiliations to our list have also joined us in our protest.

We must therefore continue our course to speak out publicly and campaign

against the intent and the process that WWF-ShAD has endeavoured to

undertake. The historical record and scientific evidence both indicate that

certification will do much harm to both Local Resource Users and the

coastal marine environment. The following reasons stand out among many

others as indicators that we COs must continue to strongly oppose the ShAD

process and the intended ASC and organize a wider resistance against ShAD

and other shrimp certification schemes in both Europe and the USA:

1. There has never been involvement nor representation in WWF-ShAD’s socalled

dialogue process for the majority of stakeholders or, more

aptly, the Local Resource Users who are adversely affected by the

shrimp industry in producer nations. ShAD’s “stakeholders” are

overwhelmingly those invested in the growth of the shrimp-export

industry.

2. With each revision to the draft, the standards and their evaluation

criteria have been progressively and deliberately diluted by the GSC to

ensure that at least 20% of the existing shrimp industry can be

certified immediately after the Standards are released. The process

clearly demonstrates the bias of the ShAD/GSC.

3. The ShAD/GSC has resolutely refrained from undertaking or commissioning

serious research to collect meaningful and verifiable inputs and

feedback from Local Resource Users in the manner prescribed by The

Economics of Ecosystems and Biodiversity (TEEB).

4. The GSC process for selecting its board members has not been fair from

the beginning and is not representative of a transparent and democratic

process. As such, the standards overwhelmingly represent industry

interests -- for example: the whole of Africa is “represented” on the

ShAD/GSC by shrimp industry nominees from Madagascar.

5. Continued lack of proper legislation and enforcement in producernations

makes adherence to any certification standard unfeasible.

6. ShAD puts too much trust in the industry to monitor and regulate

itself. The certification programme depends upon an untried and

untested auditing system. Other critical aspects of the process too

require a “leap of faith” -- that previously disastrous practices will

miraculously reverse their effects once the ShAD standards are

released.

7. The ShAD standards continue to perpetuate unsustainable and destructive

open-throughput systems of aquaculture -- with a legacy of 400,000

hectares (and counting) of abandoned ponds in producer-nations.

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 The standards also promote bad practices relating to so-called

“mitigation of the effects of mangrove loss”.

8. The process conveniently ignores wide-spread community displacement,

human rights violations and environmental damage to many thousands of

hectares of land by the shrimp industry prior to 1999. Under the

present standards, ponds in these regions could be certified. Trends

indicate that they will. The ASC becomes, therefore, a confessional for

the shrimp industry and will grant indulgences in the form of

certification.

9. Export-oriented tropical shrimp production does not contribute towards

food security. Food security should not be measured by the weight of

export-production or the profit-curve of the industry, but instead by

the availability of healthy and sustainable means of local food

production for local consumption.

10. There remains the great risk that WWF-ShAD certification, by placing a

green stamp on tropical shrimp, will actually expand the demand for

farmed tropical shrimp -- both certified and uncertified -- thus

promoting the continued (and possibly more rapid) expansion of

unsustainable practices.

11. Feed issues are still not satisfactorily resolved and there is still no

effective plan to meet increasing feed demands. The projected reliance

on GM soy and palm oil is of great concern.

12. The COs had requested a breakdown of development time spent by ShAD in

developing their social, environment and technical standards. We have

not received this, yet.

13. ShAD/GSC and their offspring in the ASC have still not taken any direct

and effective actions to influence consumers in the importing nations

to reduce shrimp consumption -- extremely pertinent to the intent and

purposes to any attempt at designing a certification program for

shrimp.

We reiterate our demands that shrimp farming should not be located

within the inter-tidal zone; it should not be allowed to affect productive

agricultural lands, or displace members of local communities.

The final draft standards represent an extremely crude attempt at

setting up “standards”. The process demonstrates a lack of careful thought

and consideration of ground realities and concern for Local Resource Users

-- people who will suffer the consequences of WWF-ShAD’s actions.

The GSC’s position that the standards will be released regardless of

their merit and consequences leaves little scope for further dialogue.

As such, we the undersigned Conscientious Objectors reject the WWF-ShAD

process and its shrimp aquaculture standards.

We reaffirm our support, as always,

For the mangroves and mangrove communities,

The Conscientious Objectors