Action Alert: Nordic Aquafarms Appeal 9-28-22

On Wednesday, September 28 at 9am the Humboldt County Board of Supervisors will hear an appeal to the Nordic Aquafarms proposed fish farm.

The massive project would be the largest in Humboldt County in years. To give you some perspective, at full build-out it is expected to account for 21% of the county’s energy usage which is as much as the cities of Eureka and Fortuna combined.

Our friends at 350 Humboldt and Redwood Region Audubon Society, along with the Humboldt Fishermen’s Marketing Association, have appealed the project due to greenhouse gas emissions from fish feed, electricity, refrigerants, 1.6 million miles of truck traffic a year, and the “sludge” waste (which they estimate to be between 130,000 and 240,000 metric tons of CO2 annually for at least 30 years) as well as potential impacts to the Bay and ocean.

Take Action:
The NEC shares these same concerns about the project.

  • You can email the Board of Supervisors at
    • provide your name and the agenda item number(s) on which you wish to comment. All public comment submitted after the agenda has been published will be included with the administrative record after the fact.
  • Attend the meeting (virtually or in-person) and give comment.
    • When the Board of Supervisors announce the agenda item that you wish to comment on, call the conference line 720 707 2699, enter Meeting ID 816 5545 3244 and press star (*) 9 on your phone, this will raise your hand. You’ll continue to hear the Board meeting on the call. PLEASE TURN OFF YOUR TV OR LIVE STREAM TO AVOID DELAYS.
    • When it is time for public comment on the item you wish to speak on, you’ll hear a prompt that will indicate your phone is unmuted. Please state your name and the agenda item number you will be commenting on. You will have 3 minutes to comment. You may access the live stream of the meeting by using the following link:
  • Instructions on how to comment will be found on September 26 at

Detailed Information from 350 Humboldt: 


Emissions from Fish Feed
Nordic will be emitting between 80,000 and 191,000 metric tons of greenhouse gases at full buildout due to their use of 36,000 metric tons of fish feed annually.These emissions cannot be eliminated by any aquafarm, but they can be mitigated by conditioning the permit to require Nordic to pay for sequestering an equal amount of carbon by funding an estuarine conservancy, like the Eel River Estuary Preserve, or any similar estuary preserve. How would this work? Nordic must certify annually to the Aquaculture Stewardship Council how much fish feed they used, what the greenhouse gas emissions embodied in that feed are, and thus the total greenhouse gases the aquafarm emitted. Use the figure Nordic reports to the ASC. They must pay into an estuary preserve one of the prices below for each metric ton of greenhouse gases they report to the ASC.

What price should be assigned. There is a range of possibilities:

  • A carbon offset from the Yurok tribe costs about $14 per metric ton of carbon sequestered
  • In California an “allowance” for one metric ton costs $28 right now in the cap and trade system
  • In the US the “social cost” of one metric ton of carbon is $51
  • In Canada it is $130 per metric ton
  • In Norway, in 2030, it will be $237 per metric ton

We don’t feel it should be lower than what other large corporations, those under cap and trade, pay for emitting carbon.

Emissions from lack of 24/7 renewable energy
The mismatch between renewable energy availability and the 24/7 demand by Nordic means about 40,000 metric tons of CO2 will be released annually by the gas turbines powering the plant at times when renewables are not available. Presently there is no way to mitigate these emissions directly. This is a problem that Google, Microsoft and the UN are working on. One solution that will be available soon, certainly by the time Nordic is operating around the clock, is the time-based equivalent of Renewable Energy Credits. These are called T-EACs for “Time-based Energy Attribute Certificates.” Nordic would simply buy T-EACs for every hour in every day in the year.

Alternatively the same contribution as is made for emissions from fish feed could be made for emissions from 24/7 demand not matched by renewable supply. RCEA could supply these figures.

Emissions from transporting sludge to central valley
Nordic wants to transport large amounts of fish waste to the central valley for composting.  A permitting condition should be serious attempts by Nordic to work with local forest and recycling organizations in the next three years to create a composting facility as a local option with a report back prior to the first harvest of fish and a requirement the fish waste be used locally if the Planning Department judges it feasible based on the report.

Emissions from 1.6 million miles annually of diesel trucks
In this case, mitigation is simple: a permitting condition should be that zero emission trucks (ZET) be used. ZETs with a 19 metric ton capacity are on the market and a new state program was just announced in August: “Privately owned and nonprofit trucking fleets of 20 or fewer vehicles and with an annual revenue of less than $15 million are eligible and will have access to funding that can cover costs related to the purchase and operation of zero-emission trucks (ZETs).”[1] An alternative to electric trucks is hydrogen. Because of the new Humboldt Transit Authority hydrogen buses and plans to connect all the way to the Bay Area, hydrogen fueling should be available by the time Nordic has product to sell. By 2028 green electrolytic hydrogen made from water with renewable energy will be available according to the HTA plans.

Emissions from high global warming potential refrigerants
We prefer a condition that requires Nordic to use ultra-low (<10 GWP) refrigerants. If this condition is not applied we suggest these conditions:

  • The permit should specify that regulations already passed by the California Air Resources Board apply on the date they go into effect. That is, a permit in 2022 does exempt Nordic from requirements that will go into effect in 2025 or 2030.
  • The permit should specify that when the refrigeration/cooling/heating system is designed Nordic must publish the design along with the refrigerants to be used, their global warming potential and the leak rates commonly agreed upon for each refrigerant in the equipment Nordic is planning.
  • An annual report must list the emissions of refrigerants due to leaks or end-of-life, or repair emissions for the whole facility. If these exceed 5,000 metric tons annually, they must be mitigated as are emissions from fish feed.

Financial guardrail measures to protect the County and the Bay and Ocean


1.     Hold a closed session to review Nordic’s detailed financial statements and forecast for construction capitalization with an independent investment banker before issuing any permits. Such a report is available through a Norwegian on-line firm using documents publicly available in Norway.

2.     Require a bond of $20 million so the mill site clean-up can be completed even if the American subsidiary of Nordic does not survive as a company. Add an addition $10 million bond to ensure the remains of an incomplete Nordic site are properly disposed of in the same situation.

3.     Require insurance to cover the many major environmental problems that could occur, such as release of fish into the Bay or contamination of our sustainable aquaculture (Bay oysters) by Nordic effluent drawn back into the Bay. If an insurance company evaluates Nordic’s plans and finds them as solid as Nordic believes them to be the policy should be reasonable but our Bay and ocean resources will be protected.


1.     Permit only a moderate sized facility. Aquafarms in the US that produce 1,000 metric tons a year are profitable and the technology is proven. That would be a reasonable starting point. If that is too small for profitability given the clean-up required, allow up to 5,000 metric tons of production a year. After three successful cohorts, a permit for another 5,000 tons could be applied for – the new Erik Heim/Marianne Ness model.

2.     OR: Segment the permit into three to five consecutive operational stages/levels and require adaptive management to ensure threats are managed if they occur. There should be contingency clauses that allow the County to rescind the permits based on occurrence of events that permanently damage the Bay or the ocean ecology or the failure of Nordic to meet permit conditions.

Nordic talking points

350 Humboldt is one of three organizations that appealed the Planning Commission’s approval of the Nordic aquafarm project. The other groups are the Redwood Region Audubon Society Chapter, and the Humboldt Fishermen’s Marketing Association. The appeal will be held in front of the Board of Supervisors Wednesday September 28. To have any chance of stopping or modifying the project we need many people to attend the hearing and comment. The hearing is at the Courthouse in Eureka in the Board Chambers and starts at 9 am, and if you are going to comment in person you will want to be there at 9 am to sign up to speak. There will be about an hour of presentations from Nordic and the three appellants and then a chance for the public. You may also comment on Zoom. Instructions are above and can also be found on September 26 at

If you are preparing comments, here are topics to consider along with some resources.

  1. Importance of mitigating climate change:
    1. Sea level rise:
    2. Floods: Flood in Pakistan:
    3. Droughts: News articles re CA also Colorado river
    4. Effects of high temperatures:
  2. Fish feed in global context and salmon farming compared to other protein sources:
  3. Fish feed, GMO, food conversion ratio:
  4. Need for and availability of zero emission trucking: New analysis from RMI shows that 65 percent of medium-duty and 49 percent of heavy-duty trucks are electrifiable today.
  5. Climate damage from refrigerants (Nordic refuses to say what refrigerants and how much they will use but will devote 25% of power to cooling).
  6. Sea level rise and Nordic: What are projections for flooding on roads Nordic will have to use for shipping fish feed in and fishes out?  Hopefully someone from Aldaran’s group will address this.
  7. Local use of the fish byproducts from Nordic that they plan to send to the central valley. Hopefully, someone from Zero Waste Humboldt will address this.
  8. Impact of Nordic’s greenhouse gas emissions: The EPA provides a calculator that shows that 3 million metric tons of CO2 (which is what we estimate Nordic will emit over 30 years at full build-out) is equivalent to burning of 6,945,634 barrels of oil, or running 7.5 gas powered powerplants for a year or consuming 294,695,481 gallons of diesel. Given the fact that the IPCC says we must reduce emissions worldwide by 50% in the next eleven years to have a hope of keeping warming to 1.5°C, approving a project with this much negative impact on the climate cannot be justified to our children, and most of all to the world that is clearly threatened with climate catastrophe.