1. Introduction ................................................................................................................ 1

2. Understanding standard setting, accreditation and certification ................................ 2

3. Purpose, justification and scope of the standards ...................................................... 3

3.1 Purpose of the standards ...................................................................................... 3

3.2 Justification for the standards .............................................................................. 3

3.3 Scope of the standards ......................................................................................... 4

4. Process for creating the standards .............................................................................. 5

5. Content of the standards ............................................................................................. 7

Issue 1: Legal compliance .......................................................................................... 7

Issue 2: Land and water use ....................................................................................... 8

Issue 3: Water pollution and waste management ....................................................... 9

Issue 4: Genetics ...................................................................................................... 11

Issue 5: Feed management ....................................................................................... 12

Issue 6: Health management, veterinary medicines and chemicals ......................... 13

Issue 7: Social responsibility and user conflict ........................................................ 15

6. Definitions and formulas .......................................................................................... 18

7. Strategy for responding to public comments on the standards ................................ 22

8. List of Process Facilitation Group members ............................................................ 24

9. List of Technical Working Group members ............................................................ 24

Aquaculture is the fastest growing food production system in the world. Global production from aquaculture is growing substantially and this trend is projected to continue. Aquaculture provides increasingly significant quantities of fish and other aquatic food sources for human consumption and is a key source of protein. The industry also creates millions of jobs on and off the farm. With appropriate management, aquaculture can be environmentally and socially sustainable, meet the growing need for aquatic foods and contribute to food security, poverty reduction and sustainable economic development. As with any rapidly growing activity, the growth in aquaculture production has raised concerns about negative social and environmental impacts related to farming, such as water pollution, the spread of diseases and unfair labor practices at farms. And as in any industry, there are some businesses addressing these issues well and some who are not doing so at all or are doing so poorly. It is important that we face the challenge of promoting and spreading practices that contribute to resolving these issues, while eliminating or reducing those that have a negative impact.

One solution to this challenge is creating standards for responsible aquaculture production, as well as a process for certifying producers who adopt the standards. Standards, when adopted, can help reassure seafood buyers, either throughout the value chain or at the consumer level, that aquaculture products do not have adverse impacts on environmental or social sustainability. One way buyers can support sustainability is by purchasing certified products that have been produced in compliance with these standards. Standards and certification systems also are valuable because they can provide added confidence to consumers that compliance with government and inter-governmental requirements has been achieved by providing additional verification and documentation of such compliance. Through a multi-stakeholder process called the Pangasius Aquaculture Dialogue (PAD), measurable, performance-based standards for the pangasius aquaculture industry are being created. The standards, when adopted, will help minimize the key negative environmental and social issues associated with pangasius farming. The first draft of the standards, presented in this document, is based on sound science and was created by consensus among the 250-plus stakeholders who have been involved in the PAD since it began in September 2007.The PAD is coordinated by World Wildlife Fund (WWF). Feedback received during the 60-day comment period will be used by the PAD‟s technical working groups (TWGs), as well as the Process Facilitation Group (PFG) that manages the PAD, to revise the standards. The revised standards will then be posted for a second 60-day public comment period. Again, input received during that period will be used by the PFG and TWGs to revise the standards, which will be presented to the full group of PAD participants for final approval.

Certification is the verification of compliance with a set of performance-based standards. Certification schemes encompass the processes, systems, procedures and activities related to three functions: 1) standard setting, 2) accreditation and 3) certification (i.e., verification of compliance, also known as “conformity assessment”). Certification may also include the labeling of companies, practices, operations or products that conform to the standards. For aquaculture certification to be credible, it must be consistent with rigorous procedures for standards setting, accreditation and certification. The certification scheme must establish and maintain the confidence of the producers and industry operators involved in aquaculture activities, as well as the confidence of other stakeholders, including consumers, governments and civil society groups.

For standard setting, which is the process of creating the required standards, it is essential that the process is not dominated by one, or a few, stakeholder groups. It is critical that aquaculture certification schemes adequately incorporate multi-stakeholder involvement in an inclusive, transparent process. Attention to the needs and conditions of small-scale producers and their communities is particularly important. If the standards are to be global, then they must include stakeholders from around the world.

The “Code of Good Practice for Setting Social and Environmental Standards,” created by the International Social and Environmental Accreditation and Labelling (ISEAL) Alliance, provides the criteria by which standard setting must take place. WWF has been accepted as an associate member of ISEAL because of the fact that the ISEAL criteria are the foundation for the process used by the PAD and seven other aquaculture Dialogues coordinated by WWF. For more information about the ISEAL criteria, go to http://www.isealalliance.org/index.cfm?fuseaction=Page.ViewPage&PageID=1046 For accreditation, which is the process of authorizing entities to verify compliance with the standards, it is important that there is no conflict of interest between the entity coordinating the standard setting process, the entity that manages the standards, the entity that accredits third-party certification bodies, or the entity that undertakes the third-party certification. Sufficient separation is required between these components to maintain independence and credibility. For certification, which is the process of verifying compliance with the standards, it is critical that there is no conflict of interest between the entity that conducts this function (i.e., the certification body) and the farm seeking certification, the entities that undertook standard setting, and the entity that manages the standard or the entity that accredits the certifiers. For this reason, third-party certification is the most robust, credible and trustworthy process. Through this process, an accredited, independent certification body analyzes the process or product, and reports on compliance.

The purpose of the PAD standards is to provide a means to measurably improve the environmental and social performance of pangasius aquaculture development and operations.

The justification for the standards as agreed by consensus at the 1st PAD meeting is based on the following points:

Pangasius is increasingly popular among consumers. While it used to only be eaten in Vietnam, it is now exported to more than 100 international markets.

Pangasius farming is experiencing an extremely fast growth, with production growing more than 60-fold in the last decade.

There is a desire by the stakeholders participating in the PAD to safeguard the sustainability of pangasius farming and consumers‟ safety, therefore maintaining quality and productivity.

There is a need to be proactive rather than reactive to problems.

There is a desire for a multi-stakeholder, consensus-based, metrics-based and transparent set of standards.

The PAD is creating criteria, indicators and standards for addressing the negative social and environmental issues related to pangasius aquaculture. Criteria are the areas to focus on to address the issues. Indicators are what to measure in order to determine the extent of the issue. Standards are the numbers and/or performance levels that must be reached to determine if the impact is being minimized.

Pangasius aquaculture and its value chains generally consist of the following operational components:

Supply chain inputs (e.g., water, seed, feed and chemicals)

Production systems (e.g., ponds, pens and cages and the other equipment and operations associated with production)

Processing

Chain of custody (e.g., from production, through processing, export, import, distribution and retail)

These standards are designed to address the most significant impacts of pangasius aquaculture, which are mostly from the production systems and the immediate inputs to production (e.g., feed, seed and water). These standards apply to production systems currently used for pangasius production, such as ponds, pens and cages.

1 Common name in Vietnam: tra 2 Common name in Vietnam: basa

The unit of certification refers to the extent of the specific aquaculture operation to be assessed and monitored for compliance with the standards. The size of the production operation can vary considerably and needs careful consideration when determining the entity that will seek assessment for compliance. As the focus of these standards is on production and the immediate inputs to production, the unit of certification will typically consist of a single farm or other production unit. The unit of certification may also encompass a group of operations that should be considered collectively as the aquaculture operation under consideration, especially in the case of small-scale farms involving the same species and similar management regime. For example, they may be in close proximity to each other, share resources or infrastructure (e.g., water sources or effluent discharge systems), share a landscape unit (e.g., a watershed), and/or have the same production system. Farms will also have cumulative effects, which will often be the main environment issue. Determining the unit of certification requires that an appropriate spatial scale and level of potential cumulative effects be considered. The certification body will determine the ultimate unit of certification and procedures for auditing.

The draft standards for pangasius aquaculture are being developed through transparent, consensus-oriented discussions with a broad and diverse group of stakeholders (e.g., producers, buyers, NGOs, researchers, governments, multi-lateral organizations, development groups and allied businesses). The PAD is coordinated by WWF. The steps in the process, to date, are described below:

WWF notified ISEAL of the intent to apply the “Code of Good Practice for Setting Social and Environmental Standards” to the PAD. ISEAL approved this step and accepted WWF as an associate member on behalf of all of the Aquaculture Dialogues.

Participation in the PAD is a voluntary process and anyone with an interest can be involved. To maximize involvement, the inaugural meeting of the PAD – as well as later PAD meetings – were publicized on the Aquaculture Dialogues website, in seafood trade publications, and in several other publications read by key stakeholders. Key stakeholders were also asked by WWF and others to participate in the PAD in order to ensure its credibility.

PAD participants agreed on eight key environmental and social issues associated with pangasius aquaculture and on the principles to address each issue.

PAD participants agreed on the objectives of and justification for the PAD, as well as the PAD process.

PAD participants agreed on a governance structure for the development of the standards. This includes the following:

Seven TWGs were formed to address the eight key issues. (See list of TWG members in Section 9.) Two of those issues (health and veterinary medicines/chemicals) are addressed by one TWG and have now been merged into one issue.

TWG members held discussions by e-mail and through in-person meetings until they reached consensus (although sometimes not unanimity) on the PAD draft principles, criteria, indicators and standards.

The draft principles, criteria, indicators and standards were presented to the PAD participants at a PAD meeting. Their input was used by the TWGs to revise the suite.

The PFG and TWG coordinators compiled the draft principles, criteria, indicators and standards and posted them for public comment.

Pangasius aquaculture operations must, at a minimum, respect and adhere to national and local laws. The PAD may develop sustainability standards beyond those required by law but the basis for aquaculture must be compliance with the legal requirements of the producing country. Principle Locate and operate farms within established local and national legal frameworks. Criteria Compliance with local and national legal frameworks. Indicators Documented compliance with local and national legal frameworks. Standards The following standards are proposed:

3 In Tilapia Aquaculture Dialogue –„evidence of lease‟

4 Pond, cage and pen-based

The responsible use of land and water resources is fundamental to sustainable pangasius aquaculture. The siting, design and construction of pangasius farms often have a negative impact on other users and the environment. To address this, a growing number of countries have established land and water use plans. Some also have approved aquaculture development plans and specific zoning of aquaculture activities. Respecting these planning decisions forms the basis for appropriate pangasius farm development.

More specifically, regarding land use, responsible pangasius aquaculture should not result in the loss of wetland habitat through conversion to aquaculture use or though impacts from siting facilities in wetlands. It is also important that pangasius aquaculture does not adversely affect the hydrological regime in the area of farm operations. For example, water movement should not be restricted or altered in such a way that aquatic animal movements are affected by the aquaculture operation. In addition, use of the water system by other users should not be adversely affected. For example, navigability of rivers should not be blocked or made more hazardous by pangasius aquaculture facilities. The level of water use also is a major concern. Therefore, the amount of water taken out of the river system and not returned must be managed to remain within reasonable limits.

Principle

Farms4 must be located, designed, constructed and managed to minimize negative impacts on other users and the environment.

Criteria

Compliance with official aquaculture development plans.

Wetland conversion.

Water movement.

Water use.

Indicators

1. Location of farm in relation to official aquaculture development plans.

2. Conversion of wetland(s) to establish the farm5.

3. Impediment to navigation, the natural hydrological regime or aquatic animal movement.

4. Amount of water abstracted per ton of fish produced.

5 Relevant only to farms established after the PAD standards have been finalized 6 Wetlands as designated by the RAMSAR convention were of particular concern. Also mentioned for consideration were (1) national parks (2) conservation of internal habitats or buffer zones in and around existing farmed areas (possibly measurable by species/unit area) and terrestrial as well as wetland habitat

Standards

1. Farms must be constructed in an area that complies with any approved aquaculture development plans effective in the area.

2. Farms must not be constructed in wetlands6 or protected areas, such as national parks or areas listed in the World Database on Protected Areas (http://www.wdpa.org/). In countries which are flood prone (e.g., Bangladesh), up to 30 percent of the flooded area can be converted.

3. Farms must not impede navigation, the natural hydrological regime or aquatic animal movement. Farms must not present hazards to the transportation of local people. Farms must not occupy more than 25 percent of a water canal.

4. The ratio of water abstracted per unit of fish production must not exceed 5,000 m3/ton of fish produced for a given culture period.

Pangasius aquaculture can have a negative effect on water quality, particularly when the farming leads to excess effluents and nutrients in pond sediments. We recognize it is difficult to operate commercial pangasius culture systems without some impact on the water used, whether diluted or concentrated, immediately detectable, or contained in the sediments. However, it is important to control ammonia, nitrogen, phosphorous and Biological Oxygen Demand and to develop specific water quality standards for them. Monitoring of effluent water quality and pond sediments is critical to ensuring the aquaculture operations are not generating unacceptable levels of pollution. Related to this is the issue of water exchange between ponds and other water bodies, which should be controlled by managing the percentage of water that is transferred.

Waste management is closely related to water pollution issues. Sludge from ponds should be disposed of properly and not discharged into public water bodies, where it can be a significant pollution source. Another major waste stream is dead and moribund fish removed from ponds. Proper disposal (e.g., burial or incineration) is necessary to ensure that this waste does not impact the environment. Principle Minimize the negative impact of pangasius farming on water resources. Criteria

Water quality of effluents.

Nutrients in pond sediments.

Sludge discharge.

Water exchange.

Waste management.

Indicators

1. Percentage change of Total Ammonia Nitrogen (TAN) between pond and inlet7.

2. Dissolved Oxygen (DO) concentration in water discharged.

3. Percentage change of 5-day Biological Oxygen Demand (BOD5) between pond and inlet.

4. Percentage change of total phosphorus between pond and inlet.

5. Percentage change of total nitrogen between pond and inlet.

6. Direct discharge of sludge.

7. Evidence of a sludge repository and sludge use.

8. Percentage change of turbidity between pond and inlet.

9. Percentage of Total Nitrogen (TN) in pond sediments.

10. Percentage of Total Phosphorus (TP) in pond sediments.

11. Maximum daily percentage of water exchange.

12. Disposal of dead/moribund fish removed from the pond.

Standards

1. TAN: maximum 700 percent change.

2. DO in water discharged is 3mg/l or above.

3. BOD5: maximum 40 percent change.

4. Total phosphorus: maximum 150 percent change.

5. Total nitrogen: maximum 120 percent change.

6. No direct discharge of sludge in public water bodies.

7. There must be evidence of a sludge repository and of sludge being used.

8. Turbidity: maximum 20 percent change.

9. TN in pond sediments: maximum of 4.3 percent at harvest.

10. TP in pond sediments: maximum of 1.2 percent at harvest.

11. Maximum daily percentage of water exchange should not exceed 25 percent, except during harvest.

12. Proper disposal of dead/moribund fish removed from the pond (e.g.. burial or incineration).

Pangasius aquaculture raises a number of important issues in relation to genetics, such as impacts to indigenous species when introduced as exotic species, the importance of preventing escapes, the need to maintain genetic diversity, and the problems of Genetically Modified Organisms (GMOs) and hybridization.

Pangasius aquaculture can impact habitats and/or the genetic integrity of local pangasius populations if the farming occurs in locations where the farmed species is not indigenous or if a self-recruiting stock is not established. This type of aquaculture also can impact the environment if measures are not in place to minimize escapes from production systems, especially via drainage systems and during flood events. Genetic changes in hatchery populations also are an important aspect of pangasius aquaculture to be addressed. Some genetic changes are likely in any stock of fish that are bred in captivity over several generations. Pangasius, in its natural habitat, has a complex population structure. Therefore, captive breeding may result in the mixing of genetically distinct stocks. Because it is not sustainable to base pangasius aquaculture on wild-caught fry or broodstock, minimizing escapes of captive-bred fish is essential to preventing genetic impacts on wild populations. A range of techniques and practices are available to prevent escapes. Escape reduction also is a good business practice, as there are economic incentives to prevent escapes. The use of GMOs and hybrid seed creates additional issues regarding genetic pollution and impacts on farm stocks and wild populations. These impacts can be prevented by avoiding the use of GMOs and hybrid seed.

Principle

Minimize impacts of pangasius aquaculture on the genetic integrity of local pangasius populations.

Criteria

Non-indigenous species.

Genetic diversity.

Escapees.

GMOs and hybridization.

Indicators

1. Farming of pangasius in locations where that species is indigenous or has a self-recruiting stock established.

3. Measures in place to minimize escapes.

4. Use of GMO or hybrid seed.

Standards 1. Pangasius farming shall take place only in locations where that species of pangasius is indigenous or has a self-recruiting stock established .

2. Seed shall be sourced from pangasius populations already established in the river system8 used by the farm. 3. Farms shall apply Better Management Practices (BMPs) to minimize escapes from production systems (including drainage systems), and to reduce the number of escapes during floods. BMPs include:

8 The term “river system” must be defined to require seed sourcing from appropriately local areas. Otherwise, one could argue that the Mekong River, for example, is one large “river system,” and source seed from Laos for a farm in Vietnam. 9 Metrics have not yet been defined for this BMP

Bund height above high water/flood levels.

Traps on water outlets to catch/kill escapes (e.g., juvenile fish, chemical treatment of effluent ponds).

Bund construction / quality / engineering standards9

4. No GMO or hybrid seed shall be used.

“Feed” refers to all feeds or feed items, regardless of where or how they are produced, and applies to all farms applying for certification. Farms that meet the standards should be able to demonstrate compliance regardless of whether their feed is made by a commercial feed mill or on site.

The use of fish meal and fish oil in pangasius aquaculture, as in other forms of aquaculture, is a key issue of concern. Concerns center around the sustainability of fishmeal and fish oil sources as well as ensuring that the amount of fish oil and fishmeal used to produce pangasius does not use more fish than are produced by farming. In addition, the practice of using locally sourced fish to feed directly to pangasius can have impacts on the environment and biodiversity.

The direct use of fish and fish products to feed pangasius is an unacceptable practice. If fish products are to be used in the manufacturing of feed, they should be from a sustainable source, should not be from a fishery where unacceptable levels of by-catch are caught and should not pose a threat to endangered species that may be inadvertently included in the by-catch. Feed suppliers can ensure that the amount and sources of fish products used in feed, or used as feed, are from sustainable sources.

On-farm feeding management and feeding efficiency are important to achieving the efficient use of available feed resources. Good feed management on the farm is essential to achieving efficient use of available feed resources and minimizing waste. Feeding rates and conversion of feed to fish should be within good standards of efficiency and consistency. Fish Feed Equivalence Ratio (FFER), and the Coefficient of Variation (CV) of the economic Feed Conversion Ratio (eFCR) provide useful means to measure whether fish product use is being managed and wastes are being minimized.

Principle

Use feed and feeding practices that make efficient use of available feed resources and minimize waste.

Criteria

Efficient use of fish products.

Efficient management of fish feed on the farm.

Indicators

1. Fish product source.

2. eFCR.

3. CV of eFCR for given size of fish.

4. FFER.

Standards

1. No direct use of fish and/or fish products as feed is permitted. Fish product source must have documented evidence provided that all fish products used as feed, or used in the manufacture of feed:

Comes from an approved list (See definitions and formulas in Section 6.)

Are not in the “threatened categories” on the International Union for Conservation of Nature and Natural Resources red list (www.iucnredlist.org/), which are Vulnerable, Endangered and Critically Endangered. Also, are not from fisheries that pose a threat to species in these categories.

Are from fish stocks that have an average score greater than 7.5 with no individual indicator below 6.0, according to Fish Source (http://www.fishsource.org/site/fisheries)

2. eFCR must be less than 1.75 for the complete production cycle.

3. CV of the eFCR must be less than or equal to 15 percent.

4. The fish feed equivalence ratio (FFER) must be less than 0.5.

Managing the health of farmed pangasius stocks depends on the overall management of the farm, including the reasonable, responsible use of veterinary medicines and chemicals. This must be undertaken in a manner that focuses on ensuring fish health and maintaining food safety and quality, while also minimizing the impacts to human health and the environment. A key measure of fish health is survival during the grow-out period. Pangasius farming can be best served by each farm having a comprehensive health management plan. Such plans should promote preventative, proactive treatments over chemical and veterinary medicine use. Regular monitoring of fish for stress or disease and the proper removal and disposal of mortalities are important components of implementing a plan to ensure optimal fish health and reducing the impact of diseases on other farms and the environment. Veterinary medicines and chemicals may play an important role in maintaining fish health and survival. Veterinary medicine and chemical use should be restricted to those approved for aquaculture applications by the country of production and those which are not banned for use in food fish by the importing country. Fish stocking density may be an important element of maintaining fish health and welfare. There is always a need to find the right balance between space efficiency, farming performance, disease control and fish welfare. Guidance on maximum fish densities for ponds and cages, especially at harvest, is an important tool for maintaining fish health. Principle Maximize fish health; ensure food safety and quality while minimizing ecosystem and human health impacts. Criteria

Survival.

Veterinary medicines and chemicals.

Record-keeping.

Fish welfare.

Indicators

1. Survival during the grow-out period.

2. Follow legislation or regulations on the use of veterinary medicines and chemicals.

3. Veterinary medicines and chemicals use.

4. Treatment recording.

5. Maximum fish density.

6. Documented health management plan and farm-book.

Standards

1. The annual survival rate must be at least 80 percent, on average.

2. Use only veterinary medicines and chemicals approved for aquaculture by relevant local authorities and which are not banned for food fish use in the importing country.

3. The use of veterinary medicines and chemicals shall:

Only be prescribed and administered by people trained to do so;

Only be based on a diagnosed condition and follow all label specifications and

Respect the withdrawal period or apply a period of 750 degree-days for those without documented withdrawal period times.

In addition, antibiotics shall never be used as growth promoters or for preventive (prophylactic) treatment;

4. Farmers must keep a record of the name, dates, amounts and withdrawal times of all veterinary medicines and chemicals used in hatchery and grow-out facilities.

5. Fish density shall not exceed 15 and 80 kilograms, respectively, per cubic meter for ponds and cages (generally at harvest).

6. Farms must create and implement, under the signed approval of a certified health specialist, a comprehensive health management plan that promotes proactive treatments (e.g., vaccines and probiotics) over chemical and veterinary medicine use. The plan should also include regular monitoring of fish for signs of stress or disease; proper removal and disposal of mortalities; and appropriate storage and handling of chemicals.

Principle

Develop and operate farms in a socially responsible manner that contributes effectively to community development and poverty alleviation.

Criteria

Conflicts with users and local communities.

Benefits to local communities.

Labor rights.

Indicators

1. Freedom of association.

2. Collective bargaining.

3. Transparency in wage setting.

4. Child labor10 without jeopardizing schooling.

5. Forced labor.

6. Bonded labor.

7. Discrimination.

8. Safety awareness.

9. Corrective actions in response to accidents.

10. Insurance.

11. Minimum wage.

12. Labor contracts.

13. Complaints by employees.

14. Complaints by people in the local communities.

15. Preferential employment within local communities.

Standards

1. Employees11 shall have free access to worker associations or permission to create a worker association if one does not exist.

2. Employees shall have the right to collective bargaining.

3. Employees shall have the right to know the mechanism for setting the wages and benefits.

4. Minimum age of permanent workers shall be 15 years old. Children over 12 years old working outside the hours set aside for school attendance could be employed for light work as long as that work does not exceed two hours per day on school days or holidays. Employing temporary workers12 below 18 years old should not jeopardize schooling.

5. Employees shall have the freedom to leave the farm premises by the end of their designated work day and not be forced to work overtime.

6. Employees shall not be obligated to stay on the job to repay debt.

7. Employees shall not suffer any discrimination13 from the employer or other employees.

8. Employees shall be made aware of the health hazards at the work place and how to deal with them.

9. Employers shall record all accidents, even if minor14, and take corrective action.

10. Employers shall ensure that all permanent workers have health and accident insurance.

11. Employers shall offer 110 percent of minimum wage15,16.

12. Employees shall have copies of their labor contract and each labor contract must include a one-month probation period for a permanent job.

13. Farm owners shall draft and apply a verifiable conflict resolution policy for labor that states that conflicts and complaints will be tracked transparently and which responds to all received complaints. At least 90 percent of the complaints should be resolved within one month after being received.17

14. Farm owners shall draft and apply a verifiable conflict resolution policy for local communities that states that conflicts and complaints shall be tracked transparently and which responds to all received complaints. At least 90 percent of the complaints shall be resolved within six months from the date of being received.18

15. Farm owners shall document evidence of advertising positions within local communities before hiring migrant workers.

Databases The databases described below do not offer certification. Rather, the purpose of the databases is to reviewavailable documentation on management and conditions of individual fisheries or regions.

Biological Oxygen Demand (BOD) BOD is the amount of oxygen required by aerobic microorganisms to decompose the organic matter in a sample of water, such as that polluted by sewage. It is used as a measure of the degree of water pollution. It also is referred to as biochemical oxygen demand. (www.answers.com) 5-day Biological Oxygen Demand (BOD5) BOD5 measures the rate of oxygen uptake by micro-organisms in a sample of water at a temperature of 20°C and over an elapsed period of five days in the dark. Change in water quality between pond and inlet The calculation for this is: (value inside the pond – value in the inlet) / value in the inlet Coefficient of Variation (CV) CV is an accepted statistical measure of variability and is calculated as the ratio of the standard deviation to the mean eFCR of the facility. It is calculated using the eFCR value for all ponds harvested in the period between inspections. (See definition of eFCR below.) Dissolved Oxygen (DO)

TAN consists of two fractions, un-ionized ammonia (NH3) and ionized ammonia (NH4+) and is the by-product of protein metabolism. TAN is excreted from the gills PAD Draft Standards for Public Comment Period 1 - April 23, 2009 21

Stakeholders who submit comments on the PAD draft standards must know their comments will be dealt with in a transparent and responsive way. This document describes the proposed strategy to manage the public comments. The strategy will be presented to the PAD for consideration.

The PAD coordinator will submit to the PFG/TWG coordinators all of the comments, as is, after the public comment period ends

TWG coordinators will take the lead in the summarization and prioritization of comments related to the issue(s) their TWG was created to address

General comments (i.e., not issue-specific) will be summarized and prioritized by the PAD coordinator

TWG coordinators will take the lead in compiling the available options for comments concerning their issue(s)

The PAD coordinator will take the lead in compiling the available options for comments/items concerning general issues (i.e., not issue-specific)

TWG coordinators will submit the original comments, the comments‟ summary, prioritization and potential options to their TWG

The PAD coordinator will submit to the PFG/TWG coordinators the original comments, comments‟ summary, prioritization and potential options for feedback that was not issue-specific

TWG members will review the comments‟ summary, prioritization and options and respond to each summary item

The PFG/TWG coordinators will review the comments‟ summary, prioritization and options and respond to each summary item