The commercial aquaponics sector in the EU may have been hampered by both the regulatory environment and the availability of subsidies for their primary competitors, horticultural farms and conventional aquaculture operations. The UK’s departure from the EU presents a unique opportunity to review agricultural regulations and subsidies, which in turn could serve as proof that reforms in the EU are required. This point was not lost on the UK Government. Following a consultation in 2018, the future direction was set out in the “Farming for the Future Policy Update” (Department for Environment, Food, and Rural Affairs 2020). On the basis that the UK Government considers the previous system—the Common Agricultural Policy (CAP)—“deeply flawed”, a new system of Environmental Land Management (ELM) was set out to contribute towards the 25-year environment plan and the 2050 net-zero carbon emissions target.
The ELM system moves away from the generic subsidies offered by the CAP and provides financial incentives for certain projects designed to improve the environment. These include using cover crops, planting wildflower margins, woodland planting, and creation or restoration of carbon-rich habitats such as peatlands, wetlands, and salt marshes. However, despite the focus on environmental benefit, the only incentive that could apply to aquaponics is funding for “locally targeted environmental outcomes”. This falls under the second of the ELM’s three-tier design whereby local people, land owners, and farmers are involved in the planning of projects in their local area. This tier is designed to provide support for regional needs as opposed to top-down control of large national or continental projects.
The UK is currently between agricultural oversight systems. Although the UK has formally left the EU, it is still in a transition state where EU systems continue to operate whilst new programmes are designed, developed, and launched within the UK. The ELM is not due to become operational until late 2024, with a pilot system beginning in late 2021 (Department for Environment, Food, and Rural Affairs 2020). During this interim 3-year period, the ELM will go through multiple iterations as plans are created, consulted on, tested, and adjusted.
This is a brief window for new ideas to be discussed, and the government is specifically asking for input and suggestions. In this section, we make three policy proposals to encourage the development of aquaponics to fit into the new ELM scheme and also to consider policy alternatives for the EU. The first of these is an adjustment to the UK ELM grants to ensure that aquaponics projects can apply for funding. The equivalent proposal for the EU is to amend the CFP and CAP such that aquaponics facilities qualify for the equivalent subsidies available to horticultural farms and that more fisheries subsidies are directed towards aquaponics projects. The second proposal is a review of organic certification guidelines so that aquaponic production methods become eligible for certification. The final proposal is a suggestion to clarify the regulatory landscape so that clear aquaponics licencing guidance can be offered and the application process streamlined.
For each proposal, we include a qualitative evaluation based on the Evaluation stage of the Rationale, Objectives, Appraisal, Monitoring, Evaluation and Feedback (ROAMEF) framework set out in HM Treasury’s Green (HM Treasury 2018) and Magenta (HM Treasury 2020) Books. The Rationale stage is assumed through the desire of the ELM to create “a productive, competitive farming sector – one that will support farmers to provide more home grown, healthy produce made to high environmental and animal welfare standards” (Department for Environment, Food, and Rural Affairs 2020). Whilst written from the perspective of the UK, the proposals address global issues for commercial aquaponics: funding opportunities, legislation, and the certification and marketing of produce. We hope that our recommendations can inform policy making in the UK, EU, and further afield.
Proposal 1: Make aquaponics eligible for ELM grants
One of the aims of the ELM is to improve the resilience of the supply chain (including the range of supply sources), a goal that could be facilitated by an emerging aquaponics industry producing food in new locations (including cities). This would shorten the supply chain, increase food production in the UK, and contribute to food security goals given that only 53% of food consumed in the UK is produced there (UK Government 2020).
The ELM seeks to improve environmental sustainability (and reduce emissions) by offering grants aimed at supporting innovative agricultural technologies and equipment. It specifies two main types of grants:
Smaller grants: for improving performance, reducing emissions, and benefiting the environment
Larger grants: targeted at higher-value or more complex investments, aiming to transform the performance of existing businesses
Whilst the proposed list of smaller grants does not include anything targeted towards aquaponics, the larger grants category is more flexible and could be open to aquaponics-related applications. The UK should use the opportunity of switching from the CAP to ELM to make it clear to investors and operators that aquaponics is a desired food production system that it sees developing from an emerging industry into an established and growing industry.
As discussed above, securing investment is the main barrier to the realisation of commercial aquaponics (Turnšek et al. 2020). Without investment potential, aquaponics projects look to grants but have found the eligibility criteria confusing (Hoevenaars et al. 2018). A Web of Science searchFootnote 3 for the number of peer-reviewed publications in “aquaponics” research shows an increase in publications every year, and it is likely that as research into technologies in this sector moves forward, yields will go up and costs come down.
As such, we suggest that aquaponics be listed as an eligible industry for funding in both the small and large grant categories (Table 1). The smaller grants would enable new facilities to open and sustain the losses that are often encountered in the first year of running a complex aquaponics system (Quagrainie et al. 2018). The larger grants will enable experienced operators to open large-scale facilities and develop new technologies and systems that will increase yields or reduce costs
The ELM guidance documentation should be expanded to include specific references to the value of aquaponics and to direct applicants to the funding available to the industry. The United States Environmental Protection Agency (2016) provides detailed business planning documentation covering marketing, operations, and financial strategy for aquaponics operators. This guidance could form a template for the UK and other countries looking to adopt similar measures.
The aquaponics industry should be included in the discussions that take place about the development of the ELM scheme. The ELM states that the UK Government wishes to discuss and consult with key stakeholders such as the National Federation of Young Farmers Clubs, National Farmers Union, Country Land and Business Association, and the National Trust. We suggest that this should also include The Aquaponics Association.
Changes to the ELM could address the lack of commercial investment in aquaponics facilities and the subsidisation of its primary competitors in the UK. Equivalent results could be achieved in the EU by making agricultural subsidies and grants available for aquaponics under the CAP and importantly by promoting this opportunity to farmers, investors, and legislators.
Proposal 2: Make aquaponics eligible for organic certification
“Organic” is usually defined as encompassing products that are environmentally and socially sustainable whilst avoiding the use of artificial fertilisers and pesticides (Department for Environment, Food, and Rural Affairs 2016). As discussed above, EU organic certification prohibits both soil-less and Recirculating Aquaculture Systems and therefore excludes both plant and fish production by aquaponics. This arbitrary distinction prevents aquaponics farmers from achieving the organic prices that would enable them to flourish. With the UK’s departure from the European Union, this is a clear opportunity for the UK to take the lead in creating a regulatory environment friendly to aquaponics. Mitigations to the organic standard could be made to include aquaponics whilst protecting the sustainability goals of the certification scheme. Soil-less plant production could be allowed provided that the media used was of natural origin, met the remainder of the requirements, and could be shown to develop and sustain a diverse ecosystem equivalent to that of organic soil. Fish production in recirculating aquaculture could be included with similar caveats to those employed by the RAS Module of the Aquaculture Stewardship Council (Aquaculture Stewardship Council 2020), namely, water abstraction and discharge, waste production, and energy use, along with existing welfare (such as stocking density) and sustainability conditions of the organic standard.
Our second proposal is to allow certification of aquaponic production in soil-less and Recirculating Aquaculture Systems as organic (Table 2). The UK has a growing demand for organic products (Nechaev et al. 2018; Zhao and Dou 2019), and the UK organic market is worth an estimated £2.45bn (The Soil Association 2020). Certification of aquaponics as organic could help the UK meet this increasing demand. A key benefit of aquaponics lies in its short supply chain, which could be located entirely within the UK. Existing conventional agriculture and horticulture farmers who sell their organic produce in the EU would still be able to apply for an EU organic label and would be unaffected by this modification of the UK certification criteria.
The introduction of this modification allowing hydroponics and aquaponics into the certification criteria could be accompanied by a marketing scheme with participation of the newly certified projects. This would boost consumer awareness, discussed above as a barrier to consumer purchasing, and would provide an incentive for the creation of new projects that would benefit from being first-to-market through the government marketing scheme.
Proposal 3: Clarify and streamline the aquaponics licence application process
As discussed above, setting up an aquaponics project requires the involvement of up to five government organisations, with much of the regulatory responsibility falling to the Fish Health Inspectorate, outlined in the regulatory toolkit developed by CEFAS as guidance for the aquaculture portion of an aquaponics business (Centre for Environment, Fisheries, and Aquaculture Science 2020). This uncertainty has hampered investment because of the legal risk.
Our third proposal is to simplify this process by the integration of the existing CEFAS regulatory toolkit into a centrally produced DEFRA toolkit (Table 3). Templates could be created for the common project scenarios to streamline this application process (e.g. small-scale projects tend not to require planning permission, water abstraction, and discharge licences). Scenario-specific templates to integrate rules, such as the use of aquaculture wastewater for crop production, or when fish stocks are imported and transported (regulated by the Fish Health Inspectorate and the Animal and Plant Health Agency, respectively), would simplify the application process for these small projects and could allow streamlining of the approvals procedure. Encouraging communication and overlap between advisory bodies to develop a cohesive regulatory framework for aquaponics would not only benefit new starters to the industry during the planning and application process, but also provide longer-term advantages for the sector. Recent surveys of aquaponics practitioners in Europe show a higher level of experience and confidence in aquaculture production than in horticulture (Villarroel et al. 2016; Turnšek et al. 2020). Integrating aquaculture guidance from CEFAS with agricultural guidance may encourage more individuals with horticultural or agricultural knowledge into the sector, improving and advancing the currently weaker side of the business. The increased oversight provided by a cohesive regulatory framework may have a risk reduction effect, for example, regarding food safety concerns in aquaponics. Guidance on, for example, nitrate accumulation (Pérez-Urrestarazu et al. 2019) and pathogen control (Weller et al. 2020) may reassure investors whilst providing robust standards to protect the industry against a potential crisis.
Investors want to see a route to enterprise profitability, which means operating on a large scale. Larger projects may require new applications for planning permission, water abstraction, etc. A clear route to converting the licencing from small to large scale is needed. If there are legal uncertainties when a project grows to a certain size, this could prevent projects from starting. Investors expect problems, but legal barriers are often the most challenging because they are outside the control of the project.
Reducing legal uncertainty requires showing a clear path for applicants (and their potential investors) to progress through permitting quickly, with clear criteria and guidance for compliance.