Amending the Environmental Conservation Law to Prohibit Commercial Octopus Farming
SUMMARY
In an August 2026 reissued report, the Animal Law Committee of the New York City Bar Association endorsed A.8043-C (M. of A. Simone) / S.7421-B (Sen. Martinez), companion bills that would ban octopus farming in New York State.
The Proposed Law would amend the Environmental Conservation Law to prohibit marine hatcheries and on-bottom or off-bottom octopus culture for human consumption across New York’s territories, inland waters, and coastal waters extending three nautical miles offshore, with an exception for scientific or educational purposes. Violations would carry a civil penalty of up to $1,000 per day, per offense. Octopus farming does not currently exist in New York or anywhere else in the United States; the City Bar supports the measure as a preventive step, consistent with bans enacted in Washington and California in 2024 and bills pending in New Jersey, North Carolina, and Congress. The bills passed both houses on June 4, 2026 and await the Governor’s signature.
- Octopuses are sentient and cannot be humanely confined. The report cites the United Kingdom’s 2022 Animal Welfare (Sentience) Act and the London School of Economics review synthesizing 300 peer-reviewed studies that informed it. A Galicia acoustic-telemetry study found wild Octopus vulgaris roamed up to 160,000 square meters weekly — roughly 40 acres — a range the report argues farm tanks cannot approximate.
- Mortality is high and slaughter methods are unresolved. Hatchling survival for O. vulgaris is at best 30–40% at day 40 and under 10% at day 60. The report states no humane stunning or killing method has been established; terminal anesthetic overdose is unsuitable for animals intended for consumption, and ice slurries have been criticized as slow and painful.
- Feed demand would strain wild fish stocks. Octopuses are obligate carnivores with a feed conversion ratio the scientific literature places near 3:1. The report cites the Food and Agriculture Organization’s 2024 SOFIA report that roughly one-fifth of the global marine catch is reduced to fishmeal and fish oil, with 75% of those ingredients going to aquaculture feed.
- Farming poses pollution, escape, and public health risks. Accumulated waste releases ammonia and nitrite; land-based recirculating systems carry energy and emissions estimated at nearly eight times a flow-through system and more than 31 times a cage system. The report notes octopuses can pass through any gap larger than their beak, and that they carry more than 20 human-transmissible diseases, including cholera.
- Existing New York fisheries would bear costs. The report argues that pollution, disease transmission, and competition for wild fish would burden local fisheries and oyster and clam farms, and that fishmeal demand drives up pelagic fish prices.
*Originally Issued February 2026; Last Reissued August 2026
BILL INFORMATION
A.8043-C (AM Simone)/ S.7421-B (Sen. Martinez)- An act to amend the environmental conservation law, in relation to octopus farming in New York.
REPORT
REPORT ON LEGISLATION
BY THE ANIMAL LAW COMMITTEE
A.8043-C (M. of A. Simone)
S.7421-B (Sen. Martinez)
AN ACT to amend the environmental conservation law, in relation to octopus farming in New York.
THIS BILL IS APPROVED
I. INTRODUCTION
The New York City Bar Association, (“City Bar”) through its Animal Law Committee, supports the passage of bills S.7421-B[1] / A.8043-C[2] (“Proposed Law”), identical companion bills to ban octopus farming in New York State.[3]
Octopus farming does not currently exist in New York, or the rest of the country. However, octopus farms are under development around the world and they have the potential to become commercially viable in the U.S.[4] Demand for octopus as a food source has grown nationally and globally. Reported catches have risen from 36,700 tons in 1950 to over 500,000 tons in 2021.[5] While there are no known plans to develop octopus farms in New York, we support New York’s proposed legislation to ban the practice preemptively consistent with other states that have passed similar statutes or are actively considering such legislation.
The City Bar supports the Proposed Law because commercial octopus farming threatens animal welfare, marine ecosystems, public health, and local fisheries, with no clear benefit. Octopuses are intelligent, solitary carnivores needing large amounts of wild-caught fish, and farming would produce pollution, disease risks, and potential escapes that endanger wild populations. Humane slaughter and proper captive care are impossible, and high mortality rates raise serious ethical concerns. Further, neuroscience findings support the fact that captivity of wildlife causes neurological (brain) damage, adding additional concerns of inhumane treatment to such farming operations. As U.S. octopus farming does not yet exist, the proposed law is a preventive, evidence-based measure that protects communities, the environment, and sentient beings.
II. SUMMARY OF THE PROPOSED LAW
The Proposed Law amends the Environmental Conservation Law to add a new subdivision 3 to section 13-0316 to prohibit the operation of a marine hatchery, or the operation of an on-bottom or off-bottom culture of octopus for human consumption in New York State, unless for scientific or educational purposes as authorized by Section 11-0515, relating to licensing The jurisdiction includes all New York territories, inland waters, and New York State waters that extend from the coastline out to three nautical miles offshore.[6] The term “octopus” is defined as a cephalopod mollusk that is a member of the order Octopoda.
The Environmental Conservation Law would be amended to add a new Section 71-0925(7-d) to provide a civil penalty not to exceed $1,000 for each day and each offense. The Proposed Law will be effective sixty days after enactment.
III. BACKGROUND
Octopus farming is a “highly concerning practice”[7] which has quickly gained national momentum. Two states have already banned octopus farming in 2024 – Washington[8] and California.[9] The Proposed Law is similar to California’s in that both bills created new legislation to ban octopus aquaculture for human consumption (with limited exceptions). Washington used an existing statute, the Shoreline Management Act, to make octopus farming impossible to permit and issued a temporary moratorium on all new cephalopod aquaculture applications.
Two other states have similar bills pending, New Jersey [10] and North Carolina. [11] A federal bill is pending in the Senate that would ban commercial octopus farming and prohibit the importation of farmed octopus or their body parts.[12] Chile has proposed a national bill[13] to ban octopus industrial breeding. In Spain, an initiative to ban octopus farming was introduced in 2025 and is under parliamentary consideration in 2026.[14]
As a response to the projected growth of the human population[15] and the decline in native octopus populations, a Spanish seafood multinational company, Nueva Pescanova, (the “Spanish company”) announced in 2019 its intent to build the world’s first commercial octopus farm in a port in the Grand Canary Islands. That proposal sparked alarm amongst scientists and animal welfare organizations.[16] In 2024, the Canary Islands rejected the Spanish company’s environmental plans as insufficient, incomplete and potentially dangerous to wildlife and public health.[17] The Spanish company would have to undergo a full environmental impact statement. The Spanish company recently abandoned its efforts to farm Octopus vulgaris in the Canary Islands.
IV. JUSTIFICATION FOR THE PROPOSED LAW
This report focuses on several arguments in favor of the Proposed Law.
a. Humane and Ethical Considerations
In 2022, the United Kingdom passed the landmark Animal Welfare (Sentience) Act,[18] acknowledging that octopuses[19] are sentient creatures and extending legal protections for their use in scientific research. The passage of the Sentience Act was shaped by a report[20] finding that cephalopods (and decapod crustaceans) have a complex nervous system and the ability to experience feelings such as pleasure and pain. Octopuses possess nine brains: one central brain and eight smaller brains, one in each arm. This unique nervous system allows them to perform complex tasks such as opening jars, solving puzzles and escaping from enclosures. There is very strong evidence of sentience in octopuses,[21] and increasing recognition that the welfare needs of octopuses require targeted protection.[22]
Besides being behaviorally sophisticated, octopuses are solitary (amongst their own species) and territorial creatures that live in complex environments.[23] O. vulgaris inhabit shallow, rocky coastal waters, frequently using tide pools and crevices to hunt or hide from prey. My Octopus Teacher[24] revealed the rich, intertidal zones where O. vulgaris spend their natural life. A recent study of O. vulgaris in Galicia, Spain tagged wild octopuses with acoustic telemetry devices and found that they roamed up to 160,000 square meters per week, equivalent to 40 acres.[25] While research scientists recommend providing an enriched environment to captive octopuses by changing the tank’s landscape, incorporating a variety of live prey, and introducing challenging tasks for them to work through,[26] it is highly unlikely that the aquaculture business will create an environment that remotely replicates the complexity and dynamism of an octopuses’ natural environment. Farming intelligent creatures in sterile, small tanks raises serious ethical concerns, given the detrimental consequences rearing them in groups may have.[27] Studies have shown that octopuses exhibit behaviors that suggest they feel distress; for example, they change in color, texture, and posture when they are in pain or stressed.[28] As with any other species, octopuses suffer when placed in impoverished environments, which negatively affects their behavior[29] as well as their brain.[30] Farming environments, by their very nature, are severely impoverished and stressful. Farming systems would also increase aggression/cannibalism at different life stages.[31] Octopus skin is sensitive and can be easily damaged during handling, transportation, or stressful confinement situations.[32]
Many octopuses, including O. vulgaris, are nocturnal, hunting primarily at night. During the day, they hide in their dens, which they sometimes decorate with shiny objects and shells. The Spanish company planned to use 24-hour periods of light during the reproduction period to speed up the spawning of the females.[33] However, the animal’s natural behavior is to avoid the light, and continued light could induce significant stress.[34] Inadequate shelter in captivity is another stressor for cephalopods.[35] Cephalopods regularly show signs of anxiety in poor captive environments such as irregular swimming patterns, lethargy, agitation, and anorexia.[36]
The high mortality rate of hatchlings in farms is another concern. Young octopuses, known as larva or paralarva, require large amounts of live food to hunt, which will be difficult to obtain in an aquaculture setting. For O. vulgaris, the survival rate in hatchlings is, at best, 30% – 40% at day 40 and less than 10% at day 60.[37] “Young [octopuses] dying of poor nutrition and inappropriate housing conditions are highly likely to suffer poor welfare.”[38]
No humane method to stun and kill octopus for consumption has been established. The only recommended method of humane slaughter for cephalopods currently is terminal overdose by anesthetic. This is inappropriate for octopuses slaughtered for human consumption.[39] The proposal to kill them in ice slurries has been criticized as causing a slow and painful death.[40]
b. Environmental and Sustainability Concerns
Octopuses are asocial, obligate carnivores and cannot survive on plants and algae.[41] Their carnivorous diet demands large quantities of animal protein and they are behaviorally sophisticated.[42] Octopuses are known as “picky eaters” and will not thrive on discarded bycatch of fishermen.[43] Their solitary nature require multiple tanks or compartments, complicating the waste management system.[44] The plan to farm multiple octopuses in a sterile setting will allow feces and uneaten food to accumulate.[45] Decomposition of feces and food fuels bacterial activity that consumes oxygen and releases toxic nitrogenous compounds like ammonia and nitrite.[46] Wastewater from aquaculture is typically discharged into the ocean.[47] Even if the wastewater is filtered before release, residual chemicals and bacteria will be discharged and could linger and harm the local marine environment.[48] Pollution from octopus farming could alter coastal ecosystems, promote harmful algal blooms and harm biodiversity. [49]
While a land-based recirculating aquaculture system (a/k/a RAS) will overcome some of the harm to the local marine environment, its energy use and greenhouse gas emissions are substantial.[50] It has been estimated that a RAS would be almost eight times greater than a flow-through system and more than 31 times greater than a cage system.[51]
A related concern is the sustainability of octopus farming due to the octopuses’ high “feed conversion ratio” (FCR). The FCR is considered an important measure of an animal’s efficiency to convert feed into increased body mass. In aquaculture, a low FCR is desired to optimize feed use, reduce cost, and minimize environmental impact by not overfeeding.[52] For efficient species such as tilapia, FCRs can be as low as 1.4 (1.4 kg. to gain 1 kg. of body weight).[53] Scientific literature suggests an octopus’s FCR is approximately 3:1, thus the weight of feed to sustain an octopus is around three times its weight.[54] Nueva Pescanova claimed that an octopus’s FCRs are closer to 2:1.[55] Sourcing fishmeal and fish oil for octopuses will place more pressure on wild fish stocks.[56] According to FAO’s 2024 SOFIA report,[57] roughly one‑fifth of the global marine catch is reduced to fishmeal and fish oil, and recent FAO‑summarized analyses indicate that 75 percent of these marine ingredients are used in aquaculture feed.[58] The industrial production of fishmeal and fish oil depletes marine resources in traditional fishing areas, reducing the availability of fish for human consumption and driving up the price of fish.[59]
Small forage fish provide a crucial role in marine ecosystems. They are subject to population collapse when high fishing rates are maintained, especially while stock is in rapid decline.[60] Thus, the introduction of farmed octopuses with high FCR rates would lead to competition with wild species for food and habitat, potentially displacing native species.[61] The depletion of forage fish has been shown to reduce the food base of other predators, including seabirds and marine mammals.[62]
c. Escape of Selectively-Bred Octopus Could Pose Risks to Local Habitats
The escape of farm-raised animals into surrounding waters is well documented and has posed disease risk to other species.[63] For example, Chile, the world’s second-largest producer of farmed salmon, has faced many commercial aquaculture crises including the release of millions on non-native salmon into the ocean due to storms and other unplanned events.[64] Octopuses are master escape artists.[65] They have no bones and can squeeze through any space larger than their beak. While the Spanish company plans to raise O. vulgaris in indoor tanks which they claim would prevent escape, no plan is foolproof. Although octopuses are not native to New York, the escape of selectively-bred octopuses into local waters could pose a serious risk to local habitats and animal populations with a high potential of transferring on-farm diseases and antibiotics.[66]
d. Public Health Risks
The risks from octopus farming extend to public health as well. Octopuses carry more than 20 diseases that can infect humans, including cholera.[67] In the wake of COVID-19 and other zoonotic disease outbreaks, new avenues for transmission should be carefully considered when planning to introduce large scale production of new animal species for aquafarming.[68]
Antibiotics are extensively utilized in aquaculture.[69] The food animal industry relies on antibiotics for four purposes: (1) treatment of infectious diseases, (2) control of infectious diseases, (3) prophylaxis to prevent diseases, and (4) non-therapeutic growth promotion.[70] Antibiotics used for non-therapeutic purposes, such as growth performance, are used for perceived economic advantages.[71] However, the use of aquaculture antibiotics has enhanced the natural selective pressures on microbial communities, leading to the emergence of antibiotic-resistant strains that are capable of dissemination, causing severe infections.[72] Because of their unique chemical structure, antibiotics are difficult to break down or degrade in the natural environment and can easily circulate in the food chain and accumulate in the human body.[73]
While claims were made that no relevant pathologies in octopuses are known, there is significant scientific research that challenges this claim.[74] The structure of proposed farming systems and the likelihood of disease in the farm setting suggest that antibiotics would be used.[75] Octopuses have a unique and complex physiology that makes it difficult to administer antibiotics effectively.[76] They do not have acquired immunity or immunological memory; they rely on their innate immunity.[77] Therefore, vaccinations cannot be used to protect octopuses against infectious diseases and there are unknown health risks with octopus farming because their immunology is poorly understood.[78] This new entry into large-scale factory farming poses public health risks and the risk of environmental contamination.
e. Adverse Commercial and Economic Ramifications
Octopus farming can negatively impact existing local fisheries, oyster farms and clam farms through pollution, disease transmission, and competition for wild fish.[79] They can disrupt local communities that depend on marine resources. The production of fishmeal and fish oil drives up the price of pelagic fish, reducing the availability of fish for human consumption.[80] This competition can lead to pressure on already depleted fish populations, adding to the same degradation to the aquaculture industry it is designed to offset.[81] We agree with the Sponsor memo that passage of the Act “will protect New York’s environment, coastal communities, animals and public health.”
V. CONCLUSION
The New York City Bar Association’s Animal Law Committee supports S. 7421-B / A. 8043-C and urges that it be signed into law.
Animal Law Committee
Martha Golar, Co-Chair
Sherry Ramsey, Co-Chair
*Reissued August 2026
Footnotes
[1] N.Y. S.7421B, 2025–2026 Leg., Reg. Sess. (N.Y. 2026).
Available at: https://www.nysenate.gov/legislation/bills/2025/S7421/amendment/B (All websites last accessed August 26, 2026).
[2] N.Y. Assemb. B. A08043C, 2025–2026 Leg., Reg. Sess. (N.Y. 2026).
Available at: https://www.nyassembly.gov/leg/?bn=A08043&term=2025.
[3] On June 4, 2026, the above bills passed both houses and are awaiting signature by Governor Hochul.
[4] Australia, Chile, Japan and Mexico have small octopus farming operations underway, according to the Animal Welfare Institute. Portugal has a scientific research center involved in octopus farming. The Kanaloa Octopus Farm on Hawai’i Island, the only known U.S. octopus farm facility, shut down in 2023 after allegations of illegal animal acquisition and operating as a petting zoo. See, Animal Welfare Institute, Octopus Farming (2025) at https://awionline.org/content/octopus-farming. Recently, a Spanish multinational company withdrew its application to build the world’s first industrial-scale octopus farm in the Canary Islands. See, infra, p. 3, 7.
[5] Sustainable fisheries partnership, Octopus a summary of the global situation in terms of production and trade (Aug. 2023), available at: https://heyzine.com/flip-book/e02633de9e.html; citing to Food and Agriculture Organization of the United Nations (“FAO”), 2023.
[6] Submerged Lands Act of 1953, Pub. L. No. 83-31, 67 State 29 (1953), (codified as amended at 43 U.S.C. §§1301-1315).
[7] See, S.7421A, Justification, https://www.nysenate.gov/legislation/bills/2025/S7421/amendment/A.
[8] H.B. 1153, 68th Leg., Reg. Sess. (Wash. 2023), available at: https://app.leg.wa.gov/billsummary?billnumber=1153&year=2023.
[9] Cal. Fish & Game Code § 15007.5 (2025), (added by Stats. 2024, ch. 758) available at: https://leginfo.legislature.ca.gov/faces/billCompareClient.xhtml?bill_id=202320240AB3162&showamends=false.
[10] New Jersey S1080, https://legiscan.com/NJ/bill/S1080/2026.
[11] North Carolina H292, https://www.ncleg.gov/BillLookUp/2025/H293.
[12] S. 1947, 119th Cong. (2025), available at: https://www.congress.gov/bill/119th-congress/senate-bill/1947. The New York City Bar Association also issued a report supporting the federal bill, see https://www.nycbar.org/reports/supporting-the-federal-octopus-act-of-2025/?back=1
[13] See, Bill 17913-12, https://www.camara.cl/legislacion/proyectosdeley/tramitacion.aspx?prmID=18570&prmBOLETIN=17913-12. Chile’s bill is likely influenced by its troubled history with salmon aquaculture. See, infra note 72.
[14] The proposal was introduced in June 2025 by MPs from Sumar, Esquerra Republicana de Catalunya (ERC), and Podemos. (Described in: INTERCIDS, Intercids proposes a legislative ban on Octopus Farming in Spain (May 8, 2025)), available at: https://intercids.org/intercids-proposes-a-legislative-ban-on-octopus-farming-in-spain/; https://intercids.org/nueva-pescanovas-scrap-planned-octopus-farm-canary-islands-now-on-to-nationwide-ban-across-spain/.
[15] According to the United Nations, the world population is expected to reach 8.5 billion by 2030, 9.7 billion by 2050, and 11.2 billion by 2100. Report from the United Nations, World Population Prospects 2024, Summary of Results (2024), https://www.un.org/en/desa/world-population-projected-reach-98-billion-2050-and-112-billion-2100.
[16] Claire Marshall, World’s first octopus farm proposals alarm scientists, BBC.com (March 15, 2023), available at https://www.bbc.com/news/science-environment-64814781.
[17] New threats of octopus farm plans revealed, Compassion in World Farming (Sept. 4, 2024), https://www.ciwf.org.uk/media/press-releases-statements/new-octopus-farm-documents-reveal-reckless-plans-that-threaten-environment-wildlife-public-health/.
[18] See https://www.gov.uk/government/news/lobsters-octopus-and-crabs-recognised-as-sentient-beings. This was the first law to recognize invertebrates with complex nervous systems as sentient. This law was preceded in 2012 by the Cambridge Declaration on Consciousness recognizing octopuses as the only invertebrate to be conscious. In 2024, the New York Declaration on Animal Consciousness stated that there is a realistic possibility of consciousness in octopuses and other animals, incorporating new behavioral evidence in their findings. New York currently has pending legislation that would recognize animals as sentient beings. Assembly Bill A107 (2025–2026 session) proposes to amend New York’s Agriculture and Markets Law to explicitly establish that animals are sentient and can be considered victims of crimes. Octopuses would likely fall under the definition of “animals” to be considered sentient beings.
[19] The Act acknowledges that cephalopod mollusks (octopuses, squid, cuttlefish, nautilus and devilfish) and decapod crustaceans (lobsters, crabs, crayfish, and shrimp) are sentient.
[20] The report was prepared by a team of interdisciplinary experts who synthesized 300 peer-reviewed studies and developed eight criteria to evaluate sentience. See, Jonathan Birch, Review of the Evidence of Sentience in Cephalopod Mollusks and Decapod Crustaceans, London Sch. of Econ. & Pol. Sci. at 5, 22-40 (Nov. 2021), available at https://www.lse.ac.uk/news/news-assets/pdfs/2021/sentience-in-cephalopod-molluscs-and-decapod-crustaceans-final-report-november-2021.pdf.
[21] Id.
[22] Heather Browning, Animal welfare risks from commercial practices involving cephalopod mollusks and decapod crustaceans, Animal Welfare 34, e24, (2025), available at https://doi:10.1017/awf.2025.25.
[23] Noam Josef, Camouflaging in a complex environment—octopuses use specific features of their surroundings for background matching, (2012) available at https://journals.plos.org/plosone/article?id=10.1371/journal.pone.0037579.
[24] Ehrlich, P., & Reed, J. (Directors). (2020). My Octopus Teacher [Film; featuring C. Foster]. Netflix.
[25] Kenn Papadopoulo, First insights into the special behavior of Octopus vulgaris using acoustic telemetry, Animal Biotelemetry 12,1 (2024), available at https://www.researchgate.net/publication/381549577_First_insights_into_the_spatial_behaviour_of_Octopus_vulgaris_in_the_wild_using_acoustic_telemetry.
[26] Tyler Van Buren, Establishing an octopus ecosystem for biomedical and bioengineering research, J Vis Exp. (Sept. 22, 202), available at https://pmc.ncbi.nlm.nih.gov/articles/PMC9109256/.
[27] Elena Lara, Uncovering the horrific reality of octopus farming, compassion in world farming (2023), https://www.ciwf.com/media/7453342/octopus-factory-farming-report-english.pdf.
[28] Carly Cassella, Octopuses not only feel pain physically, but emotionally too, first study finds, Science Alert (March 5, 2021), https://www.sciencealert.com/scientists-identify-the-first-strong-evidence-that-octopuses-likely-feel-pain; see also, Robyn Crook, Behavioral and neurophysiological evidence suggests affective pain experience in octopus, iscience 24 (March 19, 2021), https://www.cell.com/iscience/fulltext/S2589-0042(21)00197-8?_returnURL=https%3A%2F%2Flinkinghub.elsevier.com%2Fretrieve%2Fpii%2FS2589004221001978%3Fshowall%3Dtrue.
[29] H. Yasumuro & Y. Ikeda, Effects of environmental enrichment on the behavior of the tropical octopus Callistoctopus aspilosomatis, Marine and Freshwater Behaviour and Physiology, 44(3), 143–157 (2011), https://doi.org/10.1080/10236244.2011.598643.
[30] Carla Bertapelle, et al., Enriched environment increases PCNA and PARP1 levels in Octopus vulgaris central nervous system: first evidence of adult neurogenesis in Lophogtrochozoa, J. Exp. Zool. (March 2, 2017), 328B: 347–359, https://doi.org/10.1002/jez.b.22735; Bob Jacobs, et al., Putative neural consequences of captivity for elephants and cetaceans, Reviews in the Neurosciences (Sept. 16, 2021), https://doi.org/10.1515/revneuro-2021-0100.
[31] Nueva Pescanova, prioritizing profits and polluting Las Palmas- the world’s first large scale octopus farm, Aquatic Life Institute (June 2023), https://www.ali.fish/campaign-reports.
[32] Id.
[33] H. Yasumuro & Y. Ikeda, supra note 29.
[34] Id.
[35] Browning, supra note 22
[36] Id.
[37] Id.
[38] Id.
[39] Id.
[40] Browning, supra note 22 at 4; see also Bjorn Roth, Live chilling of turbot and subsequent effect on behavior, muscle stiffness, muscle quality, blood gases and chemistry, 18 Animal welfare 1 (2009), https://doi.org/10.1017/S096272860000004X.
[41] Giulia Malerbi, Octopus farming is a dangerous detour for marine conservation (commentary), Mongabay (Oct. 8, 2025), https://news.mongabay.com/2025/10/octopus-farming-is-a-dangerous-detour-for-marine-conservation-commentary/.
[42] Jennifer Jacquet, The case against octopus farming, Issues in science & technology (Winter 2019), https://issues.org/the-case-against-octopus-farming/.
[43] Letter from Jennifer Jacquet, Dep’t of Environmental Science and Policy, Univ of Miami, Support US OCTOPUS Act to keep octopuses wild (Aug. 16, 2024), https://ctbergstrom.com/publications/pdfs/2024Science.pdf.
[44] Ashley Meader, Proposed octopus farm fails environmental impact assessment, Faunalytics (Oct. 10, 2024), https://faunalytics.org/proposed-octopus-farm-fails-environmental-impact-assessment/.
[45] Id.
[46] Akeem Dauda, Waste production in aquaculture: sources, components and managements in different culture systems, Aquaculture and fisheries (May 2019), Vol 4, Issue 3, available at https://doi.org/10.1016/j.aaf.2018.10.002.
[47] Id.
[48] Meader, supra note 42.
[49] Letter by a coalition of 160 signatories to the Chilean Government (specifically the National Agency for Research and Development (ANID) Fund for the Promotion of Scientific and Technological Development (FONDEF) (Aug. 20, 2025), https://www.salvemosalospulpos.org/wp-content/uploads/2025/08/Letter-to-Chiles-research-and-development-agency-2.pdf.
[50] The growing threat of carnivorous aquaculture, Compassion in World Farming (Oct. 10, 2025), https://www.ciwf.com/media-and-news/news/growing-threat-of-octopus-carnivorous-fish-farms-revealed/.
[51] Id., 17, citing Aubin Papatryphon, Characterization of the environmental impact of turbot (Scophthalmus maximus) re-circulating production system using Lifecycle Assessment. Aquaculture (Dec. 11, 2006); 261(4):1259-68.
[52] Aquaculture Feed Efficiency, Sustainability Directory (March 23, 2025), https://fashion.sustainability-directory.com/term/aquaculture-feed-efficiency/.
[53] Dennis DeLong, Tank culture of tilapia, Southern Regional Aquaculture Center, Publ. No. 282, June 2009, at https://aquaculture.mgcafe.uky.edu/sites/aquaculture.ca.uky.edu/files/srac_282_tank_culture_of_tilapia.pdf.
[54] Malerbi, supra note 41.
[55] The growing threat of carnivorous aquaculture, supra note 50.
[56] Id., at 4, 19.
[57] FAO, The State of World Fisheries and Aquaculture 2024 (SOFIA 2024), available at https://doi.org/10.4060/cd0683en.
[58] European Fishmeal and Fish Oil Producers, FAO Report: fishmeal and fish oil are essential to aquaculture (November 24, 2023), https://effop.org/news-events/fao-report-fishmeal-and-fish-oil-are-essential-to-aquaculture/.
[59] Patricia Majluf, A review of the global use of fishmeal and fish oil and the fish in: fish out metric, Science Advances (Oct. 16, 2024) at 9, available at https://pmc.ncbi.nlm.nih.gov/articles/PMC11482318/pdf/sciadv.adn5650.pdf.
[60] Timothy Essington, Fishing amplifies forage fish population collapses, Proc. Natl. Acad. Sci. U.S.A (April 6, 2025), available. at https://doi.org/10.1073/pnas.1422020112.
[61] Jacquet, supra note 42.
[62] Jack Alder, Forage fish: from ecosystems to markets, Annual Reviews in Environments and Resources, 153-166, 158 (Nov. 2008), available at https://www.researchgate.net/publication/224018060_Forage_Fish_From_Ecosystems_to_Markets.
[63] Farmed fish escapes, Oceana (no date), available at https://usa.oceana.org/farmed-fish%20escapes/?copilot_analytics_metadata; See also, Javier Atala, Global assessment of ecological risks associated with farmed fish escapes, Glob. Ecol. Conserv. (March 2020), vol. 21, available at https://doi.org/10.1016/j.gecco.2019.e00842.
[64] Elena Basso, Those who eat Chilean sea salmon cannot imagine how much human blood is carried with it, GUARDIAN (Dec. 2, 2025), available at https://www.theguardian.com/global-development/2025/dec/02/chile-salmon-farms-fish-industry.
[65] Wajeeha Malik, Inky’s daring escape shows how smart octopuses are, National Geographic (April 14, 2016), available at https://www.nationalgeographic.com/animals/article/160414-inky-octopus-escapes-intelligence.
[66] Malerbi, supra note 41.
[67] Andrew Rich, A retrospective study of pathologic findings in cephalopods (extant subclasses: Coleoidea and Nautiloidea) under laboratory and aquarium management, Vet. Pathol. Sage Journals (July 18, 2023), available at https://doi.org/10.1177/03009858231186306; Catalina Lopez, The Aquatic Animal Alliance warns about the serious environmental risks of an octopus farm in the Canary Islands, Aquatic Life Institute (April 20, 2025), https://www.ali.fish/blog/the-aquatic-animal-alliance-warns-about-the-serious-environmental-risks-of-an-octopus-farm-in-the-canary-islands-w9jbk.
[68] Yuhua Chen, Vibrio cholerae: a pathogen shared by human and aquatic animals, Lancet Microbe (June 2022), available at https://www.thelancet.com/journals/lanmic/article/PIIS2666-5247(22)00125-2/fulltext.
[69] Elshafia Ali Hamid Mohammed, et al., Antibiotic resistance in aquaculture: challenges, trends analysis, and alternative approaches,) Antibiotics (basel)(Jun. 11, 2025) available at https://pubmed.ncbi.nlm.nih.gov/40558188/.
[70] Terence Centner, Regulating the use of non-therapeutic antibiotics in food animals, Georgetown International L. Rev., Vol. XXI, issue 1 (2008), available at https://www.csjn.gov.ar/pubextrs/verIndice?tm=PP&nm=383&fascic=2008-21-01.
[71] Id.
[72] Mohammed, supra note 69; See also New York City Bar Association reports on the subject of non-therapeutic use of antibiotics on animals in agriculture, with respect to both New York State and Federal proposed legislation, at https://www.nycbar.org/wp-content/uploads/2023/05/20073090-NonTherapeuticAntimicrobialAgents_FINAL_4.18.17.pdf and at https://www.nycbar.org/wp-content/uploads/2023/05/20072377-POTUS2ndTermTransitionMemo.pdf.
[73] Id.
[74] Report by Aquatic Life Institute, supra note 67.
[75] Id.
[76] Our Hen House, A wave of change: banning octopus factory farming with Amanda Fox, Brenna Anderst & Allie Taylor, episode 810 (May 30, 2025), available at https://www.ourhenhouse.org/ep810/.
[77] Sheila Castellanos-Martínez, Pathogens and immune response of cephalopods, Marine biology & ecology (Sept. 2013), 447:14-22, available at https://www.sciencedirect.com/science/article/abs/pii/S0022098113000592?via%3Dihu.
[78] Anna DiCosmo, Neuroendocrine-immune systems responses to environmental stressors in the cephalopod Octopus vulgaris, Frontiers in Physiology (Sept. 28, 2016), available at doi.org/10.3389/fphys.2016.00434.
[79] Lara, supra note 27.
[80] Majluf, supra note 59.
[81] Report by Aquatic Life Institute, supra note 67.