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Our 2022 and Onwards Scaleup Plan

By Karthik Pulugurtha and Haven King-Nobles


This post discusses Fish Welfare Initiative’s plan for determining if, and if so how, to scale up in India over the next 4-6 years.


Plan Summary

  1. Identify welfare improvements that are sufficiently implementable and impactful. We are not confident that our current welfare standard meets our bar for either sufficient implementability or impactfulness, and we are not going to scale up significantly until we are. We will resolve this uncertainty by continuing testing with our farmers in the Alliance for Responsible Aquaculture (ARA), with the end goal of finding something that we can scale up via our process in step 2.

  2. Until we have an improved welfare standard, we will continue working with corporations and governmental entities in order to build both relationships and our knowledge of how to bring change in these systems. We believe that government and corporate work are both necessary now in order to enable greater scalability later. Furthermore, they increase the interest of farmers working with us now and give us redundancy. We will conduct some projects with these bodies, such as transitioning procurement at early adopting corporations (e.g. SAGE) and by working to develop standards that we can later help enforce (e.g. through the Bureau of Indian Standards). We expect these steps 1 and 2, completed concurrently, to be finished in mid-2023.

  3. If our impact evaluation concludes with positive results, we intend to scale up our work with both corporations and governmental entities. For corporations, this likely involves larger procurement commitments to transition their purchasing to ARA farms. For the government, this may involve one or more of several different approaches, the most promising of which include working with the Food Safety and Standards Authority of India (FSSAI) to require certain welfare-oriented standards for aquaculture and/or adding certain aquaculture best welfare practices as eligibility preconditions for government insurance.


When to Scale: After Finalizing Welfare Standard

Current status of our welfare improvements: As of November 2021, we have field staff working with 52 fish farm ponds as part of the Alliance for Responsible Aquaculture, with a focus on water quality and stocking densities. However, although farmers mostly implement the actions we recommend water quality does not improve as frequently and as significantly as we would like. Stocking density changes are easier to implement, although our current stocking density cap does not seem to have made a measurable improvement to water quality. We know roughly what basic standards ought to be for carp welfare in India (see our commitment and our report), and we know that farms often do not meet these standards, but we're still less certain what practices farmers ought to implement to reliably meet these standards. Until we have these questions answered, we feel that it would be imprudent to significantly expand the implementation and enforcement of our standards.


Method for Determining Welfare Improvements

1 - Preliminary impact evaluation

We plan to conduct a preliminary test of the most promising 1 to 5 welfare improvements. This will involve taking environmental data as well as behavioral, physical, and physiological indicators of welfare (such as growth rates) as well as economic data.


A positive result from both the preliminary impact evaluation would act as a ‘tripwire’ for us to move onto a large-scale impact evaluation, as well as progress with full scaleup of our strategy.


2 - Full impact evaluation

After identifying preliminarily impactful welfare improvements, we will conduct a full impact evaluation, where we aim to implement standards as rigorously as possible in order to fully understand the welfare implications of our interventions. This will involve taking measurements not possible in the smaller scale preliminary tests, such as cortisol.


A negative result from the full impact evaluation would be enough to make us slow down or stop scaling up. A positive result will be enough for us to change our internal philosophy from being in the exploration stage to being in the exploitation stage.


After this, we will continue to collect data perpetually each year in order to reaffirm that our improvements are working. However, this will likely be significantly less data than currently being collected, especially for farms/farmer producer organizations who have already been working with us for multiple years.


Our current focus is semi-intensive Rohu and Catla farms in the grow-out stage, with our aim being to develop expertise for these specific systems. However, we will continue to run small-scale surveys and trials with other groups, and stay open to pivoting or adding projects to address other fish groups.


Why focus on a three-pronged approach with farmers, corporations, and governmental entities?

Our default is to focus on as few of things as possible, and we recognize that running three intensive program areas simultaneously clashes some with that default. We don’t make this decision lightly—here’s our reasoning for why we think this is a good idea:

  • We need to work with the Alliance for Responsible Aquaculture (ARA) in order to have a group of farmers who are interested and willing to test improved welfare standards. Working with farmers also gives us significant clout with corporations and policymakers, who see it as a “noble initiative.”

  • There are synergistic effects to our credibility by working with each: Both the corporate and government work incentivizes farmer participation in the ARA. For instance, the possibility of someday selling to a large corporation at a welfare price premium increases farmer interest. And when farmers learn that we are working with a recognizable government institution, they (as well as the corporations) also gain greater interest.

  • We are somewhat skeptical we can effectively scale up without corporate or governmental support. The corporate work speeds up our timelines for scaling, and the governmental work offers in expectation the greatest reach (though with longer time horizons).

To learn more about our future plans, see our high-level theory of change.


Possible Avenues for a Successful Scaleup

The following are two possible avenues FWI could take in order to scale. We include them to give a sense of the strategies we may pursue later after we have resolved the question of our welfare standard.


Conditional Subsidies Model

The Indian government currently supports a large number of fish farmers through subsidies. These subsidies are offered by agencies like NFDB, NABARD & State Governments and aim to help farmers:

  1. Set up new farms

  2. Renovate existing farms

  3. Cover production costs through low-interest loans

  4. Secure their investment through insurance schemes

FWI could advocate for certain practices to be made prerequisites to apply for certain government subsidies (which makes some economic sense as well, given that higher welfare fish endure fewer mass mortality incidents). FWI intends to work with prominent government research institutes like CSIR-IGIB, NEERI, and/or CIFA to produce compelling research advocating for the incorporation of higher welfare standards. The ARA will provide the farms to produce the research connecting sustainability and food safety to fish welfare.


If these conditional subsidies were to be adopted by at least one state in India, they would potentially improve the lives of millions of fish. Audits from organizations like FWI must be made part of the process to ensure proper implementation of fish welfare on the farm.


Market Implementation Model

A reliable percentage of the Indian market has shown willingness to pay a premium for meat, milk, and eggs sourced from traditional or more ethical farms. Because fish products are gaining a reputation for having a high chemical footprint, it is the perfect moment to transition the sector. What may be more compelling to producers and consumers is that Indian state governments have begun cracking down on traders on these grounds. FWI could support the creation of brand labels that offer food safety through the incorporation of higher welfare practices. The upscale market in various Indian cities is prepared to transition to products from higher welfare production systems.


To strengthen the reach of higher welfare fish, FWI intends to produce compelling research connecting fish welfare and food safety through its projects with prominent government research institutes, such as the aforementioned CSIR-IGIB, NEERI, and/or CIFA. This research would also enable FWI to advocate for incorporating welfare standards requirements in government fish markets, which have the largest market share in the country.




As always, if you have feedback on our strategy feel free to reach out or comment below.




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