Dr. Jason Clay is the Senior Fellow at World Wildlife Fund.


Leaders in the aquaculture industry within the US say that it's now well known that mangroves habitats are not good sites for locating shrimp ponds and that the problem of mangrove displacement is largely in the past. But according to an aerial survey just conducted by Wetlands International in Thailand, the displacement of mangroves there is an ongoing and serious problem. What is the real situation?

We don't know. We really don't know what the situation of mangroves is with aquaculture. I think the destruction of mangroves in some areas is clearly still going on. I think that a lot people advising the industry know that it shouldn't go on, that it's not financially viable in the long-term, but people on either side of the issue haven't been doing the kind of research to say definitively that it's stopped.

I think the last time they did the survey was about 5 years ago and there were about 10,000 more ponds in obvious mangrove areas.

I think the place I would look is in Esmeraldas in Ecuador. I know there's active clearing going on there now. And I think that those are the places that you'd want to bring to the industry's attention to see if they really are committed to stopping it.

According to a recent article in the World Watch magazine, the World Wildlife Fund reported that 150,000 hectares of shrimp ponds have been abandoned between 1985 and 1995. Can you comment on this?

It's a statistic that was probably taken from a report that I wrote, and that report is basically trying to pull together all the information that's been in the press, in journals, in the literature, and to bring it all together into one place and just show what different people are saying about it. I think they cite World Wildlife Fund as the author of that, but the research was done by other people.

I don't know that all the information in the report is right, but I think that there's been an awful lot of pond abandonment, or at the very least ponds that are now used for things like tilapia in Ecuador or bloodworm in China, instead of shrimp. There's a lot more fallowing that's going on now with the ponds that are left for 2 or 3 years and trying to bring them back later.

Again, we don't know how many ponds have been abandoned. We don't know what the average life of a productive pond is, what is a semi-intensive system and an intensive system. All these are good questions. We need the answers in order to have any kind of sustainable industry in the future.

How are we going to find out?

I think we've got to invest more in GIS, in doing the interpretation of photos over time, but I think the real way you find out is because people know it's important. People who are concerned about making the industry more sustainable - it should be the industry, the NGOs; it should be everybody. It's in nobody's interest to have the ponds abandoned. That means putting them in the right place to start out with so that they last longer.

Is abandonment of ponds indeed a problem?

When you build a shrimp pond, you invest anywhere from 10 to 50,000 dollars per hectare on just the construction of the pond and the infrastructure that goes around that. And even small farmers may not spend quite that much money but they have to invest a lot of their own labor, which they don't pay themselves for, so it's a huge investment. It's really in everybody's interest to make sure that investment lasts as long as possible.

Historically what's happened if these ponds are abandoned (and we know that a number of them are) then they just move someplace else and build another pond. They don't tend to restore the first pond back to wetlands, back to agricultural land, back to whatever it was before; they just abandon it. And so I think stopping that is the real important issue for all of us to address.

What is the average lifespan for shrimp ponds?

There's good indication that the more intensive the pond, the less the average lifespan, and that the most intensive ponds are probably 5, 7 years. The ponds that are more intensive, and that's where they put more shrimp in per square meter and give them more food and more inputs, those systems tend to not last as long because there's too many moving parts and there's too many ways for them to go wrong.

The systems that have stocking densities that are very low per meter tend to be the ones that would last longer. Because they don't have as much stress in the ponds, the animals aren't diseased as quickly, or diseases don't spread as fast, they don't use feed in many of the extensive systems. Vietnam has just been wiped out this year in two of its major growing areas with diseases, and that's an extensive system.

How would you compare the long-term value of a healthy mangrove ecosystem as opposed to the economic arguments of using the same resource for shrimp aquaculture?

The value of a mangrove is a highly speculative kind of thing. There are a lot of subsistence goods that are put in it. Some of the data from the Philippines show that families will get as much as $1000 worth of construction material, food, fuel wood, different things like that for household use, in addition to things they sell off on. The average values that academics have come up with range from about $1000 per hectare for mangroves to maybe $11,000 per hectare.

The $11,000 is about what an intensive shrimp operation would generate per year. But the intensive shrimp operation doesn't have a time frame that goes into decades and generations and so there's that problem. Moving shrimp ponds behind mangroves might actually be a way to have your cake and eat it too, in the sense that you can have production, maybe not intensive but semi-intensive at least.

We know, for example, that nitrogen and phosphorous coming out of a shrimp pond would actually increase growth in mangroves, which would allow you to cut more wood for construction and fuel wood and all kinds of things; would allow more growth of algae which would feed more fish. So you could potentially make mangroves more productive and produce shrimp.

The balance is the trick, because if you produce too many wastes and too many effluents, then you're going to kill the mangrove. And that's why zoning and citing is so important.

There's pretty good evidence that probably 90% of environmental problems that arise from shrimp aquaculture have to do with where you build the pond. And if you get it built in the right place then you can avoid an awful lot of mistakes. But it's not just where you build one pond, it's particularly where you build the 100th pond or the 1000th pond. In most cases one pond built almost anywhere could be sustainable. It's when you start getting the cumulative effect of many ponds in the same ecosystem that they start having problems.

According to some NGOs, it is difficult and often prohibitively expensive to replant mangroves in abandoned shrimp ponds. What is your opinion?

There are various schools of thought about restoration of mangroves. One is that if they are indeed built in tidal areas the most important thing to do is to breach the embankments. And as long as you allow water to flow in and out, then you could actually even just disperse seeds on the water and they will take root and grow.

And there are people who do mangrove restoration ecology in Florida who think that planting mangroves is really kind of a waste of time. It would be very expensive to plant mangroves. I'm not sure that planting mangroves is actually necessary.

If shrimp operations are moved above the tidal line and moved out of mangroves, then that isn't going to be such a big issue. And the real issue for restoration is going to be how you take the salinity out of the soil so you can use it for something like agriculture or whatever if it becomes abandoned, or for some other form of aquaculture, or even enter into some kind of a fallow production system where you have, like in China now they have 3 years of shrimp production and 7 years of other kinds of aquaculture, as a way to deal with diseases and other issues.

That's like crop rotation?

Yeah, it's amazing. We've been doing agriculture for thousands of years and we finally learned a lot of things about agriculture, like crop rotations and terracing and all kinds of things, and we haven't really taken those lessons and applied them to aquaculture yet, which is too bad because I think we could avoid an awful lot of mistakes doing that.

But I heard about rotating between rice and shrimp?

There's a traditional system in Bangladesh where half of the year, in the wet season, is devoted to rice when there's fresh water, and then the other half is devoted to shrimp and brackish-water aquaculture. Those systems aren't really market-oriented because they're not that productive. The rice production is pretty minimal because rice really doesn't tolerate that much salt in a lot of those fields.

Regarding the largest remaining tracts of mangroves in South America and in Africa, to what degree might they be imperiled by the growth of shrimp aquaculture?

I think if we've learned anything in the last 20 years, it's that the lessons that have been learned through aquaculture development at best have pretty much been learned in one site, but they haven't been transferred to other areas very well. So I would be very worried about the expansion of shrimp aquaculture into mangrove areas, in areas where there isn't a shrimp industry now.

Because I think new operators might easily begin to work in those areas. There's a very small operation in East Africa now--in Tanzania--that has been incredibly destructive for mangroves that was started by a local guy who decided that there is money in shrimp. And he didn't have any expertise, any knowledge about shrimp aquaculture, but he just started building a pond in a mangrove. And it has had disastrous results; hasn't really produced very well either.

Then there was another area like that where the investors were from the outside and they knew more about what was happening with shrimp aquaculture and mangroves and so they avoided mangroves. But I think we've got to be careful about that.

The big areas of the world in terms of the remaining mangroves, really though, are Indonesia and Brazil. That's where the most mangroves in the world are. There are big mangroves in Africa, but Brazil and Indonesia combined have probably half the world's mangroves that are intact, relatively speaking. So I think those are the areas that you would be very concerned about. Africa is of concern just because we know that there is commercial interest in East Africa in shrimp aquaculture and so, whatever happens there, to avoid mistakes from other areas would be extremely important.

One of the key benefits of aquaculture is to reduce pressure on marine fisheries, yet fishmeal is used to feed shrimp. To what degree are shrimp farms using fishmeal and what's the potential impact?

Well, I think the fishmeal issue is extremely important for aquaculture, not just for carnivorous or omnivorous aquaculture - salmon and shrimp in particular, but also now tilapia more so. I believe the figure's something like 27% of all fish caught in the oceans are used for fishmeal and fish oil, so that's a big chunk. In terms of how much is used for aquaculture, it's I believe around 20, 25% but it's rising.

The other big users are poultry and pig production and things like that. Now those industries have figured out how to produce poultry and pigs using much less fishmeal, and quite frankly it hasn't been because of the impact of fishing on the oceans. It was because the cost of fishmeal is twice that of soybean protein, and so they've switched to soybeans. I think the same kind of thing has happened in salmon production, that the use of fishmeal has dropped by half. In shrimp production the use has dropped by about half as well, in fact without increasing weight-gain in the process.

I think some of the technological changes are going to make that happen even faster, that they'll be using less and less fishmeal, and they'll substitute vegetable proteins and vegetable-based amino acids and oils for the fish oil.

But those are going to take some time. As the shrimp industry expands in the next 5 to 10 years there's going to be a huge problem there. But that's only one of the impacts on the ocean. I mean the destruction of the wetlands, both mangroves and wetlands and tidal areas and estuaries, all those things affect breeding and the feed of a lot of different species in the ocean and that has a big impact.

And I think ironically, at least in the short-term, one of the big impacts also of aquaculture, particularly shrimp aquaculture, has been that it has flattened the price of wild-caught shrimp and this has meant that shrimp trawlers have had to take more to make the same amount of money. And so it's intensified ocean fishing in a way that's probably had a negative impact on ocean fish, particularly given that there's huge bycatch of shrimp trawlers around the world - a lot of complicated issues there.

I thought you said at first that the use of fishmeal is rising, but then you say that the use is being cut by half?

The use of fishmeal for aquaculture is increasing because the total amount of aquaculture is increasing so phenomenally. But the percentage of fishmeal in fish food has actually declined a lot. And in fact, with salmon, they've experimented with feeds that have no fishmeal or fish oil and it has worked at least experimentally, although it looks like having some fishmeal and fish oil is going to be important.

Can you explain why using fishmeal is a problem?

One of the major problems with using fishmeal, particularly in high concentration in the fish foods, is that you will often be using as much as two kilos or two tons of fish to produce one ton of farmed fish, or farmed shrimp. That's what the old ratios of the fishmeal content in foods were doing.

Today it's about 1:1 or a little bit less than 1:1, but there are serious questions about providing for world food security, if you're basically reprocessing and then charging much more than twice as much to the consumer. You're potentially taking food off of poor people's plates and putting it on people who can afford higher-priced items.

To what degree do you think the capture of wild post-larvae is impacting the fisheries for shrimp aquaculture?

Again, we don't know. There are people that have measured 40 organisms killed for every shrimp larvae that's captured, 100 even 400. The problem is, we don't know how significant those losses are for the recruitment for a lot of different species. It stands to reason that since we use billions of larvae in almost every country, there are trillions of other things that are being killed in the process of capturing those larvae.

So adopting the precautionary principle, which is if you don't know what the impact is, try to have as little impact as possible, we should avoid that. And the best way to avoid that is to domesticate shrimp.

About half the shrimp farms in the world today actually depend on the wild-caught post-larvae. And in the process of catching the post-larvae, anywhere from 40 to 100 to 400 other organisms die in the process. Given that in even small countries billions of post-larvae are used in the shrimp industry - and in Thailand and Ecuador it's HUGE numbers of billions - this could have a really big impact. And since we don't know what the impact is, we should be cautious about it.

We should move towards hatchery programs, we should move towards domestication programs. One of the ways to reduce the impact of shrimp aquaculture is to close the system, to the extent that we can. There are two major places where the system is open.

One is where you're bringing the stock in to rear in the ponds and the other is when you're running a lot of water through the system. So bringing the stock in and closing that system by having hatcheries and breeding programs and all kinds of other gains that could come from domestication.

You could domesticate shrimp to the point that you could put them to market in a third of the time you do today that they could gain twice as much weight on half as much feed, they could have disease resistance, they could be resistant to stress, just all kinds of things we've done with domesticated farm animals - chicken is probably the most notable recently.

There's no reason at all to assume that we couldn't have the same kind of achievements with shrimp. And Farm Gate, between 6 and 8 billion-dollar-a year industry, almost one billion in cost is spent on post-larvae. There is a lot of money to be made for the company that finds out how to domesticate shrimp. So there's some good incentives built into the system already. And there are a lot of companies working on it, so I do think that that part of the system's going to be closed fairly soon.

The one issue that I think also needs to be made about food, in addition to the fishmeal, is that currently the industry estimates are that 30% of all feed to shrimp ponds is never even consumed by shrimp because it's fed too much at one time. It goes to the bottom and rots. It creates stress in the system and probably extenuates disease and wastes an awful lot of fishmeal and other expensive items. Food also is probably one of the single largest expenses of semi-intensive and intensive shrimp operations. So wasting 30% right off the top is a really stupid thing to do. We do know that there are better ways to feed, that could cut down a lot on the total feed used and on the fishmeal used.

Do you think less intensive shrimp aquaculture is the direction the industry needs to go, or do you think high-stocking rates can be contained in a sustainable manner?

I think that there are a lot of production systems around the world. Ecuador is what they call semi-extensive. I think the stocking rates in Ecuador are probably okay; they might even be increased a little bit. In Thailand they definitely need to be decreased; they are trying to produce too many shrimp in too small an area.

And it's one of those things that's kind of counter-intuitive. Sometimes if you put fewer shrimp in the pond you actually harvest more at the end of the season. Plus, you have lot lower costs in terms of buying the shrimp you put in and feeding them, and all that stuff. You have fewer effluents to treat.

So there are lots of economic reasons to use lower-stocking densities. I think the reason people do use higher densities is because they don't know that much. A lot of people who produce shrimp have never been to high school. There's an awful lot of issues they don't understand, particularly the smaller, less educated shrimp producers. And somebody's got to be out there working with them and showing them how to do it right. Again, the feed companies, the input manufacturers, the people who buy from them could all help out in this. But if they don't those systems are going to crash.

How can increasing the survival rate of post-larvae reduce negative impacts and boost profits?

A lot of the shrimp statistics are really educated guesses. But the educated guess of the consultants in the industry are that of all the shrimp that are put in to stock these ponds to grow out - the post-larvae - less than half survive to the point of harvest. If you could increase that rate to, say 70%, you would more than double the profits.

You'd do that because you'd have more shrimp that you're harvesting at the end, you'd have the food that you're putting into the system actually being consumed, because most people don't realize that in a pasture you can see how many cows there are and when a cow dies you know it. In a shrimp pond you have a death rate but you don't know what it is because you don't see the shrimp.

So your assumption is that you need to feed as many shrimp as you put into the pond. So you overfeed them, which creates more stress, but also is extremely wasteful. You're spending money on food and nothing's eating it; it's just going to the bottom. And then you have to spend money on cleaning up the water quality.

So you could make a lot of money, reduce your effluence tremendously by lowering your stocking density, by increasing your survival rates. You actually get more shrimp out of the pond that are harvested than by the old way by stocking fewer shrimp.

George Lockwood has said that the use of antibiotics is an accepted and necessary practice, both in aquaculture and agriculture, although he thought that they should be used carefully and perhaps even be regulated. What are some of the dangers of the excessive use of antibiotics?

First of all, at this point in time, antibiotics aren't a major problem in shrimp aquaculture. There are a few exceptions, but for the most part they're not included in feed manufacture. Antibiotics don't affect a lot of the diseases that shrimp get, so they don't work. That's one of the big reasons why they are not used. But people have found that spot use of medicines have worked much better.

As shrimp farming becomes intensive in many parts of the world and as the number of ponds in an area tends to overload an ecosystem - even if it's not more intensive on each farm, the farms accumulatively become more intensive - then I think there will probably be a tendency to use more chemicals and more medicines as well.

The biggest problems with this is that with an animal it usually just goes into the feces and it dries out on the ground and that's that, but with the water issue, that third dimension that aquaculture has, which none of these agricultural systems have, you've got not only the shrimp that are being affected, but you've also got the medications going into the natural environment, affecting natural populations and their resistance and creating mutant diseases that may have less tolerance to that could wipe out wild species as well.

We've heard a lot from NGOs about the negative socio-economic impacts of shrimp aquaculture. To what degree do you think these problems should be addressed by the industry?

Left to its own devices the industry isn't going to address socio-economic issues, except to the extent that they get bad press, or that it affects labor, or it affects their ability to get permits. And I think that last issue is the key one. I think if you want the industry to address socio-economic issues you have to do two things.

You have to make licensing and permitting conditional on certain kinds of performance that includes socio-economic performance, not just environmental or financial. And you have to really make sure that there are good ideas and good alternative ways to do things where companies are going to be just as financially viable or even more so; they're going to be able to perform in an area and still make money.

I don't think people have thought very much about how to change the industry from its socio-economic impact. And I think we need to put our minds to that because it's hard to convince people in the industry to come up with new ideas to do things. That's maybe not their job; that's the job of NGOs and academics and other people, and they have been doing it. So we need to come with new models.

For example, why not have workers form associations and collectively own part of the company, so that they benefit from some of the value that they add to production. This could happen in hatcheries, this could happen in grow-out ponds, or this could happen in processing plants.

Do you believe that shrimp aquaculture raises the standard of living?

Shrimp aquaculture, in some areas, has generated tremendous amounts of employment. I think the employment for nationals has tended to be on the lower-wage side of the scale. It hasn't been managerial jobs, it hasn't been technical jobs, but in countries that have 30 to 70% unemployment, or underemployment, that's a big deal; even a minimum wage job is a big deal.

But a point in fact: we don't know how much employment has been generated. We know about foreign exchange earnings and it's very hard to deny that on balance shrimp hasn't had a very positive effect on foreign exchange. There's no question about it. I think under-invoicing has kept a lot of money out of countries, and I think that you really, really have to believe in the trickle-down theory to think that that's actually going to trickle down to the coastal communities.

There's also the big issue of the people who lived in a region prior to shrimp being displaced by the industry, not even employed by it. There's beginning to be some data that's coming out now that shows that shrimp aquaculture tends to hire people that are not from the area. In part that's because the people that are in the area don't want to be in 9 to 5 jobs and they don't necessarily want to work for the people that have displaced them or have kicked them out, they may not have the skills necessary, or they just may not have enough desire to work for those kinds of wages.

But in any case the industry itself has become a big magnet, as big a magnet for people moving, as cities have. I don't know if that's a positive thing, putting so many more people on the coast.

Do you think it's possible for debt-ridden countries to earn this badly needed foreign exchange by shrimp farming in a sustainable and socio-economically just manner?

I think that the shrimp industry is here to stay. I think it has generated a lot of foreign exchange. I think it's been a positive contributor to the economics of those countries. I think there are tremendous environmental impacts. I think there are subsidies, both indirect and direct, from the environment, from the populations, from governments. But that's true of agriculture, that's true of all the other industries as well. And I don't think we should single out shrimp as being the only evil or the only production system that's not playing on a level field, if you will.

That being said, there's a lot of room for improvement. Shrimp industry is going to be around, in some form or another, in the foreseeable future so we need to figure out how to make it better. And I think we're beginning to see how to reduce the impact on the local and regional environments.

We haven't thought very much at all about the social impacts, about how to improve those impacts. We haven't really thought about the larger ecosystem, impacts and subsidies from nature that the current industry entails. I think we have to start looking at those two because acknowledging that the shrimp industry is going to be around also implies that there's going to be more and more people doing it.

The first pond is always sustainable; the 100th or the 1000th is the problem. We need to think more about the impact of that 1000th and manage for it, zone for it, make sure that the sighting is done right.

Do you think international lending institutions are now giving enough considerations to environmental and socio-economic impacts before making loans for shrimp aquaculture?

The Inter-American Development Bank, I don't believe has actually ever given a loan for shrimp aquaculture. I think the World Bank has just given its first loan, after a 4 or 5-year hiatus, to Mexico for shrimp aquaculture in a larger package. And they've put an awful lot of environmental and social conditions on the loan. The Bank has also commissioned a paper looking at the environmental impacts of shrimp aquaculture with an eye towards developing policy about that issue.

Have they done enough? Maybe not, but I do think it's very important that they get engaged in the issue. Rather than saying, "don't support shrimp aquaculture", I would like to see them figure out what the best practices are and help get the producers of the world to those practices. I don't want them either on the sidelines or not even in the ballpark. I would rather have them involved in a proactive way of helping turn this industry around.

This industry has really been a kind of frontier industry with a frontier mentality. And we need to start establishing what the rules of the game are. We need to bring some order into Dodge and I think those are the kinds of institutions that can do it. Will they? With a little encouragement from their friends, maybe. That's where the NGOs come in.

Can you explain what you mean by the possibility of eliminating production costs?

I think that in the next 10 years, my goal at least, is to try to figure out ways that we can show the shrimp industry how to reduce their cost and reduce their environmental impact, and increase their profits. And I believe that a lot of these issues compound each other, so if we can increase the survival rate from 50 to 70%.

If we can eliminate that 30% of feed that's wasted, then we'll have less water problems. We won't have to pay to exchange water, to aerate water; it'll be fine as is. Then we can lower our stocking densities and produce four times as much. These are the kinds of things that we need to start looking for.

Can you comment about the possibility of future certification of products using sustainable methods and the need for third-party logistics?

There's a lot of desire, I think, to produce a shrimp that can be certified and sold for a market premium. The question is what is it that we'd be certifying? And I don't think we agree on that. And the only way we can come to an acceptable agreement is to bring all the parties to the table and hammer this out and it could take 2 or 3 years, realistically.

I think we need to move the whole industry a foot rather than 10% of the industry 100 feet. So we need to come up with initial buy-in certification systems that say this shrimp is being produced with these best practices, or better practices, than we know today. The yardstick is going to change. It's going to get tighter over time but this is how we're starting and this is how you can buy in, and then we're going to start helping the industry move forward over time.

Even so, it's going to have to be an independent 3rd party that does the certification. We can't have the fox guarding the chicken coop, whether it's the industry doing its own certification or code or whatever. We can't have the NGOs doing it either because they have their own vested interests. It has to be independent certifiers. It's got to mean something in the end to the consumers.

Consumers need to become much more aware about the shrimp that they are eating, whether it's wild-caught, whether it's pond-raised; what the impacts are. We don't yet know what sustainable shrimp production -- either from wild trawlers or from aquaculture -- would actually look like if you saw it. But I think we'll know more over time.

But consumers need to know where their food comes from, not just about shrimp but about agriculture and all kinds of things. So this is part of an educational process. You've got to know what you're putting into your body, what your impact is.

In my opinion, if you want to say the polluter pays, the ultimate polluter is the consumer; it's not the business that delivers the product but the consumer that creates the demand.

For which criteria do you anticipate there being problems, as far as having consensus?

The big issues that we're not going to be able to resolve are how to address past abuses. How do you deal with shrimp ponds that were built on mangroves? That's going to be very hard. It's going to be much easier to deal with how you establish new shrimp ponds. So at the very least we ought to move forward.

But I think we also have to address some of those other issues. I think some ponds have to be retired. In Japan they've got a system where the farmers themselves have decided to retire, because as you get more and more ponds into the system you have to take some out of production, and that's going to happen as shrimp matures as an industry.

So we need to take those areas that have the biggest environmental impact out. And I think we may not agree on Year One or Two, or even Three, but in 5 years or so. This is a long-term commitment to engage and change this industry. For those who want to have an impact, it's going to take that long.

But I think the big issues are probably going to get into the issues of genetically modified organisms. Shrimp may start to be fed vegetable-based manipulated canola to replace fishmeal. There are trade-offs. Do you want to have an impact on the wild? Do you want to have an agricultural impact? Which is the lesser evil?

But if we can agree on 75%, that's a damn good start. Let's start with that and move forward and let's whittle away at the other issues that we disagree on.

What do you think the potential of aquaculture is at this day and age?

Aquaculture in 30 years is trying to do what agriculture did in 6000, and so the learning curve is real steep. So we've got to learn from shrimp and salmon, to produce better tilapia, milkfish and carp, and to even produce cheaper salmon and shrimp. We can take pressure off the ocean; we can take pressure off of terrestrial systems as well.

There's pretty good evidence that aquaculture is going to take pressure off the major fisheries in the ocean. In some cases because it's simply going to drop the price so much that it's not going to be feasible to fish for those fish anymore. I think that that is going to be a major, major environmental improvement - getting the fishing fleets dismantled around the world. And if aquaculture can even play a tiny part in that, then the whole thing would have been worthwhile.

Aquaculture can be a major contributor to food supplies on the planet, but it's got to be more sustainable than it is now. And if the industry doesn't figure out how to make those tough choices and how to invest in those new technologies, then the consumers and governments are going to force them to.