Background:
The Mangrove Action Project has teamed with the Ocean Conservancy to support an appeal to the Gulf of Mexico Fishery Management Council in January 2009 to halt the development of its Open Ocean Aquaculture Fishery Management Plan.  Despite the support of 124 of our colleagues and overwhelming public opposition, the Council signed off on the plan and sent it to the Secretary of Commerce for final approval.

Now is the last opportunity for conservation and consumer organizations, fishing groups, seafood businesses, independent scientists, and other concerned parties to voice their opposition to this legally-questionable plan to establish a fragmented approach to regulate open ocean fish farming in the Gulf of Mexico.  The Aquaculture FMP lacks the environmental, socioeconomic and liability standards needed to protect Gulf ecosystems and their associated communities from the myriad of scientifically-documented risks of open ocean aquaculture.  If approved by the Secretary of Commerce, the Aquaculture FMP will directly undercut the role of Congress in fully considering overarching federal legislation to develop a coordinated national framework for open ocean aquaculture to regulate this nascent industry.


Get Involved:
MAP and the Ocean Conservancy urges supporters to read the following letter to Gary Locke, and sign and return the letter by July 20, 2009. Please send to:

Jamie Ferro, Aquaculture Policy Analyst, Ocean Conservancy

aquaculture1@oceanconservancy.org

Be sure to include the correct and full spelling of your name, your organization, and your title in the following format:

Name
Organization Name
Title


Letter to Gary Locke:
July 31, 2009

Secretary Gary Locke[1]

U. S. Department of Commerce

14th Street and Constitution Avenue, N.W.
Washington, DC  20230

RE: REQUEST FOR COMMENTS: NOTICE OF AVAILABILITY OF THE FISHERY MANAGEMENT PLAN FOR REGULATING OFFSHORE MARINE AQUACULTURE IN THE GULF OF MEXICO (FMP) - RIN 0648-AS65

Dear Secretary Locke:

We, the undersigned XXX conservation organizations, fishing groups, consumer organizations, seafood businesses, independent scientists, and other concerned parties strongly encourage you to disapprove the Aquaculture Fishery Management Plan adopted by the Gulf of Mexico Fishery Management Council (Council) on January 28, 2009.  While the Council, its Joint Management Committee, and the Interdisciplinary Planning Team (IPT) worked diligently on this plan, it is still fundamentally flawed in its approach.  Included among a host of shortcomings are the following 4 critical issues:

1.      The Gulf Council and NOAA lack the statutory authority to develop a permitting system for open ocean aquaculture under the Magnuson-Stevens Fishery Conservation and Management Act.  Congressman Nick Rahall, Chair of the House Committee on Natural Resources, clearly articulated this issue in his letter to the Council dated October 24, 2008.  A bipartisan group of 37 Members of Congress voiced similar concerns to you on June 12, 2009. The Department of Commerce must not move forward without appropriate authority.

2.      The Aquaculture FMP is also legally deficient as it fails to meet the minimum requirements of the National Environmental Policy Act and the Endangered Species Act.  Among other weaknesses, the Programmatic Environmental Impact Statement is based on unfounded assumptions and incomplete information (including ignoring the vast body of relevant, peer reviewed scientific information), all reasonable cumulative impacts have not been identified, and the range of alternatives considered is too narrow.

3.      The Aquaculture FMP lacks the types of environmental, socioeconomic and liability standards needed to protect Gulf ecosystems and their associated communities from the scientifically-documented risks of open ocean aquaculture.  These risks include enhanced pressure on domestic and foreign forage fish fisheries, genetic impacts from interbreeding of escaped and wild fish, disease and parasite amplification and retransmission from farmed fish to wild fish, changes in benthic communities from nutrient pollution, mortality of birds, marine mammals and other predators attracted to fish cages, and price competition in the marketplace between wild and farmed product.  Nothing in the FMP ensures these risks will not be realized during the development of a new industry in the Gulf of Mexico.

4.      Finally, a decision by you to approve the Aquaculture FMP will directly undercut the role of Congress in fully considering federal legislation to develop a coordinated national framework for open ocean aquaculture, with explicit environmental performance standards, to regulate this nascent industry. If approved, the Gulf Aquaculture FMP would establish a harmful precedent by initiating a fragmented system for regulating offshore aquaculture when future plans for national legislation under a new Administration, a new Congress, and new leadership at NOAA remain unresolved.

Over 16,000 public comments have been submitted to the Gulf Council on the Aquaculture FMP. Less than 50 have been in support of the plan.  Clearly, the general public does not support this plan and neither do the XXX organizations or individuals that have signed this letter.  We urge you to disapprove this plan and halt any further development of the Aquaculture FMP.  Continuing to pursue such an approach is both contrary to current law and an irresponsible use of public dollars, especially when other mandatory regulations, such as the implementation of the new Magnuson provisions, require the Council's attention and resources.


Sincerely,

Name
Organization Name
Title