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Below is a letter from the Coalition for U.S. Seafood Production (CUSP) submitted to the National Oceanic and Atmospheric Administration (NOAA) suggesting changes to the Gulf Plan to improve its commercial viability:

A core group of seafood industry stakeholders with a common interest in growing domestic aquaculture banded together in 2013 to form the Coalition of U.S. Seafood Production (CUSP).  CUSP is made up of aquaculture producers, retail and restaurant customers, researchers, technology and feed suppliers, public aquariums and other not-for-profit organizations. The group aims to provide expertise and support for government action that will enable aquaculture growth.  

In the United States, we are poised to expand domestic seafood production. Our efforts can help create jobs from working waterfronts to the agricultural heartland; make safe, nutritious, sustainable domestic seafood available to U.S. consumers; complement wild catch recovery efforts with farmed seafood; and reduce the seafood trade deficit.

In August of 2014, the National Oceanic and Atmospheric Administration (NOAA) posted the proposed rule, Fishery Management Plan for Regulating Offshore Marine Aquaculture in the Gulf of Mexico (Gulf Plan), to the Federal Registrar for public comment.  Since its inception, CUSP has identified approval of marine aquaculture in the Federal Waters of the United States as a top priority; specifically, the final approval of the Gulf Plan.  This plan should allow commercial production in a way that is environmentally, socially and economically responsible in the Exclusive Economic Zone (EEZ) of the United States. We are highly supportive of the end goal of the Gulf Plan, commercially viable aquaculture in the EEZ, and would like to commend NOAA for moving forward with it.

Having said that, we feel there are several critical areas that need to be addressed in the Gulf Plan to make it commercially viable. CUSP believes a primary objective of NOAA is to attract commercial investment into the Gulf of Mexico via aquaculture growth.  We therefore propose the following suggested changes to the Gulf Plan we feel will improve economic incentives for commercial aquaculture in the US, add jobs to the labor force and maintain environmental integrity in the Gulf of Mexico.

SUGGESTED CHANGES:

1) From the rule: “The rule would require entities that seek to locate offshore aquaculture and hatchery operations in the Gulf EEZ to apply for a Gulf aquaculture permit and, if approved, to comply with application and operational requirements and restrictions of that permit. Permits would be valid for 10 years. Approved entities could renew the permit at 5-year increments after the first 10 years in order to continue operations. The Council considered several alternatives to how long a permit is effective and NMFS specifically seeks comment on whether 10 years is appropriate.”

CUSP does not believe that a permit length of 10 years with 5 year renewals is sufficient in duration to attract significant commercial investment. The costs associated with establishing a facility in the EEZ are significant, and a commercial producer would likely not turn a profit for several years after the initial investment. CUSP questions the need for any duration limits on the permit length if the approved producer remains in compliance of their permit on an annual basis. However, if NOAA insists on establishing permit durations, we feel the initial permit should be 20 years. Also, we believe the permit renewal should be at least 10 years. 

2) The Gulf (29 million KG) and per farm (20% of Gulf, or 5.8 million KG) maximums are too low.  

It is our opinion that these numbers are set too low to generate commercial interest based upon the risks associated with being a pioneer in EEZ aquaculture.  The 20% cap for one company is too limiting and will decrease significant interest. As stated above, the investment capital required to start an offshore facility will  be sizeable. CUSP believes the proposed cap would restrict cash flow to the point where profitability is delayed to the point of limiting investor interest. We do not believe a cap set on individual companies; if a company is able to secure financing and demonstrate compliance with environmental and other permits, they should not be penalized by a system that has its roots in the sharing of fishing quotas. In addition, these companies should be allowed to permit multiple locations so they have the capacity to fallow specific offshore facilities while maintaining production in other locations. This will encourage a global standard of production practices. 

We also question the size of the overall limit (29 million KG). The U.S. seafood trade deficit is billions of dollars; the production limit would only address a drop in the bucket of our overall deficit. CUSP questions the need for an overall cap, but if one must be set, a clear path must be defined that would allow for an increase in that number over time.

3) From the rule: “Overfishing and overfished thresholds for wild stocks have been approved by the Council for evaluating the status of managed stocks and stock complexes. These thresholds will be used by NMFS to determine if offshore aquaculture in the Gulf EEZ is adversely affecting wild populations, causing them to become overfished or undergo overfishing.”

This statement needs major clarification. There are numerous stressors that could cause declines in wild stocks. Clearly these stocks are already depressed unrelated to offshore aquaculture. How does NOAA prove aquaculture is the environmental stressor causing potential negative impacts? Without clearly defined, unbiased, evidence-based science this statement seems to provide federal regulators with an arbitrary way to pull support from a commercial facility that has been compliant with their permit. We want to know how NOAA will be able to differentiate causes in declines of wild stocks.

As stated above, CUSP strongly supports the efforts of NOAA to establish commercial aquaculture in the EEZ of U.S. waters through the execution of the Gulf Plan. We believe a properly implemented Gulf Plan can provide a road map for development of commercial aquaculture in the federal waters of other regions in the United States. We strongly suggest that NOAA take our recommendations and make changes to the Gulf Plan in order to make it more commercially viable.

Thank you for the opportunity to provide comments.

Steven Hart, Executive Director, Soy Aquaculture Alliance

Chris Stock, Sales Manager, Zeigler Bros., Inc.

Craig Browdy, Director of Research and Development, Zeigler Bros. Inc.

Alan Cook, Vice President Aquaculture, Icicle Seafood

Michael D. Chambers, Aquaculture Specialist, University of New Hampshire

Maine Aquaculture Association

Neil Anthony Sims, Co-Founder; CEO, Kampachi Farms, LLC

John Connelly, President, National Fisheries Institute

Don Kent, President, Hubbs-SeaWorld Research Institute

Lorenzo M. Juarez, CEO, Baja Aquaculture, Inc.

American Soybean Association

Chris Weeks, PhD, Michigan State University

Bob Miller, Vice President, Aquaculture, Pentair Aquatic Eco-Systems, Inc. 

Joe Hendrix, SeaFish Mariculture, Houston, Texas

Dan Vogler, Harrietta Hills Trout Farm, LLC

East Coast Shellfish Growers Association

Anthonie M. Schuur, Vice President and President Elect (2016), California Aquaculture Association

Phil Cruver, CEO, Catalina Sea Ranch

Bill Dewey, Taylor Shellfish Farms

George Chamberlain, Managing Director, Integrated Aquaculture International, LLC

Randy Rhodes, Harvest Select

Sean J. O’Scannlain, President & CEO, Fortune Fish & Gourmet