Act Now for the Gulf of Mexico!

DEADLINE IS AUGUST 1, 2022

See Instructions for submitting comments below.

The National Oceanic and Atmospheric Administration (NOAA) is carving up the Gulf of Mexico to establish floating factory farms. They are asking for the public to comment on these sites, called Aquaculture Opportunity Areas. This is your opportunity to say No to Factory Fish Farms in the Gulf of Mexico! 

Offshore Finfish Farming - OFF - is the mass cultivation of finfish in marine waters, in underwater or floating net pens, pods and cages. They are factory farms that harm public health, the environment, and local communities and economies that rely on the ocean and its resources. 

Unfortunately, US federal agencies are promoting this type of industrial food production. As a result of a Trump-Era Executive Order (EO 13921), the National Oceanic and Atmospheric Administration (NOAA) created an atlas, identifying “aquaculture opportunity areas.” 

NOAA created an atlas for the Gulf of Mexico, identifying 9 ideal locations for these factory fish-farms. Two of these ideal locations are located right in the Gulf dead zone.

These facilities discharge untreated fish waste and chemicals directly into natural waters, Pens are packed with finfish and can become a breeding ground for parasites like sea lice, and other fatal diseases. In response, industrial farms use a variety of antibiotics, pesticides, and other chemicals, which pollute the ocean and contaminate the fish. They also release nitrogen and other pollutants that will exacerbate the red tides already wreaking havoc in the Gulf of Mexico.

NOAA is accepting public comments on these aquaculture opportunity areas and specifically on their  “Notice of Intent To Prepare a Programmatic Environmental Impact Statement for Identification of One or More Aquaculture Opportunity Area(s) in  Gulf of Mexico and To Conduct Public Scoping Meetings” (Agency/Docket Number RTID: 0648-XB900 RTID.)  If you want to view the entire atlas, click here.

Take Action Now! Tell NOAA that you support Alternative 1, the No Action Alternative, in which no AOA would be identified in Federal waters offshore of the Gulf of Mexico!

INSTRUCTIONS: ALL COMMENTS MUST BE SUBMITTED ONLINE. GO TO THIS LINK, THEN COPY AND PASTE THE COMMENTS BELOW, OR USE THESE COMMENTS TO WRITE YOUR OWN. DEADLINE IS AUGUST 1, 2022

COMMENTS: 

I urge you to adopt Alternative 1, the No Action Alternative, in which no AOA would be identified in Federal waters offshore of the Gulf of Mexico.

NOAA’s efforts to regulate aquaculture in the Gulf of Mexico are illegal. The 5th Circuit court case Gulf Fishermens Ass’n held that NOAA does not have authority to permit or regulate aquaculture in U.S. federal waters, as there is no Congressional authorization to do so under MSA or otherwise (see Gulf Fishermens Ass’n v. Nat’l Marine Fisheries Serv., 968 F. 3d 454 (5th Cir. 2020)).

The legal authority of Executive Order 13921 to push forward with designating Aquaculture Opportunity Areas is a gross power grab. Former President Trump should not have changed the regulatory process through an Executive Order, which circumvents Congress and our democratic electoral process. 

These farms are “water grabs,” by which the federal government and corporate partners seize the ocean to establish an industry that will harm coastal communities and the livelihoods of people who live and work along the water. Furthermore, NOAA has been funneling millions of dollars of taxpayer money into the pockets of corporations seeking to develop this CAFO-style fish farming in U.S. waters.

These floating factory farms take significant time and money to build; they are not community driven; nor will they benefit people living in coastal communities. In the recent NOAA listening sessions on offshore fish farming, oral comments have overwhelmingly opposed these facilities. It seems the only ones who support them are well-heeled corporations, such as Cargill, Merck, and Sysco.

Aquaculture facilities are intensive operations that generate large amounts of nutrients (nitrogen and phosphorus) and other waste products. The organism that causes Florida red tides, Karenia brevis, is known to intensify as a result of those nutrients. Even your own scientists have stated this hypoxic zone was caused by “high levels of nutrients, primarily from activities such as industrial agriculture and inadequate wastewater treatment.” Industrial scale aquaculture in the Gulf would worsen this existing problem.

In 2018, Southwest Florida experienced one of the worst red tide events in recorded history. On Sanibel Island, the City of Sanibel removed more than 850,000 pounds of dead marine life from the beaches. This event had widespread impacts on the local economy, with the local Chamber of Commerce reporting more than $47 million in economic losses from July to December related to tourism, real estate and recreational fishing. Permitting an aquaculture facility in the shallow Gulf waters in an area where red tide frequently occurs would be irresponsible and would exacerbate our existing water quality issues.

Two of the aquaculture opportunity areas - C-11 and C-13 - are located in the Gulf of Mexico Dead Zone, which indicates that NOAA is not making decisions based on the best scientific information for the benefit of the Gulf of Mexico coastal communities or marine ecosystem.

Additionally, the threat of fish escapes is likely, especially given the propensity for intense hurricanes to hit the Gulf region. Farmed fish are genetically inferior fish, and when they interbreed with wild stock, they bring down the fitness and survivability of the wild fish stocks. Floating CAFOs incubate and proliferate diseases that then spread to the wild fish populations, harming both the marine ecosystem and wild fisheries.

Fish farms directly lead to overfishing of forage fish. Most farmed marine fish require large amounts of fish in their feed – much of this comes from wild prey fish, like menhaden, sardines and other small fish that are critically important to the diet of marine wildlife – birds, dolphins, sharks and other fish. Removing massive amounts of bait fish from our oceans means less food available for wild fish and can change relationships in our ecosystem with many widespread consequences.

Lastly, this type of industry has a massive carbon footprint associated with the global sourcing, capturing, blending, and shipping of feed inputs to go into the fishfeed, and related infrastructure associated with keeping them in cages, feeding them, medicating them, and harvesting them. 

This is not a solution to our world’s problems. This type of industrial activity will only exacerbate our environmental, economic, and social problems. 

Thank you for considering my comments and my support of the No Action Alternative.