Offshore Factory Fish Farms

On 12/15/21 the Times published a guest column, authored by Mote CEO Dr. Michael Crosby and aquaculture researcher Dr. Kevan Main, that promoted industrial offshore aquaculture, primarily because of its potential economic value. The authors prefaced their column by stating: Offshore aquaculture should not be developed in Florida without rigorously responsible management plans. As an environmental lawyer and boardmember of our region’s two Waterkeeper organizations, I agree with that statement. 
The rest of the column, however, goes on to champion an unprecedented project under review by the Environmental Protection Agency (EPA) and Army Corps of Engineers (Corps) that would permit an industrial fish farm in offshore Gulf waters that could fuel red tides where they originate and impact native fish populations with disease and parasites. Mote has been promoting this controversial project, in which it is a prospective financial beneficiary, aiming to provide the juvenile fish stock and monitor the site – for a fee.  
The big problem here is that the project has not been developed with the “responsible management plans” embraced by the authors, particularly with regard to the monitoring of its potentially large and potentially very negative effects on the environment and fisheries of the SW Gulf. There is currently a vacuum of regulatory oversight and the authority for permitting and monitoring offshore aquaculture in the US has “devolved” solely to the EPA and Corps.
The problem revolves around the fact that these agencies have almost no experience with permitting and monitoring anything similar to offshore aquaculture activities. The permitting process and monitoring requirements for this project echoes the failed EPA permitting and monitoring scheme for common inland projects like scrap yards and the Corps permits for anchorages. They are woefully inadequate to insure against the potentially catastrophic negative impacts that might arise from this project and succeeding expansion of factory fish farming along our coast and beyond. 
What are these potential impacts? The rapid international expansion of offshore fish farming of caged and concentrated fish has been marred by many international incidents of devastation of wild fish populations through transmission of diseases and parasites from the caged fish. The EPA monitoring plan for this project provides almost no effective monitoring of infection of closely related local species that are abundant immediately around the cages, in order to prevent potentially devastating damages to recreational and commercial fisheries.
Perhaps more importantly, EPA’s proposed permit requirements are totally insufficient to detect and quantify the impacts from Red Tides on the Suncoast that might be triggered or fueled by concentrated fish wastes and excess feed flowing from the fish pen and polluting the waters around the site.
Proper monitoring requirements must be developed by independent, scientific experts – not just proposed by industrial fish farmers or EPA regulators. If ever there was a need for review by a robust body like the National Academy of Sciences, this is it.
At a minimum, these and other concerns should be addressed in the form of a full environmental impact study (EIS) as required by the National Environmental Policy Act. EPA reviewed the applicant’s abbreviated Environmental Assessment and made an inappropriate and arguably illegal determination that the project would have “no significant impact” and did not trigger a full EIS review. 
Without assurances that disease/parasite or nutrient/red tide effects will not result from the proposed project, it does not meet the columnists’ criterion of “rigorously responsible management plans.” It should not be permitted to go forward without such. Moreover, any review of this proposed project should consider the cumulative impacts of the multitude of projects to follow should this “pilot project” move forward.
Mote Marine’s motto is “We are guardians of the sea and all living things that depend upon it.”  Mote should therefore, by its own words about responsible management and its motto, be at the forefront of demanding more thorough analysis before projects with high potential for significant impacts on the marine environment and surrounding communities are implemented.  
The leadership at Mote should guard against diluting its mission, which is to advance science through research, education and research. Mote’s historic role of guardian of the seas is needed today more than ever. The appearance of chasing money and playing politics erodes Mote’s mission and role. Our coastal waterways are imperiled and we need all the help we can get.

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