Keep Ocean Fish Farms off Energy Platforms

Dear Secretary Salazar,

I appreciate the opportunity to submit comments regarding the Minerals Management Service's (MMS) Proposed Rule for Alternative Energy and Alternate Uses on the Outer Continental Shelf.

To strengthen the rule, I urge you to consider prohibiting the use of energy facilities for ocean fish farming. When presented to the public last summer, MMS's rule contained language that would allow ocean fish farms to be associated with energy platforms. Even if this has now been removed from the final rule, a prohibition would help ensure that that new uses for energy facilities don't cause more harm than good.

Open ocean aquaculture involves a myriad of risks that have not been thoroughly researched. Both accidents and the day-to-day activities of ocean fish farming facilities have the potential to significantly harm the environment, human health and the economies of coastal communities nationwide.

Offshore aquaculture in the United States could pose many of the same documented problems as large-scale net pen and cage aquaculture have created around the world. These problems include, but are not limited to: antibiotic, fecal and toxic chemical pollution; the transmission of infectious diseases, bacteria and parasites; and escapement of farmed fish into the wild, intermixing with or overtaking wild populations. Finally, offshore aquaculture in the U.S. could cause negative socioeconomic impacts by competing with existing wild capture seafood industries. As the number of fishermen dwindles, support businesses, like marine supply stores, will also suffer, risking massive job loss and hurting our economy.

Because of these and other harmful effects, policy reports from our own Government Accountability Office and the U.S. Ocean Policy Commission have stated that if open ocean aquaculture is to be permitted, it is essential that it be regulated with strong safeguards to protect both the environment and local fishing communities.

MMS is an energy agency and is not properly equipped to comprehensively manage ocean fish farming.

It is also questionable whether MMS has the legal authority to permit ocean fish farming - a wholly new industry in our oceans. The 2005 Energy Act gives MMS authority over "authorized marine-related" alternate uses. As of yet, Congress has not authorized ocean fish farming as a valid marine related use. In fact, Congress has refused to pass several bills to permit offshore aquaculture - in large part because they did not have strong environmental and socioeconomic safeguards.

To avoid all these problems, I ask you as Secretary of the Interior to include a prohibition against using energy platforms as sites for ocean fish farms.

[Your comment here]

Thank you for taking my concerns into consideration.