The Emmett Environmental Law & Policy Clinic, in collaboration with the Environmental Law Institute (ELI), submitted comments today on regulations proposed by the National Marine Fisheries Service (NMFS) to implement the Fishery Management Plan for Regulating Offshore Aquaculture in the Gulf of Mexico (FMP).  While the proposed regulations represent a positive first attempt to implement a comprehensive offshore aquaculture FMP, the Clinic and ELI nevertheless suggest that the regulations are in need of significant improvements to address and minimize the environmental risks and impacts of offshore aquaculture.

The comments make several concrete recommendations, including that NMFS should (1) develop a scientific basis for determining maximum sustainable yield and optimum yield; (2) consider the full range of impacts when conducting project reviews; (3) expand and increase monitoring and reporting requirements; (4) expand the range of available remedial actions; (5) require short-term aquaculture permits for novel systems; (6) require that wild broodstock must be collected for each individual spawning event and that all juveniles are first generation descendents; and (7) expand site selection and financial assurance requirements.

The comments are based on a white paper, Offshore Aquaculture Regulation Under the Magnuson-Stevens Fishery Conservation and Management Act, that the Emmett Clinic, ELI and the Ocean Foundation issued last year.