Comment on FR Doc # E8-14911

Dear MMS administrator, Establishing aquaculture on the OCS and in the open oceans is fraught with serious problems. While it may seem reasonable from a financial standpoint to concentrate cultivation and harvesting marine food sources into the well controlled areas of sea pens and pelagic corrals, feeding these operations is likely to become an economic disaster. OCS fish farming will depend on new practices that will dramatically increase the stresses on our existing - and currently failing wild fisheries. These practices will include: - Commercial fishing down into the lower trophic levels to extract food (krill, shrimp and forage fish) for the aquaculture operations. This practice will be in conflict and direct competition with a wide variety of interdependent marine animals - such as marine mammals, sharks, birds and existing commercial wild fisheries. - Disrupting the balance of the ecosystem by subsidizing commercially exploitable species at the expense of all others. This practice compromises the roles that any and all species play in the balance of life in healthy ecosystems. This is particularly dangerous because the balance of life in the ocean depends on so many animals that we have yet to understand - and may not even know. (e.g. Why has the Atlantic Cod failed to recover after 15 years?) - High concentrations of fish in pens will require the high concentrations of antibiotics to stave off diseases and other pharmaceuticals to mediate stress. This practice will become a springboard for bacterial and viral diseases that will infect wild populations and further compromise our wild fisheries. - Farmed fish will escape, mingle and breed with wild stocks, further compromising the existing wild commercial fisheries. - The expense of OCS fish-farm infrastructure will limit aquaculture access to large corporate entities that will not be flexible enough, or willing to modify their operations when the aforementioned problems clearly threaten the health of the seas. It is highly probable that these corporate entities will be economic entities ruled by stock values and short term market forces rather than long term governed sustainable practices. - Given the ambiguous boundaries of the sea, OCS aquaculture operations will be far from the view of the public and regulatory agencies (self-monitoring has always been the tacit law of the sea). When problems arise they will only be noticed by those who created the problem. This is a recipe for disaster. - For the aforementioned problems, OCS aquaculture threatens the existing and already compromised commercial wild fisheries. For these reasons, large OCS aquaculture operations should be prohibited. OCS Aquaculture is not an answer to sustainable food harvesting from the sea, rather it would likely become the final blow to the already compromised health of our oceans. Sincerely, Michael Stocker Director Ocean Conservation Research