Comment from Ken Nedimyer, Coral Restoration Foundation, Sea Life inc

As this offshore aquaculture plan is developed, keep in mind that there is already an offshore live rock aquaculture program in place for the Gulf of Mexico and the South Atlantic, and the rules governing one type of activity should not conflict with the other activity. For the most part, live rock aquaculture is a passive operation that does not require feeding and does not produce any down stream effluent. The placement of the seed rock on the sea floor may have a slight local impact, but that impact tends to be positive by enhancing the benthic habitat. Also keep in mind that the program being developed by the Gulf Council will serve as a template for other regional councils, and with that in mind I would like to point out that offshore coral and octocoral aquaculture operations are already in place and operating in the federal waters of the Florida Keys. These pionering operations are producing corals for restoration and research uses in the Florida Keys, and producing octocorals for commercial sale to the aquarium trade. Like live rock aquacultue, they are passive programs that do not receive any feeding or produce any effluent, and the structures they are grown on and provide habitat for a wide variety of native invertebrates and fish. This type of aquaculture should be encouraged, and we wish to bring this to the attention of the Gulf Council and the South Atlantic Council as the make rules governing other types of offshore aquaculture activities.