Comment from Alexis Cabarcas-Nunez, University of Puerto Rico

Overall, the Aquaculture Fishery Management Plan (FMP) report is a good document for promoting the development of offshore aquaculture operations in the Gulf of Mexico. However, we would like to make some observations on it: 1. We agree to allow only native species from the Gulf of Mexico for developing offshore aquaculture operations in the Gulf. However some controversy could emerge related to the requirement to only allow the culture of fish coming from broodstock captured from the Gulf. Some existent hatcheries, for instance, in Florida have broodstock ready to produce fingerlings of native species from the Gulf for aquaculture operations, but the broodstock have been captured in places different than the Gulf such as East Florida. The migratory pattern of some species such as cobia has been reported to migrate distances farther than 365 miles. We wonder if there are marked genetic differences of inner-Gulf cobia and cobia found in Sebastian-Florida. We knew a 2005 publication from the Texas A. M. University related to genetic variation of cobia in the Gulf, but still we can conclude anything. . 2. We support the preferred alternative to only allow the use of Council managed species for culture in the Gulf, but please ensure these include current promising fish species for aquaculture. 3. In Action 2, alternative 3(a)(2)(ix), a description of endangered and threatened species, essential fish habitat, wild marine fishes, wild invertebrates, and migratory birds present at the proposed aquaculture site, including their abundance and distribution will be required. We wonder if the permit applicant could fulfill these requirements by making a video-survey (as you suggest n Action 6, (3) (d) on the proposed site and complementing the site characterization with existent information. If there is no available information on the site regarding the above issues, what should the permit applicant do to fulfill these requirements? It is known that describing wild marine fishes and invertebrates needs consideration on the seasonal variation and influence of other factors. It will be good to clarify what is expected. Video surveys and some samplings, complemented with existent information on the site could be a useful tool to assess the reliability of a site for aquaculture purposes. In case there is no available information, how much additional monitoring for describing the site in more detail would be required during the development of the aquaculture operation? 4. In Action 5, Alternative 3 (3), among the factors that will be used to assess allowable aquaculture systems will be the efficiency of mechanisms used for feeding; the efficiency of mechanisms used for feeding will depend on the device or techniques used for feeding (automatic or time feeders, pumps, manually, etc.), the feeding frequency, experience of the workers, etc. but in some cases it could be independent of the aquaculture systems used to contain the cultured organisms (cages, net-pens, etc). Please clarify how the “efficiency of mechanisms used for feeding” will be used to evaluate allowable systems. 5. In Action 5, Alternative 3 (4), among the factors that will be used to assess allowable aquaculture systems will be the ability of the system to disperse wastes. The waste dispersion around a site will depend on many factors and not only on the allowable aquaculture systems to be used. Thus, although it is known that some aquaculture systems could better disperse the waste than others, this desirable condition could be affected by other factors such as site characteristics (currents), farm practices (feeding frequency, stocking density, etc), cages type (submersible and floating), cage array, distance of cages off the bottom, feed type (floating, neutral, submersible), etc. These complex factors will be difficult to assess when evaluating the suitability of an allowable aquaculture systems. Please include the factors for this evaluation. 6. In Action 6, preferred Alternative 3 (c), among the criteria for siting marine aquaculture facilities are that the permitted site would be twice as large as the total area encompassed by allowable aquaculture systems to allow for fallowing and rotation of systems. We suggest that fallowing be based on the level of benthic impact. Otherwise, cages could be rotated every two years for about 12 months. Recovery of the seabed after farming is variable, but usually takes 12 months or longer, depending on the site characteristics and nature of the impact. 7. In Action 6, preferred Alternative 3 (d) states that the permit applicants would have to submit a video survey of benthic habitat at the proposed site to allow NOAA Fisheries Service to evaluate the benthic habitat at the proposed site and ensure siting would not affect any EFH or permitted artificial reef areas. This information could be obtained without a video if those sites are already marked or identified. The video could complement that information and provide useful data on specific characteristic of the proposed site such as presence or absence of macrofauna and flora, bottom and sediment type, etc. 8. Action 9, preferred Alternative (2), suggests as the biological reference points and status determination criteria for aquaculture in the Gulf of Mexico, the Proxy for MSY to be equal to OY, and the proxy for OY not to exceed 64 million pounds, and that no individual, corporation, or other entity can produce more than 20% of OY. However, as it was established in the discussion and rationale on Action 9 in the FMP, these concepts could have little utility or are not generally applicable to the management of aquaculture operations. The MSY in the FMP refers to the total yield harvested by all aquaculture operations in a given year. The MSY reference point in fisheries is based in estimation to ensure the sustainability of the fisheries stocks. But in aquaculture all the production stocked that survives must be harvested and replaced again for new batches (stocks). The reference points for aquaculture operations should be based on the concept of assimilative or carrying capacity of each proposed site. The assimilative capacity of a site will depend of many variables such us current velocity, site depth, sediment type, wastes discharged, etc. Because there is no information on the carrying capacity of the Gulf, some assumptions and some preliminary reference point and status determination criteria could temporarily be established. For example, oxygen = 5 mg/L at a distance 100 m from the cage operations; setting limits for medicine to some distance (100 m), setting limits for biomass allowed, nutrients, etc., while the information on the carrying capacity of the sites are obtained. Then models could be developed to better manage the aquaculture operations. Established amounts of biomass per site could be allowed with an option to increase it while some information on the carrying capacity of the site is obtained. The carrying capacity of a site (in term of biomass) could be expanded if the aquaculture operation uses good management practices 9. Could one company submit two or more permit application simultaneously? If that option is considered, how it would work (i.e. a company could only apply for a second permit after fully operating the first permitted operation), what about of a permit application for expanding a site already permitted? Will this scenario be considered as a new application or a modification of the existing one? 10. Nothing is said about the site size to be permitted for an application. Considering the size of the Gulf and the space apparently available for aquaculture purposes and based on the desirable criteria to protect the environment and natural resources, one company could ask for a site larger than the minimum distance selected as appropriate between one aquaculture facility and another (1.6 nm2, Action 6, Alternative 3b). What is the size site expected? Based on the criteria summarized in sub-alternatives 3(a) and 3(e), approximately 28,719 nm2 would be suitable for offshore aquaculture in the Gulf of Mexico, so the distance between aquaculture facilities could be farther than the recommended 1.6 nm. Considering the site available for aquaculture, fallowing of cages must be mandatory, because it could allow the recovery of impacted areas. The main impact on a cage operation occurs immediately underneath the cages, so fallowing could allow the recovery of the impacted areas in one or two subsequent culture periods. Preferred Alternative 3 would require a permitted site to be twice as large as the area encompassed by allowable aquaculture systems. What would be the size to proper deploy the systems to be used? Does that size include the expected impact zone for that facility and some buffer zone?.