Pacific Island Fisheries: Programmatic Environmental Impact Statement; Aquaculture Management Program

Aloha, our group has many concerns regarding open ocean aquaculture, especially what our members have seen here in Kona including the attraction and potential harm to endangered monk seals. As per comments you've received regarding this issue -- comments with which our members concur. Open ocean aquaculture is prohibited in federal marine waters because of the proven negative impacts industrial/commercial aquaculture has on ocean ecosystems and wild fish populations. In the past, U.S government agencies applied the Precautionary Principle to protect the ocean, but the previous U.S. administration began to undermine this position, setting in motion dangerous decisions. We have to lean-in now to put ocean protections back on course. That is why it is critical that you act now to steer the government back towards protecting our imperiled oceans, which are already under threat by climate change. Concern with which our members concur and that others have stated include: The potential lack of legal authority for NOAA to be considering an aquaculture program requiring rule-making for the Pacific Island Region Open-ocean aquaculture farms (OOA) are industrial concentrated feeding operations that without exception alter and pollute ecosystems whether on land or sea. The impact of applying antibiotics and pesticides into pristine ocean environments. The impacts of inevitable alteration of wild fish population behavior. The impacts of increasing surface level ocean temperatures with both declining surface oxygen concentrations and increased stratification that leads to reduced ventilation of the subsurface ocean. The impacts of climate change on pathogens and parasites on OOA as well as wild fish populations. The impact of slowing ocean currents due to climate change which will result in more concentrated waste, feed, pesticides, and antibiotics in and around OOA operations. The impact of increasing numbers of extreme weather events, including hurricanes. Whether it would be a more effective use of federal funding and resources to develop and promote proven local aquaculture programs and operations, such as aquaponics and traditional Hawaiian fishponds which provide better food security, and create more centralized, organized communities that are far less carbon intensive. The impacts on the ability to service OOA from Pacific Islands coastal infrastructure due to sea level rise. Whether OOA violates the Public Trust Doctrine which underlies the view that the United States holds ocean resources in trust for the benefit of all its citizens. The impact of the U.S. Department of Interior review (2017 Presidential Executive Order #13792) recommending the elimination of the current prohibition of commercial fishing in the Pacific Remote Islands and Rose Atoll Marine National Monuments and a reduction in the boundaries of both these Marine National Monuments. The contents of the report by the Secretary of Commerce (2017 Presidential Executive Order #13795) as to whether any Marine Monument or Sanctuary designation or expansion during the past 10 years has had a negative impact on commercial energy or mineral development. Allegations of mismanagement, misuse of power, and conflict of interest issues with WESPAC, the "Responsible Council" for the DPEIS which "controls millions of dollars that flow through a special fund with little oversight on how the money is being spent and by who…a significant amount has gone to businesses that are owned or managed by current council members as well as contractors who are politically aligned with WESPAC's goals to promote commercial fishing interests." (Honolulu Civil Beat, 6/10/19). The potential impact of OOA on the Deeds of Cession which transferred sovereignty to the United States while protecting the customary rights and property of the people of American Samoa and the status of the current legal action being taken against NOAA and WESPAC (Territory of American Samoa v. NOAA, NMFS, et al.…