Capt. Keith Wils
03-09-2016, 12:51 PM
-----Original Message-----
From: oldgrin <oldgrin@aol.com>
To: oldgrin <oldgrin@aol.com>
Sent: Wed, Mar 9, 2016 12:29 pm
Subject: Just released: The Michigan QOL agencies do not recommend pursuing of commercial net-pen aquaculture in the Great Lakes at this time
FYI
Synthesis Report Regarding Net-pen Aquaculture in the Great Lakes - March 9, 2016
http://www.michigan.gov/mdard/0,4610,7-125-48096_48099_71766---,00.html
Denny Grinold
Conclusions:
The Michigan QOL agencies do not recommend pursuing of commercial net-pen aquaculture in the Great Lakes at this time for the following reasons:
•
Given the ecological and environmental risks and uncertainties, as pointed out by the Science Panel and with further information provided through public input, commercial net-pen
aquaculture would pose significant risks to fishery management and other types of recreation and tourism. Furthermore, both collaborating management interests and tribal nation interests would likely not agree to Michigan moving forward and pose a significant challenge in any attempts to do so.
•
The $3.3 million to implement a commercial net-pen aquaculture program by the State to protect the public’s interest in the Great Lakes and provide the stated expected service to the industry are not provided through any conventional funding models available to the QOL agencies. There would need to be a new funding stream identified for this industry effort to support initial costs as well as the $2.33 million needed annually to monitor and maintain the program and protection of the state’s resources. This level of public investment for an estimated return of $10 million (under the modeled scenarios for two facilities) does not appear to be a prudent use of the state’s resources at this time.
•
Regulatory authority does not currently exist to issue registrations for commercial aquaculture in the Great Lakes.
It is important to note that MDEQ must make a Part 325 and NPDES permitting decision regardless of the ability to license an aquaculture facility. Any policy decision regarding aquaculture in the Great Lakes must be carefully constructed to prevent a preempting of DEQ’s permitting processes which could result in unnecessary litigation; and to prevent stimulating permit applications. Decisions made in this process have a very high likelihood of legal challenge.
While not recommending the pursuit of commercial net-pen aquaculture in the public waters of the Great Lakes, the state can and will continue to work within existing authorities to assist the industry in development of well-designed flow through, closed and recirculating aquaculture facilities.
8
From: oldgrin <oldgrin@aol.com>
To: oldgrin <oldgrin@aol.com>
Sent: Wed, Mar 9, 2016 12:29 pm
Subject: Just released: The Michigan QOL agencies do not recommend pursuing of commercial net-pen aquaculture in the Great Lakes at this time
FYI
Synthesis Report Regarding Net-pen Aquaculture in the Great Lakes - March 9, 2016
http://www.michigan.gov/mdard/0,4610,7-125-48096_48099_71766---,00.html
Denny Grinold
Conclusions:
The Michigan QOL agencies do not recommend pursuing of commercial net-pen aquaculture in the Great Lakes at this time for the following reasons:
•
Given the ecological and environmental risks and uncertainties, as pointed out by the Science Panel and with further information provided through public input, commercial net-pen
aquaculture would pose significant risks to fishery management and other types of recreation and tourism. Furthermore, both collaborating management interests and tribal nation interests would likely not agree to Michigan moving forward and pose a significant challenge in any attempts to do so.
•
The $3.3 million to implement a commercial net-pen aquaculture program by the State to protect the public’s interest in the Great Lakes and provide the stated expected service to the industry are not provided through any conventional funding models available to the QOL agencies. There would need to be a new funding stream identified for this industry effort to support initial costs as well as the $2.33 million needed annually to monitor and maintain the program and protection of the state’s resources. This level of public investment for an estimated return of $10 million (under the modeled scenarios for two facilities) does not appear to be a prudent use of the state’s resources at this time.
•
Regulatory authority does not currently exist to issue registrations for commercial aquaculture in the Great Lakes.
It is important to note that MDEQ must make a Part 325 and NPDES permitting decision regardless of the ability to license an aquaculture facility. Any policy decision regarding aquaculture in the Great Lakes must be carefully constructed to prevent a preempting of DEQ’s permitting processes which could result in unnecessary litigation; and to prevent stimulating permit applications. Decisions made in this process have a very high likelihood of legal challenge.
While not recommending the pursuit of commercial net-pen aquaculture in the public waters of the Great Lakes, the state can and will continue to work within existing authorities to assist the industry in development of well-designed flow through, closed and recirculating aquaculture facilities.
8