Upholding NEPA in NOAA's proposal for offshore aquaculture legislation
This letter was sent to Washington Congressional Representatives Inslee,
McDermott, Dicks, Dunn and Baird.
July 1, 2004
Re: uphold NEPA in NOAA's proposal for offshore aquaculture legislation Dear Representative,
As the CFO of a consumer owned business representing nearly 40,000 households throughout King County, I'm urging you please to sign onto Representative Capps' "Dear Colleague" letter to uphold the National Environmental Policy Act (NEPA) with respect to offshore aquaculture legislation soon to be proposed in Congress. NOAA plans to submit legislation that would allow, for the first time, aquaculture in federal waters. Yet NOAA has failed to conduct a Legislative Environmental Impact Statement (LEIS). This violates NEPA.
As you know, NEPA requires that all "proposals for legislation and other major Federal actions significantly affecting the quality of the human environment" include a detailed statement on the environmental impacts of the proposed action. 42 U.S.C. §§ 4332(C).
The purpose of the NEPA requirement is to ensure that decision-makers are fully informed of the environmental impacts of their decisions before making them, and to provide the public with information and opportunity to comment on issues that directly affect them. I'm concerned that the omission of LEIS by NOAA will severely limit a thorough consideration by Congress, and the public, of critical information about the harmful effects of offshore aquaculture.
Open ocean aquaculture threatens the health of the environment, with large amounts of fish waste, disease, and antibiotics to the certain escape of penned fish, which interbreed with wild fish and alter the composition of native genetics. Genetically engineered (GE) fish are not permitted within Washington State's two-mile coastal zone. Yet, it's likely under the NOAA proposal that GE fish farms might be sited just outside the state's coastal boundary, invalidating the existing State protection.
Before aquaculture legislation is passed in Congress, these environmental impacts must be reviewed. Please sign onto Representative Capps' letter requesting that NOAA conduct a LEIS before presenting Congress with offshore aquaculture legislation.
Chief Financial Officer