Stop industrial fish farms from colonizing U.S. coastal waters

Issues on the record, awaiting the decision

• PendingThe notice lists five specific candidate regions in Question 1 -- New England, Mid-Atlantic, South Atlantic, U.S.

  The notice lists five specific candidate regions in Question 1 -- New England, Mid-Atlantic, South Atlantic, U.S. Caribbean, and Pacific Islands -- but provides no explanation of how these five regions were selected over others, what screening criteria were applied, or why, for example, the Pacific Northwest coast or the Atlantic offshore are not listed. The selection of candidate regions is itself a consequential planning decision that shapes all subsequent analysis, yet it is presented here without any stated rationale. NOAA should publish the criteria and data used to arrive at this list of five regions so that the public can evaluate and comment on the screening methodology itself.

  A hole PLAN found in the agency’s own analysis, quote verified against the document

• PendingThe Background section acknowledges that 'additional NEPA analysis beyond the PEIS may be necessary as a part of permitting and authorization processes for individual operations,' yet it simultaneousl

  The Background section acknowledges that 'additional NEPA analysis beyond the PEIS may be necessary as a part of permitting and authorization processes for individual operations,' yet it simultaneously states that 'aquaculture operations proposed within an AOA would have the same Federal and State permitting and authorization requirements as anywhere else.' These two statements together mean that AOA designation confers no additional environmental protection while still channeling development into designated areas, making the PEIS a planning document that pre-selects locations without guaranteeing any enhanced scrutiny. NOAA should clarify in writing what environmental benefit the PEIS provides over existing site-specific review and whether AOA designation creates de facto approval pressure on permitting agencies.

  A hole PLAN found in the agency’s own analysis, quote verified against the document

• PendingQuestion 9 asks the public to supply GIS layers and spatial data for subsistence harvest, culturally important sites, protected species and habitats, ocean acidification indices, and kelp beds -- data

  Question 9 asks the public to supply GIS layers and spatial data for subsistence harvest, culturally important sites, protected species and habitats, ocean acidification indices, and kelp beds -- data categories that are central to any programmatic environmental impact statement. The agency is effectively offloading to the public the obligation to compile the baseline environmental record. NOAA should disclose what spatial datasets NCCOS already holds for each candidate region and commit to conducting its own independent data gap analysis before relying on public submissions to fill those gaps.

  A hole PLAN found in the agency’s own analysis, quote verified against the document

• PendingThe notice states that NOAA identified 13 AOAs totaling more than 21,000 acres in the Gulf of America and off Southern California on September 19, 2025, and that the NCCOS published an Atlas for Alask

  The notice states that NOAA identified 13 AOAs totaling more than 21,000 acres in the Gulf of America and off Southern California on September 19, 2025, and that the NCCOS published an Atlas for Alaska on February 19, 2026, identifying 77 options across 10 study areas. However, no information is provided on whether the required Programmatic Environmental Impact Statements for those already-identified AOAs have been completed within the two-year window mandated by E.O. 13921, and no explanation is given for why NOAA is now soliciting new regions before demonstrating completion of the NEPA obligations for the first regions. NOAA should publicly report the status of all required PEISs for previously identified AOAs before expanding the program to additional regions.

  A hole PLAN found in the agency’s own analysis, quote verified against the document

• PendingQuestion 5 asks respondents to identify 'resource use conflicts' and 'ongoing or planned activities or ocean uses' that might make an area unfavorable, but the notice provides no list of currently kno

  Question 5 asks respondents to identify 'resource use conflicts' and 'ongoing or planned activities or ocean uses' that might make an area unfavorable, but the notice provides no list of currently known conflicts, no summary of conflicts identified during the Gulf of America or Southern California AOA process, and no baseline of existing ocean uses such as commercial fishing grounds, shipping lanes, or military operating areas. Without that baseline, public commenters cannot know what has already been considered and cannot provide meaningfully targeted input. NOAA should publish the conflict inventory developed during prior AOA processes before soliciting new regional input.

  A hole PLAN found in the agency’s own analysis, quote verified against the document

• PendingThe notice asserts that AOA identification will use 'the best available science' and account for 'key environmental, economic, social, and cultural considerations,' but the RFI itself reveals that bas

  The notice asserts that AOA identification will use 'the best available science' and account for 'key environmental, economic, social, and cultural considerations,' but the RFI itself reveals that basic siting data -- depth, current, wave climate, proximity to shore -- has not yet been collected and must be solicited from the public through Question 3. The agency is asking the public to supply the technical foundation that should underpin any scientifically credible regional selection. NOAA should explain what existing scientific data it already holds for each candidate region and why that data is insufficient before asking the public to fill the gap, rather than treating public submissions as a substitute for agency analysis.

  A hole PLAN found in the agency’s own analysis, quote verified against the document

• PendingQuestion 6 asks whether AOA size should be 'aligned with regional or state/jurisdictional economic development goals for aquaculture,' which introduces an economic development criterion that is not de

  Question 6 asks whether AOA size should be 'aligned with regional or state/jurisdictional economic development goals for aquaculture,' which introduces an economic development criterion that is not derived from environmental suitability analysis. The document's own framing describes AOAs as areas evaluated for environmental, economic, and social sustainability, but subordinating size decisions to state economic development goals risks allowing political and economic targets to override environmental findings. NOAA should explain how it will weight economic development goals against environmental suitability findings when the two conflict, and commit to documenting that reasoning in the PEIS.

  A hole PLAN found in the agency’s own analysis, quote verified against the document

• PendingThe notice acknowledges that 'some forms of aquaculture have been practiced in coastal waters for decades, generating a substantial body of peer-reviewed scientific literature, state-level environment

  The notice acknowledges that 'some forms of aquaculture have been practiced in coastal waters for decades, generating a substantial body of peer-reviewed scientific literature, state-level environmental reviews, and site-specific NEPA analyses,' but it does not identify which specific impacts from that literature are already well-characterized and which remain uncertain. The PEIS is supposed to assess impacts programmatically, but without NOAA first synthesizing what is already known from existing literature, the PEIS risks duplicating or ignoring that record. NOAA should commit to preparing and publishing a synthesis of existing environmental impact findings from prior aquaculture NEPA documents before scoping the new PEISs.

  A hole PLAN found in the agency’s own analysis, quote verified against the document

• PendingQuestion 4 asks the public to identify locations that should be avoided due to protected species presence, including 'large whales, sea turtles, dolphins, sea otters, sea lions,' but the notice provid

  Question 4 asks the public to identify locations that should be avoided due to protected species presence, including 'large whales, sea turtles, dolphins, sea otters, sea lions,' but the notice provides no information about what protected species distribution data NOAA's own scientists -- who manage Endangered Species Act consultations -- already hold for the candidate regions. Asking the public to flag protected species concerns without disclosing NOAA's own holdings creates an asymmetric process where agency data may contradict public input without that contradiction being visible. NOAA should disclose its existing protected species distribution data for all candidate regions as part of the public record for this RFI.

  A hole PLAN found in the agency’s own analysis, quote verified against the document

• PendingThe notice states that tribal coordination is required under E.O.

  The notice states that tribal coordination is required under E.O. 13921, which directs identification of AOAs 'in coordination with appropriate state, jurisdiction and tribal governments,' and Question 9 asks for data on 'cultural and subsistence harvest, community subsistence activities, culturally important sites.' However, the three scheduled listening sessions -- two on weekday afternoons and one evening -- and the 45-day comment window provide no description of how government-to-government tribal consultation will be conducted separately from this general public RFI process. Soliciting tribal cultural and subsistence data through a public comment portal is not a substitute for government-to-government consultation. NOAA should describe its tribal consultation plan and timeline before closing this comment period.

  A hole PLAN found in the agency’s own analysis, quote verified against the document