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Massachusetts Aquaculture Strategic Plan Chapter V - Environmental Review

Introduction

Aquaculture is a relatively new and promising industry in Massachusetts, therefore it stands to reason that communities as well as individuals are concerned about proposals for its promotion. Water quality is frequently a prominent concern when aquaculture facility siting options are discussed. The problems posed by competing uses such as marine and coastal environments, as well as social considerations, such as private ownership, can be addressed in a thoughtful deliberative fashion, by incorporating good siting and environmental data into the initial stages of the decision-making process.

To assist proper siting, support aquaculture-related management and policy decisions, and ensure the long-term sustainability of this fledgling industry, the state needs to develop sound data and reliable information. The effective utilization of data will be the cornerstone for deciding fundamental issues such as, land-use patterns, and how water-based activities affect water quality and aquatic habitats in marine and coastal environments. In addition, this information is necessary to enhance the development of a balanced, comprehensive, and effective policy that will promote aquacultural enterprise.

This chapter contains the following subsections: Siting and Monitoring. While these two topics are related, siting and monitoring present different perspectives and concerns and therefore, require separate attention. The information required for siting is both site and species-specific. Conversely, monitoring is broad-based and must be consistent with a range of current and future uses and needs.

Monitoring data required to describe ambient environmental conditions of a specific fishery, at a specific site proposed for aquaculture is, different on both spatial and temporal scales from physical, chemical, and biological parameters needed to document the presence/absence of change. Several regulatory programs also govern site-selection and the on-going operations of established facilities. Siting decisions must take into account issues such as: the natural productivity of the area under consideration; proximity of wild fisheries; migratory stocks; competing uses; navigational constraints; questions of coastal access; and upstream uses. In addition, an up-and-running aquaculture facility will have to satisfy National Pollutant Discharge Elimination System (NPDES) permitting conditions according to monitoring parameters required by this well-established program. NPDES permitting, however, may not necessarily be relevant to the siting process itself.

Siting

General Considerations

If Massachusetts is to successfully site aquaculture facilities and promote the growth of the aquaculture industry, economic investment required for its success must incorporate sound management decisions while also protecting environmental quality. A wide array of environmental, political, economic, and social considerations affect proper siting of aquaculture projects. These practical considerations are often site, and species specific, however, general features of the state of Massachusetts, both political and geographic, must also be considered when making siting decisions.

Within the borders of Massachusetts exist two distinctly different hydrogeographic and biogeographic provinces. North of Cape Cod, water temperatures are consistently colder, especially during winter. These colder temperatures can cause problems with icing, which is a major impediment to the use of cages and other aquaculture structures. Moreover, cold water temperatures, even south of Cape Cod, can often be lethal to a wide variety aquaculture species. Conversely, summer temperatures in the Massachusetts and Cape Cod Bays, especially near-shore, are often too warm for most salmonids, the species most commonly used for finfish aquaculture in the northeast. However, south of Cape Cod, warm summer temperatures actually promote growth of certain shellfish and finfish, where cold winter waters can greatly increase culture time and consequently, costs.

In both of these areas of Massachusetts, many of the species traditionally associated with aquaculture are difficult, if not impossible, to culture profitably. Thus, the first step for any siting venture in Massachusetts coastal waters must be the generation of a detailed annual temperature profile. Any siting decision must use temperature profile information to determine the optimal temperature range for the species and systems under consideration. The responsibility of generating this profile, and incorporating the information it contains into the siting decision, needs to be clearly specified.

Equally important to the temperature profile is a description of prevailing hydrographic conditions. This information will determine the usefulness of the site for particular categories of aquacultural enterprise. Current direction and velocity, affect the delivery of plankton to filter-feeding shellfish and the elimination of wastes from systems where feeding and/or medication are required. Structural adequacy of moorings and other project deployments must be demonstrated with regard to sea-state conditions at the site.

Good water quality is a fundamental concern for siting aquaculture facilities. The water quality of most Massachusetts coastal environments is generally acceptable and capable of supporting most of the kinds of aquaculture ventures that are likely to be introduced within the state. Water quality in Massachusetts is poorest in urban estuaries and inner harbor areas. Aquaculture may be precluded in these areas, not only because of water quality, but also because of the presence of other well established conflicting uses such as commerce and navigation.

For most, if not all, potential sites there is limited or no environmental/water quality data upon which siting and operational decisions can be made. Consequently, for all siting decisions critical information must first be generated regarding water temperature, dissolved oxygen, and pathogen and toxic contaminant concentrations. The responsibility for gathering this information also needs to be determined.

Siting for shellfish aquaculture facilities is further constrained by the fact that shellfish projects can be located only in beds classified as "approved" under the National Shellfish Sanitation Program (NSSP). This restriction limits the availability of potential shellfish aquaculture sites in near-shore environments within Massachusetts.

The experience of other states and countries which have successfully addressed problems concerning siting protocols for aquaculture facilities has been utilized in developing systems within the state. Combining the best of these collective solutions and adapting them to the state's needs, should aid the development of siting and operational monitoring systems to encourage aquaculture development.

Many aquaculture projects require a near-shore location where water and sediment quality are often most degraded by upland activities. This situation limits the potential availability of many sites in Massachusetts for successful aquaculture development. Nevertheless, there are several areas in Massachusetts which support relatively pristine conditions suitable for aquaculture. Long-term suitability, however, may be jeopardized by future pressure for development and by changing land uses. This existing and potential conflict between land and water uses is an important policy and management question. To balance the competing demands on coastal areas, successful planning for aquaculture must integrate long range land and water-use planning.

Specific Siting Considerations

Siting an aquaculture facility requires evaluation of diverse kinds of information ranging from ambient water quality, to state and local regulatory concerns. The following reviews existing regulatory authority, siting criteria, and mapping as a siting tool for regulators, policy decision makers, and entrepreneurs.

The current Massachusetts regulatory scheme assigns control to local governments for the issuance of aquaculture licenses in waters and flats up to the three-mile limit. This authority however, only applies to licenses for shellfish aquaculture. To date, no comparable regulations/licenses exist for finfish aquaculture.

The succeeding siting considerations and the monitoring criteria are each discussed in accordance with the following four categories of aquacultural enterprise described in Chapter III.

1. No Structures/No Additions/No Discharges: Prototype, Shellfish Bottom Culture

2. Structures (Water-Based)/No Additions/No Discharges: Prototype, Shellfish/Seaweed Water Column Culture

3. Structures (Land-Based)/Additions/Discharges: Prototype, Recirculating/Flowthrough Culture

4. Structures (Water-Based)/Additions/Discharges: Prototype, Net-Pen Culture of Finfish

Category 5 projects, Projects in Federal Waters, can involve any of the four categories referenced above. Siting and monitoring criteria for category 5 projects, are not discussed in this section.

Category 1.
No Structures/No Additions/No Discharges: Prototype, Shellfish Bottom Culture

Aquaculture facilities in this category typically involve intertidal and subtidal bottom culture of shellfish. Authority granted under Massachusetts General Laws Chapter 130 (MGL Ch. 130), section 57, requires DMF to review applications to ensure site-specific shellfish culture activities, approved in via a town-issued license, will not have an undue adverse affect upon area natural resources. DMF's review begins by assessing the water quality using a sanitary survey which establishes a classification for the area such as approved, restricted, or prohibited. The primary basis for classifying shellfish growing areas is the concentration of fecal coliform bacteria counted in water samples collected from the site. If a site is classified as either prohibited or restricted, the municipality can not issue a shellfish aquaculture license.

Under (MGL Ch. 130) section 57, and as part of the current siting process, DMF is required to review the public hearing record to identify other potential problems including the presence of other productive fisheries or competing uses. A grid survey is used to assess the density of shellfish population per square foot as well as the presence of other resources at the site. DMF must also consider the presence of threatened or endangered species, such as the piping plover, their critical habitats, and seek advice on these issues from other appropriate agencies. Finally, DMF must also consider the effect of the proposed activity on current public access to shoreline habitats, as well as effects on sea grasses and other vegetative systems.

For the purpose of aquaculture facilities siting, the Army Corps of Engineer (ACOE) is concerned with environmental impacts and obstructions to navigation. To facilitate the aquaculture permitting process, the ACOE has developed thresholds regarding size and type of facility. Facilities under 10 acres, which covers most bottom shellfish operations, are subject to the ACOE Programmatic General Permit (PGP) program. Facilities over 10 acres would require submission of an individual permit application. DMF often collaborates in providing site-specific information to the ACOE regarding both of these type of permits.

Under the Wetlands Protection Act, local Conservation Commissions are authorized to review aquaculture projects proposals in tidal flats, saltmarshes and submerged lands. Conservation Commissions are required to ensure that proposed activities will not adversely affect drinking water supplies, wildlife habitat, or interfere with stormwater runoff.

Category 2.
Structures (Water-Based)/No Additions/No Discharges: Prototype, Shellfish/Seaweed Water Column Culture.

These operations involve using gear suspended in the water column from buoys that can be moved vertically for ease of maintenance and harvesting. This category also covers production of algae and other nonshellfish species, where feeding is not required. An Individual Permit from the ACOE is required for most subtidal, suspended, or transient facilities. Some suspended or floating shellfish culture activities are allowed under the PGP. Municipalities do not have licensing authority over these nonshellfish aquaculture operations, however Conservation Commissions do have oversight authority under the WPA.

Criteria for siting subtidal, suspended, or transient shellfish cages, are essentially the same as siting intertidal shellfish operations. These operations, however, receive a higher level of review, due to potential navigational and engineering limitations, and the potential effects aquaculture structures may have on the ambient environment and endangered species.

Category 3.
Structures (Land-Based)/Additions/Discharges: Prototype, Recirculating/Flowthrough Culture (Addressed elsewhere)

Category 4.
Structures (Water-Based)/Additions/Discharges: Prototype, Net-Pen Culture of Finfish.

At present, no process exists within Massachusetts government to assess siting proposals for finfish aquaculture. Municipalities have no "home rule" regulatory authority with respect to finfish aquaculture as they do for shellfish aquaculture, except under the WPA.

The following basic elements are for incorporation into a aquaculture siting procedures check list:

a. Endangered species habitats must be identified within a given distance from the proposed culture site. Gear modification or alternative site selection may be required to reduce potential adverse effects to protected species and their habitats.

b. Issuance of a water quality certification from the Massachusetts Department of Environmental Protection must be obtained, and criteria set forth in the Clean Water Act and the Rivers and Harbors Act must be met.

c. Applicants must provide accurate plans for pen facilities, existing resources, and current and proposed uses in the site, and in adjacent areas. These plans must, at a minimum, also include: the number, size and location of pens; a mooring plan; and, the maximum area to be utilized by pen systems.

d. A baseline survey will be required that includes video diver survey, sediment and infauna analysis, water quality sampling, and hydrographic data collection such as current and water depth information. As part of this baseline survey, benthos must be characterized in terms of sediment structure, community structure, and basic hydrography.

e. Water depth must be sufficient at all times to allow circulation beneath pen systems.

f. The engineering specifications of any proposed system must be sufficient to withstand the worst expected sea state and other hydrographic parameters at the selected site. The ACOE will determine if engineering design is sufficient in its permit review process.

Mapping for Aquaculture in Massachusetts

Maps are the traditional tools used to visually display information and locate and monitor the physical environment. The recent explosion in information technology now offers many more mapping formats then previously available. Maps can be customized to show the user the exact information needed for any particular use. In addition, maps can easily be revised to reflect changes to the physical and natural environment.

Use of information technology for mapping is rapidly becoming a significant management tool for ocean and coastal planning. Several marine oriented items now under review in the Massachusetts legislature, require mapping using modern mapping tools. The Open Space and Seaport Bond bills are examples of such items, which if passed, present opportunities for funding coastal mapping initiatives. Mapping based on information technology could greatly benefit the business community, regulatory agencies involved with aquaculture, and state and municipal planners. In addition, maps and data produced could significantly enhance private support by aquaculture entrepreneurs. These maps, once developed, can guide applicants for aquaculture licenses to appropriate sites and help simplify the license application process. Regulatory officials reviewing license applications rely on standardized maps, which facilitates the recording of baseline and operational monitoring data. Planners developing and modifying zoning and land use designations in harbor areas will also benefit from the development of these maps and the accompanying coastal and marine resource data sources.

On the down side, base map preparation is costly and time consuming. Identifying users and the appropriate use specific scale is a crucial component for developing useful maps. It is important to note, that inaccuracies inherent in mapping exercises necessitate the continuance of site and field investigations, as well as long-term monitoring efforts. Field investigations that verify current baseline information and establish precise locations of crucial data and information will continue to be essential.

In Massachusetts, various agencies and organizations are engaged in the mapping of geographic data using information technology. MassGIS coordinates many of these activities among the agencies and with the state's Management Information System (MIS) efforts. Since its inception in 1985, MassGIS data base has developed in close cooperation with federal agencies, local communities, and special interest groups. MassGIS base maps have been derived from 1:25,000-scale USGS topographic maps. This scale, while efficient in terms of cost for state-wide needs, does not provide the precision, detail, or up-to-date qualities necessary for coastal and marine mapping requirements.

To promote, regulate and assist the aquaculture community, maps on a scale of plus or minus 1 m, rather than the plus or minus 10-15 m, are needed. To date, MassGIS has operated in a cost-for-services mode. An agency or outside user, orders and pays for data layers to be digitized, and then purchases customized maps. Because custom map production is time consuming, efforts using CDROM technology are currently underway at EOEA. This conversion will make the MassGIS data base more cost effective and increase accessibility to outside users, allowing the private sector to assume more of the custom map generation function for non-agency users.

Assuming passage of the Open Space Bond bill, MassGIS will begin an aggressive multi-year mapping effort to enhance the precision of the state's base map through the generation of black and white orthophoto maps. Orthophoto maps provide precise positional information which future agency mapping efforts could share. Orthophotos provide a pictorial representation over which interpretive data can be superimposed. Stored in the existing MassGIS archives, are a number of useful layers of coastal marine data, developed by MassGIS, DFW, ELF, and CZM. The utility of these data varies depending on their origin and their intended use.

In October 1994, the United States Department of Commerce's NOS began a multi-year shoreline mapping project to update the state's nautical charts. Results of the NOS mission will include precise delineations of the shoreline at Mean High Water (MHW) and Mean Low Water (MLW). Additionally, information about docks and piers, and other features commonly seen on a nautical chart, will be included, and incorporated into MassGIS.

CZM is working closely with both MassGIS and NOS to unify these efforts and to develop a comprehensive and long term 1:10,000 scale coastal map series that will better meet the requirements of coastal and marine users. Phase I of this project, to be completed by September 1995, will produce rectified color aerial photographs using the NOS source data currently available. Phase II will add and refine marine jurisdictional designations to the MassGIS by Spring 1996. Phase III will produce color orthophotographs for the entire coast.

CZM has received funding under a federal grant to establish a Marine Resources Information System. This integrated with MRGIS will collate, standardize and manipulate existing geographic information relating to ocean resources. New information layers will also be added as compatible information is gathered. CZM is working with DMF, MassGIS and other agencies to initiate this system.

Considerable amounts of basic physical and interpreted coastal marine information still need to be acquired and/or synthesized. Data on bathymetry, navigation channels, circulation, fisheries assessments, and many other categories of essential information are needed for planning, regulating, monitoring and promoting aquaculture interests. Some of these data are already available within the scientific community. The USGS Atlantic Marine Geology Division, Woods Hole Oceanographic, the National Marine Fisheries Service, and Salem State College are merely some of the regional information sources which can be tapped. These, and other data, need to be collected, organized, and integrated into the MassGIS to improve accessibility for broader categories of coastal users.

In discussing mapping as an appropriate tool for aquacultural siting and monitoring initiatives, it is important to address the development of siting maps that would indicate favorable aquaculture conditions. Unfortunately, there are a number of drawbacks to this approach. First, there are many different species which are the subject of aquaculture, each requires different habitats, structures, etc. The volume of data that would have to be collected and digitized to display these species specific requirements would be prohibitively expensive. Second, previous siting experience suggests that maps of potential aquaculture sites can be used to prevent, rather than promote, the development of aquaculture facilities in otherwise ideal locations. Lastly, sites can change, either subtly or drastically, over time as a result of natural or man made disasters.

Having considered these deterrents, the Working Group recommends that aquaculture-relevant maps be produced which identify areas where aquaculture would be constrained or prohibited using the following parameters:

1. Physical Characteristics
- temperature
- wind direction
- direction and velocity of currents
- maximum wave height/wave direction
- velocity overwash zones
- bathymetry
- surface water designations, such as outstanding resource waters (ORWs)
- Mean Low Water and Mean High Water (MLW, MHW)
- barrier beaches
- shoreline changes

2. Areas with Biological Management Designations
- ACECs
- endangered species and critical habitats
- identifiable nursery areas
- location of eelgrass (DEP)
- plankton density
- shellfish management areas

3. Cultural Features
- access issues
- competing uses, adjacent or at location, (land use and land cover data are available from 1972 and 1985; 1990 data completed for the Cape, and 1995, for Buzzards Bay)
- upland ownership (public vs. private)
- location of NPDES point sources (water pollution)
- navigation channels
- navigational markers with a 100' to 200' contraindication buffer (all markers in N.E.) soon to be available on disc
- dredge and disposal sites (ACOE digital data)
- shipwrecks

Note: Many of the parameters listed above have already been or are in the process of being digitized, however, scales frequently vary.

Monitoring

Good water quality is an important prerequisite for successful aquaculture. Maintaining a healthy coastal environment is not only important to the organisms to be cultured at a site, but also for flora and fauna that are indigenous to the site, and to the migratory species that circulate through and around the site. Maintaining good water quality ensures a healthy valuable product will be marketed, and helps to ensure the prolonged productiveness of the area, reducing the need to develop other sites.

Maintaining good water quality, particularly in intensively developed coastal environments such as Massachusetts, requires frequent monitoring. Effective monitoring can detect changes in environmental quality that result from aquaculture operations, as well as other impacts to coastal areas. In addition, monitoring can quantify the scope and duration of environmental impacts.

Early identification of environmental degradation through a routine monitoring program permits the aquaculturist to institute minor operational changes, for example altering feeding frequency of net-pen reared finfish in order to correct an identified problem before it reaches an extreme condition. Early identification of environmental problems prevents cumulative environmental degradation and can save the grower money. When degradation reaches an extreme level, cultured organisms experience depressed growth rates, disease, and even death. A situation all growers want to avoid.

Monitoring also permits comparison of baseline values of flora and fauna already existing in the area prior to siting an aquaculture facility. This data provides useful information on the extent of impact from a single operation and possible cumulative impacts from many operations located within a single water body. In general, successful monitoring can aid growers in raising organisms at a site for long periods of time while minimizing impacts to the environment.

Healthy coastal ecosystems are characterized by a diversity of species. Change in species diversity at a particular site is commonly used as an index of environmental quality. Some aquaculture practices, such as feeding of net-pen finfish, may attract new, wild species, hence resulting in a transient increase in biodiversity. Evidence indicates, however, that over time continued inputs of food, essential nutrients, and other "contaminants", typically results in a net loss of biodiversity near an aquaculture site. Opportunistic species, such as Capitellid worms, often dominate affected sites. Changes in the abundance of sensitive indicator species may reflect initial impacts, while the total absence of indigenous benthic fauna reflects more severe degradation. Some effects on the benthic community must be expected at an in situ aquaculture site. However, the level and duration of such impacts need to be monitored at regular intervals to determine if the degradation is persistent, worsening, or extend beyond the immediate confines of the permitted facility. If conditions become critical, steps need to be taken to reduce impacts to the area. Such steps could be as simple as modifying feeding frequency or the volume of feed offered to prevent unconsumed food from accumulating in benthos. Although more drastic action may sometimes be required, such as moving the entire culture system, temporarily, or perhaps permanently, to allow the area to recover.

Process for Defining Monitoring Protocols for Proposed Aquaculture Projects in Massachusetts

Current aquaculture in Massachusetts is largely limited to shellfish culture in the southeastern coast, with some land-based aquaculture occurring in the western part of the state. However, when considering a process to define monitoring guidelines, the Working Group reviewed the complete spectrum of aquacultural enterprise.

The Working Group surveyed aquaculture monitoring protocols from outside the United States, in Canada, Italy, Japan, Norway, Scotland, Chile, GESAMP, and also domestically in the states of Washington, New Jersey, Connecticut, Rhode Island, and Maine. Although all were instructive, none provided a truly successful "fit" with the environmental, political, and cultural features that define marine aquaculture in Massachusetts. Particularly, the state's physical location on the boundary between two biogeographic provinces, its highly developed, intensively used coastal environment, and its long tradition of home-rule make Massachusetts truly unique.

Maine has, by northeast standards, a relatively well established aquaculture industry. The majority of Massachusetts waters are part of the Gulf of Maine system, therefore the Monitoring Subgroup relied heavily on Maine's experience. From this information a three step process to generate the data and information will need to be developed to monitor the environmental impact of aquaculture projects. This proposal, and the process it defines, must be seen as iterative, subject to continuing revision. The following is an adaptation of the Maine three-step model.

Step One - Categorize the project
Define the project using one of four possible categories (see Appendix F) to describe a continuum of potential impact on Massachusetts marine/coastal waters. These four categories are consistent with the kinds of aquaculture facilities discussed in the Regulatory Chapter and in the siting section of this chapter.

Category 1 Aquaculture
Applies to low-impact, bottom-culture systems where there are no structures suspended within the water column. These systems do not inhibit other individuals from using the overlying water and do not contribute extraneous additions of food or other inputs to the system. Category 1 aquaculture requires minimal baseline evaluation of the site. For example, information on traditional usage, level of productivity, and so forth are generally sufficient. Operational monitoring, (referring to long-term, continuous monitoring activities in contrast to baseline monitoring) of a category 1 projects, should not be extensive. Operational monitoring for these types of projects can consist of an annual inspection of the site by local regulators to ensure the use of site is consistent with permit conditions. In addition, an annual report submitted to DMF should be required for each category 1 site. This report should include, at a minimum the number of seed deployed and amount of crop harvested. (Note: This information should be handled by reporting officials as proprietary information. Since reports such as these were recently ruled to be public information, confidentiality will require new legislation.)

Category 2 Aquaculture
These projects will involve a more intensive use of the physical space, with structures suspended within the water column or intertidal zone, thereby impeding access to other individuals who might otherwise use the overlying water. No additional inputs of feed or other agents are permitted in Category 2 aquaculture sites. Baseline information required for Category 2 aquaculture efforts will include all the information required for Category 1 projects, plus an evaluation of the potential impact of the suspended structures. This evaluation shall include:

a. A detailed design plan for the facility including concise drawings of the equipment to be deployed into the environment;

b. A description of the proposed site including: measurements of depth; tidal current velocities, benthic habitat (including video diver survey); sediment type; submerged vegetation; and resident fauna; and

c. Information on known uses of the proposed site by endangered species and a discussion of the potential for impacts on endangered species.

Operational monitoring at category 2 sites shall include an annual site visit and a biannual evaluation of the benthic environment within the site which includes a video diver survey. Any entanglements of protected species shall be reported within 24 hours to DMF and NMFS. In addition, an annual report of production at the aquaculture site (confidentiality maintained) shall be required. Documented in this report will be all animal entanglements and user conflicts that have occurred within the previous year.

Category 3 Aquaculture
These operations are land-based and intensively managed facilities such as shellfish or finfish hatcheries or recirculating culture systems. Facility discharges are concentrated and remotely deployed into the environment. In considering a Category 3 culture system, regulations addressing point-source discharges are currently well established and guidelines/regulations are clearly outlined as part of the NPDES permitting process. Therefore, the Working Group felt it unnecessary to address environmental monitoring of a category 3 culture system as the system is already in place. It will be necessary, however, to ensure that the effluent from an intensive Category 3 aquaculture system is classified as "agricultural effluent" and to apply those regulations required for the discharge of such waste effluent to all category 3 aquaculture facilities.

Category 4 Aquaculture
These operations represent the most intensive level of field-deployed in situ aquaculture and consequently demands the most intensive environmental monitoring. This category involves both structures within the water column and added inputs of organic and inorganic materials. All of the information required for the previous 3 categories of aquaculture development will be needed for a successful category 4 project. In addition, the Maine model, with appropriate adaptation to reflect unique features of Massachusetts, offers a reasonable framework for environmental monitoring of finfish aquaculture operations. (See Appendix F, Categories of Aquaculture Projects in the Commonwealth of Massachusetts.)

Step Two - Develop Baseline Monitoring Guidelines
Baseline monitoring guidelines must be developed that are consistent with the aquaculture categories established in step one. These guidelines are "time-zero" data, and are the foundation needed to assess the impacts projects may have on the ecosystem effects over time.

The baseline data established in this phase will serve as the parameters for step 3 which will detail operational monitoring guidelines. The baseline data is of critical importance, and how they are defined needs to be an integral part of the aquaculture facility permitting process. The following are questions which need to be addressed in order to develop an aquaculture permit application:

 
 

 
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