CMRC public comment letter

The Rhode Island Saltwater Anglers Association (RISAA) has reviewed the Public Notice relative to CRMC File Number 2014-04-106. Although this application does not increase the size of the lease area, we have a few concerns/ comments related to this notice. We request that CRMC and/or the applicants respond to these issues before moving further through the approval process. Our waters are too precious to lower the bar in this process to favor the growth of aquaculture.

First, we believe that CRMC’s statement that those entering protests must “cite what law or laws, if any, would in their opinion be violated by the work proposed” discourages public input by limiting what comments the public can provide. Since CRMC is already considering administrative approval for this application, meaningful public comment should be encouraged, not discouraged. The comments below are grouped by the appropriate section.

A. Guidelines for the Siting of Aquaculture Gear

We believe that, with the proposed conversion of the existing lease from submerged cages to floating cages, this application may violate the “Planned Revisions to the CRMC Aquaculture Application Process” from February 7, 2022. Guidelines for the Siting of Aquaculture Gear state that “Floating gear should be a minimum of 750 feet from the nearest residential structure….” The lease boundaries with new floating gear configuration, place the floating gear inside the minimum 750 ft. requirement. There does not seem to be any indication in the Guidelines that the home owner needs to object to the lease.

There are additional details in the Guidelines for Siting document that are not addressed in the application:

  • Does the applicant have a minimum $15,000 proof of performance bond?
  • Is the floating gear at least 200 feet from an existing CRMC approved recreational mooring field?
  • Has the town recommended areas where floating gear should be discouraged and/or encouraged and would those areas apply for this lease conversion?

C. Additional Category B Requirements

The application lacks disclosure on some or all of the following additional category B requirements as outlined in the Coastal Resources Management Council Guide to Commercial Aquaculture Applications.

#4(a) List of all property owners within 1000’; list of all approved aquaculture leases within 1000’; list of CRMC designated ROW(s) within 1000’; CRMC water use types within 1000’; and any shoreline(s) within 1000’ which have been preserved for conservation, recreation and/or public access through easements, purchased by the state or municipality, or are owned by a land trust or state-recognized conservation organization.)

#4(b) A plan demonstrating reasonable public ingress and egress to and from the proposed site for traditional water activities such as boating, swimming, and fishing.

#4(d) The projected per unit area yield of harvestable product.

#4(e) The cumulative impact of this particular aquaculture proposal in this area, in addition to other aquaculture operations already in place. (At minimum, applicants should consider the impact of any other aquaculture operation within 1000’ of the proposed site.)

#4(g) The impact of the proposed activities on the scenic qualities of the area.


It would be helpful for the public to understand how CRMC intends to implement and to enforce Planned Revisions and Guidelines for Siting. Are submerged leases sited within 750 ft that would convert to floating gear exempt from the Guidelines for Siting? We ask that CRMC staff request an update of the application to fill the information gaps, redistribute the application for public comment, and in advance of any CRMC meeting that considers this application, provide a written response to these comments.