1st. Pre-Permit Meeting with State 09/16/09
I had the first pre-permit meeting with the Mississippi Dept. of Marine Resources and various other involved dept’s. to cover and discuss overall program and give information and get feedback on setting this program up as an aquaculture program and any requirements needed for said program from each dept.
A few of the dept’s. at the meeting were
State Dept. of Commerce
Dept. of Environmental Equality
Secretary of State(public lands attorney)
Dept. of Marine Resources and a few others that popped in and out during the meeting including coastal erosion control, habitat dept, and artificial reef dept.
Was also brought up to maybe contact and find out if Shellfish Bureau of Ms may be interested in getting involved or maybe even sharing in an existing research study they are already involved in or that is currently ongoing.
There were lots of generalized questions that still need to be ironed out, such as would this actually be considered aquaculture since it is a rock product and not an actual living organism. Our stand was, based from other states rules, that if something live grows on the rocks such as micro or macro fauna then it is then considered live.
State still needs to find out a lot of information such as ….
If rocks are added to the waters, then aquatic life or plants grow on the rocks, would they then be treated as a new product or structure and be restricted to where they then couldnt be removed because of the new growth or since we introduced the rocks would it be ok to remove them after life has grown on them.
Also, have the State Dept of Commerce has to come up with an outline and process to create an “appraisel process” so then they can determine how much they would charge for a permit from their end of things. I personally disagree with this way of setting up a permit fee, as I dont see it being fair that they base a permit fee on what could possibly be the forcoming profits of doing such a business, and then charging an appraised fee based on proposed profits instead of getting a permit for doing this as a business as it is. I see no way to create an appraisel of a program when it has never been done before in state waters.
A lot of discussion on checking to see what surrounding states have done as far as rulings, fee’s and permitting for aquaculture programs since Ms. doesnt really have any direct and distinct information. A lot of this seems to be a learn and do as you go at this point.
There will be another pre-permit meeting in the upcoming weeks once everyone has had a chance to determine each dept’s, exacting role for this entire process and has gotten a few other dept’s involved with the overall process espicially the legal dept.
An alternative that came up during the meeting process, for the OysterCrete program was that maybe we just create the rocks for the reefs and then sale them to clients or customers and possibly selling them directly to the state for use and inclusion in their existing programs. This would eliminate most of the permits needed for the state part of this for the OysterCrete program.
The aragocrete program, as it was brought up, may be served better by only curing and selling the rocks or moving the entire program offshore outside of state jurisdiction, where there are already existing rules and regulations that could govern this type of project.
As a side note, we have already obtained a letter of authorization from the State Dept. of Agriculture to run and utilize our program as we see fit since we are neither introducing any outside plants or animals into the native waters.
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