Dear Commissioners:

Thank you for the opportunity to comment on the Draft Navigational Risk Assessment for the proposed Ventura Shellfish Project. The undersigned groups have extensive knowledge of marine resources off the California coast and experience navigating the various laws and policies associated with coastal and marine development. Together, we would like to offer caution with consideration of an offshore aquaculture operation in federal waters and voice our concern that the Commission would submit materials to the Army Corps of Engineers when the Port does not have the authority to pursue this project in federal waters without the approval from the Ventura Local Agency Formation Commission (“LAFCo”). We recommend that you do not approve sending the Draft Navigational Risk Assessment for the proposed Ventura Shellfish Project at this time.