The Failures Tracker
The cost, the years, and the agencies between you and a permit.
Everything below is sourced. Where a number isn't published, we say so. Where we propose a fairer one, it's labeled proposed. Nothing on this page is invented to make a point — the system is plenty damming on its own.
17
Active CA leases
$250K
Danger-zone $
15mo
Danger-zone time
Exhibit A
The real cost of a permit.
Every bar is a real published or interview-sourced cost range, drawn to the same dollar scale.
Typical co-op / family operation. [est. — range from grower interviews]
CDFW + SLC + RWQCB + USACE filing fees. [est. — many fees not published]
Eelgrass, benthic, marine mammal, water quality baselines.
Required to assemble the EIR document itself.
The all-in cost of getting a single new lease through CEQA.
The EIR bar — the rightmost monster — is what kills most small projects before they ever reach the water.
Exhibit B
The real timeline.
Each bar is months of waiting. The dashed line is the runway most small farms have on day one — about 15 months.
What a typical small farm can survive on starting capital.
Even minor changes to existing infrastructure.
Switching from one shellfish or seaweed species to another.
On an already-operating lease.
5–10+ years is normal. Some applications outlast the applicant.
Exhibit C
The Gauntlet.
- State
- Federal
- Local
- Tribal
Every CA agency a typical new open-ocean shellfish or seaweed farm interacts with. Most of these run in serial, not parallel. Some can't begin until others end. None of them know what the others have asked for.
- 01CDFWState
Lease + species authorization
Wait 12–36 moFee $1.5K–$10K - 02California Coastal CommissionState
Coastal development permit
Wait 12–24 moFee $2K–$15K - 03State Lands CommissionState
Tidelands / bottom lease
Wait 12–24 moFee $1K–$8K + rent - 04RWQCBState
Water quality (401 cert)
Wait 6–18 moFee $500–$5K - 05USACEFederal
Section 10 / 404 federal permit
Wait 12–36 moFee Free–$100 - 06NOAA / NMFSFederal
ESA & MMPA consultation
Wait 6–24 moFee Free - 07CDPHState
Shellfish sanitation (if applicable)
Wait 3–9 moFee $1K–$5K - 08Local countyLocal
Use permit / harbor district approval
Wait 3–12 moFee Varies widely - 09Tribal consultationTribal
AB 52 / SB 18 where triggered
Wait 3–12 moFee — - 10CDFAState
Aquaculture registration
Wait 1–3 moFee $500
Many of these fee ranges are estimated from public schedules + practitioner reports. Where ranges aren't published, the EIR Wizard proposes small-business-friendly defaults clearly labeled "proposed."
Approved by the Commission · 8/23/2023
The four phases between you and a water bottom lease.
This is the official Fish & Game Commission flow for new state water bottom aquaculture leases — including the Public Interest Determination added in 2023. Phases run sequentially. Permit Reef tracks where a real application sits in the flow and what's stalling it.
- 0Phase 0
Enhanced pre-application
Prospective applicant contacts CDFW Aquaculture Coordinator. Pre-application consultation, project design, informal consultation with agencies of jurisdiction.
- 1Phase 1
Initial vetting & scoping
Bottom Lease Application submitted to CFGC. Requirements review by staff. CSLC & CDPH consultation. 90-day public notice if requirements met. MRC + Tribal Committee discussion scheduled.
- 2Phase 2
In-depth analysis
CEQA Initial Study; EIR or Negative Declaration. Social/economic considerations analysis. Public Interest Considerations evaluation. Tribal consultation. Agency partner comments.
- 3Phase 3
Commission decision
CFGC receives CEQA document, public interest analysis, and recommendations. Three discretionary actions in one meeting: CEQA certification · public interest determination · lease decision. Approved lease proceeds to other agencies.
Source: California Fish & Game Commission — Figures Displaying Steps in the Enhanced Process for Applications for New State Water Bottom Leases for Aquaculture (approved 8/23/2023). Full document on the Resources page.
Figures reproduced from the CFGC-approved process document (8/23/2023). Tagged real-data.
Exhibit C·b — Federal precedent
NOAA's Aquaculture Opportunity Areas.
NOAA's PEIS-adjacent process produced Atlas / AOA identification reports for the Southern California Bight — the closest thing the U.S. has to a programmatic siting layer. Useful precedent. Imperfect model. We surface it here so growers and agencies can see what already exists at the federal level before California writes its own.
Read our full read on the NOAA precedent →| Process | NOAA WCR Final PEIS · signed 9/10/2025 by NMFS West Coast RA | real-data |
| Selected alternative | Alternative 4b · all types of aquaculture · Santa Barbara Channel + Santa Monica Bay | real-data |
| Species framing | Finfish, shellfish, macroalgae — not shellfish/seaweed-first | real-data |
| Tiered review for small farms | Not in scope · programmatic, but no small-farm carve-out | real-data |
| What CA should adopt | Pre-screened siting atlas · shared baseline · transparent suitability | proposed |
| What CA should add | Shellfish/seaweed-first scope · small-farm tier · tribal co-management | proposed |
Source: NOAA WCR AOA Final PEIS & Decision Document (PEIS-006-48-1WC-1728044280). Local mirrors on the Resources page.
Humboldt Bay is, for now, the one open door.
Coast Seafoods runs an active sublease program in Humboldt Bay where new growers can lease space inside an existing master lease — skipping the multi-year, six-figure new-lease gauntlet entirely. San Diego Bay has limited equivalent paths. The rest of California's coast does not.
The EIR Wizard surfaces these sublease-eligible zones automatically when you pick a location.
Surfaced in partnership with
Kelpful Coalition
The advocacy group organizing growers, scientists, and policy folks around CA aquaculture reform. Learn more →
Sublease vs. new lease
- Timeline
- 3–9 mo
- 60–120 mo
- Up-front cost
- < $10K
- $150K–$500K+
- CEQA EIR required
- Usually no
- Yes, almost always
- Risk for small farm
- Survivable
- Existential
Where we actually are
Progress, no spin.
We will not paper over how early this is. Every counter below is the truth, updated as the database grows.
10/11
Agencies mapped
4/24
Public datasets ingested
18/many
Permit forms catalogued
0/1
EIR templates accepted by an agency