Letter to NOAA Fisheries Assistant Administrator Doremus - Maine Delegation Requests Comment Period Extension for Biological Opinion with Profound Impact on Maine Lobstermen

Letter

Dear Acting Administrator Doremus:

We are writing to request an extension of the public comment period to March 1, 2021, for the draft Biological Opinion (BiOp) on ten Fishery Management Plans in the Greater Atlantic Region and the New England Fishery Management Council's Omnibus Habitat Amendment 2.

Maine's lobster industry is an economic engine for the state, generating approximately $1.4 billion annually and supporting the livelihoods of 4,500 lobstermen in addition to the thousands of Mainers employed through lobster dealers and seafood processors, vessel and trap manufacturers, restaurants, and other coastal businesses. Last year, Maine led the nation in lobster landings, with over 100 million pounds of lobster valued at $485 million. As you know, lobster is regularly the highest-value species harvested in the United States.

The ramifications of this BiOp and the recently proposed take reduction rule are immense, and we recognize that all parties are operating under a court-ordered deadline that must be adhered to. We believe, however, that providing a modest, additional amount of time for review and analysis of the BiOp by stakeholders will help to ensure that future regulatory actions on the fishery are effective and fully informed by those who know the most about it.

We have heard from industry leaders and state regulators who are all concerned that the current comment deadline of February 19, 2021 does not provide adequate time to review the volume of data and the new model, which was not previously shared with stakeholders. Moreover, the proposed 98 percent risk reduction requirement for all U.S. fixed gear fisheries over the ten year conservation framework is deeply troubling and warrants additional time for thorough evaluation by industry as it could ultimately result in a total shutdown of the lobster fishery by 2030.

We support the Maine Department of Marine Resources (DMR) proposal to extend the comment period deadline for the BiOp to align with that of the proposed rule under the Atlantic Large Whale Take Reduction Plan: March 1, 2021. Doing so would help ensure that DMR can effectively utilize staff resources and provide NOAA Fisheries with the thorough analysis and comments that this significant federal action deserves. This extension will also provide lobstermen--the majority of whom spend their days out on the water--with additional time to understand and comment on the more than one thousand pages of material that, when finalized, may drastically impact their livelihoods.

Thank you for your attention to this important matter; we look forward to your response.

Sincerely