Letter to Gina Raimondo, Secretary of Commerce - Maine Delegation, Governor Mills Renew Call for Biden Administration to Extend Lobster Gear Deadline

Letter

Dear Secretary Raimondo:

We are providing an update on the supply chain and availability issues related to the
requirements of the National Marine Fisheries Service's (NMFS) new Atlantic Large Whale
Take Reduction Plan (ALWTRP) rule and requesting that you reconsider a modest delay in
implementation of a component of this rule. The continued scarcity of required gear is making it
increasingly unlikely that fishermen, despite their best efforts and those of suppliers, will be able
to achieve timely compliance.

In good faith, lobstermen have been seeking out the necessary supplies required to modify their
gear by the May 1st deadline, and suppliers have been hard at work trying to meet the demand.
Fishermen have sought to purchase weak links being manufactured by several gear suppliers in
the region. Many have been advised that they can place an order but receive no estimate or
certainty on when they might take delivery. Fishermen and regulators alike had expected Brooks
Trap Mill to provide high volume production of a manufactured weak link which was critical to
meeting Maine's demand. Unfortunately, and unexpectedly, Brooks has faced challenges with
its mold and has no clear timeline for resolution. What is clear is that production will not be
beginning as soon as anticipated. Another weak link that had been widely available, made by
Plantes Lobster Vents, Inc., was just recalled due to a batch failure that could not be isolated.
Unfortunately, this required the removal of all available product from the shelves. A number of
fishermen who have already installed these weak links may now have to remove and replace
them with an alternative product, if they are able to obtain it.

NMFS has compounded these challenges by refusing, without any scientific basis, to approve the
use of knots as weak links despite demonstrable evidence that knots in certain diameter ropes can
provide the necessary breaking-strength in vertical lines.

Once again, we ask you to urge NMFS to extend the compliance date to July 1, 2022 in light of
the operational realities of the supply chain and with less than six weeks from the
implementation date.

This reasonable request is supported by the Small Business Administration's Office of
Advocacy, which asserted in a March 3 letter to you that the agency was putting fishermen "in an
impossible scenario" and "if they are not granted a short delay of the compliance deadline, they
may stand to lose significant amounts of revenue, or in some instances their entire business." We
could not agree more with the objective assessment.

We thank you for your attention to this matter and look forward to your prompt response.

Sincerely,