Letter to Michael Pentony, Regional Administrator Greater Atlantic Regional Fisheries Office - Golden Presses Feds for More Maine Lobstermen Representation on Regulation Advisory Panel

Letter

Dear Mr. Pentony:
I am writing to share my strong support for appointing representatives from the Maine Lobstering Union Local 207 (MLU) to the Atlantic Large Whale Take Reduction Team (ALWTRT). As the only industry organization comprised exclusively of lobstermen with active commercial lobster and crab fishing licenses, the MLU would bring an essential perspective to the ALWTRT.
Since 2013, the MLU has been an integral part of Maine's lobster industry and economy. Now with over 250 members who fish across all of Maine's Lobster Management Zones, the MLU reflects the diversity of our state's lobster fleet and coastal communities. Additionally, the MLU members are the sole owner of Lobster 207, LLC, a wholesale, retail lobster cooperative that markets and sells locally and sustainably caught seafood directly to customers in Maine and across the country. In other words, MLU members are involved in every facet of the supply chain -- from the harvesting and processing to the sale and distribution of the product.
Given the MLU's unique composition and cooperative business model, I believe that the organization meets the criteria set forth under the Marine Mammal Protection Act (MMPA) to ensure that take reduction teams are inclusive of "all commercial and recreational fisheries groups and gear types which incidentally take the species or stock." It is my understanding that neither the MMPA nor the Take Reduction Team Operating Protocols set a specific number of seats for a take reduction team, but rather they require that the team consist of an equitable balance among representatives of the fishing industry, fishery management councils, state and federal resource management agencies, the scientific community, and conservation organizations. With a larger membership than the number of federally permitted lobster trap harvesters in several other team member states, including New Hampshire, Rhode Island, and New Jersey, MLU's absence from the ALWTRT means that a significant stakeholder group is not adequately represented.
Moreover, the MMPA provides the National Marine Fisheries Service with the authority to add members to the take reduction team if the agency determines that a particular constituency is not adequately represented and prospective members have the ability to both bring first-hand knowledge and perspective to bear on the relevant fishery and to work collaboratively. For nearly a decade, the MLU has engaged with local, state, and federal officials as well as the scientific community on various projects to improve our understanding of the distribution of right whales and their potential interactions with certain gear types and fishing effort. They are currently working on new data collection models utilizing fishermen and their fishing gear to obtain vital information about right whale habitat in the Gulf of Maine. This data, if brought to bear, would prove invaluable to the ALWTRT as they continue to assess the underlying causes of right whale serious injury and mortality.
In order to ensure that the ALWTRT is indeed representative of all commercial fisheries groups, I strongly urge you to appoint representatives from the MLU. Their unique makeup as an entirely fishermen-member enterprise that participates in every aspect of the industry make them an indispensable industry participant whose voice deserves to have a seat at the table.
I appreciate your attention to this important matter. Please contact Eric Kanter in my office at Eric.Kanter@mail.house.gov or (202)-981-3603 should you have any questions.

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