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Letter: To Carlos Gutierrez, Secretary, U.S. Department of Commerce

Dear Secretary Gutierrez:

We're writing to express our strong support for the fishery disaster declaration request by the Commonwealth of Massachusetts, and we respectfully request that you issue this declaration as quickly as possible.

On February 21, Governor Deval Patrick wrote you expressing the Commonwealth's intent to seek a declaration of economic disaster on behalf of its commercial groundfishermen.

On April 9, he submitted a report to the Commerce Department documenting the economic disaster. The report found an 18 percent loss in groundfish fleet revenue since the implementation last year of Framework 42 to the Northeast Multi-species Fishery.

The Massachusetts report's findings track closely with NOAA's report, An Examination of the Potential Impact on All Affected and Interested Parties of Framework 42 to the Northeast Multi-species Fishery Management Plan, which was completed in January pursuant to Section 215 of Public Law 109-479, the Magnuson-Stevens Fishery Conservation and Management Reauthorization Act. NOAA's report estimated that Massachusetts vessels will lose 20 percent of income under Framework 42.

Framework 42, which was implemented in November, places new restrictions on fishery catch and requires reductions in allotted days-at-sea. The changes have been devastating to the groundfishing fleets of Gloucester, New Bedford, and the Cape and Islands of Massachusetts, since more than a quarter of these vessels fish exclusively inside areas where the new regulation orders each day-at-sea to be counted twice. As a result, many of these fishermen now have just 24 days to fish during a season. The hardship is particularly acute for the many small-boat fishermen who cannot safely fish beyond the inshore areas where each day at sea is countedtwice.

Framework 42 is not limited to Massachusetts, but our state is potentially the most adversely affected, since half of the 800 active groundfish vessels in the Northeast are based in Massachusetts, and three-quarters of the Massachusetts groundfish fleet are small and mediumsizevessels. The Massachusetts ground fish fleet has declined from 572 vesselsi n 2000 tojust 400 in 2005, and the decline was steepest for small and medium-sized vessels, which fell by 35 percent.

Massachusetts fishermen need immediate relief to survive the new restrictions and avoid a total collapse of the groundfish industry. We believe the state has made a compelling case to support a fishery disaster declaration, and we urge you to provide the declaration as quickly as possible, so that immediate steps can be taken to remedy the economic losses.

With respect and appreciation, and we thank you for considering our request.

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