We, the Undersigned, Earn Our Livelihoods from the Seafood Industry
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We, the undersigned, earn our livelihoods from the seafood industry. We are essential workers and an integral part of the nation’s food security, not just during a pandemic. Fishing has been the backbone of working waterfronts and coastal communities for generations, supporting not just the families of harvesters, but also those of dealers, processors, marine suppliers, service providers, grocers, restaurants, the tourism industry, and other sectors by providing healthy and sustainable seafood to the nation. As such, we request the following be given priority as BOEM considers the approval of the first large-scale offshore wind energy area in United States waters: • All energy, including “clean energy,” has environmental impacts that must be fully understood and weighed in the context of an overall power strategy. While protecting our air and climate is important, so is protecting marine ecosystems and biodiversity. The power density of offshore wind projects is among the lowest of any energy source, and the industrialization of such large areas will permanently change marine ecosystems and threaten a strategic food supply. • The fishing industry must be included early in the planning process of any offshore development project, and long before the point that a Construction and Operations plan has been finalized. Our historic fishing locations and practices will be directly and permanently impacted by any offshore development, and every effort should be made to preserve and protect them. Any planned project will benefit from the expertise of our industry. So far, this has not occurred in any meaningful way. • Accurate and sufficient data is needed when considering where to locate offshore development projects. Inadequate and incomplete data does not capture long-term trends (or short-term anomalies) in fish distribution and fishing activity. Resources must be committed in order to address and fill data gaps. When analyzing potential siting locations for wind energy, BOEM and offshore wind proponents deconflict with most if not all other conceivable uses, from viewshed to shipping to national security, but rarely acknowledge commercial fishing – an activity that directly conflicts with offshore wind. The data gaps referenced above (and misuse of existing and incomplete data) have contributed to willful ignorance of the importance of these areas to fishing. • Research is essential to adequately describe and mitigate impacts on the fishing industry. We need significantly more investment in research on lasting impacts on our long-running science surveys that inform stock assessments (upon which fisheries management decisions are based), fish distribution, spawning behavior, larval settlement, and socio-economic impacts on fishing communities. • We need a better process for planning, locating, and monitoring transmission lines. This needs to be implemented after significant uncertainties are resolved regarding cable impacts to fisheries and the environment, and the likely benefits of a coordinated transmission system are fully explored. • Compensatory mitigation must make up for any direct and indirect impacts to fishing and fishing communities from offshore development and must not discriminate between states. Such payment schemes are only appropriate after all impacts are minimized through project siting and design. Presently, programs and policies ostensibly designed to address commercial fishing concerns by both the offshore wind industry and federal and state governments “divide and conquer” the fishing industry by artificially balkanizing on a state-by-state basis the interests and needs of many multi-state fishing and processing companies. In federal waters, neither fish nor fishermen cross state borders. Yet conflicting decisions impacting this regional industry, including compensatory mitigation, are addressed at the state level. Each state and each wind project will force regionally impacted fishing companies to jump to the beat of separate regulations, forums, evidence required, and barriers to entry. • Fishermen must be involved in the development of any compensatory mitigation plan and such plans should be fully funded, equitable, transparent, and based on the best available science. Mitigation plans must be comprehensive and encompass all businesses directly impacted by reduced revenues, which include fish houses and processing plants. A “one size fits all” approach will not work given the diverse demographics of the various fishing sectors, port and harbor communities, and fishery dependent businesses that operate in impacted areas. • While the wind industry and BOEM have expressed interest in permitting fishing within arrays and minimizing negative impacts, there has been no investigation with respect to the willingness, capacity, or cost of the maritime insurance industry to insure vessels working there. Since the insurance industry assesses risk in deciding coverage exclusions or the cost of coverage itself, the fact that developers or the government provide the fishing industry with assurance of being able to fish within arrays does not mean that fishing will, or can, take place if coverage is excluded or the cost of insuring the activity becomes prohibitive. There is no reason to believe that the current process ever envisioned or will contain sufficient funds needed to pay the industry the potential additional premium cost of coverage (if insurance is even available) for fishing within the arrays. • We support the incorporation of safe navigation corridors in all offshore development projects. Considerations of safe navigation must occur in the first design stages of offshore wind projects, not balanced against the maximum possible power generation after a power purchase agreement is set. We are tired of fishermen’s safety being ignored for the sake of additional turbines and profit for developers. • The wind industry should not be treated differently than the fishing industry under the Jones Act. Fishermen adhere to the Jones Act and they understand its goals to foster a thriving U.S. fleet and U.S. shipyards, and promote national security. Offshore wind activities do not comply with the intent of the Jones Act; these foreign companies are not investing in the U.S. by constructing qualified vessels abroad instead of domestically. • Our jobs and way of life are at risk from offshore development; these losses are not accounted for in the overestimated jobs circulated by the developers and quoted by politicians. This misinformation is used to make fishermen appear economically insignificant, when, in reality, a true economic comparison is impossible. Short-term local investments – most subsidized by the American public and benefitting parent companies located outside the U.S. – during project planning and construction stages will do nothing for the lasting benefit and character of coastal communities. We already learned this lesson the hard way in the Gold Rush and again when heavy rural community investments during the “oil boom” did not contribute to long-term community welfare. • Fishing communities have been systematically ignored by our elected representatives who are prioritizing political goals and aspirations over serving ALL of their constituents. Enough is enough. Until the above issues have been addressed, we demand a 5-year moratorium on offshore wind development. This moratorium will give us the necessary time to create an effective planning process in conjunction with BOEM. The current process does not protect our sustainable fisheries and we repeat, enough is enough. Thomas Joseph James Mckissack MWI Hackleman Fishing Gilmartin Birmingham, AL Tempe, AZ Atascadero, CA Captain Atlantic Capes Fisheries Kirk Abernathy Ken Kaysen Jesse Barrios Kenai, AK Wholesaler Commercial Fisherman Commercial Fishing Evans Meats and F/V Kahootz Captain Michele L Gilmartin Seafood Aptos, CA F/V Filthy Riches Deck Department Birmingham, AL Avila Beach, CA F/V Michele Lee Tom Dolan Kenai, AK James Luker Fishing Charters and Edward Tamsi Young Packaging Commercial Salmon Commercial Fisherman Rory Gilmartin Supplies, Inc. Fishing Sunshine Lady Seaman Lillian, AL Monterey Bay Charters Avila Beach , CA F/V Michele Lee Aptos, CA Kenai, AK Ted Norton Tyler Noble Food Sales Brandy Cogburn Commercial Fisherman Katie McGauley KeyImpact Sales Controller Miss Kat Data Manager Montgomery, AL Pacific seafood Bakersfield, CA Alaska Groundfish Data Arcata, CA Bank John Barry Tiffany Noble Kodiak, AK Commercial fisherman Paddy Davis Commercial Fisherman Optimus Fisheries LLC Fishing Miss Kat Julia Bonney Buckeye, AZ F/V Cynthia Bakersfield, CA Executive Director Arcata , CA Alaska Groundfish Data Chris Bluff Derek Gerecke Bank Gilbert, AZ Geraldine Davis Commercial Fisherman Kodiak, AK Fishing Miss Kat Rich Wolverton F/V Miss Jessie Bakersfield, CA Rey Blanco US Foods Arcata , Ca General Manager Phoenix , AZ Joseph Moock Pacific Seafood David Kirk Retired Kodiak, AK Nicholas Gaitan Secetary Seawatch International San Tan Valley, AZ Port San Luis Bakersfield, CA Kit Durnil Commercial General Manager Scott Isaacs Fisherman's Association Dylan Conroy Resurrection Bay Scottsdale, AZ Arroyo Grande, CA West Coast Fisheries Seafood Consultants Seward, AK Jeffrey Chester Jennifer Diller Bellflower, CA Distribution Commercial Fisherman Linda Behnken Scottsdale, AZ F/V TKO Daniel Fugere Commercial Fishing Atascadero, CA Commercial fisherman Alaska Longline Dewey Acker Gold Coast LLC Fishermen's Association COO William Diller Benicia, CA