Harvesters' Letter to U.S. Coast Guard Concerning the Alternative Safety Compliance Program and Industry Outreach

 The following letter was sent by the Seafood Harvesters to the Coast Guard's Chief of Commercial Vessel Compliance, May 10, 2016.Captain Kyle McAvoy, USCGChief, Office of Commercial Vessel Compliance (CG-CVC)United States Coast Guard, Stop 75012703 Martin Luther King, Jr. Avenue, SEWashington, DC 20593-7501Sent by email and USPSDear Captain McAvoy:The Seafood Harvesters of America (the Harvesters) is a nationwide commercial fishermen’s association that represents 17 commercial fishing organizations from Alaska to the Gulf of Mexico to New England[1]. We are writing to you today regarding the Coast Guard’s development of an alternate safety compliance program (ASCP) under section 4503(d) of 46 United States Code.Section 4503 was amended in 2010 to require the Coast Guard to develop an ASCP in cooperation with the commercial fishing vessel industry. Section 4503(d) requires the Coast Guard to prescribe this program by no later than January 1, 2017, and requires commercial fishing vessels, fish processing vessels, and fish tender vessels subject to that subsection to comply with the ASCP by January 1, 2020. This provides the commercial fishing vessel industry three years to make the required physical changes to our vessels to comply with this program. While section 4503(d) was amended during the past year, the above basic parameters have remained in place for almost six years.We are distressed by the lack of outreach by the Coast Guard given the above impending deadlines. When the Harvesters’ members contact District-level Coast Guard officials, it is clear to us that those officials generally do not understand how our industry is organized or how to contact us and have inconsistent understandings of Headquarters’ intentions. This is occurring more than five months after we wrote to the Coast Guard Headquarters Fishing Vessel Safety Division on November 18, 2015 offering to assist the Coast Guard in its outreach effort.Given the statutory deadlines and the lack of outreach, we are concerned that the resulting ASCP will require many of us to make unnecessary and expensive changes to our vessels in less time than the statute intended to provide us. We request the Coast Guard immediately act on the following items:

  1. Assess commercial fishing vessel incidents causing loss of life or significant property damage on a regional and fishery basis and use this analysis to develop regional and fisheries-specific safety recommendations for the ASCP;
  2. Asses the extent to which changes in the management of each fishery have improved fishing vessel safety and reduced the risks of fishing vessel operations for each fishery and incorporate this into those fisheries-specific safety recommendations for the ASCP;
  3. Schedule and conduct within the next 60 days regional planning meetings to receive the input of all affected commercial fisheries;
  4. Provide commercial fishermen with a meaningful opportunity for public comment on draft ASCP regulations; and
  5. Dedicate sufficient resources to develop the ASCP in a timely manner while addressing the above concerns or request the Congress extend the statutory deadlines for the ASCP.

We understand that the Coast Guard has many mission requirements and limited resources, but we don’t understand why the Coast Guard has attempted so little outreach to our industry during the more than five years since section 4503(d) was enacted. We ask that you let us help you coordinate the increased outreach effort requested above. Our executive director (interim) is Scott Coughlin. He would be happy to assist your outreach specialists in any way. Scott can be reached at scott@seafoodharvesters.org or (202) 888-2733.Thank you for your cooperation with this request.Sincerely,Chris Brown signature fileChristopher BrownPresident [1] Alaska Bering Sea Crabbers, Alaska Whitefish Trawlers Association, Cape Cod Commercial Fishermen’s Alliance, Cordova District Fishermen United, Fishing Vessel Owners Association, Fort Bragg Groundfish Association, George’s Bank Cod Fixed Gear Sector, Inc., Gulf Fishermen’s Association, Gulf of Mexico Reef Fish Shareholders’ Alliance, Massachusetts Lobstermen’s Association, Midwater Trawlers Cooperative, New Hampshire Groundfish Sectors, North Pacific Fisheries Association, Purse Seine Vessel Owners Association, Rhode Island Commercial Fishermen’s Association, South Atlantic Fishermen’s Association, United Catcher Boats.