Seafood Harvesters Comment Letter on the Administration's Oil and Gas Leasing Program

March 9, 2018

The Honorable Ryan ZinkeSecretaryUnited States Dept. of the Interior1849 C Street N.W.Washington, DC 20240

Ms. Kelly HammerleNational OCS Oil & Gas Leasing ProgramBureau of Ocean Energy Management45600 Woodland RoadSterling, VA 20166-9216

Dear Secretary Zinke and Ms. Hammerle:We write to express our deep concern about the National Outer Continental Shelf Oil and Gas Leasing Program for 2019-2024, and to offer our assistance as you advance your outreach and revision processes.In our view the Draft Proposed Program released in January gives unbalanced weight to energy production and under-emphasizes a critical directive of the Outer Continental Shelf Lands Act, namely its directive to consider “economic, social, and environmental values of the renewable and nonrenewable resources contained in the outer Continental Shelf, and the potential impacts of oil and gas exploration on the resource values of the outer Continental Shelf and the marine, coastal and human environments” (43 U.S.C. 1344(a)(2)(f).Those are the environments where the Seafood Harvesters live and work. We represent over 3,900 small businesses, nineteen thousand jobs, almost $500 million in income and $1.25 billion in total economic output. Our members go to sea every day from Alaska to California, Texas to Florida, and from the Carolinas to New England. They bring to market the healthy, domestic, sustainable seafood that feeds America.Because we represent such diverse fleets—and vessels operated by thousands of independent men and women—we focus on issues of common concern that transcend parochial or partisan politics. Nothing unites us more than the waters we navigate and the commitment we share to protect them. In a very real sense, America’s renewable fish stocks and the habitats that sustain them are national treasures. The species we catch are unchanged for millennia, and their stewardship is a privilege and duty we take seriously. Responsibly managed and harvested, our nation’s “strategic protein reserve” can support us indefinitely.By contrast, oil supplies are nonrenewable, and offshore exploration poses significant dangers. Where seafloor drilling takes place, leaks and spills occur, and when crude oil is transported by tanker, risks of vessel disablement, accidental groundings and collisions are ever-present.Offshore drilling threatens fish and fishing jobs, irreplaceable habitat, and the heritage and economies of coastal communities. It also threatens the proven sustainability of many U.S. fisheries that sacrifices and investments made by fishermen have helped to produce. While oil spills barely register on balance sheets of the corporations responsible, they can devastate those least able to withstand them: America’s fishing families and the species we harvest.While acknowledging the obvious—that our industry is dependent on petroleum products—it is also true that maximizing the exploitation of fossil resources wherever they can be found is an outdated approach that does little to create a more promising future. This is less a political statement than a recognition that our national needs and values are changing. Rapid advances in renewable energy production will increasingly provide policymakers with new opportunities to prioritize food security and rational climate policies over risky oil exploration and large-scale corporate profits.Plainly put, our nation's wealth can no longer be measured solely in terms of GDP. It must also be evaluated in terms of accumulated knowledge and our ability to protect, nurture and support our citizens and our natural resources.It is our understanding that only one meeting seeking public comment has been held in each affected state since release of the Draft Proposed Program. If your goal is to seek meaningful input from coastal communities and the businesses that operate there, then something greater than a minimum-defensible level of public outreach will be required. Because the Seafood Harvesters operate throughout the United States, we are equipped to help as you seek to better understand the “marine, coastal and human environments” most likely to be impacted by offshore oil exploration and drilling.Please consider us ready to assist your outreach efforts as you continue to revise the leasing program.Sincerely,Christopher Brown, President

Our Mission and Members

“As domestic harvesters of an American public resource, we recognize and embrace our stewardship responsibility. We strive for accountability in our fisheries, encourage others to do the same, and speak out on issues of common concern that affect the U.S. commercial fishing industry, the stewardship of our public resources and the many millions of Americans who enjoy seafood.”

Alaska Bering Sea CrabbersAlaska Whitefish Trawlers AssociationCape Cod Commercial Fishermen’s AllianceCordova District Fishermen UnitedFishing Vessel Owners’ AssociationFort Bragg Groundfish AssociationGeorges Bank Fixed Gear Cod Sector, Inc.Gulf Fishermen’s AssociationGulf of Mexico Reef Fish Shareholder’s AllianceMidwater Trawlers CooperativeNew Hampshire Groundfish SectorsNorth Pacific Fisheries AssociationPurse Seine Vessel Owners AssociationRhode Island Commercial Fishermen’s Assoc.South Atlantic Fishermen’s AssociationUnited Catcher Boats