April

9, 2018

His Excellency Charles D. Baker, Jr.
Governor of the Commonwealth of Massachusetts
Office of the Governor
State House, Room 280
Boston, MA 02133

Dear Governor Baker:

We the undersigned are members and supporters of our nation’s $60 billion commercial
fishing industry. We are committed to speaking out about the offshore wind energy
industry’s efforts to develop in the United States, whenever and wherever offshore wind
development has the potential to significantly impact our livelihoods.

Now is a particularly critical time for our collective voice to be heard. In April your
Administration is scheduled to select a company to construct the nation’s first industrial-
scale offshore wind project off the coast of Massachusetts. We therefore seek your
immediate, direct involvement to ensure that our concerns are promptly given the
attention they deserve; and if further time is needed to address these issues, then we ask
you to consider delaying the April selection.

It is imperative that the Massachusetts wind project and any that follow, which propose to
share those same waters which have been inhabited by our historic fishing industry for
centuries, are designed, constructed, and operated in a way that takes into account the
activity of the nation’s commercial fishing fleet. Based on the past several months of
interaction with the offshore wind industry, we do not have confidence that our interests
are being adequately taken into account, nor will be in the future.

Three issues of key importance have emerged, first, the project size and number of
turbines; second, the lack of a plan or process to study impacts; and third, a lack of
coordination or communication among projects. We address these in detail below.

At the same time, there is an increasing consensus among industry members that these
specific issues reflect an underlying problem: The “fishing engagement” efforts of offshore
wind developers have shown themselves to be woefully insufficient, lacking in
transparency, and unnecessarily burdensome on fishermen. We are concerned that our
voices are being divided and diluted by the current patchwork of engagement initiatives,
and we do not have any confidence that the situation will improve without firm direction
from state and federal policy-makers.



1750 K Street, NW | Suite 900 | Washington, DC 20007
202-595-1212 | www.fisheriescoalition.org
Three separate, developer-led outreach efforts have been launched, and all are stumbling
to produce meaningful dialogue or move us closer to real solutions in areas ranging from
navigation, access, cable routes, radar interference, and gear loss. Equally troubling, it has
become clear that offshore wind developers are unwilling or unable to coordinate their
interactions with commercial fishermen to tackle issues that cut across multiple project
areas. Thus far these efforts have been more akin to “window dressing,” disparate activities
designed ultimately to provide a means to claim that fishing interests have been
considered, rather than an actual serious and successful engagement with fishing interests.

In sum, the “engagement process” as presently constituted is proving to be a wholly
ineffective means of interacting with the commercial fishing industry—an industry whose
members are already required to attend dozens of other regular public meetings on a
myriad of regulatory issues related to our profession.

It is ironic that the possibility of oil and gas development off the U.S. East Coast—as
problematic as that may be for many fishermen—has not generated nearly the same level
of consternation among fishermen recently as the prospect of an offshore wind industry
unwilling to undertake the hard work of a serious, substantive engagement with our
industry.

We believe a better, simpler path forward exists. We outline such a path in the second half
of this letter, and we ask you to endorse our plan

Three Issues of Critical Concern:

1) Project Size/Number of Turbines

We believe Massachusetts should curtail the numbers of turbines associated with first
offshore wind project to allow for a robust foundation of impact studies on fisheries and
fishing activity before any decisions are made regarding additional offshore wind projects.
If a decision is made to approve a wind project this Spring, that project should be as modest
in size and scope as possible to facilitate the study of its many impacts through all the
phases of the project (before, during, and post-construction).

We are pragmatic and we understand that we do not “own” the ocean where these wind
farms are being sited. But we do not believe that a renewable resource like wind energy
should be allowed to displace another renewable resource like wild fisheries. To guard
against that outcome, a measured, restrained approach to the initial project size is best. It
is irresponsible to allow construction of sizable wind farms without a deep understanding
of their impacts. That understanding must be informed by a robust analysis of local data—
not just extrapolations from the European offshore wind experience. The U.S. Continental
Shelf is not the North Sea, and our fisheries and fishing operations are also very different.

We are strongly in favor of a cautious procurement approach that allows U.S. state and
federal regulators time to study and then correct policies governing domestic offshore
wind projects. We encourage the Commonwealth therefore to award no more that 400 MW
in this round of solicitations to allow fishermen, fisheries scientists, and fisheries
regulators the opportunity to fully determine the impact offshore wind farms will have on
our businesses and the resource.


2) Lack of a Plan or Process to Study Impacts

Even if a smaller wind project is approved, there is not currently a process or plan in place
to measure its varied impacts on the fishing industry. To be sure, there are BOEM
guidelines that require developers to study fisheries impacts. The problem lies with what
the BOEM guidelines lack. For example, there is no framework for deciding who will
perform the studies to ensure their rigor and credibility; and nothing to ensure that studies
even take into account input from the fishing industry.

The Massachusetts Coastal Zone Management’s Fisheries Working Group is making efforts
to address the problem, but a detailed Study Plan that enjoys broad support among fishing
stakeholders is urgently needed. A Study Plan could lead to analyses that helps developers
locate individual turbines within a project area. Under the current process, Construction
and Operations Plans (Plans that detail turbine layouts) may be finalized by developers
with no input at all from the fishing industry and no impact analysis. Without a Study Plan
in place, BOEM’s existing guidelines are proving of little value to fishing industry
stakeholders.

3) No Coordination or Communication Among Projects
The combination of federal and state processes for selecting and managing offshore wind
projects is resulting in narrow, siloed decision-making among developers and regulators
alike. The result is little, if any, communication or coordination among projects. This has
major implications for the fishing industry. For example, transit lanes for vessels accessing
the fishing grounds south and east of the project sites may not align as individual projects
are left to pursue their own solutions.

Coordination around cable corridors is likewise absent. Coordinating cable routes can
significantly lessen the impact to fishing operations and prevent unnecessary exclusions to
mobile gear or prohibitions on grappling for lost fixed gear. The importance of
coordinating with the fishing industry on the cable routes is a lesson learned from the
European experience, but one that it appears is being ignored here.

The Path Forward: A Standardized Process for Developer Engagement With Fishing
Stakeholders

We believe a better path forward exists.

Our view is that a “hitting of the reset button” is needed. If honest communication and
effective approaches to issue resolution can be established, that success will broadly
disseminate and serve both industries well for years to come. The reverse is also true: if the
nascent offshore wind industry fails in its relationship-building in in this first round of
procurement, then negative consequences will extend far beyond.

The Port of New Bedford is utilized daily by vessels home ported from Maine to North
Carolina. One need only spend a morning in the auction house there to hear a multiplicity
of languages, and accents from down-east to southern drawl. As both the nation’s most
economically valuable fishing port for nearly two decades, and the primary offshore wind
staging port on the East Coast, the Port of New Bedford is a logical place to serve as the
point of interaction between the offshore wind industry and the commercial fishing
industry.


It is in this context that we support having the New Bedford Port Authority take on a
leadership position as the central facilitator of communication between the two industries
for all offshore wind projects in development in the Massachusetts Wind Energy Area
(WEA). This could potentially grow into a role as central facilitator for other wind projects
in development along the Northeast seaboard where commercial fishing impacts are
anticipated. In our view, establishing the NBPA as the central clearinghouse charged with
administering a standardized, consolidated information-exchange and issue-resolution
process, can only serve to benefit the interests of both the fishing and offshore wind
industries.

The NBPA has the technical expertise and the credibility within our community that is
essential to effective communication and problem-solving among stakeholders. Moreover,
as a public entity, the NBPA is in a unique, independent position to operate in this role

A standardized, consolidated process for the offshore wind industry’s engagement on
fisheries issues is the only path forward. We envision the NBPA, as the facilitator of that
common process, creating a constructive environment where project plans and
information about operations are shared with the fishermen, where issues in need of
attention are articulated back to the wind developers, and where potential conflicts are
diffused and problems solved.

We also expect that this sustained engagement with the fishing industry can translate into
more conciliatory interactions with fishing communities all along the Eastern Seaboard. To
be sure, every wind project will have its own unique characteristics, and differing fishing-
related impacts, but we are convinced that the framework we are proposing has the
greatest chance of success irrespective of the particular issues that may arise.

It is with this goal in mind that we would like you to endorse the following “standard
operating procedure” for engagement with the commercial fishing industry for all
Massachusetts WEA projects. We also ask for your help in encouraging the federal Bureau
of Ocean Energy Management to require other developers pursuing projects along the
Eastern seaboard to adopt the same process.

• Each wind project will follow a common, standardized process for fisheries
engagement, but with different components that reflect the unique makeup of that
project’s fisheries stakeholders.

• Each wind project will strictly adhere to the Fisheries Communication Plan process for
WEAs (as described in BOEM’s 2015 Guidelines for Providing Information on Fisheries
Social and Economic Conditions for Renewable Energy Development on the Atlantic Outer
Continental Shelf), including the holding of quarterly public meetings with fishing
interests and monthly meetings with a smaller advisory committee (for the
Massachusetts WEA the NBPA Fisheries Advisory Committee on Offshore Wind would
assume this role).

• The monthly advisory committee (for the Massachusetts WEA the NBPA Fisheries
Advisory Committee) will provide regular advice to the wind project on the following:

Ø Affected fisheries;
Ø Communication methods and tools;
Ø Impact reduction measures for fishery resources and fishing
operations;
Ø The effectiveness of impact reduction measures;
Ø Opportunities for coordination across projects;
Ø Best practices for project dismantling/decommissioning at end of
project life;
Ø Mandatory Mitigation

The concerns we are voicing are serious, but we have confidence in the potential of the
process outlined above to successfully address these concerns. Likewise we have
confidence in your leadership as Governor in these matters. We are grateful for the
willingness you have shown in the past to take sensible steps to ensure that one of great
and historic industries of the Commonwealth and our nation--commercial fishing--is
respected in the state and federal policymaking process. We appeal to you to take sensible
action again on our behalf.

Thank you for your consideration.

Sincerely,

Businesses and Organizations David Stanley, VP of Operations
Bergie’s Seafood Inc.
John F. Whiteside, Jr., General Counsel Cape Quality Seafood Restaurant and
American Scallop Association Market
Massachusetts, New Jersey, North Carolina, Massachusetts
Rhode Island, Virginia
Rob Newberry, Executive Director
Jon Williams, President DelMarVa Fisheries Association
Atlantic Red Crab Co. Maryland, Virginia
Massachusetts
Michael Quinn, General Manager
Ed Mullis, General Manager East Coast Fabrication
B&C Seafood Standard Marine Outfitters
Virginia Shoreline Resources
Massachusetts
Gene Bergson, Executive Vice President
Blue Harvest Fisheries Jim Lovgren, Board Member
Virginia Fishermen’s Dock Co-Op
New Jersey

Greg DiDomenico, Executive Director Erik Orman, Owner
Garden State Seafood Association Tempest Fisheries
New Jersey Massachusetts

Bonnie Brady, Executive Director Katie Almeida, Fisheries Representative
Long Island Commercial Fisheries The Town Dock
Association Rhode Island
New York
Ernie Panacek, General Manager
Jeff Reichle, Chairman Viking Village
Lund’s Fisheries New Jersey
New Jersey
Sigurd Johannessen, President
Paul Weckesser, Owner Warrior Fuel Co.
Mass Fabricating & Welding Massachusetts
Mass Contracting & Construction
W Trading, Inc. Lori Steele, Executive Director
Massachusetts West Coast Seafood Processors
Association
Harriet Didriksen, President Oregon, Washington
New Bedford Ship Supply Co.
Massachusetts Richie and Ray Canastra, Owners
Whaling City Seafood Display Auction
Peter Anthony, Fleet Manager Massachusetts
Nordic Fisheries
O’Hara Corporation
Maine, Massachusetts Fishing Vessels
Home ported in Maine, Massachusetts,
John Haran, Manager Rhode Island, New Jersey, and Virginia
Northeast Fisheries Sector XIII
Massachusetts F/V 1990 Appleby
F/V Adventura
Ken Melanson, CEO F/V Adventuress
Northern Wind F/V Alexis Martina
Massachusetts F/V Ambition
F/V Angenette
Charlie Quinn, CEO F/V Ann M
Quinn Fisheries F/V Anne Kathryn
Massachusetts F/V Anticipation
F/V Araho
Meghan Lapp, Fisheries Liaison F/V Arcturus
Seafreeze, Ltd. F/V Asher & Ariana
Rhode Island F/V Ashley Gail
F/V Atlantic
Bob Jones, Executive Director F/V Bailey Boy
Southeastern Fisheries Association F/V Beiningen
Florida F/V Bella Rose
F/V Betsy Gals II
F/V Blue Canyon
F/V Blue Cove

F/V Blue Delta F/V Fisherman
F/V Blue Eastern F/V Fjord
F/V Blue Harbor F/V Francis Elizabeth
F/V Blue Harvest F/V Freedom
F/V Blue Lagoon F/V Friendship
F/V Blue North F/V Frontier
F/V Blue Ocean F/V Gabby G
F/V Blue Pacific F/V Gambler
F/V Blue Sea F/V Generation
F/V Blue South F/V Grand Larson III
F/V Blue Stream F/V Harvester
F/V Blue Water F/V Hear No Evil
F/V Blue Wave F/V Heritage
F/V Blue Western F/V Holly & Abby
F/V Brittany Eryn F/V Holly Jean
F/V Buzzards Bay F/V Hope & Sydney
F/V C-Venture F/V Horizon
F/V Capt John F/V Hunter
F/V Capt Ralph F/V Hustler
F/V CB Keane F/V Iberia II
F/V Celtic F/V Illusion
F/V Challenge F/V Imigrante
F/V Charlies Pride F/V Immagrante
F/V Chief & Clyde II F/V Incentive
F/V Coleman F/V Italian Princess
F/V Conor And Michael F/V James & Matthew
F/V CPH F/V Jason & Danielle
F/V CPH-Titan F/V John & Nicholas
F/V CSM F/V Joyce D
F/V Curlew II F/V Justice
F/V Cygnet F/V Justice
F/V Debbie Ann F/V Karen Elizabeth
F/V Debbie Sue F/V Karen L
F/V Destiny F/V Kathryn Marie
F/V Determination F/V Kathy & Jackie
F/V Donny C F/V Kathy Ann
F/V Double Diamond F/V Kathy Marie
F/V Drake F/V Kayla Rose
F/V Edgartown F/V Kelly Marie
F/V Edurance F/V Kingfisher
F/V Elizabeth F/V Lady Deborah
F/V Endurance F/V Lady Dee
F/V Enterprise F/V Langley Douglas
F/V Ester M F/V Lena Pearl
F/V Evan Christine F/V Lerano
F/V Evening Prayer F/V Let It Ride
F/V Excalibur F/V Liberty
F/V Expectation F/V Lightning Bay
F/V Fairwind F/V Ligia
F/V Fish Tails F/V Lindsay L

F/V Lori L F/V Raiders
F/V Luc Imar F/V Ranger
F/V Lucimar F/V Rebecca Mary
F/V Lucky Thirteen F/V Reflection
F/V Luso American I F/V Reliance
F/V Luso American II F/V Resilient
F/V Madelyn F/V Resolution
F/V Maelstrom F/V Rhonda Denise
F/V Majestic F/V Richard & Arnold
F/V Majestic F/V Roanoke Fish Co
F/V Mandrake F/V Rose Marie
F/V Margaret Holley F/V Rost
F/V Mary K F/V Ruthie B
F/V Mary L F/V Santa Queen
F/V Mattie And Maren F/V Sao Marcos II
F/V Max & Emma F/V Sao Marcos II
F/V Mayflower F/V Sao Paulo
F/V Megan Marie F/V Sao Paulo
F/V Mirage F/V Sarah Ann
F/V Mischief F/V Seafarer
F/V Miss Crockett F/V Second Wind
F/V Miss Emma F/V Sereno
F/V Miss Leslie F/V Settler
F/V Miss Shauna F/V Seven Seas
F/V Miste Rose F/V Shamrock
F/V Monomoy F/V Sharon Nicole
F/V Moragh K F/V Shelby Ann
F/V MS Manya F/V Sirius
F/V N. Pride F/V Socatean
F/V Nashira F/V Sorry Charlie
F/V Nellie M Stanley F/V Sovereign
F/V Neskone F/V Sovereign Star
F/V Norseman F/V Stardust
F/V Odessa F/V Stephanie Bryan
F/V Olivia Catherine F/V Survival
F/V Orion F/V Susan Rose
F/V Patience F/V T Luis
F/V Patriots F/V Tenacity
F/V Pee Wee F/V Thor
F/V Perception F/V Thunder Bay
F/V Phoenix F/V Thunder Bay
F/V Pilgrim F/V Timberwolf
F/V Polaris F/V Tradition
F/V Pontos F/V Travis & Natalie
F/V Poseidon F/V Tucker Roy
F/V Predator F/V Unicorn
F/V Prevail F/V United States
F/V Provider F/V Venture
F/V Provider III F/V Virginia Clipper
F/V Pyxis F/V Virginia Dare

F/V Virginia Queen F/V Water Tender
F/V Virginia Wave F/V Weatherly
F/V Walker Bay F/V Wisdom
F/V Warrior F/V Yankee Pride



cc:

The Honorable Ryan Zinke, Secretary of Interior
The Honorable Wilbur Ross, Secretary of Commerce
The Honorable Rob Bishop, Chairman, Committee on Natural Resources, U.S. House of
Representatives
The Honorable Raúl Grijalva, Ranking Member, Committee on Natural Resources, U.S.
House of Representatives
The Honorable Paul Gosar, Chairman, Committee on Natural Resources, Subcommittee on
Energy and Mineral Resources, U.S. House of Representatives
The Honorable Alan Lowenthal, Ranking Member, Committee on Natural Resources,
Subcommittee on Energy and Mineral Resources, U.S. House of Representatives
The Honorable Doug Lamborn, Chairman, Committee on Natural Resources, Subcommittee
on Water, Power, and Oceans; U.S. House of Representatives
The Honorable Jared Huffman, Ranking Member, Committee on Natural Resources,
Subcommittee on Water, Power, and Oceans; U.S. House of Representatives
Massachusetts Congressional Delegation
The Honorable Jon Mitchell, Mayor, City of New Bedford
Dr. Walter Cruickshank, Acting Director, Bureau of Ocean Energy Management
The Honorable Matthew Beaton, Secretary of Energy and Environment, Commonwealth of
Massachusetts
Dr. David Pierce, Director, Department of Marine Fisheries, Commonwealth of
Massachusetts
Ms. Judith Judson, Director, Department of Energy Resources, Commonwealth of
Massachusetts
Mr. Thomas Brostrom, Bay State Wind
Mr. Jeffrey Grabowski, Deepwater Wind
Mr. Erich Stephens, Vineyard Wind