Comment from Beal, Glenda

26.07.16_RFI for Ropeless Fishing Ropeless fishing rules WILL NOT WORK in Maine waters. PERIOD. Ropeless contraptions are impractical, dangerous, expensive, and unfeasible. There is no kind of technology or scenario where considering this gearing is sensible or practical for Maine fishermen. Lobster fishermen work closely together in productive fishing bottom. Setting a long string of multi-trap trawls between other fishermen’s trawls without setting on top of each other is very difficult even when fishermen ARE ABLE TO SEE each other’s end lines that indicate where trawls lie along the bottom fathoms below. Trying to haul a trawl that has been entangled with someone else’s is incredibly hard and dangerous. Even large boats with powerful haulers find this tricky and perilous. Fingers and hands have already been lost in the taut, entangled rope, gear has been parted off to become expensive, wasteful ghost gear on the bottom, and people have been hauled overboard to their deaths because of entanglements. If boats ALREADY have difficulty avoiding each other's trawls, how will this be accomplished when no one can even SEE where the other trawls are placed on bottom due to hidden "ropeless technology”? Complicated tagging and electronic marking will NOT work to keep fishermen from setting ropeless gear over the top of each other. People who propose this kind of device are clearly inexperienced with the conditions a Maine fisherman faces on a daily basis. Rope inside a ropeless device must come to the surface in order to retrievel traps lying on bottom, then must be dealt with before resetting the gear. Coiling up tens of fathoms of rope to stuff back into any kind of “ropeless” device will not be at all efficient use of time. There is no way a crew can expect to haul the amount of gear in a day which is necessary to make a profit, having to deal with this kind of contraption. To complicate matters further, it’s completely predictable that the coiled or bagged up rope will entangle in itself upon release and never make it to surface! Additionally, gear lying on the bottom will grow massive amounts of kelp, barnacles, and other sea creatures as it is exposed to the bottom marine environment. Ropeless equipment will get covered in marine life in no time, which will then no doubt also destroy or prevent the mechanisms from functioning properly. Maintaining this equipment will mean another unreasonable requirement added to the constraints of a lobsterman’s day. If the release mechanism ceases to function or the rope tangles up, what then? This would mean costly loss of gear, lost day’s wages, and replacement costs that would sink a business already being threatened at every turn with out of control expenses. The type of bottom that Maine fishermen work varies widely from mud, rock piles, ledges, deep crevices, and other difficult bottom features. Expecting some kind of ropeless device to work in all these various conditions is unreasonable to anyone who has an inkling of what Maine lobstermen deal with. Gear will be caught down and lost because of these cumbersome devices. There will also be tremendous purchase cost to every fishermen who would be forced buy all the ropeless contraptions and the equipment needed onboard to operate them. When these are lost due to entangled gear, malfunction, or snags on rocky bottom, replacements must then be purchased. How will these costs be overcome? Certainly not with the lobster prices paid for our product which already are not keeping up with inflation of business expenses or the cost of living. Maine fishermen use different trap configurations in different depths of water. Inshore fishermen may fish singles or pairs, which would multiply the expense of this unreasonable ropeless gearing because more devices will be necessary. The proposal to force this gear on these inshore fishermen is especially unnecessary and cost prohibitive. When people are injured, maimed, or hauled overboard due to difficulties caused by entanglements from using ropeless gear, won’t we then be “saving the right whales” at the expense of human life and limb? Tracking right whales in Maine waters is proving what Maine fishermen have said all along. Right whales are not being harmed here and rarely even venture into our waters. Trials of the ropeless gear in Maine waters is also proving what lobstermen have said all along. IT WILL NOT WORK. NO ONE needs, wants or can afford the extra complication or expense of this unworkable, unnecessary gear. The call for its use is completely unwarranted and unreasonable. The idea should be scuttled immediately.