Level of Enforcement 



Just as important in determining what en- 

 forcement capabilities will be necessary is 

 determination of the desired level of enforce- 

 ment. In other words, should enforcement 

 agencies mobilize to catch 50 percent of the 

 violators, 75 percent, or 100 percent — in 

 which case the costs could prove to be 

 astronomical. Without a quantified level of 

 enforcement, the allocation of enforcement 

 resources becomes a matter of intuition rather 

 than one of reasoned judgment. 



Currently, the Coast Guard simulation 

 model used for costing purposes indicates that 

 the agency assumes it can catch or deter ap- 

 proximately 95 percent of the 2,150 expected 

 annual violators within the budget appropria- 

 tion level requested. 24 That percentage, 

 however, does not appear to have been set as 

 an enforcement goal based on any policy deci- 

 sion as to what level of enforcement is desira- 

 ble. In addition, the percentage shown may be 

 much too high, depending on what types of 

 violations (over quota, use of prohibited gear, 

 fishing in closed areas) are being counted. A 

 middle-ground approach is probably required 

 and a specific definition of that approach 

 would be desirable. This should be followed 

 by regular assessment of changing enforce- 

 ment needs as well as the actual level of en- 

 forcement compared to the desired level. 

 Determination of the level of enforcement 

 could also be enhanced by asking Regional 

 Councils to make a projection of desired en- 

 forcement actions in their areas, possible com- 

 pliance inducements for fisheries in their 

 areas, and potential domestic-enforcement 

 plans. 



A major shortcoming of the Coast Guard's 

 analysis of the appropriate level of enforce- 

 ment is the lack of an adequate method for 

 assessing the benefits that can be expected 

 from various enforcement strategies. Since 

 significant resources may be required to oper- 

 ate an effective enforcement system, the Coast 

 Guard's current inability to systematically 

 estimate the expected value of enforcement is 

 a serious flaw. However, since the determina- 

 tion of appropriate enforcement strategies is 

 only one part of the broader process of fish- 

 eries management, what is probably needed is 

 a more general analytical system which could 

 provide quantitative estimates of the impacts 

 of alternative management techniques, includ- 

 ing — but not limited to — the enforcement 

 strategies, on the catch and profits of commer- 

 cial fishermen, the quantities and prices of fish 

 available to the domestic consumer, the state 

 of recreational fishing, and other measures of 

 the benefits of management. 



One such general analytical system is cur- 

 rently being developed for NOAA by the 

 Center for Technology Assessment and 

 Resource Policy at Stanford University. This 

 system is based on a generalized computer 

 systems model which can integrate the best 

 available scientific information about any par- 

 ticular fishery in order to assess the quantita- 

 tive impacts of various management tech- 

 niques on the fishery. Since even the initial ap- 

 proach to enforcement is expected to cost 

 nearly $100 million per year, benefits should 

 be clearly identified and quantified to the ex- 

 tent useful. Some of the benefits may include: 



. A future increase in stocks and yields due 

 to tighter controls to prevent overfishing. 



. Less pressure on stocks caught as bycatch 

 due to better controls on gear and areas 

 fished. 



. Less conflict among fishermen for certain 

 grounds and reduced gear conflict. 



27 



