B-2 



MR. ROBINSON: Mr. Brewster? 



THE CHAIRMAN: Yes? 



MR. ROBINSON: My name is John Robinson, of the Center 

 for Law and Social Foiicy; and my comments are tnese: It 

 seems to me that any regime is really only as good and only 

 as real as the body that regulates it. And from the draft 

 EIS it's extremely difficult to know a great deal about the 

 regulatory body. We don't know about how much money it's 

 going to have, where the money is going to come from. We 

 don't know just what it's going to regulate or how it's go- 

 ing to regulate it. 



We know, for instance, from your discussion of last 

 Decemoer — the previous meeting — the language of Recom- 

 mentation IX-2 of the last Consultative Meeting doesn't 

 rule out some kind of meaningful regulation of the way it 

 can be fished, how much can be fished, or when it can be 

 fished. But we don't really know from the draft EIS what 

 you propose to be a minimal acceptable regulatory body. 



Secondly, in a related fashion, the draft EIS makes 

 a great deal -- and correctly so — out of the need for 

 scientific data collection; and yet we don't really know 

 from the draft EIS what the relationship between the 

 scientific data-collecting body and the regulatory body 

 will be. 



If, for instance, the regulatory body can control the 

 data-collecting body, there is of course the danger that 

 the data collected will be biased by the regulatory agency's 

 interests. If, however, the scientific body is totally in- 

 dependent of the regulatory body, there's a danger the data 

 will be collected and shot into a void. 



We'd also need to know, I think — since this regime 

 will be, basically, as far as we can tell, a fishery manage- 

 ment body — how this regime is going to differ from other 

 fishery management conventions — specifically, how it's 

 going to avoid the failures of these previous conventions. 



Thirdly — and I suppose of most concern in terms of 

 any success at all — is the problem of the less develop- 

 ed nations. As we understand the politics of this regime 

 and of the treaty itself, there's a real pressure that 

 exists on the part of the Group of 77 and the less develop- 

 ed nations as a whole. They're looking for — anxious 

 for — a piece of the action, and the Club of 13 that con- 

 trols Antarctica is quite reluctant to share any of the 

 produce out of whatever kind of living resource harvest- 

 ing goes on. 



