B-9 



rirst or a^i , mteriiT: ar r sncements 



■•."e feel tnat the iimnediane introduction of some tcrTr. of 

 regulation of the fishery is essential. We notice tnat m 

 tne description of prooosed federal action on page 6, tne 

 draft EIS suggests two ways of dealing with harvesting in 

 the interim period. The first would oe to assume tnat " tecn- 

 nological and other limitations vy'ill ensure low harvesting 

 levels for the next several years" . The second would be to 

 negotiate, as a supplement to the international agreement, 

 very conservative catch limitations, with provisions for 

 phased expansion of that lim,it. . 



V^e fully endorse the statement on page 7 favoring the 

 latter option. Although the latter option would be far more 

 difficult to negotiate, it indeed reflects a more sensible 

 approach to the exploitation of a resource with which there 

 is very little international experience. We hope that this 

 sub-option will be adopted and we hope that it will be fully 

 negotiated before the Convention is signed. 



Secondly, the Development of conservation measures . 



We feel that the tools of conservation should be spelled 

 out in the Convention. We notice that the proposed federal 

 action would leave the development of specific conservation 

 measures to the decision-making body established under the 

 agreement . 



While we do not claim that sufficient information is 

 already available to establish catch limits and other specific 

 conservation measures on a long-term, definitive basis , we 

 do feel that the appropriate decision-making body — the 

 Commission, in the Government proposal -- should be explicity 

 authorized in the Convention to implement controls in the 

 following areas: 



Catch limits for each species, according to 



- age or size class 



- geographic area 



- season 



Total catch limits for each species 



Allowable gear 



Total effort or time spent in harvesting 



