jeopardize an endangered species or its habitat. There- 

 fore, it might have been more appropriate for the council 

 to demonstrate that a lack of adverse impact on the peli- 

 can, or at least an acceptably low risk of adverse impact 

 on pelican populations, would be associated with the se- 

 lected OY formula. 



The Northern Anchovy Plan has dealt with the issues of 

 ecological relationships of the target species, even if 

 only in a qualitative manner. Therefore, the Northern 

 Anchovy Plan does illustrate a beginning of ecosystem level 

 as contrasted to single species fishery management. The OY 

 formula selected in the plan would result in harvesting 

 levels considerably lower than MSY levels , on the basis of 

 ecological considerations including the role of. anchovies 

 as forage fish. 



Bering Sea Groundfish Draft Plan 



In contrast to the Northern Anchovy Plan, the Bering 

 Sea Groundfish Draft Plan covered many species . Like the 

 Anchovy Plan, however, it dealt with an area in which there 

 are abundant mammal and bird populations and on which con- 

 siderable ecosystem level data are available. 



In the Bering Sea Groundfish Plan, the OY levels select- 

 ed were essentially the same as MSY, except for depleted 

 stocks where OYs were set at EY levels. For depleted stocks 

 no recovery would be anticipated except through immigration. 

 It seems apparent that the selected OY values represent very 

 intense fishing on the stocks of the Bering Sea. 



Because the domestic fishery is such a small part of 

 the total fishery in the Bering Sea, estimated at most on 

 the order of \°L of the total harvest, there would have been 

 room to reduce OY levels without adversely affecting the 

 domestic fishing industry. One possible motivation for re- 

 ducing OY levels from MSY levels could have been the ecolog- 

 ical consideration of reducing the considerable risk of ad- 

 verse impacts on the groundfish and the marine ecosystem 

 from such intensive fishing. 



Another reasonable potential ecological consideration 

 not even mentioned in the plan is the possible recent reduc- 

 tion in northern fur seal populations which may have been 

 associated with the intense groundfish harvesting of the 

 1970s in the Bering Sea (U.S. Department of Commerce, 1979). 



37 ■ 



