these quotas may be too high, not leaving enough left over 

 as forage for tuna and other species. 



In setting the OY for illex, a safety factor was incorp- 

 orated to allow for incomplete data, in line with conservation 

 principles (Holt and Talbot, 1978). 



U.S. mid-Atlantic squid catch in 1976 was 901 metric tons, 

 on the order of 17 of OY. U.S. fishery capacity was estimated 

 at 24,000 metric tons. There was considerable room in the plan 

 for increasing the ecological safety margin by reducing OY with- 

 out affecting domestic fisheries. 



The plan implied that because of their short life span, 

 squid which are not harvested are wasted. The implicit attitude 

 that nonconsumptive uses of a fishery are not valuable is con- 

 trary to the conservation definition in the FCMA, the intent 

 of ecological legislation, and good management practice. 



Summary : The potential impacts of an intense squid fishery 

 on squid prey and predators, including marine mammals, were rec- 

 ognized in the plan. No quantitative estimates of the impacts 

 of various harvesting levels on the ecosystem, e.g., food avail- 

 able to predators, were attempted, although rough calculations 

 along the lines of the anchovy example (discussed earlier in this 

 appendix) were possible given the data in the plan. For one 

 species OY was set below MSY to allow for deficiencies in data 

 used in MSY estimation, reflecting one aspect of the conserva- 

 tion intent of the FCMA. 



Draft Spiny Lobster Plan, 1978 



The Western Pacific Council is developing a plan for spiny 

 lobster. These comments apply to the draft version of May 1978, 



Species : Spiny lobster, Palinurus sp . 



Distribution : Depth range of 1 to 200 meters; commonly as- 

 sociated with coral reefs or rock bottom, around islands. 



Management objectives adopted in the plan were to : 



1. Maintain the reproductive potential of spiny lobster 

 stocks ; 



2. Permit expansion and continuation of economically via- 

 ble spiny lobster fisheries: 



F-20 



