Marine mammals were mentioned in the fishery management 

 plan, but only with respect to the direct marine mammal 

 impacts on fisheries, namely the consumption of fish already 

 caught in some kind of fishing gear but not yet removed 

 from the water, and the indirect impact of marine mammals 

 on fisheries, namely the high estimated fish consumption of 

 marine mammals in the Bering Sea. The corresponding po- 

 tential reduction in food available to marine mammals asso- 

 ciated with proposed OY levels was not considered in the 

 plan. Maintenance of optimum sustainable populations or 

 maximum net productivity of marine mammals were not addressed 

 in the plan. 



The plan acknowledged the different kinds of biologi- 

 cal data available for the Bering Sea with reference to 

 the DYNUMES model and the kind of information it contains; 

 however, no further use of that quantitative data was re- 

 flected in the plan. It would have been possible, as il- 

 lustrated with the northern anchovy example, to do rough 

 quantitative estimates of the changes in average fish stand- 

 ing stock anticipated with the selected OY levels, and a 

 corresponding change in total food production available to 

 predators. However, no such calculations were carried out, 

 nor were similar qualitative evaluations made. 



The management strategy in the Bering Sea Groundfish 

 Draft Plan seemed to be single species in essence even 

 though many species of fish were considered. MSY was cal- 

 culated separately for each species, with no allowance for 

 the effects of the intense fishing on other species in the 

 same ecosystem on the assumptions underlying the MSY cal- 

 culations. The multispecies nature of the report appeared 

 to be a matter of organizational convenience rather than 

 conceptual approach to the management of the overall fish- 

 ery . 



The intents of environmental legislation were recog- 

 nized in this fishery management plan in the stated objec- 

 tives. However, they were not reflected in the conservation 

 and management measures , namely the selection of OY levels . 



Squid Draft Plan 



The Mid-Atlantic Draft Squid Management Plan provided 

 an example of a plan dealing with only two species groups, 

 longfinned and shortfinned squid. For this plan, data both 



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