stock is accounted for by replacing deaths from that stock, 

 most of those deaths due to predation. A fishery can affect 

 predators in two ways. First, it removes fish resources 

 which would otherwise be available for predators. Second, it 

 can decrease the average standing stock of fish which may re- 

 duce the density of the fish in the water, affecting predators 

 that depend on concentrations of prey for efficiency in feed- 

 ing. 



Summary : This FMP is an example of the single species 

 approach to fisheries management. MSY was calculated for each 

 species separately, with OY set at MSY for all species except 

 depleted ones, for which OY was set at EY . Fishing at this 

 intensity is almost certainly overexploitation. No safety mar- 

 gin was included in the selection of OY levels , but would have 

 been an appropriate ecological consideration. 



No evaluation was made of fishery impact on carrying ca- 

 pacity for marine mammals or other predators , even though there 

 are indications that fur seal numbers have declined recently. 

 The implicit assumption that predator interactions are account- 

 ed for through estimates of natural mortality in MSY calcula- 

 tions is not valid. With the DYNUMES model information, at 

 least rough calculations of impacts on predators would have been 

 possible. Although the precise impacts of reduced food avail- 

 ability on predators are not predictable, trends can be antici- 

 pated . 



The Bering Sea groundfish draft FMP recognized the eco- 

 system issues addressed by the FCMA and MMPA, but did not apply 

 them to OY selection. 



Final Northern Anchovy Plan, 1978 



The Pacific Fishery Management Council developed a plan 

 for northern anchovy, implemented in 1978. OY was updated in 

 1979 and will continue to be revised annually in accordance 

 with the OY formula adopted in the plan. These comments concern 

 the final March 1978 version of the plan. 



Species : Northern Anchovy, Engraulis mordax 



Area : The central subpopulation of the northern anchovy 

 extends from 38°N latitude off Central California to 30°N 

 latitude off central Baja California and out to 200 miles. The 

 entire central subpopulation exceeds U.S. FCZ boundaries and 

 will eventually require cooperative management with Mexico. The 

 U.S. FCZ contains 70% of the stock. 



F-8 



