ing back again to begin to address the issue from a more regional 

 perspective. 



At the same time actions by the Office of Sustainable Develop- 

 ment and Intergovernmental Affairs, which were properly aimed at 

 determining needs of effected communities, bypassed State govern- 

 ments and left them scrambling to catch up. 



We have some specific concerns with elements of the Federal pro- 

 gram. Again I'm echoing what others have said, but I think it 

 needs to oe repeated. 



One of our fundamental concerns is that to date the Federal pro- 

 gram has been announced and introduced in a piecemeal fashion, 

 and lacks clear overarching vision or objectives. The so-called 

 visioning process is barely underway. We do not have a clear pic- 

 ture of the impact of the restrictions on commercial fishermen and 

 their allies in the seafood industry. We do not even have good de- 

 mographic and economic baseline data on the industry from which 

 to measure impact or the success or failure of assistance programs 

 or mitigation measures, which are already underway. 



Lacking such information, we're nevertheless caught up by a cri- 

 sis atmosphere, and we're forging ahead with loan and grant pro- 

 grams. To what end? 



Mr. Collins has warned that "there are large imcertainties about 

 the future competitiveness of aquaculture, particularly regarding 

 the ability of U.S. growers to compete against foreign growers." He 

 urged "considerably more extensive market research" to identify 

 where additional effort in Northeastern aquaculture should be fo- 

 cused. Has such research been accomplished? No. But both the 

 Loan Guarantee Program and the Fishing Industry Grants Pro- 

 gram for the Northeast Fisheries Assistance Program are soliciting 

 proposals by fishermen for aquaculture ventures. 



Again, we caution against schemes aimed at shifting excess fish- 

 ing capacity from groundfish to export species. As was noted in the 

 East Coast Fisheries Federation's July newsletter, "the one frantic 

 message during the 'town meetings,' and other public hearings dur- 

 ing the spring was 'don't push the problem south.' The industiy 

 said it, the New England Council said it, the Mid-Atlantic Council 

 said it. It was said in New Beford, Point Judith, Riverhead, and 

 Cape May. It was said to Commerce Secretary Ron Brown by the 

 delegation led by Senator Pell." 



Nevertheless, both the Loan Guarantee Program and the Fishing 

 Industry Grants Program of the Northeast Fisheries Assistance 

 Program are soliciting proposals by fishermen and processors that 

 would have the effect of shifting capacity to underutilized or export 

 species. 



Furthermore, as we have previously indicated to NMFS, we're 

 concerned that the loans and grants to fishermen directly affected 

 by amendment 5 which support a shift of capacity to species not 

 covered by amendment 5, and this could result in subsidized fisher- 

 men having a competitive advantage over fishermen already har- 

 vesting such species. This would adversely affect the economics of 

 unsubsidized fishermen and place yet another sector of the indus- 

 try at risk. 



The issue of overcapitalization continues to require a direct and 

 square — needs to be addressed squarely. Again you referenced that 



