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ing the state's response and should be treated as its point of contact we continued 

 toleam of decisions and developments after the fact. Two examples: 



We learned of the availability of loans under the Northeast Fisheries Assistance 

 Program (NFAP) from Connecticut. When I called NMFS for information and loan 

 applications I was informed that I could get them from our Fishing Families Assist- 

 ance Center (FFAC). I protested that we did not have one, only to be told that we 

 did and that the coordinator had recently been named. This was news to me. 



Despite the fact that we had made repeated requests to review and conament on 

 the forthcoming Northeastern Fishing Industry Grants (NFIG) Program and had re- 

 ceived a bootleg copy of the prepubGcation draft of the announcement we did not 

 learn of its publication from NMFS. Again, we learned of it from a third party. We 

 did not receive the formal mailing from NMFS because we stUl were not on their 

 mailing list three months, with several reminders in the interim, after we informed 

 program managers that we were the state's point of contact on the Conmiercial 

 Fisheries Initiative. 



These are perhaps petty examples, but their occurrence, combined with other inci- 

 dents, contribute to an impression that the state is not considered a full partner in 

 the response. 



CONCERNS WITH SPECIFIC ELEMENTS OF THE FEDERAL PROGRAM 



Lack of Vision, Objectives & Baseline Information 



Fundamentally, our concern with the federal program is that to date it has been 

 announced and introduced in a piecemeal fashion and lacks a clear overarching vi- 

 sion or objectives. The so-called "visioning process" is barely underway. We do not 

 have a clear picture of the impact of the restrictions on commercial fishermen and 

 their allies in the seafood industry. We do not even have a good demographic and 

 economic baseline on the industry from which to measure impact or the success or 

 failure of assistance programs or mitigation measures. The requirement for such 

 comprehensive information was the first short term need identified by Charles Col- 

 lins in his paper "Beyond Denial," published last March. An attempt to develop a 

 regional information base was abandoned; we have commissioned one for Rhode Is- 

 land as part of our strategic assessment. However, it will be of limited use beyond 

 our borders unless all parties in the region can come to an agreement on common 

 terms and definitions associated with the industry. What is a "commercial fisher- 

 raan"? How far on shore should we look when assessing impact? 



Unguided Emphasis on Aquaculture 



Nevertheless, caught up in the momentum generated by a crisis atmosphere we 

 are forging ahead with loan and grant programs. To what end? Mr. Collins has writ- 

 ten that "there are large uncertainties about the future competitiveness of aqua- 

 culture, particularly regarding the ability of U.S. growers to compete against foreign 

 growers. In March he urged considerably more extensive maricet research" to iden- 

 tify where additional effort in northeastern aquaculture should be focused. Has such 

 research been accomplished? No. But both the loan guarantee program and the fish- 

 ing industry grants program of the Northeast Fisheries Assistance Program are so- 

 liciting proposals by fishermen for aquaculture ventures. 



Counterproductive Emphasis on "Underutilized Species" 



Again, we caution against schemes aimed at shifting excess fishing capacity from 

 groundiish 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 during the spring was 'don't push the problem south. The industry 

 said it, the New England Council said it, the Mid-Atlantic Council said it. It was 

 said in New Bedford, Point Judith, Riverhead, and Cape May. It was said to Com- 

 merce 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 which would have the effect of shifting capacity to 

 underutilized species. Furthermore, as we have previously indicated to NMFS, we 

 are concerned that loans and grants to fishermen directly affected by Amendrnent 

 5 which support a shift of capacity to species not covered by Amenoment 5 could 

 result in subsidized fishermen having a competitive advantage over fishermen al- 

 ready harvesting such species. This would adversely affect the economic of 

 unsubsidized fishermen and place yet another sector of the industry at risk. 



Need for Focus on Exit Strategies 



It is almost universally accepted the that the northwest and mid-Atlantic ground- 

 fish fisheries are in crisis because of overfishing (at least in part) and that the 



