85 



Fees & Taxes 



Any increase in fees or taxes upon the seafood harvesting industiy should be flat- 

 ly rejected. Currently, the industry has been promised some $30 million in financial 

 assistance to be invested in economic transition and diversification. 



When the seafood industry finds itself in this critical time of diminished cash 

 flows, significant indebtedness and the need for renewed investment, taxation or the 

 removal of financial resources is completely counter-productive. 



Tn fact, such action may well cause the exacerbation of the losses in gainful em- 

 ployment which have been caused in the past decade by federal action and other 

 factors. 



Conservation of marine resources appears to be rapidly ascending as a National 

 priority. Should it in fact become a priority, then the Departments ofCommerce and 

 the Interior should be prepared to allocate budgetary resources to advance that pri- 

 ority. 



Simply examining the issue of by-catch reveals the current economic waste being 

 suffered by harvesters at the direction of the government. By allowing them to re- 

 tain landed and expired fish, more needed economic resources could be retained 

 within the industry. 



Science & Technology 



The requirement of "best scientific information available" poses a daunting and 

 unnecessary challenge for the councils, the Secretary, and others. Subjective inter- 

 pretation of what is best will necessarily lead to conflict and contention. 



Clearly, harvesters must play a role in the development of accurate scientific in- 

 formation. While sea sampling, log books and observers presently provide them with 

 a role, it is limited. 



Recently announced Fishing Industry Grants point the way toward increased sup- 



Sort for harvester-based research. Similarly, it appears that Saltonstall/Kenneay 

 rrants are beginning to be redirected toward their original and necessary intent of 

 applied research. 



A reauthorized Magnuson Act must carry this trend further. First, funds should 

 be guaranteed for additional harvester-based research. Second, partnerships with 

 institutions of higher learning should be encouraged. Third, a requirement that "aU 

 available scientific information" be considered and should be instituted. Further, the 

 Council and/or National Marine Fisheries Service should be required to document 

 in writing the differences among presented information and reasons why any pre- 

 sented information was not included in the decision-making process. 



Last, those research projects which solely affect the seafood industry, such as ves- 

 sel buy-back programs, should be reserved for industry research and development. 

 Accordingly, funding such as that described above can be properly applied to aevelop 

 commercially practicable solutions. 



BIOLOGICAL RECOMMENDATIONS 



Habitat 



Much of the destruction or habitat loss has occurred within the fisheries which 

 are within our shore side or coastal habitat areas. Under the Atlantic Coastal Fish- 

 eries Cooperative Management Act, P.L. 103-206, a major objective is to direct the 

 responsibility of managing the Atlantic coastal fisheries and the states through the 

 Atlantic States Marine Fisheries Commission. Thus, the Atlantic Commission and 

 both the Secretaries of Commerce and Interior are mandated presently to improve 

 the process for mutual state implementation of necessary fishery management 

 measures, including the loss of vital habitat areas. P.L 103-206 provides a strong 

 means to manage both fisheries and habitat within the important inter-coastal state 

 areas and jurisdiction beyond territorial waters. Clearly, extending this Act to in- 

 clude all Commissions throughout the nation will bring about habitat protection 

 without encumbering the Magnuson Act. Additional funding, however, would be re- 

 quired. 



Overfishing and Recovery Plans 



The 602 guidelines should be maintained as informed guidelines established 

 under the present Magnuson language. Sec. 301(b), advisory guidelines. 



I support the councils' position that the Secretary can reject any recommendation 

 which does not conform to the Guidelines and the National Standards. 



I believe any overfished fishery must undergo a rebuilds approach; however, I do 

 not agree with a legislated rebuilding program (recovery program) that ignores the 

 social needs of the fishing public. Any rebuilding program must be designed to 

 maintain the maximum fishing infrastructure of a fishing community. More impor- 



