49 



Bycatch reduction, much of the rhetoric surrounding bycatch is 

 actually the roar of allocation battles between gear groups. Cur- 

 rently there is no magic gear that harvests target species without 

 bycatch. 



Through the end, two things are clear. One key to bycatch reduc- 

 tion appears to be individual vessel accountability, and Chris spoke 

 to that topic. In those voluntary pools that have operated in Alas- 

 ka, bycatch rates have been dramatically reduced. NMFS and the 

 council should be given the legal means to construct mandatory ac- 

 countability programs. 



The other key is gear research, both to reduce bycatch and to 

 make lost gear easier to retrieve and remove. 



The other thing that we would like to see NMFS get some direc- 

 tion on is releasing a PIN number, it is personal identification 

 numbers for vessels, and having those posted with their bycatch 

 rates on the electronic bulletin board. There is nothing like peer 

 pressure to get a dirty boat to clean up its act. 



There has been a lot of discussion about giving the councils the 

 authority to designate critical habitat. Although Aleutians East 

 shares the growing national concern regarding the effect of habitat 

 loss and habitat degradation have on tne marine environment, we 

 do not believe that the councils should be given a role in designat- 

 ing critical habitat or actively participating in the permitting proc- 

 ess for construction and other projects. The councils do not have 

 the staff, the expertise or the time to devote to such a critical task. 



We strongly support developing legislation that strengthens 

 NMFS' role in overseeing permits for projects that have potential 

 ill effects for the marine environment, and we strongly support im- 

 proving the Clean Water Act to clean up our Nation's watersheds 

 and oceans. 



Emergency order closure authority, one of the frustrations we 

 have with timeliness in regulatory areas is with the regional direc- 

 tor's ability to have a 24-hour closure. Right now it is required that 

 such closures be published in the Federal Register. We understand 

 the concerns about due process, but we believe that if under an 

 FMP the regional director is given the authority to have emergency 

 closures, we can get faster response time and not go over quotas. 



Conflicts of interest, we agree with the comments that Ms. 

 Blackburn made. It is a difficult issue to address. By their very na- 

 ture, the councils are composed of people who have some kind of 

 interest in the fisheries conducted in the U.S. EEZ. We can't under- 

 stand why anyone with no interest would subject themselves to the 

 meetings the council has or how they can make reasonable deci- 

 sions. We do not believe that scientists or fish managers are free 

 from biases or conflicts, either. 



There is one kind of conflict of interest that is measurable, and 

 that is a financial conflict of interest. We have included some lan- 

 guage in our testimony that deals with that. We do not believe that 

 financial interest is necessarily a prerequisite to recusal, but in 

 some cases where there are very few people involved in the fish- 

 eries and the direct benefit from an action taken by the council 

 would accrue to a member and not to a large group of people, we 

 believe that council member should recuse himself or herself from 

 participation. 



