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BYCATCH AND WASTAGE 



The major management problem facing industry today is the bycatch and waste 

 issue. The term "bycatch" refers to other fish or crab that are caught while the gear 

 is targeting a specific species. There are two types of bycatch; economic discards and 

 prohibited species bycatch. 



Economic discards are fish which are legal to retain, but are the wrong species 

 mix or the wrong size for processing quickly. These fish are dumped over the side 

 and constitute a large amount of wastage. In the Bering Sea from January through 

 August 7th of this year there have been over 470 million pounds of groundfish (21.6 

 percent of all fish caught in the Bering Sea) dumped dead into the ocean. A large 

 majority of the fish that was dumped was caught by factory trawlers and consisted 

 of pollock, Pacific cod and rock sole. Much of this fish could and should have been 

 utilized. In the Pacific cod fishery alone, over 63 million meals were thrown away 

 because the cod taken was either the wrong size or caught in another trawl fishery. 

 We recommend that a provision be established in the Act which would require the 

 utilization of all species which are legal to retain and are covered under a manage- 

 ment plan. This would halt the massive amount of waste that occurs as a matter 

 of "good business" every year. 



The prohibited species bycatch, on the other hand, is required to be discarded. 

 The amount of halibut and crab that are thrown away each year is disconcerting, 

 especially when one realizes that the size of most of these animals is very small, 

 certainly too small for utilization. There has been a push by some members of in- 

 dustry and others to require the retention of the prohibited species when they are 

 taken incidentally. We oppose this for several reasons. The members of industry 

 that are pushing for retention of the prohibited species are the very ones who are 

 dumping the large amounts of fish that they could legally keep and process. They 

 just aren't as high value a species as halibut or crab. We strongly believe that prior 

 to allowing retention ofprohibited species, the needless wastage that is now occur- 

 ring must be stopped. The second primary reason we are opposed is that the caps 

 which are set as upper limits for incidentally caught prohibited species are too high.. 

 They are higher than they were for the foreign fleet and little is being done to force 

 the gear groups to bring their bycatch down to a more acceptable level. Until that 

 happens, we would oppose the retention of prohibited species. 



USER FEES AND ASSESSMENTS 



The members of the KLVOA strongly supported the requirement to carry observ- 

 ers and the implementation of user fees to pay for funding the research plan. In 

 looking at the future of fisheries management, with some form of limited access like- 

 ly to be implemented in the future, there has been a significant amount of discus- 

 sion in regards to user fees to pay for this type of program and for the management 

 of the resource. We believe that any user fee which may be established must clearly 

 be defined as to purpose, and money raised in a certain region must be designated 

 to be spent in that region. There should also be an upper limit as to what the 

 amount of fees could be. We are very concerned that a loosely defined, open ended 

 fee structure could financially cripple the small boat fleet in Alaska. We currently 

 have user fees which cover the research plan, various municipalities which tax the 

 fleet, raw fish tax paid by the inshore fleet, as well as the recent passage of a tax 

 for the offshore fleet. The profit margin is so narrow for many operations that a 

 large user fee could be devastating. 



STRENGTHEN THE COUNCIL SYSTEM 



In our opinion the Council system is very important and serves a need that can't 

 be duplicated. It is of concern to see the Commerce Department recently begin to 

 interpret the Secretary's authority in modifying Council action prior to approval. We 

 believe that it would be very detrimental for Congress to amend the Act to allow 

 for a centralized decision making authority in Washington D.C. While the Secretary 

 should and does have oversight authority, it is mandatory that the regional council 

 system stay not only in place, but be strengthened. A management system run from 

 Washington D.C. would make it almost impossible for the members of our group and 

 other small groups, as well as individual fishermen, to have their voice heard in the 

 decision making process. 



The Council system, by utilizing experienced, knowledgeable individuals, will un- 

 derstandably have instances where a Council member will vote on an issue for 

 which he or she is financially involved. We believe that the conflict of interest model 

 under which the Alaska Board of Fisheries operates is an ideal situation. Board 

 members are required to state for the public record whether they have a financial 



