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AEB are related to commercial Ashing — ports and harbors and airport expansions 

 and improvements are all aimed at providing infrastructure for fishing. 



The tiny village of Akutan is one of the oldest continuously settled villages in 

 Alaska and one of the busiest groundfish ports in Alaska. Only the small number 

 of processors keep it from being listed and nationally ranked. The local people, how- 

 ever, are not direct participants in Bering Sea fisheries. They lack the vessels nec- 

 essary to venture beyond the relatively sheltered waters near their village. For rea- 

 sons best known to the State of Alaska, these villagers were not allowed to partici- 

 pate in the Bering Sea CDQ fisheries. Only two AEB communities, False Pass and 

 Nelson Lagoon were allowed to participate directly in the pollock CDQ fishery. 

 These two communities are attempting to include Akutan in the benefits derived 

 from their participation. 



Sand Point, King Cove, False Pass and Nelson Lagoon are all sites that were cre- 

 ated to take advantage of commercial fishing opportunities. During the late 1880's 

 and through the 1970's smaller more remote villages were abandoned as the de- 

 pendence on fishing grew. Sanak, Unga, Belkofski, Squaw Harbor, Morzhovoi, Thin 

 Point, Wosnesenski and other village residents were forced to choose between leav- 

 ing their homes and having no chance for economic stability. 



The specter of these abandoned villages haunts the region. The entire social and 

 cultural fabric of the remaining Aleut population depends on the continued ability 

 to rely on the fisheries resources near their homes. 



To protect their interests as much as possible, borough residents have become ac- 

 tive participants in fisheries policy and regulatory forums. They have taken a keen 

 interest in both state and federal fisheries management issues including the Marine 

 Mammal Protection Act, the Magnuson Act, and the Endangered Species Act. 



It has been substantially harder to identify the critical issues that will arise dur- 

 ing the reauthorization of the Magnuson Act than it was for the MMPA and ESA. 

 Many of the frustrations our fishermen have stemmed from the way in which the 

 Secretary and NMFS have chosen to implement the act rather than flaws within 

 the act itself. These comments will focus on five issues: comprehensive rationaliza- 

 tion, bycatch reduction, critical habitat designations, "emergency order closure au- 

 thority," and the implementation of conflict of interest standards with recusal provi- 

 sions. 



COMPREHENSIVE RATIONALIZATION 



The current push for comprehensive rationalization schemes presumes that pri- 

 vatization of a public resource will result in a net economic benefit for the nation. 

 Although many AEB residents would receive IFQ's, the concept that fish can be 

 owned, traded, and even sold before they are caught has no parallel in Eastern 

 Aleut thought. Residents believe that promoting American corporate values into 

 fishery management will result in a focus on profits rather than the long-term 

 health of fishery resources which is critical to the survival of coastal communities. 



On a purely practical level, Aleutians East fishermen cannot visualize how TFQ 

 systems can be implemented without placing at least two observers on each fishing 

 vessel. Individual quotas require individual monitors. It is clear from this year's pol- 

 lock CDQ fisheries that single observers cannot accurately assess when a vessel 

 reaches its quota. Clearly, the cost of such observers can be borne more easily by 

 large vessels than by the smaller vessels operated by Eastern Aleutian fishermen. 



The IFQ systems discussed by the North Pacific Fishery Management Council 

 also provide incentive for establishing "black markets" for fish. This is particularly 

 dangerous for species like rock fish which can be easily overharvested. 



We could support limiting the number and kind of vessels that can participate in 

 federal fisheries, but we cannot support the cost both to the resource and the small 

 boat industry of an IFQ program. 



BYCATCH REDUCTION 



Much of the rhetoric surrounding the bycatch issue is really nothing more than 

 another allocation battle. Currently there is no magic gear that harvests target spe- 

 cies without any bycatch. The key to bycatch reduction appears to be individual ves- 

 sel accountability. In those voluntary pools that have operated in Alaska, bycatch 

 rates have been dramatically reduced. But, currently NMFS and the Council lack 

 the legal means to construct mandatory accountability programs. Since there are al- 

 location as well as conservation problems associated with bycatch. Aleutians East 

 Borough supports amending the Magnuson Act so that effective vessel incentive pro- 

 grams can be adopted as part of the Fishery Management Plans. 



