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end of directed foreign fishing would not have occurred until last year several years 

 after it actually ceased. I suppose this falls into the category of "be careful what 

 you wish for, it might come true." In any event a review of industry proposals of- 

 fered since 1976 suggests both industry and national interests have been well 

 served when Congress chose to ignore calls for radical change in the Act. Given the 

 great diversity in this nation's fisheries, we need maximum flexibility in our re- 

 gional management system and not a centralized federal bureaucracy. 



Having covered our general philosophy, I will now turn to some of the specific pro- 

 posals that have been offered for consideration during this year's reauthorization 

 process. 



A number of groups have suggested that the Act mandate the selection by Coun- 

 cils of "risk-averse" management strategies. The rationale is that since the data and 

 underlying science supporting fisheries management is subject to interpretation, 

 Councils should always err on the side of caution so as to avoid overfisning. We 

 agree that fishery science, especially stock assessments, have limitations and that 

 caution is warranted. In fact, this has long been the philosophy of the North Pacific 

 Council in setting harvest quotas. Therefore, we support the general idea of requir- 

 ing Councils to be more cautious depending on the quality of the available data. 

 However, we also believe that as part of any such amendment there should also be 

 a directive that the Councils require an accurate assessment of the amount of fish 

 being harvested in each particular fishery. It may sound odd, but there are still 

 some fisheries where the report of total catch is really a loose estimate. For in- 

 stance, it is likely that harvest estimates for our nation's biggest fishery, the pollock 

 fishery off Alaska, are being understated by the lack of accurate data from some 

 sectors. While onshore processors are required to weigh every pound of fish and re- 

 port the catch by species, other participants use a system of product recovery rates 

 (PRR) to estimate the harvest. PRRs are a reverse calculation where you estimate 

 the catch based upon the amount of finished product retained after processing. 

 There are numerous problems with this system. The actual product recovery rates 

 themselves vary greatly during the year depending upon the condition of the re- 

 source, and from company to company depending upon the skill, care and machinery 

 being utilized. To compound the problem, discarded catch is not accurately factored 

 into the equation. This is important since large amounts of fish can be discarded 

 both prior to and during processing operations. 



In addition, even small errors in PRR calculations can result in a gross 

 undercounting of harvest. For instance, the National Marine Fisheries Service used 

 a PRR of 18 percent for surimi for the at-sea sector at one time. This was later re- 

 vised to a more accurate 15 percent. To illustrate the effect of this 3 percent dif- 

 ference, let's say that the at-sea fleet reported total production of 150,000 tons of 

 surimi. At a recovery rate of 18 percent, this would mean that the fleet had caught 

 about 830,000 tons of fish. However, if the recovery rate were actually 15 percent, 

 that would mean that the true harvest had been 1,000,000 tons. And if, as some 

 calculate the actual recovery rate for the at-sea fleet is closer to 12 percent, the total 

 harvest would have been 1,250,000 tons of fish. It is our opinion that when we are 

 dealing with one of the most valuable fisheries in the nation we should not risk 

 using a system with such potentially huge margins of error. A uniform system re- 

 quiring weighing of catch is resource responsible and should be required from both 

 an allocative and management standpoint. 



The National Marine Fisheries Service has recently decided to require accurate 

 measurement (by weight or volume) of all fish caught by those participating in the 

 Community Development Quota fisheries of Alaska. We must ask why it is impor- 

 tant to have an accurate assessment for this 7Vn percent of the fishery, but not for 

 the other 92V2 percent? 



A second issue which Congress should confront is waste and bycatch. A number 

 of commercial fisheries across the nation are under attack because of high discards 

 of both target and non-target species. Bycatch and discard of non-target species is 

 a very thorny issue but should be- addressed if we are to stem the criticism our in- 

 dustry faces. Proposals were recently discussed by the North Pacific Council that 

 would require processors to retain non-target species bycatch, process it, and donate 

 it to charity. Although this plan has encountered resistance in some quarters, we 

 feel that it, or something like it, needs to be explored. The owners of these re- 

 sources, the American public, will not continue to tolerate high levels of waste of 

 valuable fish stocks. 



A related problem has to do with high discards of target species as well as ineffi- 

 cient processing. The public will not tolerate fisheries in which 10 percent, 20 per- 

 cent, or more of the target species catch is thrown overboard or wasted due to ineffi- 

 cient processing methods and high grading practices. We suggest that Congress at 

 least look at giving the Councils some type of directive in this area. A step was 



