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We are aware, as well, of the economic waste resulting from the massive discards 

 of target species in those and other fisheries. Although we are compelled to accept 

 the fact that there are forces at work in the marine ecosystem that are beyond the 

 reach of human intervention, there is much that can and should be done to ensure 

 that fishing gear and practices are employed in responsible ways. 



Americanization of the groundfish fisheries of the Bering Sea, although a laudable 

 goal and a great achievement, was not without risk, and did not come without cost. 

 For example, the Bering Sea crab pot sanctuary, long closed to foreign trawlers by 

 international agreement, was opened to American trawl vessels with the aim of 

 stimulating the growth of our groundfish fishing industry. Unfortunately, the pro- 

 tection of that most critical nursery ground was sacrificed. The American groundfish 

 fishermen took full advantage of the opportunity to increase their harvests, but at 

 the same time, non-selective trawl gear inflicted substantial damage on incidentally 

 taken crab resources. In this context, it should be noted that Russia has long main- 

 tained bottom trawl closures in critical habitats of the Sea of Okhotsk, and has been 

 rewarded with a rich abundance of valuable king crab. 



Thus, the ACC feels that, in the United States, the pendulum has swung too far 

 in the direction of development. Federal managers must no longer permit, much less 

 encourage, fishing activities that significantly contribute to the depletion of bycatch 

 species, many of which are in such poor condition that directed fishing is either pro- 

 hibited or severely restricted, as is the case for king crab. This is not primarily an 

 issue of allocation, as some in the would have the public, the Congress, and the Ad- 

 ministration believe. Rather, this is first and foremost a matter of conservation. 



Federal managers must also face up to the fact that certain fleets long nurtured 

 by our government, engage in fishing activities that are not only destructive of 

 bycatch species, but also wasteful of target species. For example, the use of very 

 large trawl nets, for which there are no mesh size restrictions, results in high vol- 

 ume discards of target, as well as non-target, species. In 1991, according to the Na- 

 tional Marine Fisheries Service, total pollock discards in the Bering Sea directed 

 fishery for that species were 245,400,640 pounds. Of that amount, large industrial 

 factory trawlers accounted for 85 percent — approximately 209,000,000 pounds. 

 These total discards were equivalent in weight to about six times the entire com- 

 mercial harvest of salmon in Washington State, or to the entire combined commer- 

 cial harvest of herring, halibut, and shellfish in Alaska, during 1990. 



Furthermore, it is reasonably estimated that, in bottom trawling operations, the 

 "unobserved" bycatch of crab is ten-to-fifteen times the bycatch found in the nets. 

 It is assumed that the mortality of crabs crushed beneath the non-capture parts of 

 the trawl gear is very high. That mortality likely exceeds the levels experienced in 

 the nets. 



Underwater camera observations of the operation of bottom trawl gear leads many 

 experienced fishermen, scientists, and other informed observers to conclude logically 

 that slow-moving bottom dwellers, such as crabs, are unable to evade trawl gear 

 moving at speeds of three-to-four knots. Gear damage to juvenile "pods" — as many 

 as 10,000-20,000 juveniles will mass together for predator protection — can have a 

 devastating impact. Trawl gear damage to king crab during the soft shell molting 

 season is also recognized to be severe. It is, therefore, extremely disturbing that the 

 federal government is failing to manage adequately for these impacts. Notably, the 

 crab industry has committed more funding to the study of these problems than has 

 the federal government. 



The effect of bottom trawling on the benthic environment is also believed to be 

 quite significant. Crab in the first instar stage of development find refuge from 

 predators by crawling into the subsurface layer of the seabed. As the ACC pointed 

 out in its 1989 congressional testimony on reauthorization of the Magnuson Act, bot- 

 tom trawling in crab nursery areas may have a very detrimental effect on crab sur- 

 vival rates. The damage is a matter of particular concern, where the large nets and 

 heavy doors and chains of industrial factory trawlers are used. 



It is easy to understand why habitat studies are particularly important. The 

 NOAA Outer Continental Shelf Environmental Assessment Program ("OCSEAP') 

 has yielded useful data on the sensitivity of crab nursery areas. OCSEAP considers 

 the North Aleutian shelf to be the primary habitat for king crab and is concerned 

 about bottom trawling impacts. The Chairman of the North Pacific Fishery Manage- 

 ment Council, in a letter to former President Bush concerning Lease Sale 92, also 

 acknowledged that the habitat in that area is critical to crab, and to halibut, as 

 well. The ACC finds it difficult to understand why federal fisheries management 

 does not adequately reflect the singular importance of that habitat. The ACC be- 

 lieves that the NOAA Undersea Research Program should attach a high priority to 

 habitat studies in this and other critical habitat areas. 



