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1991, the Bering Sea crab fisheries accounted for 51 percent of all fishing-related 

 fatalities in the waters off Alaska — 32 of the 63 lives that were lost. In the sablefish 

 and halibut fisheries off the coast of Alaska, lives are lost each year in a mad scram- 

 ble by thousands of vessels to harvest the available resource in a matter of hours 

 or a few days. The prevailing system of "fishing derbies" requires that, if fishermen 

 are to earn their livelihoods, they must do so regardless of severe weather and sea- 

 state conditions. Other fisheries, many of which are seriously overcapitalized, are 

 experiencing varying degrees of the same problem. 



Unfortunately, more humane systems of management are politically difficult to 

 devise, as they involve some element of allocation of finite, and sometimes declining, 

 resources. In the public debates and policy deliberations, safety issues tend to be 

 lost, as the focus all-too-often falls on purely economic considerations. The Act must 

 be amended to ensure that the priorities of our fisheries management system accord 

 with the fundamental values ofour society. The protection of human lite must come 

 first. 



The ACC is joined by other industry groups in proposing amendments that would 

 address overcapitalization in our fisheries, by providing in the Act that there should 

 be avoidance or reduction and elimination of excess fishing capacity. We feel that 

 the problem of overcapitalization is so serious and so widespread that it should be 

 addressed explicitly and decisively in the National Standards of the Act. There may 

 be proposals aimed at restricting the authority of fisheries managers to limit access. 

 However, the ACC helieves that the full array of limited entry options should be 

 preserved, including those of individual fishing quotas and license limitation 

 schemes. 



There are further ways in which the Act can and should be improved. Controversy 

 over allocation decisions cannot be avoided. However, industry and public accept- 

 ance can be strengthened. A means of achieving this, in the context of the fisheries 

 off the coast of Alaska, would be to provide for a higher-than-usual level of concur- 

 rence among the members of the North Pacific Fishery Management Council. Re- 

 quiring a two-thirds vote for allocations that would depart from historical shares in 

 a given fishery would certainly contribute to the confidence of the affected industry 

 and the interested public in the fairness of the management system. 



Fees are currently being addressed by some public interest organizations and in- 

 dustry groups solely in the context of limited entry. However, it must be pointed 

 out that any fish taken from the Exclusive Economic Zone by any fishermen rep- 

 resents a private gain for which a reasonable fee might well be charged. It must 

 also be recognized that, in a fishery successfully managed for sustainable utilization, 

 the public loses nothing when a private company or individual gains. Fisheries re- 

 sources are renewable, and fees should reflect that nothing is being taken from the 

 public that cannot soon be restored. In that regard, the ACC recommended to Con- 

 gresswoman Unsoeld that she ask the Congressional Research Service to prepare a 

 study of resource-related fees. We are delighted that the Congresswoman saw fit to 

 make the request. We hope that the study will contribute constructively to the de- 

 velopment of a fair and reasonable fee system. In any case, the ACC and others in 

 the Washington-based industry will argue strongly for dedication of fees from a par- 

 ticular region to the management of fish there, for authorization to use fees for the 

 administration of limited access programs, and for the continuation of federal fund- 

 ing from general revenues for general fisheries management. 



The ACC joins other Washington-based groups in proposing that a two-thirds vote 

 be required of a council for the delegation of management authority to any state or 

 other non-federal authority. This requirement would improve fairness in the system, 

 by reducing the likelihood of politically-motivated decisions to delegate authority in 

 a manner that would disadvantage non-residents of any particular state. 



Finally, the ACC and the other identified groups propose that the Congress place 

 concrete limits on allocations to local communities. So-called "community develop- 

 ment quotas" can serve legitimate social and economic purposes. However, in the 

 absence of explicit limitations, abuses can prove to be very costly to those who are 

 not the recipients of the special quotas. We must remember that our fisheries are, 

 for the most part, seriously overcapitalized. To provide special quotas to one group, 

 it is necessary to reduce the harvests of others. There must be a balance between 

 providing for development of truly disadvantaged local communities and allowing 

 the economic survival of the historical participants in the fisheries. It is interesting 

 that the earlier-referenced FAO paper prepared for the 1992 Cancun Conference 

 stated, "Further development of trie fisheries sector cannot be achieved without an 

 overall reduction of the [global] fleet size to a level where fishing effort, at the most, 

 matches the maximum sustainable yield of the resources being exploited or, better, 

 to an even lower level to ensure long-term profitability and sustainability of fish- 



