159 



lion pounds of fish. The composition of the discards was: Pacific cod, pollock, floun- 

 ders, rock sole, and other species. 



This fishery is conducted during the spawning period for rock sole, and the target 

 is females with roe or eggs. Because this product fetches a high market price, the 

 fishery is economically important. But the question is, is this type of fishery sustain- 

 able? In actuality, we know little about the impacts of targeting on spawning aggre- 

 ? Rations. We do know that it is much easier to catch the fish because of their grouped 

 brmation during spawning. But what of the impacts on the population? And what 

 of the impact of the other species which are considered bycatch and are subse- 

 quently discarded? And what of the impact on the benthic environment? Because 

 there are no scientific answers to these questions, we give the benefit of the doubt 

 to the lucrative fishery. NMFS justifies its response by explaining that, since we 

 cannot prove that this fishery impacts the rock sole population or other species that 

 are caught, we have no reason to disallow the fishery. 



Yet, it can be argued that the foregone opportunity of other fishers who are 

 targeting Pacific cod or pollock is in fact worthy of economic consideration. And fur- 

 thermore, disrupting the benthos and the productivity of the ecosystem may cause 

 irreparable damage to the health of the rock sole fisheries and other marine species 

 that are interdependent in this food web. 



We propose that fisheries be conducted in a more sustainable and selective man- 

 ner. Gear selectivity is an area where numerous wasteful fisheries could be elimi- 

 nated simply by allowing cleaner gear to prosecute those fisheries. Gear technology 

 has gone through few improvements because NMFS has not moved forward with re- 

 search to experiment with gear types that can target specific fish while minimizing 

 the bycatch of other marine species. There are numerous gear technicians that are 

 developing "better mouse traps" for catching the desired fish of marketable size, but 

 these innovative people are making little neadway because of the agency's reluc- 

 tance to promote clean fishing. And as NMFS stands idly by, fishing efficiency has 

 improved in the forms of: increased catching capacity, more powerful engines to 

 haul in gear, larger refrigeration units and huge vessels capable of sailing to distant 

 waters in search of exploitable fish stocks. We now have a distant water fishing fleet 

 in the North Pacific that has emulated the foreign fleets that this nation once 

 loathed. And the unethical destruction and waste continues. 



We are concerned that economic efficiency has outweighed environmental consid- 

 erations in improving the way in which fisheries develop. Fishers that use different 

 gear types and compete for the same target species need not compete against the 

 same quota. Instead, preferential allocation should be the reward of clean fishing 

 practices. Specifically, we recommend that the Act be amended to provide broader 

 authority to manage bycatch problems through fishery management plans (FMPs). 

 The Act should contain a directive to reduce the problems caused by bycatch and 

 provide the tools to reach that goal. Additionally, incentives must be created for con- 

 servation engineering so that low-impact types of fishing gear can be developed. 



We are aware that some sectors of the fishing industry are attempting to oppose 

 gear selectivity and instead move forward with chat is termed "full utilization." This 

 is not a solution to the bycatch and discard problem. In fact, full utilization actually 

 legitimizes bycatch and does nothing to address the issue of lessening the amount 

 of those marine species not intended to be caught. 



ECOSYSTEMS AT RISK 



Another issue that is receiving increased attention is the declining numbers of 

 marine mammals, seabirds and fish species that are part of the North Pacific eco- 

 system. Probably of greatest concern is the fact that these species now compete with 

 the commercial fishing industry in their pursuit of prey. Most notably, is the impor- 

 tant role of walleye pollock in the North Pacific ecosystem. It is known that pollock 

 constitute the largest biomass in the Bering Sea, and are critical to the survival of 

 numerous marine species that interact within that marine ecosystem. However, the 

 commercial importance of pollock has outweighed its ecological importance in the 

 food web. Pollock is a fish that is shared by nations around the North Pacific. Pol- 

 lock is caught during all phases of its life cycle. And it is particularly favored during 

 the roe season. It is fished on both the western and eastern sides of the Bering Sea, 

 and until recently, it was fished in the international waters of the "Donut Hole." 



The economic importance of the pollock fishery is fairly recent. It wasn't until the 

 late 1970s that pollock was the fish of choice to use for surimi paste, fish sticks and 

 fillets. And it wasn't until the late 1980s that the U.S. fishing industry learned how 

 to metamorphose this otherwise "trash" fish into a marketable product. Now walleye 

 pollock boasts the status of the largest single-species fishery in the world. 



