160 



Amazingly, the pattern of boom and bust style fisheries precedes that of the pol- 

 lock fishery. In the North Pacific, many fish species have experienced periods of 

 high abundance, increased fishing pressure and subsequent decline, only to be re- 

 placed with another fish species deemed commercially important. In the 1950s, for- 

 eign fishers exploited herring, yellowfin sole and Pacific ocean perch to near col- 

 lapse. Pollock are yet another fish species that have become economically important 

 because of their high abundance. But, we may be in another downturn. The biomass 

 estimates for pollock reveal a declining trend over the past seven years, while com- 

 mercial fishery quotas for the species have remained the same and in recent years, 

 have increased. Simultaneously, species that depend on pollock as a prey source, 

 such as Steller sea lions, harbor seals and seabirds such as black-legged and red- 

 legged kittiwakes, common murres and thick billed murres are declining, showing 

 signs of an ecosystem out of sync. 



Over the past 30 years in the North Pacific, the catch composition of commercial 

 fish species has changed and fishery removals have increased concomitant to marine 

 mammal and seabird declines. We are concerned that NMFS is not addressing the 

 important issue ecosystem considerations. We recommend that the Magnuson Act 

 address the need to improve fisheries management to include multi-species model- 

 ing that addresses the existence of interspecific relationships in the marine environ- 

 ment. 



It is abundantly clear that an unhealthy ecosystem cannot support a sustainable 

 fishery. There are other fisheries in the United States that are currently suffering 

 the ecological and economic woes of poor stewardship. In the case of the New Eng- 

 land fisheries, the tragedy of the commons is clearly illustrated by the short-sighted 

 economic goals that prevailed the decisions of fisheries managers. History has al- 

 ready taught us that when left to a free for all, we will take more than can be natu- 

 rally replaced. Allowing increased unnatural removal of fish from an otherwise nat- 

 ural system will eventually offset the system. Underestimating the impacts of those 

 removals has long-term effects on the sustainability of that natural system. 



We propose that the Magnuson Act address the concept of maximum sustainable 

 yield (MSY) of fisheries from an ecological perspective. This would mean that the 

 single species are no longer to be managed in a vacuum and instead that the inter- 

 action of these species is considered when determining what level of removal is to 

 be permitted. Simply, we do not know what the MSY of many fish stocks are and 

 furthermore, we do not know at what level other species in the ecosystem interact 

 with the commercially important fish stocks. The widely accepted second-guessing 

 approach has not improved the economic yield — of fisheries.- -In attempting to — 

 find out how far we could go, we have pushed the concept of MSY too far. We must 

 include risk-averse types of management that are precautionary. The edict of the 

 precautionary approach is simple: if the impact of the activity is unknown, then err 

 on the side of conservation. 



THE REVOLVING DOOR OF THE NATIONAL MARINE FISHERIES SERVICE 



Conflicts of interest on the regional fisheries management councils is a belabored 

 term. But the conflicts in fisheries management is more pervasive than the regional 

 councils For example, the goal of the Department of Commerce is to improve fish- 

 eries exploitation for the betterment of the U.S. economy. In this vein, it is an ardu- 

 ous task for NMFS to have the role of ensuring the conservation of living marine 

 resources. Additionally, there is an increasing number of ex-federal and state fish- 

 eries scientists who shepherded the U.S. fishing industry through the domestication 

 process only later to turn to the fishing industry for employment. We view this as 

 a problem in that it only exemplifies the difficulty in removing industry influence 

 from science. 



The numerous loan guarantee programs that were authorized under the Merchant 

 Marine Act have effectively set up a symbiotic relationship between the industry 

 and NNFS. NMFS provides the funding for vessel construction and operation only 

 to have the fishing industry indebted to the agency, which in turn must maintain 

 fishing quotas so that vessels can continue operating in order that their loans can 

 be paid off. Currently, the overcapitalization of the U.S. fishing fleet in the North 

 Pacific alone has caused federally funded vessels to go bankrupt. And all the while, 

 NMFS has knowingly approved loan guarantees that allowed for excess capacity. 

 Subsidy programs to the U.S. fishing industry should be scrutinized with the U.S. 

 taxpayer in mind. 



In addition to subsidy programs, the U.S. fishing industry is the only extractor 

 of natural resources that does not pay to utilize the resource. And the costs of man- 

 agement are borne by the U.S. citizen. The fisheries of the united States are a com- 

 mon property resource which belong to everyone, or which belong to no one. It is 



