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"Explicitly define bycatch and establish a national policy to minimize its neg- 

 ative impacts on fish populations and the marine ecosystem by reducing bycatch 

 and economic discards in all commercial fisheries to insignificant levels ap- 

 proaching zero; Require all fishery management plans to establish a program 

 for reducing bycatch of all gear within the plan's jurisdiction * * *" 



Alaska Marine Conservation Council Proposal to Implement Clean Fishing 



Although there is consensus both within and outside governments that bycatch 

 is a major problem, little has been done to minimize it because proposed incentives 

 and disincentives are complex, expensive, difficult to enforce, or disruptive to the 

 fisheries. We recognize that in these times of tight budgets and attempts to reduce 

 bureaucracy, mechanisms must be used that are simple, cost effective, easily en- 

 forceable, as unobtrusive as possible to current fishing operations. They must also 

 allow for individual choices and responsibility. 



History shows us that the U.S. fishing industry, is highly inventive and flexible 

 when there is an economic incentive or advantage to be exploited. Therefore the way 

 to promote the development and use of selective gear is simply to give priority of 

 harvest to selective gears and practices. Thus fishing operations would not be forced 

 to change, but the economic incentive of priority harvest would lead to rapid, vol- 

 untary change to cleaner fishing now and into the future. 



This is not a new idea and in fact was the most successful technique ever used 

 under the Magnuson Act. Priority harvest was the centerpiece of Magnuson Act 

 Americanization of the EEZ Alaskan waters. Each year it was determined how 

 much the American segment of the industry could utilized through the fishing year, 

 and that portion of the Total Allowable Catch (TAC) was reserved for the American 

 fishers to harvest. The remainder of the TAC was allocated to the other segments 

 of the industry. The rapidity with which the fishing industry responded and ex- 

 panded its TAC requirements astounded all observers. 



Somehow this most successful mechanism got lost in the shuffle and pressures of 

 ongoing fishery management. Today utilizing this technique to promote clean fish- 

 ing would require classification of fishing practices and gears into groups by relative 

 selectivity. Most of that data is already available from federal on-board observer 

 data. 



Determining the amount of TAC those selective segments could utilize projected 

 throughout the coming year would be a straightforward Council process. Reserva- 

 tion of the priority allocation of the TAC would reduce the level available for less 

 selective gears. Seasons for harvest would still be set using the same current Coun- 

 cil process. As switching to selective gears and practices continues, the proportion 

 available for nonselective gears will decrease and be eliminated. The goal of reduc- 

 ing bycatch and economic discard wastage can be accomplished by allowing individ- 

 uals and industry make these economic choices. There will be a real, ongoing incen- 

 tive for industry to develop and use further selective practices. 



Other management tools can also be used to help expedite this procedure and al- 

 leviate ongoing problems. These tools can and should include vessel incentive pro- 

 grams (VIPs) for vessels carrying 100 percent observer coverage, variable seasons, 

 closed fishing areas and overall increased observer coverage. (Conflicts of interests 

 within observer programs must be addressed to prevent trans-corporate or owner- 

 ship conflicts.) 



In summary, in order for the United States to meet our international commitment 

 to promote "clean fishing" we urge you amend the act to: 



1. Insert the following specific language from Agenda 21 in both the body and 

 purpose of the Act — "promote the development and use of selective gear and prac- 

 tices that minimize the waste of catch of target species and minimizes bycatch of 

 non-target species." 



2. Include the following language in National Standard Five: "Conservation and 

 management measures shall assign harvest priority to use of selective gear and 

 practices that minimize waste of catch of target species, minimizes bycatch of non- 

 target species and minimizes disruption to habitat." 



3. Establish conservation as the top priority of the Act, not solely efficiency or op- 

 timum yield and set a goal of eliminating economic discards in the Alaska EEZ. 



Finally, Some councils including our own are proceeding to limited access fish- 

 eries. We recommend any limited access systems which do not effectively promote 

 the reduction of bycatch and the elimination of economic discards be curtailed or 

 modified in order to fulfill our national goal of promoting clean fisheries. 



