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been frustrated by the tiine-consuining nature of the federal regulatory process. 

 Congress has tried a number of times to force the process to work in a more timely 

 fashion, but as yet writhout satisfactory results. It is unrealistic and unfair to expect 

 that the states shoxild be more closely held to a strict time standard than the 

 federal goverrunent is able to meet itself. 



One suggestion for dealing with this problem would be to allow the federal 

 government, in declaring a moratorium on fishing for a species in state waters, to 

 establish the actual effective date of the moratorium at some point in the future; but 

 not to exceed six months front the date of declaration of the moratorium. This 

 approach would have significant advantages. It would allow an additional 

 opportunity for states to meet internal procedural requirements. It would, at the 

 same time, establish a degree of certainty. The states would not be speculating about 

 threatened federal action — a decision will have been made that will take effect at 

 a time certain unless a state acts. The Committee should consider whether this 

 might be a more practical and effective approach than the language currently 

 contained in the bill. 



A second problem that should be anticipated is the special provision for 

 weakfish that is contained in the bill. The bill would allow the states only six 

 months to come into compliance with the Commission's current weakfish fishery 

 management plan. This is unwarranted and would create an unnecessary disparity in 

 the approach taken by the bill. One of the strengths of this bill, and in my view an 

 essential element, is the recognition of and reliance upon the prominence of the 

 states in determining how to approach conservation and management of coastal 

 fishery resources. This provision would single out a particular species above all 

 others for special treatment, without regard to the overall program for management 

 of coastal fisheries that the states, through the Commission, have under way. 

 There is no question that this species needs conservation. The Commission's program 

 for managing weakfish is constantly responding to the changing conservation needs of 



