93 



Mr. Thomas Mari'ton 

 June 4, 1993 

 Page Two 



Management of fisheries within the three mile Unit is a state 

 responsibility. Abrogating this responsibility to the federal 

 government through the Council system would be a severe 

 infringement of the states right to manage their fisheries. 

 Species for which the Commission has drafted plans are found 

 primarily within 3 miles of the shore, and generally occur at 

 lesser levels in federal waters. 



Additionally, the Council system, as currently structured, 

 has proven to be cumbersome, time consuming, and often ineffective 

 in preventing the decline of marine species. According to a 1991 

 report by the National Marine Fisheries Service, 75 percent of 

 recreational and commercial finfish species in the northeast 

 Atlantic continue to be overfished, even with the Council system 

 in place. All but two of the species listed in the attached table 

 are covered under a Council adopted fishery management plan (either 

 Mid-Atlantic or New England Council) , yet they continue to be 

 harvested in excess of their capacity (it should be noted that all 

 but one of the plans were implemented in 1986 or earlier. Compare 

 the success of these federal plans to the success of the Atlantic 

 Striped Bass Plan that began to be enforced by the states only on© 

 year earlier) . At this point in time, and until the Council 

 systems begins operating more efficiently, fisheries management 

 programs have a better chance of being developed by the states 

 working in concert with each other as opposed to management by the 

 federal fishery management process. 



2. Mr. Schill raises a number of complaints about the 

 Commission and the current management process, would anyone like 

 to respond. 



The primary concern expressed in Mr. Schill 's testimony 

 regarding this legislation appears to be the Commission's 

 inadequate job of soliciting and receiving public input. Public 

 input into the development of fishery management plans is vital to 

 the success and acceptance of these plans and should be a part of 

 the planning process. 



The states, through the Commission, develop broad coastwide 

 fishery management plans which are intended to protect the 

 biological condition of the resources on a coastal basis. These 

 plans do not allocate resources among user groups or dictate 

 specific details of state implementation plans. Each state is 

 responsible for developing and implementing state-specific plans 

 and guidelines which conform to the coastwide plan. Many of the 

 coastal states have citizen advisory groups which provide input to 

 the state fishery management agency, which then should convey these 

 views to the Commission prior to, and during the development of, 



