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international harvest, they will forfeit an American industry for nothing 

 in return. The guy on the deck is willing to make some "shared 

 sacrifices" - if they are, in fact, "shared". Where will the U.S. be in 

 the future when our ability to harvest food fish from the offshore waters 

 has been reduced or eliminated? What benefits will come from the lost 

 jobs that will result? 



Continued Secretarial authority is strongly supported by the fourteen 

 commercial fishing associations who are involved with these species. We 

 believe that there is growing support cunong other groups. The American 

 Fisheries Society recently dropped all mention of reverting authority to 

 the Councils in their position statement, even though that was suggested 

 in early drafts. Further, in recent discussions among the Councils, 

 support for reverting authority to the Councils has failed to gain the 

 support of the New England Council and has been seriously questioned by 

 others because no mechanism for a fair and equitable voting process has 

 been suggested. The enviro-sportf ishing coalition supports a vote of all 

 sitting Council members so that they can take advantage of the fact that 

 there is almost a complete absence of any representation from HMS 

 commercial fisheries on the five east coast Councils. How can that 

 coalition work against retaining management authority in the hands of 

 professional fisheries managers where scientifically-based decision- 

 making should reign? 



The underlying issue relates to claims that constraints on Secretarial 

 authority are supposedly restricting management options unnecessarily. 

 As in the FACA case, we believe this is a deliberate attempt to reduce 

 the oversight and reasonable requirements for balancing costs and 

 benefits. We believe it is dishonest for certain special interest groups 

 to portray the Secretary of Commerce as a paper-tiger constrained by a 

 mandate that all U.S. fishermen be given a reasonable opportunity to 

 harvest a fair international allocation and once international programs 

 are established that NOAA must not unilaterally reduce U.S. fishermen's 

 quotas. 



BWFA believes that NOAA has not clearly made its case that this is a 

 significant problem which has conservation, as opposed to allocation. 

 Implications. In fact, BWFA believes that the record of action taken by 

 NOAA in the past two years clearly establishes the fact that the 

 Secretary has ample flexibility and, in all cases, has implemented 

 regulations that more than fulfill U.S. management obligations. The 

 Secretary has established seasonal and user group suballocations, a 

 minimum size larger than that recommended by ICCAT, trip limits, target 

 species thresholds for an allowed bycatch of bluefin, variable bag limits 

 by size, prohibited gears, experimental fisheries, mandatory permitting, 

 reporting and observer progreuns for fishermen and fish dealers, and other 

 measures all within the last two years. In particular, the swordfish 

 Total Allowable Catch (TAC), using a risk-averse model, produces U.S. 

 Quotas that are one-half to three-quarters of a million pounds lower than 

 the procedures likely used by other nations to set their quotas. 

 Management and conservation action on some highly migratory species has 

 also been taken without international programs being in place. These 

 actions have been implemented at a much more rapid pace than is possible 

 under the Council process. 



Industry believes that reasonable constraints (oversight) are necessary 

 to prevent the Secretary from eliminating U.S. commercial fisheries in 

 the face of enviro-sportf ish lobbying. We strongly believe that the 

 alliance between environmental and recreational groups that is making 

 this such a big issue, including their recommendation for reverting 

 authority to the Councils where enviro-recreational interests clearly 

 dominate, is a self-serving gambit to enhance the uncontrolled and poorly 

 monitored recreational fishery for these large pelagics. If Congress 

 reviews the status of most fish stocks under ICCAT jurisdiction and 

 compares their status relative to optimum MSY harvesting targets, they 

 will find that ICCAT' s record is better than our own Atlantic regional 

 Councils. The hypocrisy of the enviro-sportf ishing coalition is clearly 

 revealed by their intense criticism of the Councils as ineffective on the 

 one hand, but then they call for transferring HMS authority from the 

 Secretary to the Councils. The coalition's portrayal of ICCAT 's 

 swordfish management progreun in- particular is an egregious example of 

 unprofessional misinterpretation of the most recent stock assessment. 

 The environmental community must portray ICCAT as being ineffective in 

 order to enhance their fund-raising efforts. 



