Moreover, the school and medium fishery long engaged in by this 

 region provides two fundamental things required under Magnu- 

 son's optimum yield requirements, and they are, a food source to 

 those engaged in that fishery, and finally, a great recreational op- 

 portunity for thousands of fishermen. 



Likewise, maximum sustainable yield under Magnuson must be 

 reviewed and considered in the context of social and economic 

 impact of closures and undue restrictions on this region or any 

 other fishery affected. More equitable structured allocations and 

 administration of bluefin allotments would result in a greater via- 

 bility for this region's depressed fishery. 



These same factors will come into play as soon as we get to the 

 point where we have more domestic regulations of yellowfin, 

 bigeye, albacore and the like. All highly migratory species will 

 wind up being affected in the same way, and therefore I respectful- 

 ly submit that that becomes very relevant. 



Likewise, the national standard requires implementation of plans 

 using the best scientific information available. User groups, as well 

 as peers, have reviewed documentation used by NMFS scientists 

 for years and have questioned the same and tried to make con- 

 structive recommendations to create a better data base and to 

 reach more sound conclusions. That is not criticism per se. What 

 that is, is involving yourself in the process. I think the Atlantic 

 Tuna Convention Act already, by providing for the best scientific 

 information available to be included, mandates these scientists and 

 those persons within NMFS considering this data to look at all of 

 the data, to look at the broadest possible base so that the greatest 

 and most equitable conclusion can be reached. 



Only then can we have effective international management as 

 well as national management. 



Standard four provides that conservation and management shall 

 not discriminate between residents of different States. Notwith- 

 standing this standard, I respectfully submit that NMFS would 

 agree that the results of their regulations over the last several 

 years have been quite discriminatory against our region. 



In particular I refer to the New York Bight, New York State, as 

 well as the State of New Jersey. An example would be a 600-ton 

 allotment this year on giants to the New England area, eight tons 

 to the State of New Jersey. That is extraordinary. 



It is a stark comparison, but it shows that the Magnuson stand- 

 ards are there to guide, but unfortunately, because of difficulty in 

 implementation and difficulty in monitoring, which sometimes is 

 the result of just a difficult and burdensome administrative process 

 that NMFS has to live with by way of less money, whatever, re- 

 sults in a very, very discriminatory practice. Not purposeful. It is 

 just the result. 



Likewise, the closures of the school bluefin and large school 

 medium fishery, from Cape May all the way out to the tip of New 

 York. We have always stated that that is the most essential of all 

 fisheries for us, yet year after year we have either had extremely 

 short closures or unpredictable seasons. 



It is essential that we rely and have that ability to have that 

 fishery. We could perhaps create buffers, buffer periods, rather, in 

 which NMFS is given the opportunity to catch up to the data 



