77 



Chairman Wydcn, thank you for this opportunity to provide written testimony for this hearing 

 of the Committee on Small Business regarding the impact of the Department of Commerce's 

 decision allocating Pacific whiting catch levels for all fishing vessels. This written statement 

 responds to four questions in your letter of May 20, 1993, to Mr. Larry Six. In addition to this 

 written statement, the Council will provide oral testimony at the hearing in Newport, Oregon on 

 June 4, 1993. 



1. How did the Council reach its recommendation on whiting allocation? 



Pre-1993 The Council began its discussions of whiting allocation in July 1990, when it 

 considered management measures for 1991. At that time, the joint venture fishery was still in 

 operation and the Council anticipated an allocation between competing joint venture interests. 

 By September 1990, it was apparent the entire whiting harvest would be harvested and processed 

 by American companies for the first time, and the Council announced its intention to allocate the 

 resource between offshore and shoreside fishermen. In its newsletter after the September 

 meeting, the Council listed how it might achieve this harvest sharing: direct allocation, delayed 

 opening dates, trip limits and trip frequency limits, area closures and limitation on the codend 

 size or capacity. At its November meeting, the Council made a tentative decision to limit the 

 amount of whiting that could be processed at sea during 1991 (192,000 mt of the 228,000 mt 

 quota). The remaining 36,000 mt would be for shoreside processing, with the provision that if 

 the full 36,000 mt was not used, any remainder would be made available for offshore use. An 

 analysis was prepared, which the Council reviewed in March 1991. After reviewing the analysis 

 and public testimony, the Council approved a proposal that combined several of the alternatives 

 considered in the analysis. The adopted measures allocated 104,000 mt to catcher-processors 

 and 88,000 mt to vessels that catch but do not process. The remaining 36,000 mt was to be held 

 in reserve and released as necessary with preference for vessels that delivered to shore-based 

 processors. The NMFS approved this recommendation on August 28, 1991. The catcher- 

 processor fishery was immediately closed because its quota had been reached. 



For the 1992 whiting fishery, the Council began deliberations in September 1991, proposing a 

 multi-year, three tier priority system. The tentative proposal would give highest priority to 

 vessels that catch, but do not process, whiting and would limit at-sea processing as shore-based 

 processing expanded. Catcher-processors would be allowed to catch or process whiting, but 

 would not be allowed to do both. In November, the Council revised its recommendation, opting 

 for a one-year allocation of the 208,800 mt harvest limit. The recommendation would initially 

 allocate 80,000 mt of whiting to vessels that deliver to shore-based processors and place a limit 

 of 98,800 mt on offshore processing. No vessel would be allowed to both catch and process 

 whiting, so catcher-processors would have to choose which type of operation they would 

 participate in. The remaining 30,000 was to be held in reserve with shoreside priority. In 

 January 1992, NMFS disapproved the Council's recommendation. The Council expanded its 

 analysis and, at its March meeting, recommended an allocation plan for implementation under 

 the Commerce Department's emergency authority. The proposal, which NMFS approved and 

 implemented April 13, placed an initial limit of 98,800 mt on at-sea processing and allocated 

 80,000 mt for delivery to shore-based processors. The remaining 30,000 mt was held in reserve 

 for priority use by vessels delivering to shore. The Council also recommended that not more 

 than 50 percent of either allocation be taken before June 1, but that portion was disapproved. 



1 



