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The Council believed its allocation plan to be consistent with its earlier recommendations, the 

 goals and objectives of the fishery management plan, and the MFCMA. Specifically, the Council 

 intended to: 



1. Prevent preemption of shore-based processing activities; 



2. Ensure a large portion of the harvest guideline in 1993, for initial trawl "A" limited entry 

 permit holders; 



3. Foster stability of shore-based processing sector by providing replacement revenues for other 

 faltering fisheries; 



4. Help stabilize faltering rural coastal economies by providing fishing, processing and support 

 industry revenues to replace income declines in other industries; 



5. Achieve maximum net benefit to the nation by putting economic benefits directly into coastal 

 communities and distributing income impacts/benefits along traditional geographic paths; 



6. Spread fishery over time and area, reducing potential pulse fishery impacts on whiting, 

 salmon and rockfish stocks; 



7. Provide a similar or greater opportunity for traditional vessels as in 1992; 



8. Prevent effort shift to other species; 



9. Address management of the entire groundfish resource rather than piecemeal; 



10. Contribute to increased long-term product yield and employment opportunities by spreading 

 harvest over a longer season; and, 



11. Discourage additional capital investment in harvesting or processing facilities. 



Council interaction with the Department of Commerce respecting the Department's decision 

 to reject the Council's recommendation 



The Council sent a letter to Commerce Secretary Ronald Brown (attached) expressing various 

 concerns with the decision and the process. 



2. Did the Commerce Department share with the Council the grounds for its decision, and 

 was the Council provided with an opportunity to defend its recommendation or 

 otherwise appeal the Department's decision? 



The Commerce Department, in its letter to Chairman Anderson rejecting the Council's 

 recommendation (attached), stated "the socioeconomic data provided by the Council and the 

 public do not justify implementing the Council's recommendation guaranteeing permanently an 

 annual allocation to the shoreside processing sector substantially greater than its historical usage 

 at the expense of the competing at-sea processing sector." In the final rule, NMFS stated "the 

 Council did not demonstrate that the extreme reallocation to the shoreside processing sector at 

 the expense of the at-sea sector would provide sufficient social or economic net benefits to the 

 Nation to justify the proposal." The Department's final action occurred after the Council's April 

 meeting and on the day the whiting season began, which provided no opportunity for the Council 

 to address the issue. 



