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Secretary Ronald H Brown 

 April 23, 1993 

 Page 2 



An entire industry, including thousands of employees and millions of dollars worth of capital investment, 

 waited for the federal review process to be completed The disapproval of the Council's action and the 

 substitution of a significantly different measure was announced on April 15, 1993, the day the whiting 

 season opened Businesses can't plan properly to jjarticipate in the fishery in this kind of environment 

 The Commerce Department had ample time to review the Council decision and, if necessary, ask the 

 Council to discuss it. again at its March meeting It is clear that a statutory lime limit on regulatory 

 amendments is needed. We will be proposing a change to the Act to require timely action on regulatory 

 amendments. 



Another problem is that the Conunerce decision on whiting aUocation is for 1993 only, while the Council's 

 measure was a long-term plan Annual allocation battles are time-consuming and hard on agency 

 personnel. Council members and the public We are confused about how to manage this fishery in 1994 

 and beyond. The final rule implementing your action states: "...limited entry should provide catcher 

 vessels with the harvesting opportunities that the Council wishes to protect for them beginning in 1994, 

 and it should not be necessary to restrict at-sea processing to achieve that same purpose " Does this mean 

 that you will not entertain a Council recommended allocation in 1994? If an allocation is considered for 

 1994, can it deviate from the percentage sharing in the 1993 final rule? There are a number of possible 

 outcomes of the limited access program Factory trawlers may find it cost-effective to buy licenses to 

 participate in the fishery. Or they may act as molherships The Council's analysis clearly indicated that 

 offshore processing capacity could easily preempt the shore-based sector, even if factory trawlers operate 

 exclusively as motherships Some level of protection will be necessary. We would appreciate your 

 thoughts about our options for 1994 and beyond 



In order to maintain the integrity of the regional council process, we need a clear message that you support 

 that process. Without this support, 1 believe the process will collapse I attended the Forest Conference 

 sponsored by President Ointo'n in Portland. One of the cornerstones of his message was that contentious 

 regional issues are best solved within the region The same is true of fishery management issues 



Mr Secretary, we hope that we can work together to maintain the integrity of the fishery management 

 process. We appreciate your leadership and cooperation in this endeavor. 



Sincerely, 



f!%^^ ^iLa^ji^<f^^'^~^ 



Philip Anderson 

 Chairman 



PA:LDS:inmp 



