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this major reallocation away from existing user groups. In 

 January, 1992 the agency's fishery management professionals 

 rejected the 1992 proposed whiting shoreslde preference scheme for 

 numerous reasons. The agency held that — 



• Increasing the preference accorded shoreslde processors 

 would exacerbate overcapitalization problems in the fishery, 



• market based solutions should form the basis of fisheries 

 allocation rules, and 



• the record did not support a dramatic reallocation. 



A copy of a memo issued by the NMFS Office of Fisheries 

 rejecting the Council's proposal is attached to AFTA's testimony. 

 We ask that it be Included in the hearing record. 



Concurrent with development of a 1992 whiting allocation, the 

 Korth Pacific Fishery Management Council was considering an equally 

 dramatic reallocation of pollock and cod away from the at-sea 

 processing sector. The North Pacific Council's action prompted two 

 Investigations by the Commerce Department's Office of the Inspector 

 General (IG). The IG determined that the North Pacific Council's 

 analysis was inadequate and urged former NOAA Under Secretary John 

 Knauss to reject the proposed shoreslde preference rule. The 

 Justice Department filed a public comment stating that the proposed 

 rule violated the National Standards contained In the Magnuson Act 

 and urged the Under Secretary to reject the rule. It also appears 

 that not one fishery management professional in NMFS supported the 

 major reallocations of pollock, cod or Pacific whiting. However, 



