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wanted to preserve access to the fishery for historical 

 partiolpants. However, the Council's own analysis revealed that 

 neither goal would bo attained by a major reallocation of Pacific 

 whiting. 



AFTA's public comment on the proposed rule demonstrated that 

 82 percent of workforce! for the at-sea sector resides in the four 

 states comprising the Pacific Council region. Many of these 

 individuals live in coastal communities. For example, our segment 

 of the Industry employs 60 workers from Grays Harbor, Washington 

 where the unemployment rate is almost 20 percent. Another 160 

 residents of Newport, Coos Bay, and T^toria earn approximately $4.3 

 million annually working in the at-sea processing sector. In 

 addition to direct employment, the at-sea processing sector Is 

 serviced by numerous West Coast ports and shipyards, fuel 

 suppliers, financial Institutions and dozens of other fishing 

 industry support industries. The Council's analysis determined 

 that the benefits of reallocating to shoreside processors accrued 

 principally to one coastal community. Given this record, the goal 

 of promoting coastal community stability was best achieved by 

 maintaining an allocation reflecting historical levels of 

 participation. 



Requiring Pacific whiting to be landed ashore for processing 

 also was not justified on the basis of protecting historical 

 participants in the fishery. First, such an approach Ignores the 

 contribution of the at-sea prooeseing fleet in Americanizing the 

 resource. Second, limiting marketing opportunities for catcher 



