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Question 3. The Connerce D^artment's allocation plan negates almost all 

 of the concerns raised by the original allocation recannendations waAe by 

 the Pacific Fishery Managonent Council. Ihe Managanent Council had turned 

 in for the third consecutive year a managanaat plan based on goals, 

 philOEO£diies and objectives vihlch have been historically accepted by the 

 Department of Conmerce since 1985. In Mardi 1992 the Council's sunitary 

 noted for the third year in a row that a preference vrould be given to 

 catcher vessels delivering shoreside. The Council's sunxnary noted that a 

 shoreside preference approach best achieved its goals by: 



* Preventing preeoption of shore-based processing by an at-sea fleet 

 with the rapacity to harvest the total resource within a very short 

 time frame 



* Fostering the stability of shore-based processing by '^providing 

 replacanent revenues to coastal ccmnunities for other faltering 

 fisheries" 



* Stabilizing "faltering rural coastal economies by providing fishing, 

 processing and support industry revenues to replace inccroe declines 

 in other industries" 



* Achieving "maxinum net benefit to the nation by putting econcmic 

 benefits directly into coastal comiunities and distributing inccme 

 inpacts/benefits along traditional geographic paths" 



* Spreading the v^iting fishery over both tiros and area and "reducing 

 potential pulse fishery ls$>acts on v^iting, salmon and rockfisb 

 stocks" 



* Preventing the shift of di^laoed traditional harvesters of whiting 

 to other, often over-utilized, fisheries 



* Contributing to the increased long-term yield of whiting by 

 spreading the harvest over a longer season 



The Department of Connerce 's self-inposed allocation dooms u« to repeat 

 year-by-year allocation fights vihen the Council's plan called for a 

 framework allocation plan that could be used year after year and into 

 v^ich you simply plugged the numbers of each year's allowable quota and 

 allocated by formula. Worse, Caonerce's allocation plan allowed for a 

 "pulse" fishery in vAiich 100,000 metric tons were taken' in a 2 1/2 week 

 period. The ovenA^lniing majority of this catch will result this year in 

 inferior product at lower than the income that would have been gained if 

 the catch had been spread over a longer season of sane six to seven 

 months. We have reliable information that most of the factory trawlers' 

 production amounted to grade KH and A grade surimi which are the two 

 lowest quality standards obtainable. The fillets produced by the at-sea 

 fleet, v^en they could produce fillets, were no better than Grade B. 



The same low quidi^ fish were obtained h^ our boats fishing for shoreside 

 processors and both the catcher boats and the processors agreed that 



