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fishing operations shoald be suspended until a higher quality could be 

 obtained. 



The fish were of poor quality early in the season this year because they 

 were ccttprised mostly of "spent" fish or fish that were recently pawned 

 out. Spent fish give a lower recovery coefficient or the percentage of 

 salable meat extracted from the viiole fish. In addition the nuscle fiber 

 texture is such that a lower quality product results. In our opinion the 

 product realized by the factory trawler fleet will be some 35 to 45 

 percent lower in value than if the fish were harvested later vAien they 

 would be of much higher quality. 



Vfe have also heard that the bycatch of other species, primarily rockfiah, 

 this year in die short factory trawler season \ma high. These fish are 

 discarded at sea and although counted are wasted and the nation loses that 

 net economic benefit. Ihese bycatch weights are deducted frctn the quotas 

 available to the other coastal trawlers fishing mixed groundf ish species. 

 Ihis of course is incone lost to these boats and plants. Unfortunatelyr 

 NMFS is unable, a vAiole month after the at-sea fishery closed, to provide 

 us with the pertinait data relating to disceu:ds, waste and bycatch by the 

 factory trawler fleet. 



Finally it should be remembered that the Council has been concerned about 

 utilization of the catch and recognizes that the factory trawlers waste a 

 great deal o£ their targeted species, whiting, which can go overboard 

 unprocessed because it is too large, too small, or because they have been 

 crushed or otherwise damaged. NMFS has records that demonstrate that last 

 year in the at-sea operations the factory trawlers and mother ships wasted 

 over 10,000 metric tons of all ^)ecies caught. tUPS doeanents this waste 

 but either will not or cannot put an econanic value on it7 Every pound 

 landed by coasted trawlers fishing for coastal plants is utilized as 

 either primary or secondary product. 



ihe Department of Ccraoerce has literally told us in its rulings that it is 

 protecting a factory trawler fleet and mother ship operation vhich over- 

 capitsdized itself in its intended target area of operations, the Bering 

 Sea and the Gulf of AlaskaT ^e thesis that Comonerce is following is that 

 they most give this fleet, in only the third year of operation in the 

 whiting fishery, greater allocations because they are overcapitalized and 

 need this opportunity. Itie coastal processors and catcher boats, and 

 remember the catcher boats have in the main sane 10 to 15 years in this 

 whiting fishery, are not overcapitalized according to the Ccuncil's 

 recODomended plans. Cooxnerce's reasoning is bankrupt. Less than a third 

 of the factory trawler fleet is in this fishery and the income derived 

 from the vAiiting fishery for the factory trawlers and mother ships 

 involved is less t^an 10 percent of their annual income. Set coastal 

 trawlers and coastal plants are supposed to give up seme 30 to 70 percent 

 of their annual operations to accoranodate and subsidize the factory 

 trawler fleet. Ten thousand tons to the factory trawlers enploys than for 

 two days. Ten thousand tons landed in a coastal port provides jobs for a 

 month and superior incone distribution. Also rentenber, our plants and 

 boats are 100 percent toerlcan owned; they buy all of their gear, 



