137 



The Commerce Deparunent did not weigh this issue against the many 

 goals, objectives and criteria outlined in the Pacific Coast 

 Groundfish Management Plan, as the PFMC and it's advisory panels are 

 obligated to do. Apparently the Commerce Department listened only to 

 the intense lobbying effort of the American Factory Trawler 

 Association (AFTA). AFTA has been very successful in hiring ex-high 

 level MMFS officials to represent it's interests in Washington O.C. 



I do not believe the Commerce Department adequately explored the 

 impact of their decision on the entire coastal fishing fleet, 

 shore-based processors, or the coastal conuaunitiee of Washington, 

 Oregon and California. 



To illustrate this point, one of the issues the Magnuson Act requirea 

 the council to consider when allocating, is the impact of that 

 allocation on adjacent fisheries. While the council's supporting 

 documentation did not go into great detail on this issue there are 

 some numbers I would like to share with you. I have included two 

 tables, one generated by NMFS staff in Seattle which lists the catch 

 and discard of groundfish in the at-sea whiting fishery (i.e. factory 

 trawlers), and another generated by Oregon Dept. of Pish and Wildlife 

 (ODFW) reporting the catch of the shore-side whiting fleet in Oregon. 

 Both of these tables represent the 1992 fishery. All of the species 

 listed are important components of the traditional coastal groundfish 

 fishery. Discards by the at-sea fleet represent significant lost 

 harvest opportunities to other fishermen, processors and coastal 

 comraunities outside the whiting fishery. 



To demonstrate the magnitude of these lost harvest opportunities I've 



compared the discarded catch of a few of these species, and how that 



discarded number relates to the total allowable catch for that 

 species in 1993. 



* Yellowtail Rockfiah: The 1992 at-sea discard was 638.5 MT. 

 This figure represents 14% of the entire allowable catch of 

 4400 MT for 1993- 



* Widow Rockfish; The 1992 at-sea discard was 387 MT. This 

 figure represents 5% of the entire allowable catch of 7000 MT 

 for 1993. 



* Pacific Ocean perch: POP was severely over fished by foreign 

 fishing fleets during the 1960'8. This stock has been managed 

 under a stock rebuilding program since the early 1980 '«. Whil« 

 POP has a zero allowable catch, the council has allowed a 



