144 



In spite of that, the 1993 allocation as recommended by the 

 Regional Management Council and the Regional director of HMFS was 

 contravened by the Department of Commerce on a strictly political 

 basis using the fact that the Shore-Side industry did not take its 

 full allocation in 1992 as partial justification for that decision. 



The Department of Commerce's politically motivated and arbitrary 

 decision to contravene the Regional Council's Recommendation for 

 the 1993 framework allocation plan, and to provide Shore-Side 

 participants with less that 30Z of the Council's proposed 

 allocation is pro:}ected to have long lasting negative effects on 

 the entire Groundfish Complex and on the economies of participating 

 coastal communities. Following are some specifics: 



1. The Regional Council's proposed framework plan if 

 applied to the last 17 years Total Allowable Catch would 

 have split the resource equally between on-shore and off- 

 shore participants, (see attachment). This confirms the 

 validity of the framework plan. 



2. Natural Resource Economists have projected that the 

 economic impact of the Department of Commerce's reduction 

 in Shore-Side Allocation from the proposed 105, OOO Metric 

 Tons to 30, OOOMT will be equivalent to the loss of more 

 than 1, SOO jobs equaling over 930,000,000.00 in personal 

 income. 



For Point Adams Packing Company Specifically, the 

 reduction amounts to the loss of 5 months of employment for 

 over 60 employees directly involved in Whiting processing. 

 A loss of 9750, OOO in personal income. 



3. Point Adams will also lose access to potential income 

 generated from Pacific Whiting on 15, OOOMT of product that 

 is not available because of the Shore-Side Allocation 

 Reduction. 



Continuation of the Department of Commerce's 

 contravention of Regional council recommendations will 

 ultimately result in closure of Shore-Side facilities that 

 were established based on anticipated continuity in 

 historical Regional Management philosophy. Councils' stated 

 goals and objectives, and the Department of Commerce's 

 obligation to act in accordance with the law as established 

 under the Fisheries Conversation and Management Act of 

 1976. 



4. The recommended Council allocation (by a vote of 9-2) 

 considers Pacific Whiting as an integral part of the 

 Groundfish Complex. Each decision on Pacific Whiting has a 

 ripple effect through out the rest of the complex and is 

 considered in the context of years of scientific data 

 resulting from studies of the dynamics of the entire 

 Groundfish Complex, as veil as other currently fully 

 subscribed fisheries. 



