145 



It la already apparent that the reduced allocation has 

 redirected the Shore-Side Whiting fleet's efforts to the 

 other species of the Groundflsh Complex and as a result, 

 those species are requiring further control by the 

 council. Continuation of the 1993 politically motivated 

 allocation scheme will put the other species of the complex 

 under further stress from a fleet that was developed to 

 harvest the volumes available in the Pacific Whiting 

 resource. These Issues were all considered as part 

 of the Council's recommendation and were all ignored by the 

 Department of Commerce in its contravention of the Regional 

 Council process. 



5. Taking of 70% of the Total Allowable Catch of any 

 resource in a pulse fishery as happened this year in 

 Pacific Whiting is at best an atrocity. It is obvious that 

 those who made the final decision had no idea what the 

 effect would be on the resource or the economy. 



a. lOO, OOOMT were taken by the factory trawlers in a 

 22 day period providing less than a month's 

 employment for their crews. The same volume 



of fish would have provided Shore-Side employment of 

 seven months. 



b. 70y. of the Total Allowable Catch was taken 

 immediately post spawn, when experience shows that 

 fish are soft fleshed, higher in moisture content, 

 and of a lower per unit average weight than at any 

 other time in their life cycle. Because of this, 

 processing recoveries are at their seasonal low 

 requiring as much as 25% more raw product to produce 

 the same number of pounds of finished product. 



For example, the factory trawlers were allowed by the 

 Department of Commerce, against the recommendation of the 

 Regional Management Council, to take over 70% of the Total 

 Allowable Catch at the worst possible time for the 

 resource. For purposes of comparison let's assume that 

 lOOX of the factory trawler effort was directed to surimi 

 production. Recovery reports from the factory trawler 

 fleet indicate that 12% was the best attainable recovery. 

 That recovery was confirmed by shore plant processing 

 during the same time period. Additionally, it is 

 documented fact that later season recovery on surimi 

 production ie, on the low end 15%. It follows then that the 

 maximum finished pounds of surimi that could have been 

 produced by the factory trawlers would approximate 

 12, OOOMT. while, had the product been processed over an 

 extended time frame by Shore-Side participants the same 

 lOO, OOOMT of the resource would have produced an 

 approximate 15, OOOMT of finished product. That equates to 

 6, 6ld, OOO additional finished pounds of marketable product. 



