146 



Addl-tionally, because of the poor condition of the fish 

 during this post spavn period, the average veight per fish 

 is approximately 205C less that later in the season. This 

 means that 20X more fish were taken to attain the same 

 total weight as the result of a huge volume pulse fishery. 



The Regional Council recommendation took all of the above 

 issues into consideration. 



6. Additional concerns involve the documented magnitude 

 of traditional species discarded by the at -sea fleet. 



Yellowtail Rockfish 1992 discard equals 14X of 1993 total 

 allowable catch. 



Widow Rockfish 1992 discard equals 5'/: of the 1993 total 

 allowable catch. 



Pacific Ocean Perch 1992 diecard equaie 22% of the 1993 

 incidental catch allowed the coastal fleet. 



The entire at-sea catch and discard of ground fish other 

 than Whiting for 1992 was 4, 765 MT, representing 77. of all 

 quota managed species. 10,500,633 lbs of non -utilized, 

 wasted resource by the factory trawl fleet. All product 

 that would, as a matter of course, be processed if it was 

 part of a shore-side whiting delivery. 



The loss of these economic benefits to the fishery and the further 

 unnecessary depletion of the resource are the direct responsibility 

 of the Department of Commerce and its unwillingness to consider the 

 documentation which supported the Regional Management Council's 

 recommendation. 



To conclude, the action taken by the Department of Commerce has 

 negatively impacted the biological and economic management of the 

 Pacific Whiting fishery, and has, contrary to legislation, ignored 

 the recommendations of the Regional Management Council. 



Very Truly Yours, 



^ 



Tom Libbjy 

 General Manager 



