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The need to have a rational business plan by all participants 

 in the fishing industry was another reason for the allocation plan 

 as originally requested by the Council. After hearing numerous 

 people testifying that it is nearly impossible to effectively run 

 a business without some knowledge of how the fishery is to be run 

 from one year to the next, was another reason for a long term plan 

 and the inclusion of the abundance driven formula. This formula 

 was modeled after the plan used for allocation coastal Coho stocks 

 between the sport and commercial entities and has proved workable 

 for many years . 



It was the element of fairness that was quoted as the rational 

 for the allocation rule by the Commerce Department. However, their 

 allocation scheme dictated that the factorship fleet suffer only 

 a 26% cutback from the 1992 harvest while the shoreside group were 

 cutback nearly 47%. Again, the Commerce Department changed a plan 

 that would have set a three year system to allocate fish based upon 

 an abundance driven formula and chose to place our industry back 

 onto a one year system. The formula based plan was documented to 

 show a split that, based on the past 17 years quota, would have 

 split the quota nearly 50/50. 



All of the original plan was thrown out by the Commerce 

 Department as they only looked (was guided) to how the season 

 compared to last year and not how the plan was to have worked over 

 time. They eliminated: (1) any long term solution of how to 

 allocate, (2) a better method of harvesting for less by-catch and 

 better yields over a longer season and (3) a solution of how to 

 spread fishing efforts by the small coastal vessels off to already 

 exploited, crowded fisheries and onto the largest fishery bio-mass 

 available off our coasts. 



Losing the balance of what would have been a rational, orderly 

 fishery, over the entire fishery bio-mass, has caused buyers of our 

 product to question whether we really have the ability to cover 

 their expected orders, hampering our ability to grow and prosper 

 with this fishery. Even worse, the large volume of very poor 

 quality Whiting products produced early on in this season by the 

 factorship fleet may have prejudiced the market regarding the value 

 and quality of Whiting and might send them to purchase other 

 competitive products from other countries. Lenders are even more 

 cautious regarding approving loans to small vessels or processing 

 plants to harvest or manufacture Whiting. This attitude will 

 extend into all other fisheries as it has been shown that the 

 Regional Council process can be completely overturned and dictated 

 to by a very small, politically appointed group with little or no 

 background history in the fisheries. It has been shown that one 

 cannot offer a business loan to a financial institution or a 

 production goal to a market as it is subject to manipulation at the 

 Commerce Department's whim. 



