186 



e 



Center for Marine Conservation 



Forrnerjy Cenlei for Environmental EducdUon. Esi, 1972 . 



Junes, 1993 



Hon. Ron Wyden 



Chalnnan 



Small Business Subcommittee on Regulation, 



Business Of>poitunities, and Technology 



Washington, DC 2D515 



Via Fax 



Dear Chaiiman Wyden: 



The Center for Marine Conservation appreciates the invitation to present testimony to the 

 Subcommittee about the Department of Commerce's decision allocating Pacific Whiting. 

 Regrettably, we are unable to present testimony before the Subcommittee. Instead we 

 provide the following comments for your consideFatlon. 



The Center for Marine Conservation promotes conservation, sustainable use, as well as 

 fidective gear and non-wasteful fishing techniques in the management of marine fisheries. 

 The Center actively participates In the regloi»l fishery management council process in New 

 England, the Mid-Atlantic South Atlantic Gulf of Mexico, and here in the Padflc 

 Established in 1972, the Center is a public, non-profit organizatlDn dedicated wholly to the 

 health of coastal and marine environments and their living resources. 



While the tangled process of developing an allocation framework for Pacific Whiting has 

 moved forward, the Center was a relatively quiet observer, focused on the potential 

 biological conservation impacts. The Center speaks out now to highlight concerns about the 

 decisionmaking process and to reintroduce several conservation Issues relating to Pacific 

 whiting. 



The federal fishery management process does not benefit fix>m a drawn-out process and last 

 minute flurries of contradictory decisionmaking. The lack of cooniinatjon between NMPS 

 and the Pacific Council and the lengthy delays in decisionmaking at the Department of 

 Commerce resulted in NMFS' proposed rule being published in March, three mondts after 

 the Coimdl's action and just weeks after the Coundl's March meeting. The final rule 

 published just four weeks later, was dramatically different The final rule also proved to be 

 based on faulty assumptions as emergency action had to be taken on May 5 to halt at-sea 

 processing. 



The Magnuson Act and Council Rules and Regulations require that management decisions be 

 based upon the best available sdentifu: information. To reverse such a decision should 

 certainly require presentation of Information more persuasive in substance and quality than 

 that used for the initial Council dedsion. 



1725 DeSales Street. NW, Ste. 500 Washington, DC. 20036 (202) 429-5609 Telefax (202) 872^0619 



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