187 



In addition to the sdentiflc Information, the Magnuson Act charges the Council with 

 responsibility to receive and consider Information regarding social, environmental and 

 cultural impacts of decisions and. Implicitly, to address and ameliorate those impacts. The 

 rwoid of the fishery tiwnagement process in the instant case iiuilcates to us that the Padflc 

 Fishery Management Council has followed both the letter and intent of the Magnuson Act 



Two last questions arise which the Center believes must be addressed. What was the rush to 

 fish? Spawning populations of whiting were reportedly drained of quality and value. The 

 pnxlucts orated, fish meal and suiiml, reflected the conditions of the fish. Those products 

 were produced into an over-sold madcet How does the public interest benefit from a lower 

 quality product being pumped into an over-supplied market? 



While these questions, on their face may not appear to be "conservation" issues, the issues of 

 overharvest and unwise use of limited resources as well as issues of public process will 

 always command our attention. 



Xdeanwhile the battles over the allocation of Pacific whiting condime to divert valuable time 

 and energy from important biological issues. The US/Canadlan disputes over whiting have 

 resulted in combined haiveste that exceed the coastwise Allowable Biological Catch, leading 

 us down the road to overfishing (1990 harvest, 106% of ABC; 1991, 125% of ABC; 1992, 

 -130% of ABC). 



Finally, the whiting management and allocation process should incorporate as much 

 biological information as possible on both the target species and bycatch of other species. 

 Data collection on whiting dlscaixls and bycatch of salmon and rockflsh should be a high 

 priority for everyone involved with this fishery. Observer data from both the onshore and 

 offshore sectors needs to be coUected and analyzed. The receiit regulation imposed on the 

 whiting fishery to reduce bycatch of salmon is a step in the right direction. 



Thank you for the opportunity to comment on this difficult process. The Center for Marine 

 Conservation looks forward to continuing to work with the Subcommittee during its 

 deUbeiations on this important matter. 



Sincerely, 



^^ 



avid Allison 

 Fisheries Conservation Director 



