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schedule as plan amendments. 



Under current statute an emergency rule can be in effect for 

 no more than ninety days, with an extension of no more than an 

 additional ninety days. While in theory this appears to be 

 enough time for a council to determine a permanent solution and 

 for NMFS to implement it, in actual practice the period is too 

 brief. We support a time limit for emergency rules of one 

 hundred eighty days, and an extension of the same length if the 

 council and NMFS are making substantial progress in achieving a 

 settlement of the problem. 



The most obvious tool that the fishery management process 

 lacks is funding. Without adequate funds it is difficult to know 

 whether we are being conservative or profligate in our management 

 of fish stocks. Good ideas or important council decisions may 

 languish until additional money can be located. We realize that 

 public funding is becoming increasingly scarce, so we are willing 

 to support the assessment of fees under certain conditions. One 

 is that the money must be spent on federal fisheries programs in 

 the region in which the fees are collected. Another is that 

 these revenues be used to supplement, not replace, existing 

 funds. A third is that guidelines be imposed on the use of this 

 income to be sure that immediate research and management needs 

 will receive priority. 



It is important to keep in mind that, due to our federal 

 budgeting process, NMFS has some degree of financial control over 

 the councils. Although this control is not obvious, it does 

 exist and has tended to distract NMFS from the work it was 

 created to do - that of research and enforcement. We therefore 

 see it as especially important that NMFS not be the agency that 

 collects any fishing fees that are assessed. We suggest that the 

 councils be allowed to designate some other authority for this 

 purpose . 



Conservation Measures 



Of course the whole point of having this - or in fact any - 

 management system is to assure the health of the fish stocks, 



