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have had. We have consistently been strong proponents of 

 adequate observer coverage. We are responsible for a new gear 

 definition, to be implemented in two weeks, that should greatly 

 reduce halibut bycatch in the pollock fishery. We convinced the 

 fleet to institute a voluntary herring avoidance program that has 

 been far more effective than the one that is in regulation. We 

 have been experimenting with different net configurations to 

 reduce bycatch in several fisheries. 



One of our biggest frustrations is that the system penalizes 

 us for doing these things. Each of these measures costs us money 

 in lost catch and lost fishing time, as well as the equipment 

 expense, and it puts us at a competitive disadvantage with the 

 fishermen who choose not to take these actions. There is 

 currently little incentive to fish responsibly other than one's 

 own sense of what is right. 



Most of the proposals that purport to be incentives are 

 actually penalties. Some urge an allocation away from trawlers 

 because it supposedly isn't a "clean" gear type. Others advocate 

 further reducing the amount of prohibited species, such as salmon 

 and halibut, we are allowed to catch. We are already subject to 

 extensive closures of fishing grounds to protect prohibited 

 species and more have been proposed. Each of these measures 

 makes it more difficult for us to break even, thus increasing the 

 proportionate financial burden. In addition, bycatch has often 

 become an emotional issue, and the facts have sometimes been 

 ignored when searching for a resolution. These circustances make 

 it harder to justify volunteering to search for more effective 

 bycatch reduction techniques. 



People continually cite the ability of the foreign fishing 

 fleet to reduce bycatch, and conclude that we are wasteful and 

 irresponsible for not doing the same. They overlook a critical 

 difference between the two situations. The foreign boats were 

 essentially operating on individual fishing quotas - when each 

 vessel had used up its share of bycatch it had to stop fishing. 

 The domestic fleet, on the other hand, is treated as one huge 

 entity. The bycatch reduction efforts by one boat penalize that 



