203 



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I would also urge you to consider requiring witnesses to 

 present their testimony and written submissions under oath and to 

 make a statement of their interest, and their qualification to 

 attest to the facts they are introducing into the record. This 

 will assist the council in giving the appropriate weight to the 

 testimony. 



The Act gives the council certain extraordinary authority to 

 promulgate emergency regulations, without the usual procedural 

 safeguards, whether or not a fishery management plan is in place. 

 In order to protect against the abuse of this authority (i.e. 

 where the requested emergency action would not have survived 

 normal review) I would suggest that all emergency actions be 

 supported by a unanimous, or at least two-thirds vote of the 

 scientific and statistical committee. In this way use of the 

 emergency authority will be reserved for those instances where 

 there is a clear and undisputed need for the action. 



Bvcatch Issues 



Another vexing issue that has been the source of much 

 frustration to those of us who try to operate responsibly is the 

 abuse of the bycatch limitations. There is no question that 

 bycatch issues are troublesome for everyone and are in need of 

 improvement. One relatively simple mechanism that would help to 

 curb "dirty fishing" is to limit the amount of bycatch any one 

 vessel can take to the same percentage of bycatch that is 



