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If self-interested individuals ere directly involved in 



regulating themselves and their competitors, does it not stand to 



reason that higher standards of ethical conduct, not lower ones, 



should be in place? Arctic Alaska recommends first that council 



members be required to state on the record their direct or indirect 



financial interests when voting on a management measure. Second, 



much more detailed financial disclosure should be required of 



council members. Third, the decision memoranda prepared by 



Commerce officials when reviewing a proposed council action should 



include a thorough analysis of the financial benefits, direct or 



indirect, accruing to council members (including their employers, 



clients, families, partners, etc.) supporting the proposal . 



b. Restoring Balance Between the Secretary end the Councils 

 and Improving the Regulatory Review Process. 



Congress has struggled and failed in efforts to ensure 



balanced representation on the regional councils. In fact, in en 



industry as diverse as the fishing industry, it is difficult to 



conceive of a formula under which the interests of all legitimate 



parties can be adequately represented and protected. If the 



conservation failures reflect the inability of user groups to 



regulate themselves, and I believe they do, the recent bruising 



allocation battles reflect the attempts by user groups to regulate 



their competitors. Review of council actions by the Commerce 



Department is the only opportunity for impartial review. 



Currently, the Secretary is limited to approving, disapproving, or 



partially disapproving council proposals. Arctic Alaska proposes 



