249 



* If use of the MSY concept is to continue, measures to account for natural 

 variability and scientific uncertainty should be incorporated into the TAC-setting 

 process. Conservative values for stock assessment parameters, such as natural 

 mortality rates, spawning success, recruitment success, etc should be used. 

 Consideration should be given to the application of a "safety factor" to the TAC, 

 similar to safety factors used in setting other environmental standards. 



RESTRICT THE INFLUENCE OF ECONOMIC AND SOCIAL FACTORS 



Another factor that has made the existing approach unworkable, particularly 

 for depleted populations, is that the definition of "optimum yield" takes into account 

 economic and social factors. This language has made the Council's management of 

 depleted fish populations an annual free-for-all of interested parties, in many cases. 

 Too often, economic and social factors have taken precedence over conservation goals 

 - and ironically, accession to short-term economic and social pressures for 

 unsustainable harvest levels has resulted in economic and social devastation. In 

 addition, the diversity of opinions on what constitutes optimality is too large to form 

 a consensus. 



* The MFCMA should make clear that economic and social factors cannot 

 compromise the requirement that a fish population with an appropriate number of 

 fish and distribution of life stages necessary for sustainable harvest and for the 

 fulfillment of the ecological roles of the fish will remain in the water. 



If a constant maximum sustainable yield (CMSY) approach is taken, this will 

 mean that harvest levels can be increased above the CMSY only in years of high fish 

 abundance. Restraint must be exercised in this case, particularly with regard to 

 further investments to increase fishing power. Such investments should be discouraged 

 so as to avoid overcapitalization over the long term. 



PREVENT STOCK DEPLETIONS AND REBUILD OVERFISHED POPULATIONS 



Many TAC levels are not conservative, because estimates of spawning success, 

 recruitment success, adult survivorship and other critical parameters are overly 

 optimistic. Furthermore, many populations have been fished down to depletion in the 

 absence of knowledge of sustainable yield levels and the ecological impacts of harvest. 

 The status of over 30% of the fish populations that are commercially exploited in the 

 U.S. is unknown. 



* Language is needed in the MFCMA to strengthen requirements that harvest level 

 determinations be based on the best available scientific information, and to mandate 

 a precautionary approach designed to prevent overfishing and adverse ecological 

 effects of fishing. Harvest levels should be decreased when warning signs (such as 

 declining CPUE and mean fish size) indicate that they are too high, and pressure to 

 increase harvest levels must be resisted. 



* The MFCMA should specify that management decisions must be risk-averse; Le., 

 they should err on the side of conservation when stock status is uncertain. 

 Conservative parameters used for stock assessments and TAC-setting should be 



