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continued reliance on open access management and limited entry with input controls 

 is not likely to address the fundamental, debilitating problems many of our fisheries 

 are experiencing. 



* Individual Transferable Quotas should be actively studied as a viable alternative 

 to open access and limited access with input controls. Criteria for selecting fisheries 

 amenable to ITQ management and for program design are needed, with a focus on 

 maximizing conservation benefits. 



* Because some time will be required to assimilate lessons from past and ongoing 

 quota management experience, we recommend that no new quota management 

 programs be initiated for one year. This waiting period is necessary for the 

 evaluation and modification of ongoing programs, and for the incorporation of these 

 lessons into the design of new programs. New quota management programs should 

 be initiated after the evaluation period if they contain provisions to address key 

 problems and promise improvement over existing open access programs in fulfilling 

 the goals of fisheries management: to rebuild depleted fish populations, to allow 

 sustainable levels of harvest of healthy populations, and to prevent detrimental 

 ecological effects of fisheries. 



MINIMIZE BYCATCH 



Bycatch is a serious problem because fish mortality is poorly documented and 

 uncontrolled, and because large amounts of fish are removed from the ecosystems 

 they are a part of. Measures to deter bycatch and dumping are clearly needed. 



EDF strongly supports proposals to expand research into the effects of different 

 gear choices on bycatch, bycatch mortality, and enforcement of bycatch reporting 

 obligations. We also believe that certain types of gear, such as drift nets, should be 

 banned. 



* A process for systematically evaluating gear and banning gear that is unselective 

 and/or damages habitat is needed. 



However, gear requirements as the only means of controlling bycatch are 

 unlikely to be effective. Indeed, reliance on one type of technological fix will 

 unnecessarily limit the competitive development of alternative bycatch control methods. 

 Other means of bycatch control, including those not wedded to any particular 

 technology, should not be precluded (e.g., season and area restrictions). Furthermore, 

 gear restrictions are difficult to enforce, as evidenced by the lack of compliance with 

 the driftnet ban reported recently. 



* Incentives to reduce, land, and document bycatch and to reduce dumping (which 

 will result in improved conservation of bycatch species due to improved data) — as 

 well as severe penalties for dumping - are needed. 



COLLECT USE FEES TO IMPROVE FISHERIES MANAGEMENT 



* Fees for the use of public fish resources should be collected and used to fund a 

 sustainable fisheries trust fund. 



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