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Experience with other trust funds created through legislation indicates that 

 stringent, earmarked protections are needed to guard against "raids" for redeployment 

 for other purposes. Consequently, the targets and uses of such a trust fund need to 

 be spelled out in some detail, and immuni ties from budgeting and appropriations wars 

 need to be built into the MFCMA. Priorities also need to be clarified. While 

 funding fisheries research with these fee revenues makes sense, it should be limited. 

 Furthermore, research may not be the highest priority in many cases. Deploying trust 

 fund revenues to reduce overfishing, bycatch dumping, and other serious problems will 

 probably often have much higher payoffs for fisheries conservation goals. One 

 example might be the use of trust funds to induce "early retirement" to reduce fishing 

 effort in overexploited fisheries. Another might be the use of funds to reimburse 

 fisher costs or otherwise encourage landing - rather than dumping - of bycatch. 



REFORM THE FISHERY MANAGEMENT COUNCILS 



Fishery Management Councils set up by the MFCMA have come to be 

 dominated by representatives of the fishing industry. While their expertise and 

 experience are invaluable, many other valid interests must be acknowledged and 

 accommodated in the decision making process. The inclusion of people with no 

 financial stake in the fisheries managed by the Council and who represent the 

 interests of the community at large, environmental interests, and other valid interests 

 would increase the objectivity of Council deliberations and votes, and increase the 

 sensitivity of Council decisions to these interests. 



* The MFCMA should require that some minimum number or proportion of Council 

 voting members should have no affiliation with user groups or government agencies. 



Conflicts of interest may be a symptom of open access management: every 

 year, Council members are asked to vote on how much of the allowable catch will be 

 allotted to various users, including their own constituents. The intial allocation of 

 individual transferable quotas, using an equitable allocation formula worked out and 

 agreed upon by all users and other stakeholders, would provide a more objective and 

 less politicized allocation process. Market forces would allocate quota after the initial 

 allocation. 



PROTECT FISH HABITAT 



Complex ecosystems interact to support the development of fish populations. 

 The structure and function of these ecosystems must therefore be protected if fish 

 populations are to remain viable. Restrictions on harvest cannot ensure healthy fish 

 populations or sustainable yield if the supporting ecosystems are impaired. These 

 ecosystems include wetlands, estuaries, embayments, coastal waters, and the open 

 ocean. The habitats used by anadromous and catadromous fishes such as salmon, 

 steelhead, shad, and eels are even more diverse, including rivers, streams, and 

 watersheds as well as marine and estuarine ecosystems. 



Human activities have impacted all of these habitats, and in many cases, 

 human-induced habitat impairment or destruction has led directly to the biological and 

 commercial extinction of living marine resources. Protection of fish habitat would 



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