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I don't profess to know the condition of bluefish stocks, 

 and recent disagreement between National Marine Fishery 

 Service (NMFS) scientists and ASMFC scientists on that 

 very subject suggest others might not either. But even my 

 relatively short time as a fishery manager prompts me to 

 caution against overreaction . 



On that note, the option range is obvious, albeit studded 

 with mine fields: if we don't exert enough control, taking 

 a risk-averse posture, bluefish stocks might precipitously 

 crash; but unless we carefully unravel the bluefish 

 conundrum, we might reduce fishing pressure to a 

 moratorium before discovering such pressure wasn't the 

 culprit after all. 



I don't suggest we do nothing. But I also warn against 

 inappropriate action which promotes more a "warm and 

 fuzzy" feeling than resource preservation. Before we fix 

 something, let's make sure it's broken. And before we 

 apply a remedy, let's identify the cause of the break and 

 apply that remedy appropriately. 



ISSUE 2. 



The question of which management entity ASMFC or the 



Council should resolve the bluefish dilemma is perhaps 



as challenging and puzzling as determining the nature of 

 the stock itself. However, I do not believe that assigning 

 sole management responsibility to the ASMFC will benefit 

 the stocks, the fishery participants or the general 

 public . 



My reasons do not spring from concerns about management 

 inadequacies within the ASMFC. I acknowledge state 

 directors' expertise in that arena. Structural and 

 philosophical differences which exist between the ASMFC 

 and the Council give root to my objection. 



One of Congress' goals when establishing the council 

 system was to ensure public participation in the 

 management process. By a ratio of two public appointees to 

 every state fisheries member, that goal has been reached, 

 and the seat allocation system has become one of the 

 councils' major strengths. No such balance exists within 

 the ASMFC. Legislative appointees are, for the most part, 

 nonpart icipants, and governor appointees, with a very few 

 exceptions, are infrequently active. The ASMFC is thus 

 characterized by a decision process rooted almost entirely 

 among state fishery personnel and a less accessible public 

 input process than offered by the council system. Against 

 that backdrop, it's difficult imagining how placing 

 bluefish responsibility solely with the ASMFC enhances 

 Congress' goal of making the management process more 



