PCFFA Fishermen's News, Dec. 2005: Finally, An MSA Reauthorization Bill!

THE PACIFIC COAST FEDERATION
OF
FISHERMEN'S ASSOCIATIONS

From Fishermen's News of December, 2005

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FINALLY, AN MSA REAUTHORIZATION BILL!

FORWARD PROGRESS SEEN WITH BIPARTISAN SENATE MEASURE

By Pietro Parravano, Glen Spain, Zeke Grader

Five years overdue, and nearly a decade since the last reauthorization, there is now legislation in the U.S. Senate to renew the nation’s primary fisheries statute, the Magnuson-Stevens Fishery Conservation & Management Act (MSA) (P.L. 94-265, 16 U.S.C. 1801 et seq.). The bill, S. 2012, was introduced November 15^th by Senators Ted Stevens (R-AK), Daniel Inouye (D-HI), Olympia Snowe (R-ME), Maria Cantwell (D-WA), David Vitter (R-LA) and Barbara Boxer (D-CA), all members of the Commerce, Science & Transportation Committee.

The Senate bill is an outgrowth of two earlier Commerce Committee staff drafts that had been widely circulated for comments (see the September 2005 Fishermen’s News article, “Reauthorization After All These Years?” that can be found at: www.pcffa.org/fn-sep05.htm). The first hearing on the new bill was held November 16^th and an optimistic schedule set for mark-up on the bill for December 13th (when amendments are considered) aiming to have it to the full Senate sometime by late January or early February of 2006.

The Bush Administration has come out with a second draft of its own bill, but still has no takers. In the House, Representative Barney Frank (D-MA) is floating a discussion draft and both Congressmen Richard Pombo (R-CA), Chair of the Resources Committee, and Wayne Gilchrest (R-MD), who Chairs the Fisheries Subcommittee, are considering introducing their own House reauthorization bills.

There are also two bills to note that have been introduced in the House, amending sections of the MSA, that may be heard as stand-alone measures or, more likely, their language may be incorporated into some of the other reauthorization measures. HR 1431, the Fisheries Science & Management Enhancement Act, introduced by Representatives Nick Rahall (D-WV) (ranking minority member on the Resources Committee), Christopher Shays (R-CT), Jim Leach (R-IA) and 37 other members, would implement many of the fishery recommendations that came out of the U.S. Oceans Commission, as well as expand upon and fund the fishermen’s cooperative research programs that have been successful in New England and in some places here on the west coast. HR. 3278, the Fishing Quota Standards Act, a bi-partisan measure by Representatives Tom Allen (D-ME), Robert Simmons (R-CT), William Delahunt (D-MA) and others, would establish national standards for individual fishery quota (IFQ) systems, including limits on how much any quota any one person could hold and favor fishermen ownership of quotas.

The first hearing on S. 2012 was held the day after introduction. Only one panel of witnesses testified, comprised of James Connaughton, Chairman of the White Council on Environmental Quality (CEQ); the National Marine Fisheries Service’s (NMFS) Jack Dunnigan; Admiral James Watkins (USN-Ret.), who chaired the U.S. Commission on Ocean Policy (USCOP); and George LaPointe, Commissioner of Maine’s Department of Marine Resources (MDMR). The hearing was amazingly cordial, considering the rancor in Congress at this time, with members from all parts of the political spectrum vowing to work together on the bill.

The bill generally was hailed as making forward progress in fishery management, not a roll-back in the protections gained under the Sustainable Fisheries Act in 1996, the last time the MSA was reauthorized. The bill is tougher on overfishing provisions, requires the regional councils to pay more attention to science when setting catch limits, calls for the development of technology to reduce by-catch, registers recreational anglers fishing in federal waters, provides for tougher conflict-of-interest provisions on all regional council members, and requires a referendum among affected fishermen to get approval before any IFQ program can be implemented.

Let’s take a close look at S. 2012, since it most likely will be the reauthorization vehicle for the MSA in the Senate, if not the full Congress, to see what changes are being proposed and what amendments might be considered. The sections of most importance to fishermen are probably found in Title I, Section 103 related to regional fishery management council functions and Section 106, related to limited access privilege programs.

Below are the main provisions of concern to commercial fishermen in the Magnuson-Stevens Fishery Conservation & Management Reauthorization Act of 2005 (S. 2012), as prepared by Committee staff, with our own commentary in italics:

Section 3. Changes in Definitions

This section makes a number of changes to the definitions set forth in Section 3 of the MSA, as well as technical and conforming changes to reflect the use of the term “limited access privilege” in place of “individual fishing quota” in various sections of the MSA, as revised by the draft. The section:

Defines the term “confidential information” as it applies to this bill to mean any information submitted to the Secretary that could cause competitive harm if disclosed.
Defines the term “regional fishery association” as associations formed for mutual benefit by persons engaged in fish harvesting or processing in a given region.
Defines the term “limited access privilege” as a permit issued for the harvesting in a limited access system authorized under section 107 of the draft. The definition mirrors the existing definition of individual fishing quota, but does not include language from that definition specifying that the quantity of fish involved must be expressed as a percentage of the allowable catch. The provision specifies that Individual Fishing Quota (should this be written as ‘limited access privilege’?)(IFQ) is included in the definition but that Community Development Quotas (CDQ) are not.
Defines the term “observer information” to cover the broad range of information that may be collected by a fishery observer, electronic monitoring system, or as part of a co-operative research program.

Note: Unlike the earlier staff drafts, S. 2012, does not provide explicitly for processor quotas. There is concern, however, that the “regional fishery association” definition is a loophole to allow for processor quotas. In mark-up, there may need to be further clarifying amendments to this definition. It is also unclear whether IFQs simply reappear in the form of “limited access privileges” but with fewer controls.

Title I

Section 101. Cumulative Impacts. This section amends National Standard 8 (section 301(a)(8) in the original MSA legislation) to stipulate that the importance of fishery resources to fishing communities must be evaluated using the best data and methodology available. The provision would also amend section 303(a)(9) to include the cumulative economic and social impacts of conservation and management measures in any fishery impact assessment submitted as part of a Fishery Management Plan (FMP).

Section 103. This section would make a number of changes and amendments to Section 302 of the MSA, which defines and authorizes the activities of the Regional Fishery Management Councils (RFMCs). Under this broad heading, the bill includes provisions covering the following topics (partial list):

(SSCs). Subsection 102(b) of the bill amends section 302(g) to more fully set forth the role of the SSCs in the RFMC process. The amendment adds new sections 302(g)(1)(B)-(E), and reclassifies the existing text of section 302(g)(1) into subsection (1)(A) with modifications.
Subsection 302(g)(1)(A), as amended, would stipulate that each council shall establish a Science and Statistical Committee (SSC) to assist in the development, collection, evaluation, and peer review of such scientific and socio-economic data as would be relevant to the development of any Fishery Management Plan (FMP) or FMP amendment.
New subsection 302(g)(1)(B) provides that each SSC shall provide its RFMC with ongoing scientific advice as needed for management decisions. This advice shall include recommendations for acceptable biological catch or optimum yield; as well as reports on socio-economic impacts, stock status and health, bycatch, habitat status, socio-economic impacts of management measures, and the sustainability of fishery practices.
New subsection 302(g)(1)(C) would require all SSC appointees to be Federal, State, academic, or independent experts with strong scientific or technical credentials and experience.
New subsection 302(g)(1)(D) authorizes the Secretary of Commerce (Secretary), with each RFMC, and in consultation with the Council Coordinating Committee, to develop a peer review process for scientific information developed for use by the Council. The provision states that such peer review process shall satisfy the requirements of the Data Quality Act.
New subsection 302(g)(1)(E) would authorize the Secretary to pay members of a SSC or advisory panel a stipend so long as they are not Federal or State employees.
Council Functions: Annual Catch Limits. Subsection 103(c) of the bill amends Section 302(h) of the MSA to require RFMCs to set annual catch limits for each managed fishery after considering the recommendations of their SSC or another appropriate scientific body.
Council Training Program. Subsection 103(f) of the bill would amend section 302 of the MSA by adding a new subsection (k), which would establish an RFMC training program. New section 302(k) would require the Secretary, in consultation with the Councils and the National Sea Grant College Program, to develop a training course for new RFMC members to provide them with a background in a variety of topics relevant to fishery management. Topics may include fishery science, management, conflict of interest requirements, economics, tribal rights and customs, and legal requirements. The course would be open to both new and existing RFMC members, and would also be available to members of committees or advisory panels as resources allow.
Conflicts of Interest. Subsection 103(h) of the bill would amend section 302(j) of the MSA to improve transparency of the process for disclosure of financial interests and recusal by Council members. Under current law, RFMC members are required to disclose any financial arrangements they may have in any harvesting, processing, or marketing activity undertaken within a fishery over which the RFMC has jurisdiction. This sub-section would amend that provision to ensure that the member also discloses: 1) any financial interests held by a fishing, processing, or marketing association that is compensating the member in any way; and 2) any entity or individual that is providing financial compensation to the member in any way. In addition, the provision would require that all such disclosure information, which is currently publicly available at RFMC offices during business hours, also be made available over the Internet. Finally, this subsection requires the Secretary to report to Congress annually, beginning in 2008, on action taken to implement the requirements of section 302(j), as amended.

Note: The Pew Oceans Commission and the U.S. Commission on Ocean Policy recommended to “separate conservation from allocation” by giving the SSC’s the final say on total catch levels and by having the Secretary appoint the SSC’s. The bill does address the concerns raised by the two commissions and this language will likely have broad support. The peer review section was something also called for and will enjoy support, but look for amendments in mark-up to make council training mandatory, not voluntary as the bill is currently written. Finally, the conflicts of interest provision does address the concern raised by PCFFA by including under the conflicts-of-interest language non-fishing members of regional councils (e.g., recreational fishing, environmental, etc.).

Section 104. Fishery Management Plan Requirements. This section would amend Section 303(a) of the MSA, which contains the required provisions of a fishery management plan. The amendments include a modification of the types of data collection required and a new requirement for the setting of a hard ceiling on fish mortality. In the first instance, this section would amend section 303(a)(5) to include fish processors among the sectors of a fishery from which data may be collected and to include economic data among the types of data required to be submitted to the Secretary as part of a Fishery Management Plan. In the second instance, this section would create a new subsection 303(a)(15) that would require an FMP to contain an annual catch limit that would be set at or below the Optimum Yield of the fishery as based on the best available scientific information. Any harvest in excess of the annual catch limit, including for a sector, would be required to be deducted from the limit for the following year, including for that sector. This provision would go into effect two years after enactment.

Section 105. Fishery Management Plans Discretionary Provisions. This section would make three changes to section 303(b) of the MSA, which governs the discretionary provisions that may be included in a FMP. First, the section would amend section 303(b)(6) to require that, in addition to the current criteria, a RMFC must consider the conservation requirements of the MSA and the fair and equitable distribution of access privileges before implementing a limited access system. Second, this section would make technical changes throughout existing section 303(b) to allow for the collection of economic data from fish processors. Finally, this section would add a new subsection, designated 303(b)(12), that would allow FMPs to contain a process for compliance with NEPA.

Note: Although not part of the recommendations from the two ocean commissions, this language should enjoy broad support.

Section 106. Limited Access Privilege Programs. This section would create a new MSA section 303A to authorize RFMCs to create a Limited Access Privilege Program (LAPP, formerly Individual Fishing Quotas) for the harvesting of fish within a given fishery. All LAPPs would be subject to Secretarial approval and could only be developed for a fishery already being run under a limited access system for at least a year. The new section 303A would also establish the following additional stipulations:

No Creation of Right, Title, or Interest. The new section 303A(b) would establish that a limited access harvest or processor privilege is to be classified as a permit that may be revoked or limited at any time without right to compensation. This permit would be considered a grant of permission to participate in the fishery and, as such, would not grant the holder any right to a fish before it was harvested or bought. As a permit, the privilege could also be revoked or modified for any failure in compliance with the program or if the system is found to have jeopardized the sustainability of the stock or the safety of fishermen.
Criteria for Establishing Limited Access Harvest Privileges. In order to establish a LAPP for harvest privileges in a fishery, a RMFC must first receive a petition signed by more than 50% of the permit holders, or permit holders representing 50% of the allocation, in that fishery. This petition must be submitted to the Secretary, who certifies its authenticity, before passing it to the appropriate RFMC (new section 303A(c)(4)). In New England and the Gulf of Mexico, such a referendum would require a two-thirds majority to be deemed successful (new section 303A(c)(1)(D)). The exception to this provision is the Gulf of Mexico Red Snapper fishery, which would adhere to procedures already stipulated in section 407(c) of the MSA. New sections 303A(c)(1) 303A(c)(5) and 303A(c)(6) list the criteria that a LAPP for harvesters would have to meet. These requirements stipulate that any limited access privilege program for harvesters must:

- Assist in rebuilding an overfished fishery.
- Reduce capacity in a fishery that is overcapacity.
- Promote the safety of human life at sea.
- Promote conservation and management.
- Prohibit any person other than a U.S. citizen; corporation, partnership, or other entity established under the laws of the U.S. or a State; resident alien; fishing community; or regional fishery association to hold a harvesting privilege.
- Require that all fish processing under an LAPP be done in U.S. territory or in U.S. waters by vessels of the U.S.
- Specify the goals of the program.
- Be subject to review every 5 years.
- Include a system for monitoring, management, and enforcement.
- Include an appeals process for administrative review of Secretarial determinations.
- Provide for a separate review process, established by the Secretary in consultation with Department of Justice and Federal Trade Commission, to determine if any acts of illegal collusion, anti-competition, anti-trust, or price fixing activity occurs among fishery associations receiving harvest privileges under the program.
- Provide for the revocation of privilege held by anyone who violates U.S. antitrust laws.

Criteria for Fishing Community Participation in a Harvest LAPP. New section 303A(c)(2) would establish that fishing communities may be deemed eligible to hold harvest privileges if they meet participation criteria developed by the relevant RFMC. These criteria must be based on the traditional socio-economic framework of the fishing community. They must also consider economic barriers to access to the fishery and the severity of projected socio-economic impacts associated with an LAPP on participants in the fishery and its related businesses. The interested community must also:

- Be located within the management area of the relevant RMFC.
- Consist of residents who conduct commercial or recreational fishing, processing, or fishery dependent support businesses within the relevant RFMC’s jurisdiction.
- Develop and submit a community sustainability plan to the council and Secretary.

Allocation of Harvest Privileges. New section 303A(c)(3) would stipulate that a RFMC’s limited access privilege program must provide for a fair and equitable distribution of the initial allocation of catch in a way that:

- Considers catch history, employment, investment, and dependence on the fishery.
- Considers historic participation of fishing communities.
- Considers the basic social and cultural framework of the fishery.
- Promotes the sustained participation of small, owner operated, fishing vessels and communities that depend on the fisheries; this may include regional landing requirements.
- Assists entry level and small-scale members of the fishing community.
- Limits the maximum share of the access privileges held by a qualified entity.
- Minimizes geographic consolidation of the fishery.
- Authorizes all those who substantially participate in the fishery to hold a limited access privilege.

Transferability. New subsection 303A(c)(6) would require a RFMC to establish a policy on the transferability of privilege shares and a program to monitor such transfers that are consistent with the policies of the council established during the allocation process.
No Waiver. New subsection 303A(c)(8) provides a savings clause which stipulates that nothing in the act shall waive any U.S. antitrust laws.
Auction. New section 303A(d) would authorize a RFMC to use an auction or other system to collect royalties from the initial distribution of privilege in a limited access program if: 1) the system or program is conducted in a manner consistent with the requirements described above; and 2) revenues from the distribution system are deposited in the Limited Access System Fund (established in Section 305(h)(5)(b) of the MSA). Funds from the Limited Access System Fund would be made available through annual appropriations.
Cost Recovery. New section 303A(e) would require a RMFC that develops a limited access program to establish a methodology for assessing the management, science, data collection, enforcement, and observer programs associated with the program and provide for a program of fees to support these activities. New section 303A(i) contains the requisite technical amendments to allow the collection of fees for this purpose.
Limited Access Privilege Assisted Purchase Program. New section 303A(g) would authorize RFMCs to establish a Limited Access Privilege Assisted Purchase Program. This program would allow 25% of fees collected from a fishery to be used to aid entry level and small boat fishermen in purchasing shares.

Development of a Limited Access Program would be performed under a RFMC’s standard rules and procedures and be subject to public comment. The Secretary would be forbidden from approving a plan that has not met all the requirements listed above. None of the guidelines described above are deemed to require the reapportionment of shares in any limited access program established prior to enactment of this bill.
Effect on Certain Existing Shares and Programs. New section 303A(h) would ensure that section 303A would not require a reallocation of quota share from any limited access system, including sector allocations, extant prior to enactment of this bill.

Note: Although different from H.R. 3278, S. 2012 does address many of the concerns of the fishing groups that requested the Fishery Quota Standards Act. The bill does not sunset (with the option for renewal) IFQ programs, but does require five-year reviews. It also does not directly specify what excessive quota share constitutes, but addresses that issue in another manner. While it is a relief that there is no language creating processor quotas (PQs) in the bill, there are still questions about processors owning harvesting quotas or attaining quota ownership through “regional fishing associations.” Moreover the bill is silent on the matter of leasing quotas, a provision in existing IFQ systems that has sometimes been abused.

The auction language, too, is problematic. It is one thing to hold auctions on a resource where there are a few large operators, such as on National Forests or for oil and gas leases, but it is quite another thing to auction resources in an industry where the operators are small and numerous and have a historic dependence on the resource and where communities have been established around those resources. The good news in S. 2012, of course, is that the bill requires that fishermen approve, through a referendum, of any proposed IFQ system.

Section 107. Environmental Review Process. This section would require the Secretary, with public participation and in consultation with the Council on Environmental Quality (CEQ) and the RMFCs, to develop a process that would bring all RMFC plans into compliance with the requirements of the National Environmental Policy Act (NEPA). This process would then be established as the sole environmental impact assessment process for fishery management plans. It would, however, have to meet a number of criteria including: 1) conformity to timelines for review and approval of Fishery Management Plans (FMPs); and 2) integration of the environ-mental analysis processes and public input timelines with FMP preparation and dissemination. The Secretary would be given 12 months to propose the revised procedures and, including 90 days for public comment, promulgate final procedures 18 months after enactment of this bill.

Note: This language is a compromise between the council chairs who wanted an exemption for the MSA from the National Environmental Policy Act (NEPA) and many in the fishing and conservation communities who wanted to preserve NEPA’s public process and requirement that alternatives be considered in the regulatory process. Moreover many worried that such an exemption from NEPA would set a dangerous precedent where polluters, developers and others would begin seeking exemptions too.

Section 113. Transition to Sustainable Fisheries. This section makes a number of changes to section 312 of the MSA. Most of the changes relate to subsections 312(b)-(e), which establish the Fishing Capacity Reduction Program, but two technical changes are made to subsection 312(a). The changes to 312(a), Fisheries Disaster Relief, include harvest restrictions among the causes of a fishery failure that could qualify a community for disaster relief. The changes to 312(a) would also reauthorize the program for FY 2006-2012.

Note: Among other things, the amendment here would allow a majority of permit holders, or individuals holding a majority of the allocation, in a fishery to conduct a voluntary Fishing Capacity Reduction Program; currently only a RFMC or State Governor may request the Secretary to initiate such a program.

Section 114. Regional Coastal Disaster Assistance, Transition & Recovery Program. This section would create a new section 315 in the MSA to establish a Regional Coastal Disaster Assistance, Transition & Recovery Program. This program would authorize the Secretary, in consultation with the relevant Governors, to provide immediate relief to the fishery sector of a region afflicted by a catastrophic fishery disaster. Economic assistance would be made available for: 1) meeting immediate shoreside infrastructure needs; 2) financial assistance and job training for fishermen in a fishery that may be temporarily closed; 3) funding for a capacity reduction program under section 312(b); and 4) any other activities authorized by section 312(a) of the MSA (Fisheries Disaster Relief), or section 308(d) of the Interjurisdictional Fisheries Act of 1986.

Note: This section is an obvious acknowledgement of the devastation disasters such as Hurricane Wilma, Katrina and Rita can visit upon fishing communities.

Section 115. Bycatch Reduction Engineering Program. This section creates a new section 316 under Title III of the MSA. This new section would direct the Secretary, in cooperation with the RFMCs and other interests, to create a Bycatch Reduction Engineering Program within one year of enactment of this bill. The new program would be tasked with developing technological devices and engineering techniques for minimizing bycatch, bycatch mortality, and post-release mortality. The provision stipulates that the program: 1) be regionally based; 2) coordinate with projects under the MSA’s cooperative research and management program; 3) use information and outreach to encourage the adoption of new technologies; and 4) provide for consultation with RFMCs so that the councils may incorporate new developments in FMPs.

Note: This section is something PCFFA and other fishing groups have long asked for: “Don’t just demand bycatch reduction, give fishermen the support they need to develop the gear to avoid unwanted catch.”

Title II

Section 204. Cooperative Research & Management Program. This section creates a new section 317 in Title III of the MSA. This new section would create a Cooperative Research & Management Program to fund partnerships between Federal and State entities in research and management activities that are consistent with the goals of the MSA. The program would be implemented on a regional basis and be developed and conducted through partnerships between Federal, State managers and scientists and commercial and recreational fishing industry participants. Project eligibility would be based on a determination of critical need by the Secretary, as made in consultation with the RFMCs. Funding would be awarded on a competitive basis and based on regional needs with priority given to projects designed to: 1) enhance data collection; 2) improve stock assessments; 3) assess bycatch or post release mortality; 4) reduce bycatch or post release mortality; 5) identify or conserve habitat areas of particular concern; and 6) collect and compile socio-economic data. Six months after enactment, the Secretary would be directed to establish a uniform, but regionally based, expedited permitting process for projects under this section.

Note: This language is similar to the cooperative research programs called for by H.R. 1431.

Section 208. Fisheries Conservation & Management Fund. This section directs the Secretary to establish a Fishery Conservation & Management Fund that shall be available to the Secretary to disburse on a regional basis for purposes including: 1) efforts to improve fishery harvest data collection; 2) cooperative fishery research and analysis; 3) development of methods or technology to improve the quality, safety, and value of landed fish; 4) analysis of fishery products for health benefits and risk; 5) marketing including consumer education; and 6) financial assistance to fishermen to offset the costs of modifying gear to comply with the MSA. The Fund may receive deposits from: 1) criminal and civil penalties, fines, and seizures made under the authority of the MSA; 2) from the sale of quota set aside by a RFMC for that purpose; or 3) outside sources including donations from State and local authorities and private or non-profit organizations. Money in the Fund would be dispersed to the various management regions based on a consensus decision by the RFMCs except that no region would receive less than 5% of the Fund.

Note: Both ocean commissions recommended the establishment of a trust fund or funds to support ocean conservation, and PCFFA has been arguing for years the need of an off-budget source of monies derived from industry to support needed programs (see “Planning and Paying for Future Fisheries Research – Fish Stocks and Fishing Communities Depend on Good Data,” in the August 2003 edition of the Fishermen’s News, available on the web at: www.pcffa.org/fn-aug03.htm).

Using monies derived from violations as the primary source for the fund may be problematic. A nominal ad valorem fee on all seafood sold in the U.S. would be more equitable and raise substantially more revenue. Also see Section 209 of S. 2012 for its discussion of the Capital Construction Fund (CCF).

Conclusion

The Senate reauthorization bill is a pleasant surprise, certainly far better than many expected. It will need some amendments, but overall is a good start. It definitely represents forward progress.

Two issues missing from the bill are mention of either ecosystem management or open ocean aquaculture. Senator Stevens has been concerned that mandating ecosystem management, which has not been fully defined, he believes, by scientists could lead to endless litigation. He also feels that some of the regional councils are already embarked on FMPs that consider ecosystem effects. On open ocean aquaculture, he and Senator Inouye are carrying the Bush Administration’s bill, which most consider a real dogand for which there is little interestand support amongst fishermen.Nevertheless, aquaculture in the marine environment has a direct effect on conserving and managing marine fish and cannot be ignored or simply shunted off into other legislation (see the October Fishermen’s News article at www.pcffa.org/fn-oct05.htm).

Many fishing groups along the West Coast, as well as nationally, will be putting together comments and suggested amendments. Readers of Fishermen’s News should contact their organization or contact PCFFA (e-mail: pcffafish@aol.com) with their thoughts and comments.

A copy of S. 2012 can be obtained through a search by bill number to the Library of Congress’s THOMAS list at: http://thomas.loc.gov.

Pietro Parravano (fish3ifr@mindspring.com) is from Half Moon Bay, California. He is the President of the Institute for Fisheries Resources and was a former member of the Pew Oceans Commission. Glen Spain (fish1ifr@aol.com) is Northwest Regional Director for both the Institute for Fisheries Resources and PCFFA, and is headquartered in Eugene, Oregon. Zeke Grader (ZGrader@ifrfish.org) is an attorney and Executive Director of the Pacific Coast Federation of Fishermen’s Associations with offices in San Francisco. PCFFA can be reached at: PO Box 29370, San Francisco, CA 94129-0370, (415)561-5080 or by email to: fish1ifr@aol.com.