PCFFA Fishermen's News, Sept. 2005: MSA Reauthorization After All These Years?

THE PACIFIC COAST FEDERATION
OF
FISHERMEN'S ASSOCIATIONS

From Fishermen's News of September, 2005

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REAUTHORIZATION AFTER ALL THESE YEARS?

AFTER A DECADE CONGRESS MAY FINALLY TAKE UP COMPREHENSIVE AMENDMENTS TO THE MAGNUSON-STEVENS ACT

by Zeke Grader and Glen Spain

It’s been nearly a decade now since Congress passed the Sustainable Fisheries Act of 1996, reauthorizing the Magnuson-Stevens Fishery Conservation & Management Act (MSA), the principle law governing our nation’s fisheries. Since 2000, there’s been a lot of talk about MSA reauthorization, but no action. There have been a few amending statutes, but no comprehensive review that usually comes with reauthorization.

Now that Senator Ted Stevens (R-AK) has left the chairmanship of the Appropriations Committee and is back in the seat as chair of the Commerce, Science & Transportation Committee there’s a new push for reauthorization of the law his name is on. It’s not just Senator Stevens either, a number of members of Congress are interested in implementing some or all of the fishery recommendations that came out of the U.S. Commission on Ocean Policy (USCOP) (see www.oceancommission.gov), and similar proposals made a year earlier by the Pew Oceans Commission (see www.pewoceans.org). Added to this is a clamor for clarification in the law on individual and community fishing quotas and the prospect of processors being granted quotas as well, as has already happened with the BSAI [Bering Sea/ Aleutian Islands] crab fishery.

In the House, the Chair of the Resources Committee, Representative Richard Pombo (R-CA) has shown no similar enthusiasm for MSA reauthorization, wanting his Committee to instead focus on what he terms “reform” of the Endangered Species Act, a nice euphemism for gutting a statute that has been critical for the protection of salmon habitat. Pombo’s resistance, however, may be overcome by the desire of other House members to take up Magnuson, namely Congressman Wayne Gilchrest (R-MD) who chairs the Resources Committee’s Fisheries Subcommittee. Senate action could also force the House to move on MSA reauthorization.

Administration’s Proposal for Wholesale Gutting of the MSA

Senator Stevens’ statements about wanting to take up MSA reauthorization apparently got the Bush Administration moving and it had a draft bill -- although it was mostly denying the existence of such a bill -- for circulation “in house” during June. The draft bill “that didn’t exist” did get out, however. It turned out to be largely a roll-back of the gains made under the Sustainable Fisheries Act and designed more it seemed to allow fishery management to avoid public scrutiny or lawsuits over flawed plans and amendments. Although the Administration has praised the USCOP report, none of the Commission’s fishery recommendations were to be found in its draft MSA reauthorization bill. Little wonder the National Marine Fisheries Service (or whatever they were calling themselves that day) was making like Sergeant Schultz, claiming they “know nothing.” No one who gave a damn about fisheries would have wanted to be associated with that draft.

The Administration draft would have make a number of changes to the MSA. Most significantly it would allow overfishing to continue for years, presumably until there was a stock collapse. But the Administration bill isn’t doing the fishing industry any favors. Rather than design programs to help the fishing industry through times of cutbacks and rebuilding because of depleted fish stocks, the Administration’s answer is to keep on fishing at low levels of abundance with little real hope for either stock recovery or a healthy fishery for the future. Specifically, the Administration’s draft bill would:

Revoke the current requirement to rebuild an overfished species within ten years.
Weaken protections against overfishing by allowing overfishing on a given species to continue for years before it is required to be stopped.
Repeal the current requirements to prevent overfishing and rebuild overfished species in a “mixed stock fishery.”
Create a new definition of “optimum” yield to exempt overfished species from certain protective requirements.
Delete the existing requirement that fishery management plans must contain adequate measures to end overfishing and rebuild an overfished species.
Change the term “overfished fishery” to “depleted” fishery. (NOTE: such a change had been advocated by salmon fishermen, among others, to prevent salmon stocks devastated by in-river habitat losses (including dam operations and water diversions) from being categorized as “overfished.” The Administration draft, however, didn’t simply do that, but, instead, would allow other fisheries where stocks had been overfished to escape scrutiny by simply being labeled as “depleted.”)
Entirely exempt fishery management decisions from the National Environmental Policy Act (NEPA), depriving the public, including fishermen, of NEPA’s requirements for environmental analysis and public participation. (NOTE: While the bill establishes vague requirements for an alternative process in the absence of NEPA, this alternative process would be virtually certain to yield inferior environmental analysis and inferior opportunities for public participation, and probably spark a new wave of litigation.)
Authorize adoption of “alternative procedural mechanisms” for establishing fishery regulations. (NOTE: Using these undefined “alternative procedural mechanisms” the Administration proposal would enable a fishery management council and NMFS to evade the requirements for public input, disclosure, and participation established elsewhere in the MSA and Administrative Procedure Act (APA).)
Exempt fishery regulations adopted through “alternative procedural mechanisms,” which could include all or virtually all of the regulations governing a fishery, from the public notice and comment requirements of the APA and MSA.
Exempt virtually all NMFS management and regulatory decisions from the rulemaking requirements of the APA.
Exempt fishery management plans, fishery management plan amendments, and fishery ecosystem plans from the rulemaking requirements of the APA
Revoke the existing duty of fishing vessels to report data (e.g., salmon bycatch in the Pacific Whiting fishery), including actual fishing catch, and replace it with a data-reporting provision that is optional.
Broaden secrecy requirements in a way that would make it much harder for the public, including fishermen, to receive information about the aggregate size of fishing harvests.
Expand the MSA’s existing Federal Advisory Committee Act (FACA) exemption to exempt from FACA any meeting that includes a federal employee, a fishery management council member, or a fishery management council staff member.
Delete the existing requirement for mandatory bycatch reporting (e.g., salmon bycatch in Pacific Whiting fishery) and replace it with a provision requiring bycatch reporting only “to the extent practicable.”
Broaden the MSA’s statute of limitations by requiring a plaintiff (which includes fishermen or fishing organizations) to file suit within 30 days after any fishery management decision, even where that decision is not published in the Federal Register. (NOTE: Under this new provision, a plaintiff could be barred from challenging an agency decision before the plaintiff even finds out about the decision. This would significantly stifle the ability of fishermen to challenge ill-conceived fishery regulations.)
Establish a new attorney fees provision that (a) contains language about court discretion in awarding fees that does not appear in attorney fees provisions in similar laws and (b) could result in a court ordering a plaintiff (e.g., a fishery organization) to pay NMFS’ attorney fees where a plaintiff unsuccessfully challenges a fishery management decision.
Change from mandatory to optional the adoption of measures “to protect and enhance the health and productivity of marine ecosystems.”
Establish a new requirement that fishery conservation measures be “cost-effective.” (NOTE: This is a vague and undefined term that has already been found to be a slippery slope. NMFS is now refusing to list many important sections of salmon streams as critical habitat because the agency has determined it is not “cost effective” to protect these waterways from development (they refuse to consider the benefits to fisheries –only the costs to developers).)
Authorize NMFS to unilaterally issue guidances about the MSA’s requirements, undermining the “National Standard Guidelines.”

Senate Staff Concept for MSA Reauthorization

In July, 2005, the staff of the Senate Commerce Committee circulated a discussion draft of a very different MSA reauthorization bill. A DC meeting among fishery groups was scheduled for August 25th and the staff requested comments on this initial draft bill by September 6th. The staff draft does include some, but not all, of the USCOP fishery recommendations that were very similar to those made by the Pew Commission.

Unlike the Administration’s draft bill, the Senate staff draft does not eliminate or alter the ten year rebuilding requirement. The staff draft, however, does not clarify when specifically overfishing must end. The staff draft is silent, too, on the USCOP recommendation (19-21) for more active ecosystem-based management, “The National Marine Fisheries Service (NMFS) should change the designation of essential fish habitat from a species-by-species to a multi-species approach and, ultimately, to an ecosystem based approach….”

The section in the Senate staff draft bill that undoubtedly will be the most controversial is that allowing for processor quotas. In defense of staff, this section was apparently put in, not because staff or any Senator is pushing it, but to draw out discussion in the reauthorization hearings on whether processor quotas should be allowed and, if so, under what conditions.

The Senate discussion draft would amend the MSA in the following ways:

Regional Councils. It limits conflict of interest provisions for council members to apply only to disclosure of financial interests but not to disqualification based on conflicts. It does not include strict conflict of interest provisions. It does not include the recommendations by USCOP (Recommendations 19-12, 19-13) to expand regional council membership. (NOTE: Some in industry may breathe a sigh of relief, but the perception that the councils are controlled by industry members with conflicts of interest could eventually doom the system; the USCOP recommendations could, in effect, help save the regional councils that provide an important mechanism for public participation in the fishery management process and a fair degree of transparency.)
Scientific & Statistical Committees (SSCs).It would provide compensation for non-government SSC members. Although it specifies that total allowable catch (TAC) shall not be exceeded for a fishery, the draft does not adhere to the recommendation by USCOP that Regional Council’s SSCs establish the TAC, and that the Council deal only with allocation (“separating conservation from allocation”). (NOTE: Although the USCOP recommendation assumed setting TACs could easily be separated from allocation, the problem of the perception – with some real evidence to back it up – that some councils have set TACs too high under pressure from industry has to be addressed if there is to be public confidence in the council process.)
Training. The staff draft requires the Secretary of Commerce to develop a training program within 6 months for new regional council members (following a USCOP recommendation), but participation in the training program is not mandatory and there are no consequences (i.e. withholding voting privileges) for those who opt not to participate. Also, the training program is not made available to the public.
Closed Meetings. The draft allows for closed meetings, but does not elaborate on what the criteria for closing a meeting to the public should be (i.e., proprietary information, national security, etc.).
Alternative NEPA Compliance. Section 103 of the discussion draft would require the Secretary to establish an alternative (integrated council) process to comply with NEPA. The White House Council on Environmental Quality (CEQ) would be required to approve the process to ensure consistency with NEPA, but specifies that such a process supersedes NEPA and accompanying CEQ regulations. Making this more confusing in Section 106 (discretionary provisions) is a paragraph allowing councils to establish a process to comply with NEPA. (NOTE: The language in the latter section, thus, raises a number of questions: 1) How does this relate to the Secretary’s authority to establish an alternative NEPA process? 2) Is this a council specific process to comply with the national process created by NMFS? 3) Is this provision necessary?)
Alternative Process to NEPA. The discussion draft establishes criteria for a NEPA alternative process, and requires that alternative process to conform to MSA timelines. It requires public input, consideration of environmental impacts and cumulative effects of proposed action, and consideration of reasonable alternatives to the proposed action (all required under NEPA). (NOTE: Although the council chairs have been yammering to get out from under NEPA, the fishing industry may be better served by preserving, not deviating, from NEPA. Enumerating specific criteria runs the risk that something will be omitted, therefore, it may be better to just require NEPA compliance generally.)
Collection of Economic Data. Also under the discretionary provisions in Section 106 of the discussion draft is language allowing for the collection of economic data from fish processors.
Collection of Information. Section 201 of the draft gives the Secretary authority to implement information collection or observer programs.
Cooperative Research & Management. Section 203 of the draft would: 1) require the Secretary to establish a national cooperative research and monitoring program; 2) encourage coordination and information sharing with other agencies (federal and state) as well as academic institutions; 3) prioritize projects focusing on improved stock assessments, bycatch, conservation engineering, HAPC identification, and collection of socio-economic data; and 4) require the Secretary establish guidelines to ensure participation in research projects does not result in the loss of a fisherman’s catch history or unexpended DAS as part of limited entry system. (NOTE: There is also a House bill, HR 1431, the Fisheries Science & Management Enhancement Act (see below), that provides for cooperative research engaging fishermen and scientists. That bill, however, contains a funding source -- the reallocation of Saltonstall-Kennedy Act (S-K) funds -- whereas the Senate draft does not identify a funding source.)
Bycatch Reduction. Section 111 of the Senate discussion draft establishes a coordinated program to develop bycatch reduction technology and consult with councils to provide incentives to adopt new bycatch reduction methods. It also applies limited access (see below), to bycatch.

The Good, the Bad and the Ugly of the Senate Staff Draft:

Standards for IFQ Systems, Quota Auctions and Processor Quotas

The discussion draft from the Commerce Committee staff does contain some national standards for individual fishing quotas (IFQs), which many fishing groups have been calling for, to assure that such programs are designed to help fishermen, not turn them into “seafaring sharecroppers,” and that fishermen have a chance to approve any such program. IFQs simply won’t work for a lot of fisheries, and for a number of others IFQs are not wanted by the fleet.

NMFS, and at least one environmental group, have been clamoring for IFQs as the “cure-all” for fishery problems, to allow fleet “rationalization” (the euphemism used to describe putting fishermen out of business). Congress directed the agency to develop a set of standards for IFQ systems, such as who is to be granted quota, who may own quota shares, and how much quota any one individual/entity can hold. But NMFS blew off Congress and now that the Congressional moratorium on IFQ systems has expired, the regional councils are moving ahead with no standards in place.

While containing language for standards, the Senate draft bill is not as comprehensive as language in the House bill, HR. 3278, the Fishing Quota Standards Act. Among other things, the Senate bill does not contain a sunset provision for such systems. There is a lot of confusion and misunderstanding about sunsets and what they’re intended to do. In California, for example, nearly all fishery legislation, including the highly successful Salmon Stamp program and most of the statutorily-created limited entry systems, have sunset clauses, usually of five years duration. The reason for these is to ensure programs are still needed over a period of years and that, in fact, a program is being implemented as intended (e.g., to assure an agency has not taken off with the money and used it for purposes other than intended). Where programs have been successful, sunsets are regularly extended. Language to create sunset clauses in IFQ programs is not intended to diminish the value of the fishery or quota shares, but simply to assure there is a periodic review of the program and that it is working as intended.

Finally, before any fishing group starts calling for the heads of the staff who wrote language in the draft to create processor quotas, remember (or it’s our understanding anyway) that this was done to spark discussion and does not necessarily reflect the opinion of staff or any Senator.

The Senate staff discussion draft bill would also do the following:

Rename IFQs/DAPs. Define Individual Fishing Quotas/Directed Access Programs as “limited access systems” (the term California currently uses for many of its limited entry programs). Section 104 of the bill would further add requirements that limited access systems take into account the conservation requirements of the Act and the fair and equitable distribution of the resource.
Establish National Standards. Establish national standards in Section 107, but does not include sunset provisions (see above).
Allocation. Require consideration of catch history in setting the initial allocation, but does not include consideration of conservation in the allocation process. (NOTE: The staff language only requires that managers include measures to allow new entrants into the fishery “where necessary and appropriate” so this provision does not have a lot of teeth. The bill does not specify what constitutes an “excessive share.” The draft bill also does not explain what it means to “substantially participate” in the fishery.)
Program Review. Require review of a limited access system every 5 years. (NOTE: The language does not, however, elaborate on the criteria for review and approval and does not describe who is eligible to participate in the review process or how the results of the review will be feedback into the system.)
Fishermen Referendum. Not require, unlike HR 3278, a referendum among fishermen to establish or approve a limited access system. Instead, the bill permits minority rules by allowing fishermen to initiate a request for a limited access system and requiring that request be supported by only 1/3 of the participants in the fishery. The Secretary must certify the request before the council can develop a limited access system, but the bill does not describe the criteria needed for certification, nor (unlike HR 3278) provide for a final vote on a program among affected fishermen.
Auctions of Quota. Allow regional fishery councils to establish an auction system to collect royalties for the initial distribution of allocations in the limited access system.
Transfer of Quota. Allow transfer of fishing quotas. (NOTE: The staff draft does not make clear the objective of transferability provisions is to guard against excess consolidation of quota shares.)
Processor Quota System.Authorizes, but not mandate, a limited access system for processors and restrict the market. (NOTE: The draft bill language specifically states that the system is intended to maintain the historic harvester/processor balance. Includes provision such that these programs may not apply to New England fisheries ( p. 26, line13). The draft states that programs should provide for greater waste reduction, but it is unclear how processor quotas will accomplish this. It includes antitrust provisions to preserve competition.)

It is anticipated that Senate Commerce staff will take the comments it receives in both the August fishing industry sit-down and the written comments it receives by the 6^th of September and prepare a new version, perhaps to serve as the focus for a Commerce Committee MSA reauthorization hearing. Comments on the Senate Commerce Committee draft can be addressed to Mr. Matt Paxton, Commerce, Science & Transportation Committee, U.S. Senate, Washington, DC 20510.

A Senate End Run to Create Pacific Whiting Processor Quotas

While staff on the Senate Commerce Committee and some members of the House are wrestling with the development of standards and guidelines for IFQs and other types of limited access for the regional councils and NMFS to follow, at least one Senator, Gordon Smith (R-OR), is charging ahead, sans standards, with legislation to create a processor quota system for the Pacific whiting fishery. S 1549, the “Cooperative Hake Improvement & Conservation Act,” was apparently introduced at the behest of a fishermen’s whiting co-op and some large whiting processors. This bill is a clear attempt to circumvent the Pacific Council and get something in place, “while the gittin’s good,” for some larger vessel whiting fishermen and processors before anyone can hit them with any “pesky standards.”

In an August 2nd letter to the Pacific Fishery Management Council, Senator Smith said the bill was intended to “rationalize the shore-based Pacific whiting fishery by providing cooperative shares to fishermen and processors who have historically participated in that fishery.” Smith went on to say in his letter, “a whiting cooperative plan holds great promise for our coastal communities by improving the economics of the fishery. Most recently the need for such a plan was highlighted by the unexpected change in salmon bycatch problems that resulted in new restrictions on the whiting fleet.”

Prior to charging ahead with processor quotas for Pacific whiting (hake), however, it may be good to see how well the economics of the BSAI crab fishery improve under processor quotas or at least who the economics improve for. It would be useful as well to look at which processors will cut a fat hog off a whiting processor quota system and, further, examine the size of their campaign contributions to the Senator. If the Senator is truly concerned for the salmon fishery, he could, of course, support removal of the four lower Snake River dams that are impeding salmon recovery in the Columbia, work to restore flows to the Klamath and back the removal of the PacifiCorps dams in that river that are blocking fish passage and impairing water quality.

Over in the House

Although there is no House bill out to reauthorize the MSA, at the time of this writing there are two bi-partisan bills of significance in the House to amend the MSA. These bills, we believe, will be good for fishermen and good for fish stocks, but they are not without their detractors. If they are not adopted as stand alone bills, the language in them, or the concepts at least, should be incorporated in any MSA reauthorization bill Congress passes.

The first of these (mentioned above) is HR 1431, the Fisheries Science & Management Enhancement Act. This bill would implement many of the fishery recommendations that came out of the U.S. Oceans Commission, as well as expand upon and fund fishermen’s cooperative research programs that have been successful in New England and in some places here on the west coast. HR 1431 would provide for:

Appointment of Scientific & Statistical Committees. Requires the Secretary to appoint and compensate members of each council’s Science & Statistical Committee (SSC), who would be qualified Federal, State, academic, or independent scientists, with no financial interest in any fishery, who have demonstrated scientific expertise in fisheries science or marine ecology, or economics or social science as it relates to fisheries management. (USCOP recommendation 19-1)
SSC Fishery & Marine Science Subcommittee. Requires each SSC to include a Fishery & Marine Science Subcommittee (FMS), drawn from members with scientific expertise in fishery biological science or marine ecology, to be responsible for making scientific determinations including allowable biological catch and bycatch limits, habitats in need of protection, and additional species protections. It would also require fishery management plans to contain management measures consistent with the determinations made by the FMS Subcommittee. (USCOP recommendations 19-2, 19-3).
Peer Review. Requires periodic peer review, by qualified independent scientists appointed by the Secretary, of each council’s FMS Subcommittee. (USCOP recommendation 19-4).
Cooperative Research. Requires the Secretary to establish a Cooperative Research, Data Collection & Gear Modification Program, involving fishermen and scientists. (USCOP recommendation 19-9). The cooperative research program is funded with $70 million in Saltonstall-Kennedy Act (S-K) monies.
Regional Fishery Council Membership. Requires, through explicit language (although current law does not prohibit) a range of qualified individuals, including the public, be considered for membership on the regional fishery councils. (USCOP recommendations 19-12, 19-13). (NOTE: This language retains that from the 1986 reauthorization that members must have knowledge or experience in the fisheries, and it further elaborates on the requirement for a balance of interests on the councils, which Commerce/NMFS has frequently ignored.)
Training of Fishery Council Members. Requires the Secretary to provide newly appointed council members with training, within six months of their appointment, in the following areas: (1) fisheries science and stock assessments; (2) basic ecology; (3) social science and fishery economics; (4) the requirements of the MSA, NEPA, APA and other relevant statutes or regulations; (5) conflict of interest policies that apply to council members; and (6) the public process for developing fishery management plans. Newly appointed members are restricted from voting on any council decision until they have completed the required training. (USCOP recommendation 19-14).
Controlling Conflicts of Interest. Prohibits a council member from voting on any matter that would affect a financial interest that member has disclosed. Members of the public may request Secretarial review of a determination to decide whether a council member voted on a matter that would have an effect on the council member’s financial interest. If a council member voted on a matter from which he or she should have recused him/herself, and his/her vote decided the council action, it shall be treated as a cause for invalidating or reconsidering the council action. (NOTE: This language does not prohibit a member from participating in discussions on an issue, only on voting on an issue where the member has a financial interest. This language, however, does not really get at the problem of individuals who are attorneys, lobbyists, executive directors or staff for organizations representing stakeholders, nor does it get at state representatives whose administrations are hostile to fish protections affecting other interests (e.g., hydropower, timber, water diversion, oil and gas).)

The other bill in the House that should be helpful for most fishermen is HR 3278, the Fishing Quota Standards Act of 2005, to establish national standards to protect fishermen in the implementation of IFQ programs (see USCOP recommendation 19-15). This legislation was requested by New England fishermen, (it was initially introduced by Tom Allen (D-ME), Christopher Shays (R-CT) and William Delahunt (D-MA)), but there was input into its drafting and support for it from west coast and Alaska fishermen’s organizations. Among other things, the bill would provide for:

IFQ Referenda. Requires that a referendum be conducted of affected fishermen, prior to the implementation of any IFQ program.
Performance Standards. Requires IFQ systems to demonstrate they are fulfilling the purpose they were established for, such as conservation and fleet safety.
Specifying Who May Hold Quota. Maintains preference for fishermen, which may include crew holding quota shares, limiting processors or other non-fishermen ownership to that which existed at the outset of the program.
IFQs Not a Property Right. Specifies that quotas are not property rights and requires periodic review of programs and a seven-year sunset that may be renewed if the program is performing as intended.
No Monopolies. Prevents excessive ownership of shares by any individual/entity by limiting quota ownership to one percent of the total quota unless a council can demonstrate that such an increase will not be detrimental to other quota holders.

What’s Missing in the Reauthorization Discussion

To date, two important issues have gone missing from the discussion of MSA amendments and reauthorization. Both were the subject of the two ocean commissions’ reports and both have a direct bearing on the management and conservation of marine fisheries. Those are:

Funding. Part of the reason many U.S. fisheries are currently in trouble is not simply a policy or institutional failure, but the refusal for three decades by various Administrations, Congress, NMFS and industry itself to develop a funding source to assure sufficient monies are available to carry out the research, data collection, management, enforcement and gear development essential for conducting and maintaining sustainable fisheries. Both the Pew Commission and the USCOP recommended the establishment of a trust fund or funds to provide monies necessary for the conservation of ocean resources and fisheries (USCOP even recommended offshore leasing as the source of funds for an ocean trust fund), but to date neither the Bush Administration nor anyone in Congress has taken this up (for more information, see the August 2003 Fishermen’s News article, “Planning and Paying for Future Fisheries Research,” at: www.pcffa.org/fn-aug03.htm).

Ocean Aquaculture. Proposals for open ocean aquaculture in the U.S. Exclusive Economic Zone (EEZ) have a direct bearing on the conservation and management of our nation’s marine fisheries, but to date the aquaculture legislation (see the article by Mitchell Shapson in this August’s Fishermen’s News at: www.pcffa.org/fn-aug05.htm) is being treated separately from MSA as if the two were not connected.

Aquaculture needs to be brought under the MSA, not be separate from it, with a strong set of national standards to assure the process for planning and leasing fish farms in the open ocean is subject to the public process and transparency in the MSA. Most important, aquaculture must be brought under the MSA to assure the protection of wild stocks (from parasites/disease, predation, interbreeding, pollution), the protection of the fishing industry (from corporate predatory practices, preemption of fishing grounds, endangerment of fishing operations), and the protection of the public (maintaining labor standards and ensuring that such operations result in a net increase in protein production, not diminish it).

So there you have it. Barring some unforeseen events, we can expect discussions to begin in earnest this fall and well into next year, after 10 years, on reauthorizing the MSA. Given some of the issues in play, such as processor quotas, it is incumbent on fishermen and their organizations to be informed and get involved. It’s your future!

Zeke Grader is an Attorney as well as the Executive Director of the Pacific Coast Federation of Fishermen’s Associations (PCFFA), the west coast’s largest trade association of commercial fishing families. Glen Spain is the Northwest Regional Director of both the Institute for Fisheries Resources and PCFFA. PCFFA can be reached at its Southwest Office at PO Box 29370, San Francisco, CA 94129-0370, (415)561-5080, and at its Northwest Office at PO Box 11170, Eugene, OR 97440-3370, (541)689-2000 or by email to: fish1ifr@aol.com. PCFFA’s Internet Home Page is at: www.pcffa.org.