One of the biggest issues being brought before the North Pacific Fishery Management Council (NPFMC) during its quarterly meeting on October 1 – 9, 2009 at the Hilton Hotel in downtown Anchorage has a really long title. It is Proposed Ammendment 94 to the Fishery Management Plan for Groundfish of the Bering Sea and Aleutian Islands Management Area to Require Trawl Sweep Modification in the Bering Sea Flatfish Fishery, Establish a Modified Gear Trawl Zone, and Revise Boundaries of the Northern Bering Sea Research Area and Saint Matthew Island Habitat Conservation Area 1. Wheww. That is long. The long and the short of it are this.

The yellow fin sole and other flat fish fishery wants more area in the Bering Sea to fish in. This because they say that the fish they want to catch is moving north due to climate changes in the Southern Bering Sea. We have a different opinion. And they want to use a “modified gear change to their fishing gear” that a scientist from the National Marine Fisheries Service says, “will lower the substrate destruction in this fish prosecution.” This is the “modification” that they are talking about. They are putting rollers on the cable that drags along the bottom of the ocean to lift that cable two inches off the bottom so “other life on the bottom” will not be disturbed. To be fair, they said the other life will not be destroyed as much as they would be if the rollers were not put on this really large and long heavy cable used to drag the bottom. Well this is going to destroy the bottom of the Bering Sea in any event. Now we must ask some questions about this proposed change in the Bering Sea Fishery Management Plan.

One is; on the research done to determine that this practice will do less harm, was there any peer review done to verify this data? The second question is; when the NPFMC is proposing to open up a here-to-fore Northern Research Area right next to Saint Matthew Island probably the size of Rhode Island, are there any other oversight issues and Federal and State Agencies that need to be consulted?

And finally; do the people who are to be most affected by this change need notification and consultation before a final rule is made? Just looking at the issue of the research and its findings, I am wondering why a "peer review" process was not done before the findings are made public. According to a news release in 2003 from the Office of Management and Budget, OMB, whenever any Federal Agency is involved in any research the size of this one, OMB says, "...all significant regulatory-science documents will be subjected to peer review by qualified specialists in appropriate technical disciplines." (Emphs my own). In a discussion I had with the researcher, there was none. Also the Data Quality Act passed by Congress states further: "...requires federal agencies to issue information quality guidelines ensuring the quality, utility, objectivity and integrity of information that they disseminate and provides..." (Emphs my own). I am wondering if this has been done.

It is time for the owners of this most precious resource, We The People, to ensure that how these resources are used to line the pockets of a few multi-national big business companies do so while following the laws we all have to follow. And to ensure that any Federal Agency responsible for any research done to seemingly support these big business companies, do the same. Can there be conflict of interest? Sure.