Comment from Harold Brown

First of all, I do not believe that Herring Midwater Trawl Vessels should fish in Groundfish Areas because of food chain and fairness issues. My experiences catching Groundfish have demonstrated to me that they definitely forage on Herring and removal of undetermined percentages of forage is not defensible in my opinion. Secondly, allowing dumping of any portion of Herring tows without sampling will result in data which are incomplete and potentially unrepresentative. Thirdly, the potential for an unscrupulous Captain to dump tows which visually have a high percentage of Groundfish bycatch'potential discards will skew the data. Therefore, my conclusion is that all tows must be sampled, whether or not they are actually harvested. No catch should not be subject to at-sea sampling.