Comment from David Gilbertson

I have been heavily involved in the butterfish export business since 1981, mostly with Tokai International. Tokai specializes in exports to Japan, and I speak Japanese, having living there for nearly 20 years. The Japanese market for butterfish is the best market for this fish, in that the prices obtainable there are higher than any other markets. However, the Japanese have certain requirements for butterfish. The fish must have high fat content, and they must have minimal, if any, feed content. The fat content gives the fish its good flavor and hence a high price, but any feed content will cause the fish to deteriorate and become, eventually, without any value at all. Butterfish feed heavily in the Fall, and in a normal year, the fat content becomes acceptable in November. It is best in December and still good in January. Within February, the fish become leaner, and their value drops quickly. By late February, the fat is low and the market loses interest in them. I understand that quota may soon be issued for a directed fishery for butterfish. Please understand that in terms of economic value, the timing of the catch is critical In order to maximize its economic value, the 2013 butterfish fishery must be allowed to begin absolutely as soon as possible, that is, on January 1st. Any delay in the opening will shorten the amount of time during which high-value fish can be caught. Any delay will result in an unnecessary waste of resource. The Japanese market for our butterfish has changed considerably since the 1980s and 1990s. Consumers have largely forgotten our butterfish, as processors have substituted other species. However, if you allow this fishery to proceed wisely, that is, allowing the catch of butterfish that meet the requirements of the Japanese market, we will be able to rebuild the market and the fishery in a way that will maximize the economic value of the catch. Please help us do so by allowing the catch to begin on January 1