of the management plans. The plans also appear to fall 

 short of meeting the intents of the MMPA by not consider- 

 ing the needs of marine mammal populations or the impacts 

 of proposed catch levels on those populations. At least 

 some preliminary treatment of the impacts on predator prey 

 interactions could have been made with the data available 

 in the plans. 



The broad brush treatment of ecological relationships 

 in fishery management plans , in comparison to the detailed 

 information included on economic and social aspects of a 

 fishery, in part reflects the nature of the NMFS Guidelines 

 for Development of Fishery Management Plans (42 FR 34458, 

 July 5, 1977). In the sections on definitions and standards, 

 the Guidelines make occasional references to habitat but no 

 specific references to marine mammals, endangered species, 

 or nontarget species. The section on plan contents con- 

 siders interrelationships of species and habitat in very 

 broad terms. Similarly, the section on plan format contains 

 only one item for ecological relationships, but seventeen 

 items for economic and social characteristics of the fish- 

 ery. While data on ecological interrelationships are seldom 

 as abundant or detailed as those on economic and social 

 characteristics, ecological data can be organized around 

 relevant considerations such as populations of marine mam- 

 mals in relation to optimum carrying capacity and maximum 

 productivity, or the status of endangered species and the 

 respective required recovery plans. For other nontarget 

 species, an eventual selection of management and conserva- 

 tion measures that constitute maximum benefit to the nation 

 will require information on the trophic and ecological re- 

 lationships involving target and nontarget species, the com- 

 mercial, recreational, and aesthetic values of nontarget 

 species, and their role in maintaining the health of the 

 marine ecosystem in terms of its diversity, stability and 

 resilience . 



The failure to attempt an ecosystem level perspective 

 in the management plans has been attributed in part to a 

 lack of the data required for such an undertaking. However, 

 even the available data have not been used to the fullest 

 extent in order to estimate impacts on predator prey relation- 

 ships , or risk of adverse impacts to marine mammals or en- 

 dangered species, for example. It seems clear that more com- 

 prehensive data analysis could have been undertaken in the 

 plans. The data required to fill the gaps which prevented 

 consideration of impacts on nontarget populations should 

 have been identified. 



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