Even when the best scientific information is fully used, 

 however, there is still room for differing interpretations 

 of that information with regard to the levels of risk to 

 nontarget marine mammals and endangered species associated 

 with various levels of harvesting. Where the data do not 

 clearly demonstrate risk levels, a range of interpretations 

 is possible, with the two extreme positions being: 



1. that an adverse impact of a particular level of 

 fishing cannot be demonstrated conclusively and, 



2. that the safety or lack of adverse impact of a 

 particular level of fishing cannot be demonstrated 

 conclusively . 



Fishery management plans available as of late 1978 seem 

 to indicate an underlying assumption that the councils do not 

 need to take the responsibility for demonstrating that pro- 

 posed OYs have acceptably low associated levels of risk to 

 nontarget populations. Instead, the councils apparently in- 

 tend to wait until adverse impacts of fishing levels on marine 

 mammal or endangered species populations can be demonstrated 

 to have occurred before modifying OY to mitigate those impacts 



ALTERNATIVE APPROACHES 



The analysis of the intents and requirements of the 

 FCMA, MMPA and ESA in this report indicates that the three 

 Acts together mandate an ecosystem level perspective for 

 fisheries management as opposed to the traditional single 

 species approach. The analysis of representative fishery 

 management plans indicates that while the plans have recog- 

 nized the requirement for a more broadly based perspective 

 on fisheries management, in practice they have not fully 

 reflected this recognition in the selection of optimum 

 yields and related conservation and management measures . 

 Consequently, the question emerges of how fishery manage- 

 ment plans can be changed in order to more fully meet the 

 intents of the legislation as well as the requirements of 

 sound management. 



This section of the report deals with specific sug- 

 gestions for changing fishery management plans to begin to 

 achieve an ecosystem level perspective on fisheries manage- 

 ment. With presently available data and theory from ecology 

 and fishery management, steps toward an ecosystem perspec- 

 tive which are feasible now include developing foodweb dia- 

 grams or conceptual ecosystem models , incorporating infor- 

 mation on predator prey interactions , assessing the risks 



42 



