2. possible impacts on marine mammals and other non- 

 target species, endangered or otherwise, are not 

 being considered fully, or effectively incorporated 

 into selection of optimum fishery yields, so that 

 fishery management plans also are not fully con- 

 sistent with the intents and provisions of the 

 MMPA or the FCMA; and 



3. while some scientists and administrators feel that 

 the goals of the FCMA, the MMPA, and the ESA may 

 be incompatible and/or that available data are in- 

 sufficient to develop multi-species, ecosystem- 

 oriented fishery management plans , the three Acts 

 do appear to be compatible. For many areas, data 

 are sufficient to develop multi-species , ecosystem 

 oriented management plans, and at least to assess 

 the risk of impacting target species , dependent 

 species, associated species and the ecosystems of 

 which they are a part. The scientific question of 

 assessing risk levels and the policy question of 

 the acceptability of those risk levels tend to be 

 confused and should be considered separately. 



To overcome these deficiencies and perceptual problems , 

 the following actions are recommended: 



1. Persons with expert knowledge of marine mammals, 

 birds, etc. , should be included on the scientific 

 and statistical committees of the regional fishery 

 management councils and should be involved in the 

 preparation of draft fishery management plans ; 



2. The guidelines for preparation of fishery manage- 

 ment plans should be amended to ensure that plans 

 take account of the potential impacts of a fishery 

 on other components of the marine ecosystem, i.e., 

 nontarget fish, marine mammals, birds, etc., in 

 order to be consistent with the intents and provi- 

 sions of the MMPA and the ESA as well as the FCMA; 



3 . Fishery management plans should contain conceptual 

 ecosystem models to illustrate the trophic and eco- 

 logical interactions among target and nontarget 

 species ; plans should incorporate techniques for 

 modeling predator prey interactions and whole eco- 

 systems into evaluation of impacts on nontarget 

 species, and should include assessments of risk 

 levels associated with alternative harvesting levels; 

 and 



vn 



