Chapter III — Marine Mammal/Fisheries Interactions 



consultations and requested the Service to provide it 

 with any proposals or draft plans that may have been 

 developed. The Commission also sought information 

 on the Service's plans for undertaking or supporting 

 research to further the goals of the International 

 Dolphin Conservation Program and for promulgating 

 implementing regulations. 



As discussed in the Commission's previous annual 

 report, the Service responded by letter of 22 October 

 1997, summarizing its plans for, and describing 

 progress it had made toward, implementing the 

 amendments. The Service also indicated that it would 

 be drafting regulations to implement the 1997 amend- 

 ments in stages. Because development of the regula- 

 tions would be dependent, in part, on the terms of the 

 international agreement then being negotiated by the 

 signatories to the Declaration of Panama, no firm 

 schedule could be provided. 



The Commission wrote to the Service on 27 March 

 1998 seeking additional information on the Service's 

 plans for carrying out the research mandated by the 

 International Dolphin Conservation Program Act. 

 The Commission expressed concern that plans were 

 being made and work proceeding without the required 

 consultation with the Commission. The Commission 

 noted, for example, that a Commission representative 

 had participated in a 17-18 December 1997 meeting 

 to consider the design of the 1998 dolphin abundance 

 survey, but had received no further information on the 

 Service's plans for this project. The Commission had 

 been advised that work was under way on the review 

 of stress-related literature, but had not been provided 

 with terms of reference or consulted on the scope of 

 the review. Similarly, the Commission noted that it 

 had yet to be consulted on two other studies, the 

 necropsy sampling project and the analyses of histori- 

 cal biological and demographic information, that, 

 presumably, were scheduled to begin soon. 



The Commission also commented on the proposed 

 schedule for the planned field experiment in which 

 dolphins will be repeatedly chased and captured to 

 assess the immediate and cumulative effects of chase 

 and encirclement. The Service had indicated that the 

 study would be undertaken in calendar year 2000. 

 The Commission agreed with the Service that thor- 

 ough planning of the project was essential, but ques- 



tioned the decision to delay the experiment until the 

 third year of the research program. 



On 15 May 1998 the Marine Mammal Commission 

 received a draft research plan from the National 

 Marine Fisheries Service's Southwest Fisheries 

 Science Center covering the various projects being 

 proposed to satisfy the requirements of the Interna- 

 tional Dolphin Conservation Program Act. The 

 Service requested the Commission's comments before 

 release of the plan to the public. 



The Commission provided comments on the draft 

 research plan by letter of 29 May 1998. The Com- 

 mission noted that preparation of the draft plan was a 

 positive step toward meeting the consultative and 

 other requirements of the Act, but believed that, 

 because most of plans for the proposed research were 

 still being developed, the draft lacked sufficient detail 

 to allow for a meaningful review. The Commission 

 therefore voiced its expectation that, as comprehensive 

 research plans are developed, the Commission would 

 be given an opportunity to review and comment on 

 them before work begins. The Commission believed 

 that, to be reviewable, the plan for a particular 

 research project should provide (1) a statement of its 

 goals or objectives; (2) a description of the methodol- 

 ogy to be used (e.g., what will be sampled or mea- 

 sured and how, how many measurements will be 

 made or samples collected, what analyses will be 

 done, etc.); (3) a proposed schedule; (4) the proposed 

 budget; and (5) as needed, an analysis showing the 

 statistical power of the project to meet its objectives. 



The Commission stressed the need to complete 

 plans for and to begin certain research projects 

 expeditiously so that the Service could collect suffi- 

 cient information to make its initial finding in March 

 1999 as to whether chase and encirclement are having 

 a significant adverse impact on any depleted dolphin 

 stock. The Commission believed that the Service 

 should make a concerted effort to obtain at least 

 preliminary results not only from the dolphin abun- 

 dance survey, but from the literature review and the 

 necropsy study, in time to factor them into the initial 

 determination. Further in this regard, the Commis- 

 sion expressed concern that, unless the necropsy 

 program were initiated soon, the Service may not be 

 able to collect and analyze a three-year series of 



119 



