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of marine mammals have been accepted for or proposed for listing 

 under the Endangered Species Act or the MMPA for depleted 

 status. Two additional stocks have experienced severe losses and 

 are being considered for Petition action to list them for protection. 



Research to develop methods and technology to reduce kills has 

 not occurred except in crisis situations. This tragic pattern of crisis 

 management must cease. NMFS must take a proactive stance to 

 prevent problems. It must fund mitigation research and mandate 

 immediate reductions in kills based on data gathered during the 

 past five years. Investing in preventing problems is much less ex- 

 pensive fiscally and biologically than trying to correct serious spe- 

 cies depredations. 



Compliance with the Act is also decreasing. The past five years 

 have shown declines in both the number o^ boats registered and 

 the number of logbooks submitted by boats. Submitted logbooks se- 

 riously underestimate take. Onboard observers find on average six 

 times as many animals killed as reported. Some fishers refuse to 

 take observers. Enforcement borders on the nonexistent. These are 

 but a few of the problems of the existing program. They are de- 

 tailed more in our written statement to which I hope you will 

 refer. 



Development of a regime which achieves a verifiable and signifi- 

 cant reduction in marine mammal mortality is paramount. We, 

 therefore, make the following recommendations: One, establish- 

 ment of fishery-specific regulations limiting the take of rnarine 

 mammals to be in place within two years of the authorization of 

 the MMPA. Two, allocation of moneys to fund and conduct re- 

 search into mitigation techniques to reduce marine mammal mor- 

 tality. Three, the immediate and continual reduction of incidental 

 and intentional lethal take to work toward the zero mortality rate 

 goal of the MMPA with emphasis on endangered, threatened, and 

 depleted stocks. 



Four, the use of historic carrying capacity wherever possible as a 

 basis to make decisions on Optimal Sustainable Populations. Five, 

 strict and mandatory enforcement and penalties to ensure compli- 

 ance with the Act and its regulations on issues of registration, 

 monitoring of catch and quotas. Six, reduction of omissions and in- 

 equities in the permitting process. 



I would like to close by emphasizing that prior to human exploi- 

 tation in fisheries interactions, marine mammals did not overpopu- 

 late, degrade the environment, or deplete fisheries resources. To 

 the contrary, before the development of large-scale fisheries, stocks 

 of marine mammals and commercially important fish stocks were 

 at an all time high. It is not necessary to allow high rates of kill of 

 marine mammals to support viable and productive fisheries. There- 

 fore, we implore Congress to reauthorize a strong MMPA which in- 

 cludes our recommendations. We believe that this approach will 

 provide for the recovery of marine mammals and the wise conser- 

 vation of marine resources and is in keeping with the wishes of the 

 American people and the spirit and the intent of the MMPA. 



Once again, I would like to thank you for the opportunity to ad- 

 dress the subcommittee with our concerns. We are happy to assist 

 you in any way to improve this critical situation. Thank you. 



