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While commercial fishermen have expressed concerns about how 

 marine mammal takes would be allocated, non-fishery user groups 

 — such as Native populations and the public display industry -- 

 are concerned about the impacts of PBR allocations on their 

 needs. 



To date, no long-term management alternatives to the PBR-based 

 regime have been suggested. Some portions of the fishing 

 industry have proposed a continuation of the current exemption 

 program. 



1. NMFS has estimated that the cost of the new program will be 

 approximately $19 million annually for research into stock 

 assessments, fishery observers, enforcement and data analysis. 

 Given current budget restrictions, is the funding available to 

 support such a program? Should user fees be established to pay 

 for observers and other costs? 



2. A number of the marine mammals stocks for which PBRs will be 

 determined are highly migratory. Takes may occur in Canadian, 

 Caribbean, or Latin American waters. Will we be penalizing U.S. 

 fishermen by first determining the level of non-U. S. removals and 

 then establishing allocations for U.S. fishermen based on the 

 remaining potential removal? 



3. Is it practical or appropriate to assign the PBR allocation 

 process to the Regional Fishery Management Councils? 



4. How will removals be monitored and enforced? 



5. Are alternatives to the NMFS proposal available? If so, what 

 are they? 



