8 



The Commission also believes that there is particular merit 

 in the process that the National Marine Fisheries Service has 

 proposed to assess and monitor the status of affected marine 

 mammal stocks and to identify priority research and monitoring 

 needs. The process will ensure critical scientific peer review 

 and opportunity for public participation. Further, it will 

 ensure that available funding and personnel are focused on the 

 most critical problems. 



Although the Commission believes that the Service's proposal 

 is conceptually sound, it has questions, as noted earlier, about 

 several aspects of the proposal. It is not clear, for example, 

 how the Service would identify or in status-of-stocks reports 

 take into account habitat degradation or destruction resulting 

 from such things as coastal development, offshore oil and gas 

 development, or fisheries-caused declines in important marine 

 mammal prey species. Also, it is not clear whether the sfC)ck 

 assessments would consider possible subtle decreases in survival 

 or productivity that could result from repeated disturbance, 

 environmental pollution, or other factors that may have sub- 

 lethal effects. Further, it is not clear whether the formula 

 proposed to be used to calculate the Potential Biological Removal 

 would prohibit authorizing in all cases take levels that would 

 cause a population stock to be reduced or maintained below its 

 maximum net productivity level. For example, if the growth 

 potential of a population is being affected by habitat 

 degradation, stress due to repeated disturbance, or some type of 

 direct human-caused mortality not identified or included in the 

 total allowable take, the use of the default values proposed to 

 be used to calculate the Potential Biological Removal when the 

 population growth rate is unknown could result in authorizing 

 take levels that cannot be sustained and which would not prevent 

 the affected population from being reduced or maintained below 

 its maximum net productivity level. 



Thank you Mr. Chairman and members of the Subcommittee for 

 this opportunity to advise you of the Marine Mammal Commission's 

 views on this important issue. I would be pleased to try to 

 answer any questions you may have. 



