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coverage. In 1990. 8 out of 1 1 (73 percent) of the Category 1 fisheries had a percent observer 

 coverage less than the 20 to 35 percent mandated by Congress. In 1991. only four of nine 

 Category I fisheries had observer coverage less than the mandated level. For those eight 

 fisheries in 1990 and the four in 1991 the observer coverage ranged from five to ten percent. 



Program Criticisms 



One of the ongoing criticisms of the Marine Mammal Exemption Program has been 

 the lack of current information. Agency verification, data entry, receipt of logbooks from 

 captains, receipt and analysis of observer data, all have fallen far beyond expected schedules. 

 For example, it has become apparent that some fishermen waited until the beginning of their 

 new season to submit logbooks from the previous season, rather than at the completion of 

 their fishing season or by December 3 1 of the year fished, as required by the program 

 regulations [54 Fed Reg 51718 (December 15. 1989)). It is unclear whether NMFS enforced 

 the logbook deadline requirement by refusing to issue a current season decal to skippers who 

 turned in overdue logbooks. This delay has meant that the agency annually reclassifies 

 fisheries without benefit of the results of the preceding year's data. 



A second problem emerged when the agency undenook its logbook verification 

 analysis. This analysis revealed that observed days' marine mammal interactions did not 

 mirror the same days' logbook reports. At the same time, the tardy verification process was 

 not conducive to correcting errors associated with late reporting because such errors were not 

 caught until far after the event. The lag time also has meant the agency has not compared 



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