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yearly data on effort, registration, reporting and takes in time to recognize trends in fishing 

 activity, reporting behavior or marine mammal populations. For example, if reported kills 

 decreased in a particular fishery between 1990 and 1991, was it due to cleaner fishing, 

 decreased reporting, reduced fishing effort, or decline in the presence of marine mammals in 

 the area? The agency's ability to answer such questions is crucial to managing marine 

 mammal/fishery interactions and to achieving the zero mortality rate goal of the act. 



In addition, the following problems have plagued the marine mammal exemption 

 database. Many of these problems will be discussed in detail in a forthcoming CMC 

 publication "Incidental Take of Marine Mammals in Commercial Fisheries of the U.S." 



• All information, observer and logbook, is submitted, entered, and analyzed at 

 the regional level. This approach has not been conducive to real-time 

 enforcement or verification and has contributed to delays in the verification and 

 quality control at the agency's headquarters. 



• There is no uniform standard of total fishery effort. Each fishery/owner 

 records fishing effort differentiy. The best example are gillnetters, who may 

 record effort as time on the water, the number of hours a single net was fished, 

 or the number of hours several nets were fished. Furthermore, effort as 

 recorded by vessel owners and observers is often inconsistent and thus does not 

 lend this data to accurate statistical verification or comparison. 



• Although the agency has attempted to use landing data to determine the 



number of vessels in a particular fishery, for the most part, the nature of the 



