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"universe" for many fishcncs is sull unknown. There arc vessels that are not 

 registered and are unaccounted for in the estimated number of vessels in a 

 fishery. As demonstrated above in Table A. not all vessels registered submit 

 logbooks, but may continue to fish. These two factors contribute to a probable 

 underestimation of marine mammal interaction, injury, and mortality, and an 

 overall inability to estimate accurately the level of MMEP participation by the 

 fishery. 



• All the above results in a serious underestimate of total marine mammal take, 

 since the agency has no idea what proportion of total fishing effort the 

 logbooks represent, nor a uniform standard to measure that effon. 



• Finally, enforcement has been minimal. No instance is known of an 

 authorization to fish having been deniecf because of failed registration or 

 reporting, nor has any in-season regulatory action occurred based on either 

 observer reports or logbook data. Since the inception of the program, the 

 agency has prosecuted only a few incidents of illegal marine mammal takes. 



Marine Mammal Interactions 



The magnitude of the marine mammal interactions is demonstrated by the information 

 generated by the NMFS interim exemption program. Although that program has been 

 nowhere near as successful as had been hoped in generating data, it is clear that take 

 incidental to fishery operations is a problem of substantial proportions. Based on reports 

 submitted by fisheries themselves, 250,000 marine mammal interactions with fishing gear 



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