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concerned that the regime proposed by the agency focuses only on fishing takes without a 

 mechanism to integrate mortality from other human activJDCs. 



• Acquisition of inrormation on the status and trends of marine mammal 

 stocks is critical to making sound conservation decisions. 



Although the Act calls for such research now, it docs not set priontjcs. In an effort to 

 focus the agency's limited fiscal resources, criteria for setting data collection priorities should 

 be pan of the reauthorization. The agency proposal sets such an ambibous schedule for 

 collecting all of the scientific data necessary, that we fear it cannot be accomplished with 

 reasonably available resources. 



• Endangered marine mammals should receive no less protection than other 

 endangered species. 



Incidental takes of endangered and threatened marine mammals should be governed in 

 accordance with the provisions of the Endangered Species Act, including Section 7 

 consultations. As such, we disagree with the agency proposal that would allow intentional 

 lethal takes of threatened and endangered marine mammals. 



• The MMPA should provide a means to focus its regime to govern 

 incidental takes on activities where those incidental takes create a 

 biological problem for the marine mammal population or stock. 



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