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stocks have experienced severe losses and are being considered for 

 petition action to list them for protection. This is a tragic 

 pattern which cannot be allowed to continue. Crisis management 

 must cease. NMFS must take a pro-active stance to prevent 

 problems. This can only be done by mandating immediate reductions 

 in incidental takes, based on the data which has been gathered 

 during the past five years. Investment in preventing problems is 

 much less expensive fiscally and biologically than the cost of 

 trying to correct serious species depredations. 



When Congress passed the interim exemption program in 1988 it 

 directed NMFS develop a plan to expeditiously reduce unnecessary 

 mortality. Instead of immediate action, NMFS has proposed a system 

 which, by their own admission, will not even begin to address the 

 critical issues of quotas of marine mammal takes, or the 

 development of monitoring systems and enforcement measures for AT 

 LEAST two more years. During that time NMFS has stated that it 

 expects fisheries to effect voluntary reductions in marine mammal 

 mortalities. Voluntary reduction in kill was also a charge made by 

 Congress to the industry during the present five-year exemption 

 program. However, such voluntary reductions have not occurred. 

 Without a system to inform fisheries of a mandatory cap on 

 incidental take, and without a way to monitor and strictly enforce 

 such a system, reductions in mortality will not occur in the 

 future. Therefore, we make the following: 



SUMMARY OF RECOMMENDATIONS 



1. Establishment of fishery-specific regulations limiting 

 take of marine mammals, to be in place within two years 

 of reauthorization of the MMPA (the Act) . 



2. The allocation of monies to fund and conduct research 

 into mitigation techniques to reduce incidental take. 



3. The immediate and continual reduction of incidental and 

 intentional lethal takes of marine mammals toward the 

 zero mortality rate goal of the MMPA, with immediate 

 emphasis on endangered, threatened and depleted stocks. 



4. The use of historic carrying capacity wherever possible 

 as a basis for making decision on Optimal Sustainable 

 Populations (OSP) of marine mammals. 



5. Strict and mandatory enforcement and penalties to 

 ensure compliance with all portions of the Act and its 

 regulations relating to issues such as registration, 

 monitoring of catch, and quotas. 



6. Reduction of inequities in the permitting process that 

 may result in unnecessary deaths of marine mammals. 



