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y MuANCE OF Marine Mammal 

 Parks AND Aquariums 



Dedicated to Consen'atwn through Pubhc Display, Education and Research 



STATEMENT OF 



THE ALLIANCE OF MARINE MAMMAL PARKS AND AQDARIDMS 



AND THE AMERICAN ASSOCIATION OF ZOOLOGICAL PARKS AND AQuARICHS 



REGARDING THE NATIONAL MARINE FISHERIES SERVICE PROPOSED REGIME 



TO GOVERN INTERACTIONS BETWEEN MARINE MAMMALS 



AND COMMERCIAL FISHING OPERATIONS BEFORE 



THE SUBCOMMITTEE ON NATURAL RESOURCES 



APRIL 20, 1993 



The Alliance of Marine Mammal Parks and Aquariums 

 ("Alliance"); an association of 25 zoos, aquariums, mari/ie life 

 parks and research facilities; and the American Association of 

 Zoological Parks and Aquariums ( "AAZPA" ) , an association of 159 

 zoos and aquariums; submit this written testimony on the National 

 Marine Fisheries Service ("NMFS") Proposed Regime to Govern 

 Interactions Between Marine Mammals and Commercial Fishing 

 Operations ("Proposed Regime"). 



The 1988 Amendments to the Marine Mammal Protection Act 

 ( "MMPA" or "Act") mandated the development of a management 

 program for marine mammal and fishery interactions. The Proposed 

 Regime sweeps permit applications for scientific research, public 

 display, and enhancing the survival or recovery of a species or 

 stock into the same regulatory net with commercial fishing. The 

 result is that under the Proposed Regime, persons applying for 

 permits which Congress has deemed beneficial to marine mammals 

 (scientific research, enhancing the survival or recovery of a 

 species or stock, and public display) will be dragged into a 

 cumbersome regulatory scheme which is likely to involve extensive 

 administrative and judicial proceedings on a frequent basis. 

 This will make it more difficult to get a permit for enhancing 

 the survival or recovery of a species or stock through a non- 

 lethal taking than it will be to incidentally kill and injure 

 marine mammals during commercial fishing operations. 



The Alliance and AAZPA recommend that public display takes 

 be excluded from the Proposed Regime or that the MMPA be amended 

 to provide that if it becomes necessary to allocate marine 

 mammals through the Proposed Regime or any other mechanism, then 

 a priority allocation be given for public display takes. 



