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gathered during the Interim Exemption Program. The negotiated 

 regime that we have come up with would establish a Scientific 

 Evaluation Working Group that would peer review decisions and 

 assumptions related to stock assessments already made by NMFS. 

 This approach seems more efficient and productive to us. 



Also, the responsibilities of our proposed scientific working group 

 correctly go beyond just the consideration of fisheries interactions 

 to include investigating and monitoring environmental changes 

 that may bear on stock status, including research on any predator/ 

 prey relationships, toxic pollutants and ecosystem issues. 



We encourage you to broaden the scope of any scientific working 

 group that may be established and use that body to review and 

 comment on stock assessment and interaction decisions already 

 made by the NMFS. 



The Maine Sardine Council's primary motivation for becoming 

 involved in the negotiations was to work toward the development 

 of a regime that would not threaten to shut down our Category III 

 herring fishery due to any impacts that New England's sink gillnet 

 fleet might be having on the region's harbor porpoise population. 



The NMFS' proposed regime and the Committee's proposal 

 would make it possible for any fishery interacting with a marine 

 mammal stock of concern — such as, possibly the harbor porpoise — 

 to be shut down once a potential biological removal level of take 

 was reached. 



Also, like the NMFS proposal, according to the Committee's 

 draft, herring fishery vessels would be required to register, pay fees 

 to fish and display Marine Mammal Interactor decals — even if the 

 fishery is known to have no significant impact on the marine 

 mammal species involved. This approach is difficult to understand. 

 We must oppose it as an unwarranted regulatory burden and cost 

 without scientific justification. 



We are pleased to see the Committee adopt the regional Conser- 

 vation Team concept suggested in the negotiated regime. 



While I do not directly represent the Maine Gillnetters Associa- 

 tion, they are a member of the Associated Fisheries of Maine, and 

 they did sign on to the negotiated critical stock regime. I think 

 that they did so, primarily, because the Conservation Team concept 

 represents a partnership between government and industry which 

 is intended to develop strategies to both mitigate takes and allow 

 for the continued viability of a fishery. 



As envisioned by the negotiated agreement and your bill, this ap- 

 proach will develop cooperation and, ultimately, we believe will 

 focus scarce resources where they can be expected to have the 

 greatest impact. 



With this negotiated proposal, because the use of permits and ob- 

 servers would be optional and used only where critical interactions 

 are known to occur, our herring fishery, for example, would essen- 

 tially maintain its existing Category III status. 



Under the Interim Exemption Program, no MMPA regulation of 

 our fishery was found to be necessary. There is no scientific evi- 

 dence that supports any additional regulation for us in the future. 



We are opposed to the requirement in the Committee's draft bill 

 that the Secretary shall place observers in each fishery operating 



