33 



If the Scientific Working Group were to submit individual 

 comments for the Secretary to use in revision of stock 

 assessments, rather than a coordinated set of comments, then 45 

 days is insufficient for incorporating their comments into 

 revisions. I recommend that the bill establish a coordinated 

 review from the Scientific Working Group. Even then, however, if 

 the comments of the Group would require extensive re-analysis of 

 data by the Secretary, 4 5 days would be insufficient to complete 

 such analysis and publish final stock assessments. 



The bill requires stock assessments to include the approximate 

 number of vessels participating in each fishery that interacts 

 with each marine mammal stock. Yet the bill requires 

 registration only for vessels within fisheries that interact with 

 endangered, threatened, depleted, or critical stocks. The number 

 of vessels, therefore, can be updated only for those fisheries 

 that interact with such stocks. Interactions and sizes of 

 fisheries are dynamic, and subsequent stock assessments will not 

 be accurate without registration in all interacting fisheries. 



AUTHORIZATION TO TAKE MARINE MAMMALS 



This subsection requires that vessels in all fisheries that 

 interact with marine mammal stocks listed as threatened or 

 endangered under the ESA or depleted or critical under the MMPA 

 register biennially. Mandatory registration is a major part of 

 the NMFS proposed regime, and NMFS supports such a registration. 



