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replaced by "human-related mortality from all causes." PBR 

 includes losses from all sources, and limiting consideration to 

 removals from a single fishery would result in problems. For 

 example, the population of harbor seals in the Gulf of Alaska is 

 declining, and human-related mortality likely exceeds the PBR 

 level. However, removals from any single source, especially any 

 single fishery, may not exceed PBR. 



Proposed subsection 118(d)(3)(C) should be changed by removing 

 "or the end of the year for which the annual potential biological 

 removal was calculated, whichever is earlier." This is because 

 problem areas will not likely be solved until a conservation plan 

 and associated regulations are promulgated. However, there 

 should be an opportunity for public involvement, such as a 

 hearing, in the Secretary's determination as to whether or not 

 the reasons for the emergency continues to exist. 



CONSERVATION TEAMS 



Conservation Teams, as advisory groups, have some merit. The 

 Conservation Teams would allow interested parties more 

 flexibility in providing input to the management of critical 

 stocks than they have under current laws. Such flexibility may 

 provide these parties a greater opportunity to become a part of 

 the solution to difficult management problems, thus facilitating 

 the implementation of management actions and improving 

 compliance. 



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