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June to September, a 3 0-day, or even 6-month withdrawal of 

 fishing privileges beginning October 1 would have no effect. The 

 Secretary should have the discretion to decide when the penalty 

 would be imposed. NMFS understands that withdrawing all fishing 

 rights and privileges of a person or vessel means these rights 

 and privileges in all Federal fisheries in which the vessel 

 operates, not just the fishery in which the violation occurred. 



ESTABLISHMENT OF PINNIPED INTERACTION TASK FORCE 



It is not clear why duties of the task forced are limited only to 

 advising on management practices regarding salmonid fishery 

 resources. Its mandate should be extended to all fishery 

 resources by deleting "salmonid" from proposed subsection 

 104(i) (1) . 



The range of advice specified in 104 (i) (A) through (C) should be 

 extended to address other factors affecting marine or riverine 

 ecosystems that adversely affect fishery resources. This would 

 allow the Secretary to analyze the role of pinniped predation in 

 the context of the entire ecosystem rather than as an isolated 

 factor. The advice should also include an evaluation of the 

 short-term and long-term benefits of management actions. 



The purpose of this task force would be to provide advice to the 

 Secretary regarding pinniped interactions with fishery resources. 



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