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Testimony of the Center for Marine Conservation 



1 . The House Bill Does Little More than Con tinue the Interim Exemption 



From a conservation perspective, the thrust of any incidental take regime 

 should be to reduce fishing-caused mortality so that marine mammal populations 

 can recover to their optimum sustainable population. The House bill appears to be 

 a quota-based regime that does little more than continue the current exemption 

 program with the addition of increased observer coverage and draconian penalties 

 for administrative violations. It does not prohibit intentional shooting of marine 

 mammals-a prohibition that even the commercial fishing industry has endorsed. 

 Nor does it provide a means to reduce mortality toward the zero rate mortality 

 goal, focus priorities on marine mammal stocks of greatest concern, or provide 

 implementation tools that will make fishermen part of the solution rather than part 

 of the problem. 



A comparison of six elements of the bill with similar elements in the 

 negotiated agreement reveals the following: 



Joint Agreement 



• Prohibits intentional shooting. 



• Requires as part of authorization a 

 reduction of fishing-caused marine 

 mammal deaths to a biologically 

 conservative removal level in the first 

 six months after enactment. 



• The time from from enactment to 

 publication of conservation plans and 

 implementing regulations is 19 

 months for fisheries interacting with a 

 critical stock where mortality exceeds 

 the calculated removal level. 



H.R. 2760 



• Silent on intentional killing. 



• Provides for Secretarial emergency 

 action one year after enactment if 

 review of information shows fishing 

 caused mortality is likely to exceed 

 the removal level. 



• The time from enactment to 

 publication of conservation plans and 

 implementing regulations is two years 

 for fisheries interacting with a critical 

 stock where fishing mortality exceeds 

 the potential biological removal level, 

 and nearly two and a half years for 

 other critical stocks. 



• Scope of program is narrowed to 

 focus on marine mammal stocks of 

 greatest concern, and fishing that 

 causes population declines or a 

 substantial portion of mortality. As 



• Scope of program extends to so 

 many fisheries that mandated levels 

 of observer coverage and enforcement 

 will be difficult to meet with available 

 fiscal resources. Enforcement is 



