53 



Testimony of the Center for Marine Conservation 



such, both observer coverage and 

 enforcement are directed at problem 

 areas and on illegal takes, not 

 administrative violations. 



directed at administrative 

 requirements rather than at reducing 

 or penalizing takes. 



• Instead of setting quotas for marine 

 mammal mortality, directs effort at 

 reducing mortality over time, with 

 benchmarks and checkpoints to insure 

 that incidental mortality caused by 

 fishing declines over time. 



• Creates quota-based system that 

 sets caps on marine mammal 

 mortality without any mechanism to 

 reduce mortality over time to meet the 

 MMPA's zero mortality rate goal. 



• Employs traditional, centralized 

 regulatory regime with standard 

 Secretarial control of timing and 

 action. Does not distinguish fishing- 

 caused mortality from other sources 

 of human-caused mortality in its 

 regulatory approach. 



• Encourages the use of an array of 

 tools that will bring innovative 

 approaches to reducing incidental 

 mortality: education; early 

 involvement of stakeholders; 

 examination of other sources of 

 mortality including predator-prey 

 relationships; moves toward an 

 ecosystem-based management 

 approach. 



The difference between the two proposals is not simply that one is the result 

 of negotiation and compromise. There is a fundamental difference in approach 

 based on the personal experience of fishermen with the Interim Exemption, and our 

 thorough analysis of its results. That difference is focus. We used our knowledge 

 of the information generated by the program to hone in on areas where incidental 

 take in fishing operations is really a problem. We used our experience of how the 

 program worked--or didn't-to craft an approach that would be successful in the 

 field. 



When we analyze the information generated by the MMEP, several 

 conclusions emerge. The MMEP was designed to gather information about 

 incidental take. It approached the task with an across-the-board registration 

 system for two out of three categories of fisheries, required self-reporting in all, 

 and required observer placement on a few. The MMEP provided accurate 

 estimates of incidental mortality where the agency acquired reliable information on 

 the number of vessels fishing, registered most of those vessels, received reports 



