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Testimony of the Center for Marine Conservation 



from most of them, and observed enough to statistically verify the reports. Where 

 one or more of those factors was unknown or unreliable, and where it could not be 

 backed up by observer data, the information generated is questionable. 



Based on our analysis of the MMEP, we have concluded that universal 

 registration may not be the most effective means to assess incidental takes in 

 fisheries. Further, the results of the program demonstrate two additional problems 

 with universal registration, and three successful elements that should be included 

 in any future regime to govern incidental mortality, namely: 



• Universal registration generates an enormous administrative burden for 

 the agency, causing time lags that may preclude recognition of trends or 

 implementation of effective in-season management. 



• Enforcement of a registration and reporting requirement consumes 

 tremendous amounts of time, staff energy and money, and does little to improve 

 the quality of data collection, since it is invariably after the fact. 



• Education appears to be more effective than enforcement in bringing 

 participants into a program and keeping them in compliance. 



• Observers can contribute significantly to our understanding of the nature 

 of interactions. 



• In the absence of on-board observers, alternative means of observing and 

 verifying incidental take can be used effectively. 



It appears that H.R. 2760 replicates many of these problems, and therefore 

 likely will fail in attaining accurate estimates of incidental mortality. While it does 

 not propose a "universal" registration for fishing vessels, registration is required for 

 vessels that interact with so many classifications of marine mammal stocks that it 

 is nearly universal. As already stated, if you do not have an accurate picture of the 

 "fishing universe," you will never elicit an accurate assessment of incidental take in 

 fishing. 



Further, H.R. 2760, in its registration requirements, does not make use of 

 existing registrations or permits, or call for an integration of state and federal 

 fishing permits in order to do so and avoid a duplicative requirement. In actuality, 

 we believe that the means to capture that picture is registration of fishing vessels 

 for fishing purposes -either through existing state, tribal, and federal permitting 

 programs, or through a universal fishing license and a registration program that 

 should be required through the Magnuson Fishery Conservation and Management 

 Act. Not through the MMPA. 



