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Testimony of the Center for Marine Conservation 



important is to deploy our finite observer resources where it is most critical to 

 obtain accurate, in-season information. The mandatory levels of observer coverage 

 set out in H.R. 2760 will, without some alternative funding source, consume more 

 dollars than all our marine conservation budget line items can afford. Yes, we 

 need observers, but how many, and where? Finally, we must employ alternatives 

 to the traditional on-board observer approach. The MMEP showed that these 

 methods can be effective in accumulating and verifying data. H.R. 2760 is silent 

 on the use of platforms of opportunity, video, dockside interviews, and other 

 alternatives to on-board observers. 



In summary, while the Interim Exemption Program had its difficulties, it also 

 taught us some lessons. It is now time to learn from the program and improve 

 upon it-not perpetuate and exacerbate' its least successful elements. If we take a 

 lesson from the last five years, it should be this: target management and 

 enforcement efforts on real problem areas, involve interested parties early in the 

 process, encourage participation and compliance through education and outreach, 

 and employ innovative, yet statistically reliable, means to gather, verify, analyze 

 and disseminate data generated by the program. We believe the following changes 

 to H.R. 2760 will accomplish these objectives. 



3. Recommendations to Improve the Co nservation Impact of H.R. 2760, 



We make the following suggestions in the hope that we can work with the 

 Subcommittee as you continue your deliberations on the reauthorization of the 

 Marine Mammal Protection Act. We have provided specific recommendations on 

 the language of the bill in a separate document. 



1 . Prohibit intentional shooting of marine mammals. It is a considerable source of 

 mortality in some fisheries and runs counter to the purposes and policies of the 

 MMPA. Since a large segment of the industry has already agreed to stop the 

 practice, why not make it clear in the law? 



2. Tighten up the timing on decision points. The deadlines for action called for in 

 the bill take too long, in our view, for action that will bring mortality below PBR for 

 critical stocks. 



3. Create a mechanism to reduce takes. There are no benchmarks in the bill, or 

 requirements that would encourage the reduction and avoidance of marine mammal 

 interactions over time. 



