61 



regime in the Compromise Proposal. 



2. Section 6(d)(4). Zero Rate Mortality Goal 



Reference is made to "reducing incidental lethal takes to 

 insignificant levels approaching zero". The Zero Rate Mortality 

 Goal, in contrast, requires a reduction in the "rates" of 

 incidental takes to insignificant rates approaching zero. We 

 support inclusion of the Zero Rate Mortality Goal if it is based on 

 mortality rates and is not a mechanism to mandate "zero take". 



3. Section 6(d). Authorization to Take Marine Mammals. 



We recommend a revision of Section 3 (d) with respect to the 

 registration issue. The State of Alaska and the Pacific Northwest 

 already have comprehensive systems to track and record fishing 

 effort in the state-regulated fisheries. The Federal government 

 has a similar system to track fishing effort in the Federal 

 fisheries in these regions. There are also fourteen fisheries in 

 the East Coast operating under Magnuson Act vessel registries. 

 These systems should be used by NMFS in lieu of creating and 

 administering a separate registration system to develop the basic 

 understanding of levels of fishing participation. NMFS can use 

 observer data and self-reporting of lethal takes to conduct its 

 analysis of fishery/marine mammal interactions. Fishing 

 participation information and lethal take information could then 

 form the basis of any interaction analysis. 



Federal funds should instead be directed at developing a 

 registration system only for those state and/or federal fisheries 

 for which comprehensive fishing participation data is not 

 available. In our Compromise Proposal, we intended that it would 

 be a primary role of the conservation teams to u^-ist the Secretary 

 in determining whether existing Federal, State, or Tribal 

 registries are available and can be used to analyze the 

 interactions between marine mammals and commercial fisheries. To 

 the extent that such registries do not exist or are inadequate for 

 a given fishery, we agree that some registration system should be 

 created to fill in the gap. Forms for self -reporting lethal takes 

 should, to the extent possible, be conformed to the existing 

 Federal, State, or Tribal registries. Another role of each 

 conservation team may be to advise the Federal Government or the 

 respective States on how their systems may be coordinated with the 

 conservation team effort. 



4. Section 6(f). Monitoring Incidental Lethal Takes 



We believe that this section should be revised in a number of 

 ways. First, observer funding should be directed only at critical 

 stocks or, in the case of non-critical stocks, the Secretary 

 determines there is some significant deviation in fishing behavior 

 which merits further scrutiny. MMPA observers are not necessary 



74-195 0-94-3 



