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Alaska would recommend that the bill be amended to reflect the 

 negotiated proposal more closely. Some important examples are 

 provided below. 



II. SPECIFIC COMMENTS 



1. Critical Stocks 



The fishing and conservation groups recommended that critical 

 stocks be identified based on consideration of the level of take 

 by fisheries and other sources in relation to population status of 

 each marine mammal stock. The proposed method would provide clear 

 criteria for critical stock definition, and ensure that effort 

 would be focused on declining and small marine mammal stocks that 

 are subject to relatively high levels of taking. 



The definition of critical stocks in the draft bill lacks clear 

 criteria, and may result in attention being directed to situations 

 where marine mammal fishery interactions are not really a problem. 

 In fact, it is hard to know from the definition proposed in the 

 draft legislation what stocks would qualify for the critical 

 category. Since there is some uncertainty about the status of 

 most marine mammal stocks and information on level of take is 

 incomplete, many species would probably qualify. This in turn 

 could defeat the purpose of creating the critical stocks 

 designation, which is intended to focus attention on those stocks 

 and fisheries where there is a pressing need to take action before 

 the marine mammal stock reaches depleted, threatened, or 

 endangered status. This is the same problem we identified with 



