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the regime proposed last year by NMFS. 



A reading of the draft bill shows that the classifications that 

 would result from implementing the bill's critical stocks 

 provisions would be similar to the NMFS legislative proposal. A 

 comparison can be made between this proposal and the list that 

 would result from the criteria in the fishing-environmental 

 negotiated proposal. The negotiated proposal examined 63 stocks 

 and categorized 12 as critical. Four of those were in Alaska 

 (harbor seal, harbor porpoise, Gulf of Alaska beluga, and western 

 Arctic beluga) . NMFS listed 31 of 49 stocks as critical (their 

 class alpha) , 7 of those are in Alaska (harbor porpoise, Gulf of 

 Alaska beluga, western Arctic beluga, Steller sea lion, spotted 

 seal, ribbon seal, and Bering Sea killer whale) . There are a 

 number of problems with the NMFS list. 



The most obvious problem is that it is overly general and fails to 

 focus attention on a select number of problem species. Clearly, a 

 method that would identify two-thirds of all stocks as critical 

 fails to focus on the true problem areas. Also, a consideration 

 of the actual stocks identified as critical in Alaska shows that 

 the NMFS method fails to select some of those that are either in 

 trouble or that have significant interactions with fisheries, 

 while at the same time it includes some species that are not in 

 trouble . 



For example, although a number of harbor seals are killed each 

 year in Alaskan fisheries, and their populations in some areas of 



