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representation from a variety of interests we would like to 

 offer two comments: 



(l)Any representetive who is not a member of a fishing 

 industry is "non-industry". We assume that the provision 

 seeking equitable distribution of "industry and non- 

 industry" was intended to mean equitable distribution of 

 industry and conservation interests rather than equitable 

 distribution of industry and all other representatives on 

 the Team. 



(2) We note that the Conservation team must include at least 

 one member of the Regional Fishery Management Council. We 

 believe that this was intended to assure that the Fishery 

 Management Council plans do not conflict with Conservation 

 Team recommendations and to assure that their perspective is 

 included in formulation of the Conservation Plan. If so, 

 then it is duplicative to also require the team to consult 

 with the Regional Fishery Management Council, as stated in 

 the legislation. 



it) Monitoring Incidental Lethal Takes 

 We strongly support the provision for monitoring to 

 determine changes in stock status, identify changes in 

 methodology, determine methods of rsducing takes and to 

 verify reporting of incidental takes. We feel that the 

 specified levels of observer coverage and the priority for 

 assigning observers is laudable. We have only two concerns 

 with this section. 



(l)We would like to be assured that, should funds bs 

 available, greater levels of observer coverage could be 

 employed without being considered "overly burdensome". 

 Currently, some fisheries may be required to take greater 

 than 20% observer coverage, and we would like to see that in 

 cases where the concern over the level of incidental take 

 was immediate and great, these higher levels of coverage 

 could be maintained. For example, the mid-Atlantic swordfish 

 fishery is currently subject to loot observer coverage due 

 to their high interaction level with multiple stocks of 

 marine mammals. This fishery should not be able to escape 

 this level of coverage because the law stipulated 20% 

 coverage and they felt that 100% was overly burdensome and 

 unfair. 



(2) We support use of observers from a number of authorized 

 sources; however, we believe that NMFS should have the 

 option to charge a fee for observer coverage, especially if 

 a fishery requires a higher level of coverage due to a level 

 of interaction that mandates greater scrutiny. We understand 

 that in Alaska, the groundfish fisheries already have such a 

 system to fund observer coverage to monitor fishery quotas, 

 and believe that such a model bears investigation to 

 determine its feasibility in other parts of the country and 

 other fisheries. 



