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initiate deliberation*; deliberation* should be initiated by 

 an applioation to the Task Force. 



Sections 8 and 9 



We have no speoifio comments. 



Section 10 Definitions 



We support the definitions listed for critical stocks, 

 maximum net productivity, and potential biological removal. 

 Although we would recommend inserting in the definition of 

 PBR the word "maximum", so that the definition would read 

 that "potential biological removal means the maximum number 

 of animals that may be removed...". With this one change, 

 we feel that these definitions are clear and well founded 

 and support the intent of the original MMPA. 



Wo do not support the use of current carrying capacity. We 

 ask that historic carrying capacity be retained as the basis 

 for making determinations of Optimal Sustainable Populations 

 (OSP) . While we understand the concern with absent historic 

 population abundance data, we remain concerned that' 

 switching to the use of current carrying capacity undermines 

 ths necessary protection of stocks which have been 

 disadvantaged. We have previously tsstified that the case of 

 the northern Right Whale is a classic example of the 

 weakness in using currsnt carrying capacity. Right whales 

 once counted many thousands among their numbers and were 

 considered quits abundant. Their current population probably 

 does not exceed 500 individuals. They are critically 

 endangered, and have enjoyed protection from exploitation 

 for over 50 years. Despite this protection, their numbers 

 have not increassd. Long term stability in population is 

 one of the most significant indicators of a population that 

 is at current carrying capacity. Yet no reasonable 

 scientist would argus that right whales are at their optimal 

 sustainable population, and therefore deserve no special 

 protection. This is but one illustration of a problem which 

 potentially affects a number of stocks. 



The fact that a population is not currently able to 

 increase because of a degraded habitat, should not exempt 

 them from protection from possible future exploitation. In 

 fact, this disadvantaged status may warrant special long- 

 term protection. This removes incentive for reversing 

 degradation and denies them important protection from future 

 harmful impacts. For these reasons we believe that historic 

 carrying capacity should bs used in making OSP 

 determinations . 



We have two other general concerns with this proposal 

 that are not addressed in any of the previously mentioned 

 sections: funding and evaluation. 



Funding. 



