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that "the incidental kill or serious injury of marine mammals 

 permitted in the course of commercial fishing operations be reduced 

 to insignificant levels approaching zero". This same goal is also 

 established for regional Conservation Teams which would be 

 authorized by the draft bill. 



Both the NMFS proposal and the negotiated critical stocks 

 regime share the goal of reducing the rate of takes to 

 insignificant levels approaching zero. 



There is a fundamental difference between these two goals. 

 The fishing industry is clearly ready to commit to reducing the 

 rate of take of marine mammals when the viability of a marine 

 mammal stock is being threatened and when alternatives can be 

 developed to make it feasible to do so. 



We do not, however, believe that it is necessary or wise to 

 adopt a goal of reducing takes to a level approaching zero. The 

 MMPA's existing goal of maintaining marine mammal stocks at optimum 

 sustainable population levels does not reguire such a strict 

 standard. The establishment of a zero take goal threatens the 

 long-term viability of the U.S. seafood industry. 



We ask the Committee to adopt the critical stock proposal's 

 language calling for the reduction of takes "to insignificant 

 levels approaching a zero mortality and serious injury rate". 



The Scientific Working Group and Stock Assessments 



The Committee's draft bill would establish a Scientific 

 Working Group which would be reguired to develop preliminary stock 

 abundance estimates which one would expect to be developed by the 

 NMFS, utilizing information gathered during the Interim Exemption 

 Program. While the Scientific Working Group would have a role in 

 commenting on NMFS stock abundance estimates, we are unclear why 

 the group should be established before those estimates are made. 



The negotiated critical stock regime would establish a 

 Scientific Evaluation Working Group that would peer review 

 decisions and assumptions related to stock assessments already made 

 by NMFS. This approach seems more efficient and productive to us. 



Also, the responsibilities of our proposed scientific working 

 group correctly go beyond just the consideration of fisheries 

 interactions to include "investigating and monitoring other 

 environmental changes that may bear on stock status, including 

 research on any predator/prey relationships, toxic pollutants, and 

 other ecosystem issues" when considering the health of marine 

 mammal populations. 



We encourage you to broaden the scope of any scientific 

 working group that may be established and use that body to review 



2. 



