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being used to bail out for-profit businesses. For years, NMFS has 

 encouraged the display industry to self -insure against this 

 problem. The larger, more prominent display facilities, under 

 membership of the AZA (American Association of Zoos and Aquariums) 

 and The Alliance of Marine Parks and Aquariums, indicated during 

 testimony that they are willing to initiate discussions on this 

 subject. Although we applaud efforts to address this issue, it is 

 important to note that 4 0% of the industry does not hold membership 

 with these organizations. These are often small, marginal 

 facilities, with histories of non-compliance and economic 

 uncertainty. As such, it is important that the animals held at 

 these facilities be provided for. 



Second, the other area being criticized as "far-reaching" by . 

 the public display industry is the 1988 Congressionally mandated 

 requirement for educational and conservation programs to be 

 provided at public display facilities. These are to meet 

 "professionally recognized standards", and be "acceptable to the 

 Secretary of Commerce". Unfortunately, "professionally recognized 

 standards" have not yet been developed by the public display 

 community. 



Critics mistakenly assert that NMFS is proposing to regulate 

 the content of these programs. Based on the diversity of display 

 facilities, NMFS recognizes that the content of education and 

 conservation programs, and the methods employed to communicate _ to 

 the public, will necessarily vary. Therefore NMFS has no intention 

 of attempting to dictate or regulate the conte nt and style of such 

 programs . While leaving decisions of form and substance to the 

 professional educators, as they should be, the proposed rule 

 includes as a basic "acceptable" requirement that, whatever the 

 content or technique, such educational programs must effectively 

 convey information that is accurate and consistent with the 

 policies and objectives of the MMPA. 



A Facility that conducts a professional education or 

 conservation program should have no problem meeting such a basic 

 requirement . 



3) How are we going to pay for them? 



The NMFS has requested no increase in funding from current 

 levels. Rather, with the increased efficiency expected to accrue 

 from the proposed rule, NMFS anticipates being fully able to 

 conduct the program envisioned by the proposed rule. 



