41 



STATEMENT OF SUZANNE lUDICELLO, SENIOR PROGRAM 

 COUNSEL, CENTER FOR MARINE CONSERVATION 



Ms. lUDiCELLO, Thank you, Mr. Chairman, Senator Stevens. 

 Good afternoon. My name is Suzanne ludicello. I am counsel for 

 the Center for Marine Conservation. The center was the coordinat- 

 ing body for the environmental groups who participated in the joint 

 negotiations. 



The groups that signed on to the document that was submitted 

 to you in addition to the center include the Animal Protection Insti- 

 tute, Friends of the Sea Otter, Greenpeace, National Audubon Soci- 

 ety, the Marine Mammal Center, and the World Wildlife Fund. 



It is very timely that you have held this hearing today as we 

 near the deadline of September 30, when the interim exemption 

 program that you enacted 5 years ago will stop. 



I would like to preface tne remarks that I am going to make 

 about the joint proposal with some thanks to the committee and 

 the committee staff for encouraging our groups to get together. 



This is not the first time this has happened, and you have been 

 encouraging us to get together with the industry since the early 

 eighties in working together on driftnets, so we appreciate the op- 

 portunity and your confidence in our ability to talk to each other 

 instead of at each other. We would like to move on to get on to 

 some problemsolving. 



Our statement takes three steps today. First of all is to discuss 

 why it is time to replace the interim exemption. The second is to 

 give you an idea of why we believe the joint proposal has a lot of 

 good conservation in it. The third are some brief comments on some 

 of the other proposals you have before you. 



In the 1988 amendments, you enacted an interim exemption. It 

 was a temporary deal. The idea was to take 5 years to gather some 

 information so that we could better understand what was the real 

 problem of incidental take of marine mammals in commercial fish- 

 ing. 



We are now reaching the end of that 5-year period. The full pro- 

 gram that the agency implemented, the Marine Mammal Exemp- 

 tion Program, has actually been on line for 3 years, but we have 

 learned a lot from that exemption program. 



We have learned more about the nature of the interactions. We 

 have learned that we cannot rely solely on log books. We have 

 learned that observed takes are five to eight times greater than re- 

 ported takes in self-reporting log books. 



We have also learned, contrary to some of the assertions that you 

 have heard today, that universal registration does not really get 

 you all the information you might want to have, either. I will talk 

 about that a little later. 



Basically, the exemption program may have had some difficul- 

 ties, but it did accomplish what it was supposed to do. It gathered 

 information, and in our view it is time to stop describing this prob- 

 lem and get on with solving it. We think that the joint proposal 

 does that, and I am going to talk just about the conservation as- 

 pects of the joint proposal and why we think that it does meet the 

 protection requirements of the MMPA. 



From a conservation community perspective, the thrust of any in- 

 cidental take regime ought to be to reduce fishing caused mortali- 



