ing commercial fishing to go on, and also a proposal that did not 

 unduly restrict commercial fisheries. 



Based on Marine Mammal Commission guidelines we did develop 

 this proposal a little late, but we got it here this December 1992. 

 I would like to just touch on a few Key points in that proposal that 

 we think are significant. 



When we set about doing the proposal, we knew that any pro- 

 posal that worked would have to do certain things and woula have 

 to have certain elements: one, we had to have an ability in the pro- 

 posal to focus our agency resources on the marine mammal stocks 

 that were most critically affected. 



We also had to have a mechanism in the proposal to allow us to 

 update the status of the stocks to determine how many animals 

 could safely be removed from a population without disadvantaging 

 the stock. Then we needed to be able to monitor the incidental re- 

 movals from the populations. 



We also know that we could not consider commercial fishing out- 

 side the context of other human-related takes, so we have an ele- 

 ment in the proposal that calculates the total number of animals 

 that can be removed from a population by all forms of taking and 

 still not disadvantage the stock. 



We conducted a quite lengthy and extensive public and scientific 

 review of the potential biological removal calculation, and then ad- 

 ditional review of our allocation plans. 



We were very careful in our proposal to make sure that we were 

 consistent with the MMPA's goal to reduce mortality and serious 

 injury to insignificant levels approaching the rate of zero. One way 

 we went about this was, in looking at our research program, realiz- 

 ing that over the years our research objectives would shift from 

 looking at stock assessments, doing stock assessment work, to look- 

 ing at efforts that would be designed to reduce incidental mortality 

 such as gear designs. This would allow us to be ahead of the curve 

 so that we would be conserving the marine mammal stocks before 

 they became critical. 



I think one thin^ that is important to note is that we are here 

 today not just lookmg at one proposal as you indicated. In fact, in 

 a way we have essentially three proposals before us. 



While on the one hand that may appear to complicate 

 everybody's job, I think it is a really fantastic opportunity, because 

 we will be able to pick and choose the very best bits from all of 

 these approaches and come up with something that we can all live 

 with in the future. 



I also think it is important to note how pleased we are at the 

 efforts that have taken place between the industry and the envi- 

 ronmental community. I think that this forms excellent ground- 

 work for us to continue to work really well together when we try 

 to implement the proposal that finally comes out. 



Now, I would like to mention just a few concerns about the nego- 

 tiated proposal. In my formal testimony we go through several of 

 what I call operational concerns, but these are things that for the 

 most part I believe we can work out. In some instances, they are 

 simply different ways to get to the same place, so I will not go 

 through those now, but I will mention three fundamental concerns 

 that we have with the negotiated proposal. 



