APPENDIX 



Prepared Statement of Sierra Club 



On behalf of the Sierra Club, we offer the following comments on the reauthoriza- 

 tion of the Marine Mammal Protection Act of 1972: 



The Sierra Club has been a strong supporter of the Marine Mammal Protection 

 Act since its inception. We urge Congress to move forward with reauthorization of 

 this important wildlife and marine conservation law. 



COMMERCIAL FISHERIES INTERACTIONS WITH MARINE MAMMALS 



The Sierra Club has reviewed proposals from a number of groups and agencies 

 to address the problem of marine mammal interactions with commercial fisheries. 



We encourage Congress to carefully examine the recommendations of the MMPA 

 Negotiating Group (Keystone Center Memorandum), which outlines a negotiated se- 

 ries of proposals to adc&ess these issues. 



Sierra Club generally endorses the proposals of the MMPA Negotiating Group, 

 with the exceptions noted below. We are impressed by the degree oi cooperation and 

 progress made by the negotiated process through the Keystone Center, and we com- 

 mend the work of the conservation oi^anizations and the conunercial fishing organi- 

 zations in coming up with a solid plan. 



In particular, the Sierra Club supports the following elements from the Negotiat- 

 ing Group: 



• the recommendations maintain the need for incidental take permits, based on 

 stock assessments, strong scientific input, and public participation; 



• the recommendations continue to prohibit intentional killing of marine animals; 



• the recommendations continue the goal of zero mortality for fisheries inter- 

 actions; 



• the recommendations provide a means for a coordinated and goal-oriented pro- 

 gram to protect marine mammals while maintaining commercial fishing activities. 



The Sierra Club in summary, strongly urges Congress to adopt the MMPA Nego- 

 tiating Group recommendations, with the following exception on reporting. 



• Sierra Club is very concerned with the continuing lack of detailed, scientifically 

 valid information on marine mammal interactions. We therefore strongly urge that 

 Congress adopt, in addition to above recommendations, an effective program of man- 

 datory reporting by fishermen of marine mammal/fisheries interactions and a pro- 

 gram of observer coverage to supplement existing information on marine mammal 

 interactions and to provide information on the effectiveness of efforts to reduce mor- 

 tality of marine mammals. 



We recognize this is a burden on the commercial fishing industry. Nevertheless 

 we believe it is in the long-term interests of both the commercial fishing industry 

 and the conservation community, to maintain as much valid, defensible data as pos- 

 sible on the real issues of marine mammal/fisheries interactions. 



For the purposes of this reporting and enforcement, registration of all boats is 

 necessary. 



We further note that there is overlap, both in terms of reporting and in terms 

 of enforcement, between the National Marine Fisheries Service and the Magnuson 

 Fisheries Act now under review by Congress. To minimize overlap and confusion 

 NMFS should be required to establish a joint program of on-board observers, man- 

 datory reporting, data collection, enforcement, and boat registration for purposes of 

 both conservation laws, MMPA and Magnuson. (See attached, new Bycatch rec- 

 onmiendation that Marine Fish Conservation Network has submitted for the Mag- 

 nuson Fisheries Conservation Act). 



Some concerns have been raised about the concept of establishing Conservation 

 Teams to address fishery regulation under the recommendations by the MMPA Ne- 

 ptiating Group. The Sierra Club feels the cooperative nature of the Conservation 

 "eams may prove helpful to resolving conflicts; however, a Conservation Team can 



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