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U.S. Tuna Foundation February 18, 1999 Mr. William M. Daley Dear Mr. Daley: The U.S. Tuna Foundation (USTF) is a non-profit trade association, which represents the interests of the U.S. tuna industry, including the U.S. Tuna purse seine fleet and all U.S. canned tuna processors, who collectively comprise approximately 90% of the U.S. canned tuna market. As the trade association for the U. S. tuna industry, we have closely followed the debate leading up the enactment of the International Dolphin Conservation Program Act (the Act) and the U.S. ratification of the International Dolphin Conservation Program Agreement. Recently, we were informed that the total eastern tropical Pacific (ETP) dolphin mortality in 1998 is approximately 2,000 animals, a far cry from the 150,000 animals estimated to have been lost in this fishery less than 15 years ago. This is a tribute to the hard work of the U. S. government, the Inter-American Tropical Tuna Commission, interested environmental organizations, the U. S. tuna purse seine fleet and the foreign fishing fleets that continue to operate this fishery. We understand that you will soon be issuing a finding on whether or not the chase and encirclement of dolphins is having a "significant adverse effect" on the ETP dolphin stocks. According to the Act, if you do not find that there has been a significant adverse effect, the United States will adopt a new, more liberal definition of dolphin-safe. The current non-encirclement definition of dolphin-safe would be changed to a no-mortality per set definition. The USTF has stayed out of the debate over the tuna-dolphin issue for quite some time. We did so because U.S. tuna purse seine vessels no longer fish in association with dolphins and U. S. canned tuna processors have maintained a non-encirclement, dolphin-safe policy since 1990. Recently, each of the U. S. canned tuna processors notified me that they intend to retain their non-encirclement policy regardless of the findings that you make in March of this year. The processors' decision is based primarily on the belief that a change in the current definition of dolphin-safe will result in confusion and concern on the part of many U.S. consumers of canned tuna products. Today, most U.S. consumers understand and accept the non-encirclement policy, but they may have difficulty understanding and accepting the new no-mortality policy. We do not expect the position of the U.S. canned tuna processors to influence the findings that you will make this March. We recognize that your findings will be based on the best scientific evidence available. We do, however, want you to know in advance, the reason for our decision to forego a more liberal definition of dolphin-safe at this time. Sincerely, David G. Burney |