the United States and abroad, all of whom receive the monthly National Parks and Conservation Magazine: The Environmental Journal.

The need to protect ocean mammals from undue commercial exploitation leading to extinction has been made plain in this Subcommittee and the House Subcommittee on Fisheries and Wildlife Conservation. Therefore, the National Parks and Conservation Association, without directing its comments to any specific ocean mammals bill, heartily supports the following minimum provisions in any bill:

(1) A ten-year moratorium on the killing of all ocean mammals excluding those presently covered by the Pribilof Fur Seal Treaty, and excepting the traditional rights of natives. This provision should hopefully allow depleted stocks to replenish their numbers.

(2) A ban of similar duration on imports of all ocean mammal products to reduce economics which foster the killing of ocean mammals.

(3) Mechanisms to insure continued protection if it is needed.

(4) A provision stating that after one year it shall be unlawful to use any means of fishing which shall either intentionally or unintentionally cause significant harm to any ocean mammal population.

(5) A provision for the funding and supervision of scientific research into the ecology and behavior of the ocean mammals.

(6) A provision stating that jurisdiction over all ocean mammals should be placed with the Secretary of the Interior, whose Bureau of Sport Fisheries and Wildlife has much of the scientific expertise regarding ocean mammals. (7) Request that the Secretary of State negotiate workable treaties to insure world-wide protection for the ocean mammals.

Additional provisions concerning enforcement, funding, and other matters will also be needed; however, the above provisions are those which the NPCA feels are most necessary if we are to insure the health of ocean mammal populations.

Mr. Chairman, I again thank you for the opportunity to submit this statement.

STATEMENT BY CHARLES H. CALLISON, EXECUTIVE VICE PRESIDENT, NATIONAL AUDUBON SOCIETY

As an organization concerned with the conservation of natural ecosystems and with man's relationship to his environment, the National Audubon Society is alarmed by the increasing pollution of the sea and the heedless exploitation of its living resources. We earnestly hope that following these hearings the Subcommittee can perfect one of the bills before it, get it reported promptly by the full committee, and passed by the Senate.

We thank you for the opportunity to present our views, because in our opinion a review and redirection of national policy with respect to marine mammals is long overdue.

New technologies in transportation, detection, capture and killing make it possible for man quickly and brashly to virtually wipe out any large animal of the sea. The available evidence indicates that most of the whales have been over-exploited for commercial purposes and some species driven to the brink of extinction. We all know how the sea otter was nearly wiped out by man's greed for its valuable fur until complete protection beginning in 1911 allowed it slowly to recover its numbers in coastal areas of southern Alaska and in a colony off the Big Sur section of California. The Pacific fur seal was decimated before an International Convention in 1911 halted indiscriminate slaughter in the open seas and brought the species under management at breeding grounds in the Pribiloff Islands and on similar breeding islands under Russian jurisdiction.

We fear that the polar bear may be sliding down hill because of trophy hunting promoted by airlines, outfitters, and other interests who cash in on the ambition of so-called sportsmen to prove their manhood by shooting one of these magnificent but virtually defenseless animals. In the old days it was indeed a test of manhood to get where the polar bears are. But stalking polar bears by aircraft and shooting them with high-power rifles takes about as much skill and courage as swatting a fly. About as much bravery and skill also, as shooting eagles from a helicopter.

The fur seal harvest has been brought into question by widespread public concern about the humaneness of slaughtering the animals by clubbing them.

This is a concern shared by the National Audubon Society. The basic philosophic and moral question, we think, is not whether a bullet or a club or some other weapon is more humane, but whether it is moral to kill animals for the sake merely of catering to man's vanity. Would anybody in the world go cold or unclad if there were no coats made of luxury furs? The question comes into sharper focus when poaching for the luxury trade threatens the very existence of a species, as in the case of some of the great wild cats.

In the case of whales, I don't think the ruinous exploitation of the great Cetaceans can be attributed to man's vanity as much as simple greed for quick profits in an international situation where there has been no real control. When vanity or profits are involved, will mankind ever exercise voluntary self-restraint in the absence of control? History doesn't offer much hope. The early Audubon Societies tried to shame women out of wearing the plumage of wild birds with some success, but nevertheless the destructive feather trade continued until it was outlawed at the retail level, and thus the egrets were saved.

I now direct my remarks to the Williams bill, S.2871, which I think is the best of the several good bills before the Subcommittee. (Others are S. 1315, S. 2579 and S. 2639.) In my comments I shall refer also to H.R. 10420, the Marine Mammals bill reported by the House Committee on Merchant Marine and Fisheries although not yet passed by the House and therefore not before this Subcommittee.

In general we endorse the provisions of S. 2871.

We think it highly desirable to consolidate management and protection responsibilities for all marine mammals in the Department of the Interior as this bill apparently sets out to do. We wonder if it isn't necessary to include a provision that explicitly directs the transfer of such responsibilities and functions from the Department of Commerce. We commend this point to the study of Committee counsel.

In Section 103 (a) on page 6, S. 2871 sets a ten-year moratorium on the talking of marine mamals for commercial purposes except for the modified application of the International Convention for the Conservation of North Pacific Fur Seals. This would be, in effect, a ten-year closed season. As some of my colleagues in sister conservation organizations have probably testified, the imposition of either an open or closed season or of bag limits by statute does violence to one of the tenets of scientific game management. This is because such legislation prevents flexibility by the Executive to adjust harvests seasonally and sometimes at short notice on the basis of new data about the condition of the species being regulated. I believe that as a general principle this tenet is sound and I subscribe to it. However, in the case of marine mamals, I believe a temporary moratorium of reasonable duration would do no harm to the principle for the reason that for most species and stocks of marine mammals, there is insufficient scientific data at hand upon which the Secretary could base sound management regulations. For Congress to insist upon commercial harvests in the absence of knowledge about populations and population dynamics would indeed do violence to the principle and could do irreparable damage to some species. If to impose a moratorium while research can get started and bring in at least some preliminary conclusions is an error, it is a small one, and clearly on the side of caution and conservation.

I believe a ten-year moratoriura is unnecessarily long. Five years would be reasonable. At the end of five years, if Congress is not too stingy in funding the needed research, the Secretary of the Interior should have at hand some hard facts upon which to decide where, how, and if, commercial harvests should be permitted. I say this with a question in the back of my mind. The question is, wouid not humanity and the marine ecosystem be better off if no commercialization of these essential and appealing animals were ever per

mitted?

Proceeding further through the provisions of S. 2871, we strongly endorse Subsection (e) of Section 103, which seeks to require tuna fishing techniques that will minimize the accidental destruction of porpoises.

We like two features of the penalty section of H.R. 10420 better than corre sponding provisions in Section 104 of S. 2871. We recommend increasing the maximum civil penalty of $10,000, and also adding the following language from the House bill to Section 104 (b): "The Secretary of the Treasury shall pay to any person who furnishes information which leads to a conviction for violation under this subsection an amount equal to one-half of the fine incurred, but not to exceed $2,500 for each violation."

We support the establishment of a Marine Mammal Commission as proposed in Title II, but we think the three members should be appointed for definite, over-lapping terms, and not to "serve at the pleasure of the President" which would tend to make them partisan appointments. We recommend staggered terms of six years.

We think it highly important that no one be permitted to serve on the Commission who has any connection with the commercial taking, processing or sale of marine mammals or their skins or flesh.

Mr. Chairman, we have no great objection to changes in Title II to make it clear that the Marine Mammal Commission is going to function merely as an advisory body, as proposed in an amendment suggested by my friends of the Wildlife Management Institute. However, if that is done, other language must be inserted making it clear that the Secretary of the Interior, or the Commission, is authorized and directed to conduct the reviews, studies, and scientific investigations that are assigned in S. 2871 to the Commission. Moreover, the ceiling on annual appropriations for such studies and investigations must be at least the $1.000.000 proposed in Senator Williams' bill. I have seen some suggestion that this should be reduced to $250,000, but such a figure would be grossly inadequate. Conservation organizations have asked for more than that to study the mourning dove, a far simpler task. The marine resources at stake here are highly important, their natural ranges extensive, and the geographic areas over which the investigations must be conducted are enormous. Thank you again for allowing us to present our views.

STATEMENT OF WILLIAM E. TOWELL, EXECUTIVE VICE PRESIDENT OF THE AMERICAN FORESTRY ASSOCIATION

Mr. Chairman and members of the Subcommittee, I am William E. Towell, Executive Vice President of The American Forestry Association, one of the nation's oldest and largest citizen conservation organizations, with an interest in the preservation of all natural resources as well as the optimum use and enjoyment of these resources. My 34 years of professional resource management experience encompasses the fields of fish and wildlife as well as forestry, although I have not worked directly with ocean mammals.

The American Forestry Association supports the philosophy of management as embodied in S. 3112 in contrast to the more restrictive provisions of S. 1315. I join with my conservation colleagues in the recommended amendments to S. 3112. But, the principal thrust of my testimony is to urge upon you as strongly as I can the importance of reserving technical management decisions about ocean mammals to trained professionals. It would be a tragic mistake to prohibit entirely the taking and use of these ocean resources. It would substitute emotionalism for professional judgment and could conceivably result in depletion of some species of mammals themselves.

The whole concept of conservation, Mr. Chairman, is based upon the wise use of natural resources. If any species is threatened with extinction or even serious decline it should be offered total protection, but to apply such restrictive prohibition against the taking of all ocean mammals would be a needless waste. Man's life upon this planet is based upon careful use of all resources and the sustained yield of renewable resources. There is nothing to indicate that all ocean mammals are threatened or that total protection is needed. Why, then, deny everyone the right to safe, regulated harvest?

A lack of understanding of wildlife population dynamics and the total dependence of all life upon its own environment leads many sincere but misinformed people to seek total protection of all wildlife as the humane thing to do. In fact, Mr. Chairman, we see developing in this country what amounts almost to a reverence for life and demands for an end to sport hunting. The concern is commendable but the direction if taken is unnecessarily restrictive and wasteful There is no substitute for man's rational use of the earth's resources. He must take to live. But. man also has a moral obligation to protect the resources upon which his survival depends. The only way we can compromise these two apparently conflicting needs is through the application of professional judgment Total protection as would be provided by S. 1315 would practically eliminate such judgment.

We should deal with ocean mammals the same way we do with land species, and manage each according to its own needs. Let's not be unnecessarily restrictive on all just for the protection of a few.

Preservation or total protection is a necessary part of conservation. It should be applied when necessary but not indiscriminately or needlessly. I see here a close parallel between ocean animals and trees with which I work more closely. Some misinformed people are demanding a total ban on clearcutting or even any harvest of trees from public lands. Such demands for restriction are based largely upon lack of understanding that trees grow, that they are a renewable resource and that it may be necessary to harvest some to perpetuate the type of forest we want. We know the same is true with some forms of land animals and it must be equally true with ocean resources. Let's not permit emotional reaction, no matter how sincere, to take the place of scientific fact and judgment. Let's give ocean mammals all the protection they need but let's control them through professional management. In the long run management may be their best protection.

STATEMENT OF JACK W. LENTFER, ALASKA DEPARTMENT OF FISH AND GAME, BARROW, ALASKA

STATEMENT ON POLAR BEARS IN RELATION TO PENDING OCEAN MAMMAL PROTECTION LEGISLATION

POPULATION STATUS

Discreetness of populations

The five nations with polar bears are marking and recovering bears to determine if they occur as geographically isolated sub-populations. As part of this cooperative study, the Alaska Department of Fish and Game and the U.S. Bureau of Sport Fisheries and Wildlife through 1971 had tagged 357 bears off Alaska's coast. Thirty-five animals recovered nine months to four years after tagging indicate that bears to the north of Alaska are a somewhat discrete group of animals with only a limited amount of interchange with bears to the west of Alaska. Lentfer (1972) presents a detailed analysis of tag recovery data.

Physical differences among animals also indicates that there may be subpopulations of bears to the west and to the north of Alaska. Hide and skull measurements from animals taken by hunters show that those taken west of Alaska are larger than those taken north of Alaska. This is confirmed by T. H. Manning (1971), a Canadian taxonomist, who by statistical comparison of measurements of polar bear skulls from Spitzbergen, Greenland, Canada, and Alaska, shows that skulls from bears to the west of Alaska are significantly larger than skulls from bears to the north of Alaska

The data suggest then that bears to the west of Alaska and bears to the north of Alaska form partially discrete populations with only a limited amount of movement between them. A line extending northwest from Point Lay has been chosen as a rather arbitrary dividing line. Much of the following information is presented based on the premise of these two sub-populations. Abundance

Relative abundance and population compositions have been used as indicators of trend in population. Total population estimates have not been made to aid in an assessment of the status of populations. Data on which total population estimates must be based are fragmentary and require a number of assumptions, any one of which could be in error, and could cause a significant error in the total population estimate.

Hunting guides have been systematically queried since 1956 on the number of bears they have seen on hunting flights. The number of bears seen per flying hour has varied from year to year, but has not shown an appreciable decline for the years 1956-1969, the period for which we have reliable data of this type (Table 1). In 1970, cross checking with guides' clients and between guides hunting in the same area revealed that some guides had started reporting more bears than they actually saw. They did this when a possible closure on hunting with airplanes was first announced, apparently to weaken any possible justification to stop hunting with planes based on a reduced number of animals in the population.

We have supplemented information on relative abundance furnished by guides with our own observations made while searching for bears for tagging and during other field studies. These observations made during March and April each year since 1966 have not indicated a decline in the relative number of bears.

Population composition

Based on 357 animals which have been captured for tagging, females with young make up 19 per cent of the population, and young (cubs, yearlings, and two-year-olds still with their mother) make up 33 per cent of the population. Mature males comprise 14 per cent and mature females 33 per cent of the bears tagged. In considering these figures, it should be realized that family groups are sought after for tagging with somewhat more effort than are single bears, and therefore might form a somewhat greater portion of the sample of bears tagged than of the true population. However, these figures are similar to those reported by guides on hunting flights. The relatively high percentage of young and females with young indicates that the population is reproducing with a relatively high annual increment. The greater number of mature females than males indicates that selective hunting for males over a number of years has altered the sex ratio.

Mortality

We do not have a measure of natural mortality. We do have an estimate of hunting mortality from 1925 through 1960 and a fairly precise enumeration of the hunter harvest each year after 1960. In 1961, it became mandatory for hunters to present skins to the Department of Fish and Game for examination, sealing, and enumeration in the harvest. The average annual kill for the years 1961-1971 has been 259.

TABLE 1.-NUMBER OF POLAR BEARS SEEN PER HOUR OF FLYING AS REPORTED BY AIRPLANE GUIDES AT KOTZEBUE AND BARROW, ALASKA, 1956-69