The seal harvest operation has resulted in a profit to the U.S. Government in all years up to FY 82. Skin sales began to decline in FY 81 and dropped to very low levels in FY 82. This recent decline in the sale of fur seal skins is probably due to a number of factors. Sales are affected by economic conditions in the United States and Europe, including high interest rates and the strength of the U.S. dollar abroad. Other factors such as changes in fashion towards longer hair furs, lack of promotion and advertising, and the influence of the environmental movement have also affected skin sales.

In 1984, a contract to perform the seal harvest was signed with the Tanadgusix Corporation of St. Paul Island, in return for the sum of $500,000 and the 1981-83 harvested skins owned by the United States (Contract No. 84-ABC-00060). Until passage of the Fur Seal Act Amendments in October 1983, the Federal Government was not allowed to contract for the seal harvest. The Tanadgusix Corporation (TDX) is expected to realize about $450,000 from the sale of the 1981-83 harvested skins. TDX employees harvested 22,066 skins in 1984 and prepared them for shipment from the island. The 1984 skins remain on St. Paul Island, pending completion of negotiations on a 1985 harvesting contract. No decisions have yet been reached on the terms of this agreement.

IV. ENVIRONMENTAL CONSEQUENCES

During the negotiations with the Party Governments, the United States initially proposed to modify the Convention to reflect the position discussed in Section A below. Since a consensus could not be reached to modify the Convention as the United States had hoped, agreement was reached on an attached Statement which expresses the concerns of the Party Governments on fur seal conservation and management.

A. Convention Extension with Attached Statement (Proposed Action)

The United States proposed to continue the Convention for four years with modifications to the text of this treaty concerning the conduct of the seal harvests, and additional research and enforcement requirements. The United States proposed modifications through an exchange of notes with Party Governments, eliminating the need for formal renegotiation. In addition to a 4-year extension, the proposed modifications included revisions to Article V, paragraph 2(d) (see Section I.A.) to allow emergency actions by harvesting nations regarding reduction or suspension of their harvests, without prior concurrence of the NPFSC.

Following negotiations, the issues raised by the United States were addressed in a Statement which is attached to the Protocol and is signed by representatives of the Party Governments. The Statement does not modify the Convention but expresses the concerns of the Party Governments over the decline of the fur seal populations, current economic conditions, and other problems of fur seal conservation and utilization. The Statement also expands on the concerns of the Governments by stating that:

(1) in accordance with Article II of the Convention, additional research should be conducted concerning current aspects of fur seal conservation including the problem of entanglement of fur seals in lost or discarded fishing nets, gear, and other debris;

(2) in accordance with Article X of the Convention, and in conformity with their national laws, the Governments will take appropriate measures to prohibit the disposal at sea in the Convention areas of synthetic materials, such as fishing nets, or parts thereof, fishing gear, ropes, packing bands, and other debris which might lead to the entanglement of fur seals, in accordance with the provisions of the Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter, of December 29, 1972;

(3) in accordance with Article X of the Convention, it may be necessary during the interim period of the Convention to take into account unforeseen circumstances as noted by the States of fur seal origin in considering measures to be taken for conservation and management of the fur seal populations; and

(4) taking into account Article XIII, paragraphs 4 and 5, as well as Article V, paragraph 2(e), within two years after the entry into force of the 1984 Protocol Amending the Interim Convention on Conservation of North Pacific Fur Seals and considering current factors, the Governments will review the operation of the Convention to determine what further agreements would be desirable in order to achieve the objectives of the Convention.

Under this proposed action, the harvest of sub-adult male seals on the Pribilof Islands will probably continue at current levels, throughout the interim period of the Convention. This would benefit the residents of the Pribilof Islands who would maintain their jobs and wages in the harvesting and initial processing of seal skins. The seal harvest supplies about 80 jobs and $500,000 annually. Expected social/cultural impacts

on island residents from new economic development proposals, including fisheries and possibly oil and gas exploration, could be mitigated by continuing their traditional harvest activities for at least four additional years.

The harvest of sub-adult male seals has been considered as a possible contributing factor in the population decline. However, since the population experienced a major increase while a harvest was being conducted between the early 1900s and the 1950s, it is difficult to attribute the current decline to effects of the harvest. Additional evidence supporting this conclusion concerns the decline in pup numbers on St. George Island, where no commercial harvested has occurred since 1973. The rate of decline on St. George is about the same as on St. Paul, the site of the current commercial harvest.

Agreement by Party Governments on an emergency mechanism which would allow the United States to reduce or suspend its harvest under unforeseen circumstances, would potentially have a positive impact on the northern fur seal population. This should provide assurance that harvesting will not have disastrous effects on this species. As noted in Section III.B.9., however, it is the consensus of the Standing Scientific Committee of the NPFSC that current harvest levels are not responsible for the observed decline in the population. On the contrary, preliminary analysis of data relating to pup mortality on land indicates that a termination of the harvest, at this time, could impede a recovery of the population. Recent work by Soviet scientists, however, suggests the need for continuing studies on the effect of the harvest and its role, if any, in the population decline. (see Section III.B.9). Section 3 of the Statement gives the United States greater flexibility in setting harvest levels on the Pribilofs, should a change in harvest strategy become necessary due to unforeseen circumstances.

While some scientists believe that it is possible that a termination of the harvest of males may actually impede a rapid recovery of the seal herds, they advise immediate action to prevent further losses of the breeding stock, especially pregnant females, in discarded fishing gear (see Section III.B.9.). An increase in international research and cooperation on methods to solve this problem is crucial to the maintenance of the northern fur seal populations. Prevention of further disposal at sea of this material, and new research mandates for all Party Governments will provide the first steps toward solving this problem. In Section 1 of the Statement the Party Governments strongly endorse additional research on current aspects of fur seal conservation including entanglement of fur seals in fishing debris. Section 2 of the Statement reaffirms the commitment of the Party Governments to take appropriate measures, in accordance with their national laws, the Convention and the Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter, to prohibit disposal at sea of synthetic materials which might lead to the entanglement of fur seals.

Maintenance of the treaty prohibitions on pelagic sealing are considered essential to the protection of the breeding stock of these populations. Although a resumption of commercial pelagic sealing on a scale similar to that at the beginning of this century is considered unlikely, the taking of fur seals by commercial fishing fleets in the North Pacific Ocean for "predator control" can be expected to increase without the protections provided by this respected international treaty.

Under the signed Protocol, the harvests on U.S. and Soviet owned islands of sub-adult male fur seals will probably continue at current levels, unless and until it is determined that the harvest is impeding a recovery of the species or there is an unforeseen event which would alter the harvest level. This proposed action, therefore, will not result in an adverse impact on fur seal stocks. If entanglement is a major factor in the population

decline, then the current average annual decline of 6.5 percent may continue thoughout the interim period of the Convention, whether or not the harvest continues. Under this assumption, the 871,000 population estimate on the Pribilofs could decline to 666,000 by 1988.

B. Extend the Convention

We could have proposed an extension of the Convention without modification for an additional four years, maintaining the current research and management regime for fur seals without change. Pribilof Island residents would continue to harvest fur seals and retain harvest and skin processing jobs and income. They would be protected from further social/cultural impacts by retention of their traditional harvesting activities for four more years.

A simple extension of the Convention was the preferred option of the other Party Governments, but the United States convinced them of the need to address issues of fur seal conservation and use, especially in light of the recent declines in stock size. This alternative, therefore, would have failed to address those concerns noted in Section A above. Specifically, under the present Convention as interpreted by other Party Governments, only after agreement by all Governments could action be taken to reduce or suspend the harvest. In an emergency situation, therefore, the Pribilof Island fur seal population could be adversely impacted by a delay in harvest adjustments.

It was the view of the United States, during the negotiations with the Party Governments, that certain clarifications were necessary to ensure the continued success of the Convention. A simple extension would have failed to address important fur seal management issues.

C. Renegotiate the Convention

The United States could have requested that Party Governments meet to renegotiate the basic principles of the Convention. Management principles of the MMPA, including OSP could be proposed as a replacement for the current harvest-oriented management regime. Harvests would be allowed only if the species or stock is determined to be within OSP. International research and the prohibition on pelagic sealing could possibly be retained.

Since the Pribilof Island portion of the population has been determined to be below OSP (Section III.B.9.), this alternative would result in the suspension of the harvest on the Pribilof Islands. Pribilof Aleut residents would lose jobs and income associated with the harvesting and processing of seal skins and the sale of meat and other by-products. Although the impacts on island residents of proposed development projects on or near the Pribilofs (Section III. C.3.) are independent of the future of the Convention, this alternative could increase the severity of these impacts. An end to the seal harvest on the Pribilof Islands would add to the potential burden of social change for island residents.

An end to the commercial harvest would result in an increase in primarily three and four year old male seals on St. Paul Island, at least in the short-term. Based on preliminary analyses, an increasing male population of this polygynous species could give rise to an increase in pup mortality on land. Thus, rather than aiding in a recovery of these stocks, a suspension of the male harvest may actually impede the recovery by altering the sex-ratios on St. Paul, and overall productivity of the seal population. Recent work by Soviet scientists, on the other hand, suggests the possibility that the current ratio of adult females to adult breeding males is not optimum, and that some

increase in the male population may be necessary. Following a detailed examination of the data on current population declines on both U.S. and some USSR owned islands, it is the consensus of the Standing Scientific Committee of the NPFSC that the harvest probably is not contributing to the decline and that no adjustments in harvest levels are required.

The proposal outlined in this alternative was discussed during the negotiations that resulted in the signed Protocol and Statement, and met strong opposition by the Party Governments similar to the strong opposition experienced during past negotiations (Section I.B.3). The Party Governments did, however, agree to review the operation of the Convention, within two years after entry into force of the Protocol, to determine what further agreements would be desirable in order to achieve the objectives of the Convention. The commitment to review the operations of the Convention is found in Section 4 of the Statement.

D. Allow Expiration of the Convention (No Action)

The United States could have allowed the treaty to expire in October 1984. Ending the Convention would have halted the present international management and research programs for the northern fur seal. Animals occurring within the 200-nautical mile EEZ would be protected by the United States under the provisions of the MMPA. There would be no U.S. harvest of northern fur seals except for subsistence purposes by the Aleuts and other Alaska Natives. However, under the authority of Section 109 of the MMPA, the State of Alaska could receive jurisdiction and management authority for fur seals. Following a recovery of the population to levels above OSP, commercial harvests could resume under applicable regulations.

While this species remains below OSP, the Aleut residents of the Pribilof Islands would experience severe social/cultural and economic impacts from a loss of their seal harvest. These impacts would occur at a time when other major changes are occurring on the islands as a result of fisheries/harbor and offshore energy development. Although eventually these development plans will result in alternative employment opportunities for island residents, the loss of the traditional seal harvest would be a major adverse impact on island residents at this time.

An end to the male harvest on St. Paul Island could result in an increase in pup mortality on land at a time when the Pribilof Island population is experiencing a significant decline An end to the harvest would not necessarily result in a recovery of this population to levels observed during the 1950s. On the contrary, ending the harvest may impede the recovery of the northern fur seal populations.

An end to international research and cooperation would seriously hamper U.S. efforts to solve the problem of fur seal entanglement in discarded fishing debris, which is currently responsible for a part of the 6.5 percent annual loss of fur seals. Since northern fur seals pass through waters outside the jurisdiction of the United States, under the MMPA we could protect the Pribilof Island herd during only part of its migration cycle. Most pregnant female fur seals appear to travel from California to the Pribilof Islands using a direct route which places them outside the 200-mile zones of both the United States and Canada. This is the portion of the population which has the greatest effect on future population size. Opportunistic taking of these animals by fishermen for predator control purposes could be expected to increase substantially in the absence of the treaty prohibitions on pelagic sealing.