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Q-58

permitted. In light of these facts, the summary and unsupported
assurances (see: 1983 Background Paper at 1, 9) of those involved
in the commercial kill that such commercial killing does not
contribute to the continuing 8 to 10 percent annual population
decline seem self-serving, at best.

Summary of the causes of the population decline as related
To the factors for which an animal may be listed.

The present or threatened destruction, modification, or
curtailment of its habitat or range.

This factor is not important because the carrying capacity
of the habitat has apparently not declined since the population
was discovered.

Q-59

buttressed by the fact that the seal herd on the San Miguel
Islands in California has continued to expand, in spite of the
fact that it is not subject to the killing bachelor males. The
factor at work could be genetic, physical disturbance, or a
reduced rate of impregnation (see: Gentry, Feb. 1983, Draft
Rept. of Progress Under the Coordinated Bering Sea-Pribilof
Reseach Proposal: 10 year Rept. at page 10 (s 15b)).

3. Disease or predation.

These factors seem unimportant as there is no evidence of
unusual disease or predation, except predation by humans, which
is discussed elsewhere.

1.

2.

Overutilization for commercial, sporting, scientific, or
education purposes.

This factor is certainly contributing to, if not causing,
the population decline. The commercial kill results in the
elimination of 24-30,000 seals per year. While most of these are
males, loss of which NOAA suggests will not harm the population's
productivity, some are females, the loss of which must reduce
both the population and productivity.

Furthermore, the rate of decline is higher on St. Paul
Island, where U.S. commercial kill occurs, than it is on St.
George Island where no commercial kill is allowed (1983
Background Paper at 4). Thus, there may be some subtle, if
unknown, effect of killing these presumably "excess" males on the
productivity of the entire population. This conclusion is

& 5. The inadequacy of existing regulatory mechanisms and
other natural or manmade factors affecting its continued
existence.

These two factors, taken together, must be considered of
overriding importance in the continuing demise of the fur seal.
The Convention requires that the fur seal population be managed
at a level which insures maximum sustainable productivity.
However, decisions made by the Parties pursuant to the Convention
have provided a demonstrably inadequate mechanism for insuring
such a result, based on the fact that all Parties now agree that
the fur seal population has declined to a level substantially
below maximum productivity, and no corrective action has been
taken. Indeed, at the 1982 and 1983 meetings of the Parties,
despite increasing evidence of a decline, and, no evidence that
the annual killing is benefiting the seal population, the parties

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Q-60

voted to continue to allow the annual commercial killing of 2430,000 seals. Clearly, the Convention, which is the existing regulatory mechanism, has failed and continues to fail, as currently implemented, to provide adquate protection for fur seals.

1983

Moreover, entanglement in old pieces of netting or other debris from packaging has long been identified as a serious cause of mortality. Numerous papers and reports have been produced on this by the North Pacific Fur Seal Commission (see: However, the only action taken Entanglement Paper at 32-33). recently has been the production (in 1982) of posters for use on board ship and in ports asking fisherman not to discard material Whether this will be helpful remains to be seen.

overboard.

However, the fact that similar materials were produced, distributed and/or posted in 1976, 1977, and 1978 asking fishermen to refrain from discarding this material, with no apparent decline in mortality, suggests that these efforts will

be ineffective.

In addition, such action even if successful only deals with a part of the problem, since the sea already contains millions of tons of such material which is presumably capable of causing substantial and continuing mortality for innumerable years. Furthermore, from a U.S. perspective, the governmental mechanisms for insuring compliance with the Convention's provisions have been equally inadequate.

The U.S. Government has

known for many years that the fur seal population was The government has also consistently identified declining.

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entanglement as a cause of mortality. NMFS, by letter of May 31, 1983, committed itself to convening a meeting of scientists in Yet August 1983 has come and August 1983 to examine the problem. gone, without the promised meeting, and the meeting date is now Such delays clearly demonstrate a lack set for August of 1984. of adequate attention to the problem and a lack of governmental mechanisms to deal with a serious failure to achieve the purposes of the Convention.

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Q-62

Q-63

G.

Summary and Conclusion

it is our belief that the Pribilof Fur Seal

In summary,
should be listed as a threatened species as soon as possible.
The population has declined by more than 50%, and the decline
continues. The current rate of decline is 8-10% per year, and
the population is at a level of less than 50% of carrying
capacity in violation of the Convention.

Moreover,

Finally, there are no
indications that the decline has abated; indeed, recent data
suggest that the rate of decline may be accelerating.
government officials have not yet been able to identify, much
less correct, the cause of the decline.

Clearly, this is the kind of situation which the threatened
species listing was designed to correct. It is clear that the
Federal Government, despite an International Convention and the
Marine Mammal Protection Act, has been unable to solve, or even
positively identify, the problems of the fur seal. More effort,
as well as focused attention, is needed. Yet, since 1974,
without the authority and mandate of the ESA, the government has
taken no direct corrective action whatsoever, apparently just
producing posters and other literature in 1977, 1978, and 1982.

Meanwhile, the situation grows progressively worse. With a
decline of 8 to 10% per year, mathematics suggests that it may
only be a short time before the species is endangered. For
example, the population is now at level of less than 50% of
carrying capacity. At a rate of decline of 10% per year, the
population will be reduced by 1/2 every seven years. Thus, if

the rate of decline remains at about 10% per year, the seal
population will be at less than 1/8th of its former level in just
14 years.
Then it will be fully endangered.

In conclusion, the situation is as follows:

1.

The population is declining by at least 8-10% per year, and the rate of decline may well be accelerating.

2.

No actions are planned or have been taken to reverse the
decline.

3. Under such circumstances, it must be assumed that the

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5.

This rate of decline is clearly threatening the survival
of the seals.

Based on the foregoing evidence and discussion, we
respectfully urge that this Petition be expeditiously granted.

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Participation in this international workshop should
include scientists, gear technicians, fishermen,
net manufacturers, and other persons who might be
expected to meaningfully contribute to a scientific
and technical workshop of experts.

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to assess the effects of this on the demography
and/or dynamics of the affected populations
and the ecosystem(s) of which they are a part;
to identify the types and sources of gear and
packing material in which marine mammals, birds,
turtles, and fish are becoming entangled;

to determine if certain species or age/sex
classes of animals are more likely to be caught
in lost or discarded gear and packing material
than other species or age/sex classes and, if
possible, why;

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to estimate the rates of deterioration or longevity of different materials, their rates of accumulation (deposition and clearance) and the likely movements of such material as is lost or discarded with respect to different points of origin;

to determine the short- and long-term impacts of lost or discarded materials already in the ocean upon marine organisms and identify steps that can or should be taken in this regard;

to identify and evaluate alternative methods for disposing of unwanted net fragments and packing material as well as incentives (both positive and negative) for preventing or reducing discards; and

to identify such information as may be needed to better understand and resolve the problem as well as the mechanisms whereby such information can be developed.

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Enclosed for filing are four copies of supplemental comments on the draft environmental impact statement for the Interim Convention on the Conservation of North Pacific Fur Seals. As explained in the filing, these comments are being filed after the close of the official comment period due to intervening governmental action. We request that the supplemental comments be considered in preparing a final environmental impact statement or in reissuing a new draft environmental impact statement.

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Q-65

Q-66

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In October 1983, the United States Department of

Commerce released a draft environmental impact statement

(DEIS) that purports to evaluate the environmental impacts
associated with renewal of the Interim Convention on Conservation
of North Pacific Fur Seals (Convention) and its alternatives.
See DEIS at i. On January 6, 1984, the International Fund
for Animal Welfare (IFAW), the Humane Society of the United
States (HSUS), and The Fund for Animals filed extensive
comments on the DEIS's analysis of the Convention and the
alternatives set forth in the DEIS.

Several months after the comment period for

the DEIS had closed, the United States Department of Justice
took the position in pleadings filed with the United States
District Court of Columbia that the EIS that had been prepared
in 1980 for renewal of the Convention not only analyzed the
environmental impacts associated with renewal of the Convention
and alternatives to renewal, but it also analyzed the potential
environmental impacts associated with (1) the annual decision
under the Fur Seal Act whether or not to accept the recommendation
of the North Pacific Fur Seal Commission and kill seals each
year on the Pribilof Islands; (2) the determination of how many

September 12, 1964

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