Q-58 permitted. In light of these facts, the summary and unsupported Summary of the causes of the population decline as related The present or threatened destruction, modification, or This factor is not important because the carrying capacity Q-59 buttressed by the fact that the seal herd on the San Miguel 3. Disease or predation. These factors seem unimportant as there is no evidence of 1. 2. Overutilization for commercial, sporting, scientific, or This factor is certainly contributing to, if not causing, Furthermore, the rate of decline is higher on St. Paul & 5. The inadequacy of existing regulatory mechanisms and These two factors, taken together, must be considered of 12 13 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. 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. 14 15 Q-62 Q-63 G. Summary and Conclusion it is our belief that the Pribilof Fur Seal In summary, Moreover, Finally, there are no Clearly, this is the kind of situation which the threatened Meanwhile, the situation grows progressively worse. With a the rate of decline remains at about 10% per year, the seal 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 3. Under such circumstances, it must be assumed that the 5. This rate of decline is clearly threatening the survival Based on the foregoing evidence and discussion, we Participation in this international workshop should to assess the effects of this on the demography to determine if certain species or age/sex 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. 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. Q-65 Q-66 In October 1983, the United States Department of Commerce released a draft environmental impact statement (DEIS) that purports to evaluate the environmental impacts Several months after the comment period for the DEIS had closed, the United States Department of Justice September 12, 1964 |