The Wildlife Society appreciates the invitation to review and comment on the Draft Environmental Impact Statement (DEIS) on the Interim Convention on Conservation of North Pacific Fur Seals.

The Wildlife Society is the international professional organization that represents nearly 8,000 wildlife biologists, managers, researchers, educators, and administrators. The Wildlife Society always has supported sound programs to perpetuate and manage wild living resources, including the Interim Convention on Conservation of North Pacific Fur Seals. The DEIS on the future of the Convention is of direct concern because it relates to our principal objectives: 1) to develop and promote sound stewardship of wildlife resources and of the environments upon which wildlife and humans depend; 2) to undertake an active role in preventing human-induced environmental degradation; 3) to increase awareness and appreciation of wildlife values; and 4) to seek the highest standards in all activities of the wildlife profession. Within this framework, we offer the following comments and suggestions in an attempt to be as helpful as possible in developing the best international management and conservation program for the northern fur seal (Callorhinus ursinus).

The Wildlife Society supports an extension of the Interim Convention on Conservation of North Pacific Fur Seals. For several years the Society has been involved actively in efforts to maintain and extend the Interim Convention because we believe it is in the best interest of the resource, the northern fur seal populations. The successful northern fur seal program, conducted under the Interim Convention, epitomizes the objectives and results of sound international research, management, and wise use. In addition, extension of the Convention will assist the United States in fulfilling the requirements of the Fur Seal Act of 1966, particularly in regard to the Aleut residents, and help ensure a stable economic base during the transition from Federal administration of the Pribilof Islands to state and local governments and private enterprise (P.L. 98-129).

We view Alternative D (Allow Expiration of the Convention) to be completely unacceptable. Human-caused impacts have occurred in practically all of the ecosystems of the world and thus require scientific management of these disrupted areas and their associated living resources. The extirpation of the

northern fur seal was prevented in 1910 by wise management that resulted in a current population of 1.4 million animals. Although we are concerned about the 4-8% annual decline in pup numbers, allowing the treaty to expire in October 1984 would end the present international management and research programs for the northern fur seal. We know of no scientific information to indicate that ending the commercial harvest of sub-adult males in this polygamous species would reverse the downward trend in pup numbers. In fact, not harvesting subadult males could actually impede recovery by altering the sex-ratio, reducing productivity, and increasing pup mortality. Further, most pregnant females, on their return to the Pribilof Islands, travel outside the 200-mile zones of the U.S. or Canada and would become susceptible to pelagic sealing. Any amount of indiscriminate pelagic sealing is unacceptable. We must support and strengthe scientific management and research as the rational instruments for maintaining, restoring, and enhancing the northern fur seal resource for the continued use and appreciation by humanity. The "hands-off" approach by allowing the Convention to expire would have a major negative impact on the species we are attemptin to conserve and on the Aleut people.

Alternative C (Renegotiate the Convention) does not appear to be viable at this time--the DEIS makes frequent reference to the fact that substantive renegotiatio is opposed by most or all parties (e.g., pages ii, 8, 10, 36, etc.). It may be desirable ultimately to have a formally revised Convention, containing at least some of the items proposed in Alternative A, as well as a revised management strategy. However, when renegotiation is appropriate, it must be initiated with sufficient lead time to ensure that if revision efforts fail time remains to extend the basic Convention.

Alternatives A (Modify the Present Convention Through an Exchange of Diplomatic Notes) and B (Extend the Present Convention) are preferable to C or D. Alternative B is the minimum that must be accomplished. We are concerned, however, that Alternatives A and B are presented as either/or. The first priority must be to extend the present Convention to ensure that indiscriminate pelagic sealing where pregnant females could be highly susceptible to harvest, does not resume. The modifications proposed in Alternative A, as well as Alternative C, must be viewed as subsets to Alternative B. With an ongoing Convention, the parties should work toward modifications--through the procedure outlined in either A or C The four (4) proposed modifications outlined in Alternative A all appear to be appropriate for improved management and research. However, failure of the partie to agree on one or more of these proposed modifications must not be grounds to withhold extension of the Convention. We suggest that Alternative A should be entitled "Extension of the Convention with Possible Modifications" and Alternative B should be "Extension of the Convention without Modifications. language of Alternative A then should make it clear that extension of the Convention is not contingent upon acceptance of all the modifications proposed. All the modifications should be sought and as many as are acceptable to the parties should be incorporated in the extension of the Convention through an exchange of diplomatic notes.

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The Wildlife Society is concerned that adequate funding, a major aspect of northern fur seal conservation and management, has not been addressed in the DEIS. Sufficient funding and manpower have not been available to collect and

Review of DEIS on the Interim Convention on Conservation of North Pacific Fur Seals

General Comment

Certain points in the DEIS should be developed more completely for the FEIS and before a preferred alternative is selected. These include final analysis of data showing that termination of the harvest may impede population recovery, assessment of the probability of pelagic sealing if the Convention expires, a more complete description of how the 5 percent entanglement loss figure is derived with a breakdown of loss by sex, and more complete analysis of effects on Pribilof Islands residents if fur seal harvesting were terminated. More complete information is especially needed because many of the references on which the report is based have not received wide distribution and are not readily available to many reviewers.

Specific Comments

This

The point should also be made that seals on St. Paul Island and St. George Island each show fidelity to their respective islands. This strengthens the argument that population declines which have occurred on both islands are not due to harvesting which now occurs only on St. Paul Island.

Pelagic sealing

The DEIS states (last sentence starting on p. 10) that Japan could reintroduce pelagic sealing either as a commercial operation or in conjunction with existing fisheries in the Bering Sea if the Convention expires.

Assessing the liklihood of pelagic sealing requires an understanding of fur seal distribution and past pelagic sealing. Continental shelf areas with high productivity affect fur seal distribution. The continental shelf and water depths are best shown by a map, but the water depth contours on the Bering Sea map are illegible (Figure 1). The DEIS states (p. 16, last para) that fur seals are most frequently seen from about 70 to 130 kilometers from land. This is generally borne out by maps (Figures 3 through 6). The DEIS also states (p. 18, para 2) that clearly, all fur seals spend some portion of their lives in water outside the jurisdictions of both the U.S. and Canada (i.e., more than 200 miles offshore). Some reviewers might consider this inconsistent with the previous statement and the maps, and it is suggested that offshore distribution be described in more detail with maps to support the text. The DEIS states (p. 18, para. 1) that the offshore region (more than 200 nautical miles offshore) contains essentially the entire population in December and January. Again, this is not borne out by maps (Figure 6c which includes December observations and Figure 5a which includes January observations).

Once it has been demonstrated what portion of the population would be vulnerable to harvest outside the 200-mile zones of the U.S. and Canada, and at what times of year, the economics of pelagic sealing should be addressed. This should include assessment of a harvest operation directed only at fur seals, and also in conjunction with existing fisheries. Items to be considered should include fuel costs, feasibility if excluded from refueling and receiving support at U.S. and Canadian ports, effects of scattered rather than clumped distribution of seals on harvest efficiency, skin processing costs, skin sale prices in an apparently declining market, distribution and availability of seals throughout the year relative to other fishery efforts and limitations because of weather, pelt quality during period when animals can be taken, and effects of world opinion and pelagic sealing and taking of females. In case Canada might choose not to exclude pelagic sealing in her 200-mile zone, a similar analy sis should be made if animals are protected within only the

U.S. 200-mile zone. Current skin processing cost and sale

price figures might be included. Processing cost per skin by
Fouke Company in 1981 was $91.50; sale price was $65 (From
Dames and Moore. 1983. Economic strategies plan, St. Paul
Island, Alaska, P. 4-36).

The DEIS states (p. 36, last para.) that international taking of seals by fishermen for predator control purposes could be expected to increase substantially in the absence of treaty prohibitions on pelagic sealing. This is an important point, and the basis for the statement should be provided, or if it is speculative, it should be so stated. It might also be speculated that certain fishermen who perceive marine mammals as competitors will always try to control them regardless of whether of not it is legal. Any possible analysis of the effects of "predator control" taking on the population should be included in the FEIS.

The DEIS states (p.23, para.1) that as much as 5 percent or more of the fur seal population may die from entanglement and that this mortality may be responsible for a large part of the observed decline in the fur seal herd in recent years. The DEIS states (p. 22, para. 2) that incidence of enganglement among females is considerably less than that observed among males taken in the harvest. The DEIS also implies that continuing the males-only harvest is necessary for the population to recover. If this is correct and if entanglement kills primarily males, then the case for entanglement as the primary cause for population decline is not borne out. This should be addressed in the FEIS. Table 8 would be more complete with a breakdown of entanglement rate by sex.

The DEIS states (p. 21, last para.) that the entanglement rate for harvested animals has averaged 0.4 percent since 1967. Fowler (1982) is cited as stating that 5 percent or more of the fur seal herd may die from entanglement (top of p. 23). The citation, Fowler 1982, is not included in the Literature Cited section (p. 72). The entanglement mortality rate is important, and this reference should be included, as well as a complete

discussion of how the 5 percent or greater figure was obtained. and its relationship to the 0.4 percent average rate in Table 8.

The DEIS states (p 21, last para.) that entangling debris on St. Paul Island seals is usually trawl net scraps and plastic packing bands. The discussion would be more complete and possible solutions present themselves if debris types were quantified by percentages as is done for Soviet rookeries (p. 22, para. 4).

Economics of harvest and Pribilof Islands villages Table 19 would be more complete if it showed that proceeds to the government (column 6) were before Canada and Japan each received 15 percent.

The DEIS states (last sentence starting on p. 28) that under PL 98-129 passed in October 1983, the Department continues its responsibilities of oversight and management of the fur seal harvest and for fur seal management as required by the Convention. It is not clear from the DEIS who has responsibility for sale of skins--the Department or Pribilof residents. It could be implied that Pribilof residents do, since the DEIS also states (p. 34, para. 3) that a treaty extension longer than 4 years is necessary for island residents to establish new markets for skins and harvest by-products. The party responsible for marketing of skins under PL 98-129 and a Convention extension should be defined in the FEIS.

If, under extension or modification of the Convention, the island residents will have responsibility for sale of skins, does this mean that the government will continue to fund the cost of harvesting, and that proceeds from sale of skins is then clear profit for island residents, or will costs of harvesting, skin