use of Tern Island and its potential effect on monk seals and 

 endangered sea turtles. Subsequently, section 7 consulta- 

 tions between the two Services were undertaken. As noted in 

 the previous Annual Report, the resulting Biological Opinion 

 recommended, among other things, that Tern Island logistical 

 support for fishing activities be limited to levels existing 

 at that time. 



On 1 July 1986, the Service forwarded to the Commission 

 and others the final "Hawaiian Islands National Wildlife 

 Refuge Master Plan/Environmental Impact Statc:r.ant . " The 

 Commission, in consultation with its Committee of Scientific 

 Advisors, reviewed the Plan and sent its comments to the 

 Service on 1 August 1986. In its letter, the Commission 

 noted that the final Plan raised, for the first time, the 

 possibility that the Service might decide at some future date 

 to discontinue operation of the Refuge field station on Tern 

 Island. Concerned about the impact that such an action might 

 have on Hawaiian monk seals, the Commission advised the 

 Service that it believed abandoning the Tern Island field 

 station would be ill-advised and that its continued operation 

 was essential for several reasons, including the fact that 

 Service personnel on Tern Island provide a presence that 

 discourages unauthorized use of beaches at French Frigate 

 Shoals, which already has the highest pup mortality rate of 

 any atoll within the species' range. In addition, the 

 Commission noted that field station personnel provide 

 valuable support for research and other projects necessary 

 for the recovery of the Hawaiian monk seal and other 

 endangered species. 



In its letter, the Commission expressed hope that the 

 Service would not find it necessary to consider closing the 

 Tern Island station. The Commission asked that, if the 

 results of any future review of station operations lead to 

 consideration of closing the station, the Service provide the 

 Commission, the National Marine Fisheries Service, and other 

 interested parties an opportunity to comment on the results 

 of that review. Furthermore, the Commission recommended that 

 the Service not make any final decision on abandoning Tern 

 Island unless it had first: (a) amended its Refuge Master 

 Plan so as to describe the modified Refuge management system; 



(b) re-initiated a review of the revised system for managing 

 the Refuge and its effect on endangered Hawaiian monk seals 

 and sea turtles with the National Marine Fisheries Service 

 under section 7 of the Endangered Species Act; and 



(c) provided the public with an opportunity to review and 

 comment on the amended plan. 



Because the Service did not respond to the Commission's 

 1 August letter, the Commission again wrote on 16 December 

 1986 to the Service expressing its grave concern about 



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