provided to invited participants at least two weeks in 

 advance of the program review. 



The 1986 Subsistence Harvest 



As noted above and in the previous Annual Report, the 

 U.S. had not acted to continue the Interim Fur Seal Conven- 

 tion prior to the scheduled beginning of the fur seal harvest 

 in July and August 1985. In the absence of an international 

 agreement binding upon the U.S., management authority for fur 

 seals on the Pribilof Islands is derived exclusively from 

 domestic laws, including the Marine Mammal Protection Act and 

 the Fur Seal Act. Under these laws, the taking of fur seals 

 for commercial purposes is prohibited. A take by Alaska 

 Natives for subsistence purposes is, however, permitted with 

 certain conditions. Under authority of these two laws, the 

 National Marine Fisheries Service published emergency interim 

 regulations on 8 July 1985 governing the 1985 subsistence 

 take of fur seals by the Aleut residents of the Pribilof 

 Islands. Those regulations governed only the 1985 harvest, 

 and, because of the continued lack of action to ratify or 

 renegotiate the Fur Seal Convention, permanent regulations 

 were considered necessary to regulate the harvest in 1986 and 

 future years . 



On 7 August 1985, the Commission, in consultation with 

 its Committee of Scientific Advisors, recommended that the 

 National Marine Fisheries Service immediately begin the 

 process of preparing proposed permanent regulations. 

 Although the Service indicated in its 8 July 1985 interim 

 regulations that proposed permanent regulations would be 

 published by 30 September 1985, no action had been taken by 

 the end of November 1985. Thus, by letter of 29 November 

 1985, the Commission repeated its recommendation that the 

 Service promptly publish proposed regulations. By letter of 

 21 February 1986, the Service advised the Commission that 

 proposed regulations would be published early in the spring 

 of 1986. Concerned about the delay, the Commission re-empha- 

 sized the importance of implementing permanent regulations 

 prior to the 1986 subsistence harvest season in its 12 March 

 198 6 follow-up letter to the Service. 



The Service published proposed permanent subsistence 

 harvest regulations on 15 May 1986 and provided a 30-day 

 period for public comment. The Commission provided comments 

 to the Service on 16 June 1986 and recommended that the 

 regulations be adopted subject to modifications concerning: 

 the need for a procedure to extend the harvest season beyond 

 8 August of each year; authorization of a full subsistence 

 harvest on St. George Island; measures that could be taken to 

 improve research on the fur seal decline; and other matters. 



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