Both the Service and the applicant responded to the 

 Commission's 14 July 1986 letter questioning the practical 

 value of the planned experiments to determine how entangle- 

 ment in small net fragments affects the energy requirements 

 of fur seals. The information provided convinced the 

 Commission that the planned experiment would provide infor- 

 mation of scientific interest, but of no practical value with 

 respect to determining whether entanglement is causing or 

 contributing to the continued fur seal population decline. 

 Noting that the Commission and the National Marine Fisheries 

 Service shared the view that the Pribilof Islands fur seal 

 population was depleted as defined under the Marine Mammal 

 Protection Act and that the Service's permit regulations 

 require detailed justification for conducting research on 

 depleted species or populations, the Commission, by letter of 

 31 July 1986, recommended that the Service not provide 

 support for the study as planned. The applicant subsequently 

 withdrew the permit application. 



In response to the Commission's letter of 15 July, the 

 National Marine Fisheries Service authorized continuation of 

 essential population studies as recommended by the Commis- 

 sion. The Service did not authorize the planned pilot study 

 recommended by the Commission to determine the feasibility of 

 possible techniques for assessing the probability of dif- 

 ferent age/sex classes of fur seals being entangled in 

 different types and sizes of net fragments. Therefore, in 

 its letter of 31 July 1986, the Commission repeated its 

 recommendation that the planned pilot study be authorized and 

 carried out as a matter of priority. 



Following consultation with the Commission, the National 

 Marine Fisheries Service published a Federal Register notice 

 on 1 August 1986 proposing to modify its fur seal research 

 permit to authorize the pilot study recommended by the 

 Commission. Information provided in the Federal Register 

 notice did not address a number of questions raised in 

 earlier comments provided by the Humane Society of the United 

 States and, on 2 September 1986, the Humane Society requested 

 that a public hearing be held to review the objectives, need 

 for, and design of the Service's fur seal research program, 

 particularly those aspects dealing with net entanglement. 

 The time required to schedule and hold a public hearing 

 prevented the Service from carrying out the pilot study in 

 1986 and the proposed permit modification request subse- 

 quently was withdrawn. 



A number of uncertainties concerning the National Marine 

 Fisheries Service's North Pacific fur seal research program 

 were raised during the review of the aforementioned permit 

 applications. For example, the Commission was uncertain as 

 to the relationship between the research activities described 



47 



