seal research program. This research previously had been 

 carried out under the authority of the Interim Fur Seal 

 Convention and, while the Convention was in effect, authori- 

 zation under the Marine Mammal Protection Act had not been 

 required. 



The first application requested authority to experimen- 

 tally entangle up to 70 seals, including adult males and 

 females with pups, to determine how entanglement in rela- 

 tively small net fragments (200 grams or less) affected 

 energy expenditure and survival. The second application 

 requested authority to mark, tag, and otherwise take up to 

 36,000 seals annually for a five-year period for purposes of 

 population monitoring and investigating several aspects of 

 the entanglement problem. 



The applications did not provide detailed descriptions 

 of the planned research and raised questions as to whether 

 the planned entanglement-related studies would contribute 

 significantly to determining the probable cause or causes of 

 the continuing fur seal population decline. Therefore, by 

 letters of 10 and 19 June 1986, the Commission requested 

 additional information on the nature, purposes, and expected 

 value of the research for which authorization was being 

 sought. 



The Commission subsequently received additional infor- 

 mation from the Service. However, it did not adequately 

 address all the Commission's questions, particularly those 

 concerning the expected value of certain aspects of planned 

 entanglement-related research. On 14 July 1986, the Commis- 

 sion advised the Service that it remained unable to determine 

 how proposed studies involving the deliberate entanglement of 

 fur seals in small net fragments would help to determine 

 whether net entanglement is causing or contributing to the 

 continuing decline of fur seal populations on the Pribilof 

 Islands. On 15 July 1986, the Commission advised the Service 

 that it also had uncertainties about the nature, purposes, 

 need for, possible effects, and humaneness of some of the 

 population and other net-entanglement studies being planned. 

 Recognizing that certain tagging and other programs were 

 essential to better assess and monitor population status, the 

 Commission recommended that authorization to continue certain 

 essential programs be provided immediately. The Commission 

 also recommended that authorization be granted, with certain 

 conditions, to incidentally entangle up to sixty fur seals 

 during the course of a pilot study to determine the feasi- 

 bility of possible techniques for assessing the rate of 

 entanglement of different age/sex classes of fur seals in 

 different types and sizes of net fragments. 



46 



