did not provide such a plan, nor did it adequately describe 

 what would be done or why. Consequently, it was not possible 

 to assess the usefulness of the data likely to be obtained or 

 whether the possible impacts on the affected animals and 

 populations were justified. The Commission advised the Service 

 of its concerns by letter of 22 March 1988 and noted that the 

 request should not have been forwarded to the Commission for 

 review without that information. 



By letters of 5 May, 13 May, and 8 June 1988 the Service 

 provided the Commission with additional information on the 

 activities to be conducted under the requested permit modifi- 

 cation, including the rationale for such research. Two proposed 

 studies appeared to reflect research needs on age-specific 

 survival and reproductive rates identified as high priority 

 during the Service's 28-29 January 1988 Workshop. These 

 included studies to: a) tag a sample of females, sub-adult 

 males, and/or pups on St. Paul, St. George, Bogoslof, and San 

 Miguel Islands so that a portion of the respective seal 

 populations could be identified in future years to assess 

 survival and (for females) fecundity rates; and b) estimate 

 survival rates of entangled and non-entangled juvenile male 

 seals on St. Paul Island and perhaps other islands. The 

 remaining projects included studies to: develop, test, and 

 use radio tags and other types of instrumentation to obtain 

 more reliable data on feeding strategies of adult females and 

 post-weaned pups; collect blood samples from seals to assess 

 certain unspecified variables and indicators of the condition 

 of seals already being handled for instrumentation or other 

 purposes; and conduct lavage and enema studies to collect 

 information on the diet of North Pacific fur seals. 



On 23 June 1988, the Commission, in consultation with 

 its Committee of Scientific Advisors, recommended approval of 

 the requested permit modification subject to certain specified 

 conditions. Among other things, the Commission recommended 

 conditioning work in 1989 and beyond upon submission and 

 review of a report detailing past research results and a 

 clear justification that continued sampling will yield 

 meaningful results that will not unnecessarily jeopardize the 

 affected animals or populations. In this regard, the Commission 

 noted that there are uncertainties as to whether the proposed 

 studies will yield the quality of information needed for 

 decision-making and whether the risk of stressing, killing, 

 or injuring individual animals is therefore justified. Thus 

 the Commission repeated the belief stated in its letters to 

 the Service on 27 April 1987 and 18 June 1987 that the North 

 Pacific Fur Seal Research Program must be developed and 

 evaluated within the context of a comprehensive fur seal 

 conservation plan. 



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