the degree to which specific species and populations of marine 

 mammals could be affected directly and indirectly if oil and 

 gas exploration and development proceeded as proposed. 



The Commission therefore recommended that the Statement 

 be revised or expanded to: (1) identify and consider the 

 possible effects of the proposed action on important marine 

 mammal prey species and feeding areas; (2) provide more thorough 

 assessments of possible direct and indirect effects on humpback 

 whales, blue whales, North Pacific fur seals, Steller sea 

 lions, harbor porpoise, and harbor seals; and (3) clearly 

 identify the assumptions, data, or published reports upon 

 which conclusions concerning the possible effects of the 

 proposed action on marine mammals and their habitat were 

 based. The Commission also recommended that the Minerals 

 Management Service consult with the National Marine Fisheries 

 Service and the U.S. Fish and Wildlife Service to identify 

 the types of monitoring programs that would be necessary to 

 verify predicted effects and to detect possible unforeseen 

 effects of the proposed action on marine mammals in time to take 

 effective mitigation measures. 



Subsequent to its 11 March letter, the Commission received 

 a copy of the National Marine Fisheries Service's Biological 

 Opinion on Proposed Lease Sale #91, which had been submitted 

 to the Minerals Management Service. The Commission, in con- 

 sultation with its Committee of Scientific Advisors, reviewed 

 the Biological Opinion and, on 24 May, provided comments to 

 the National Marine Fisheries Service. In its letter, the 

 Commission iterated the statements in the Biological Opinion 

 that increasing numbers of humpback whales are found along 

 the central and northern California coast in the vicinity of 

 the proposed Lease Sale and that the observed movements of 

 humpback whales may be in response to shifts in distribution 

 of prey species. The Commission noted that the Biological 

 Opinion addressed possible direct effects of noise and oil 

 spills on humpback and other endangered whales, but did not 

 appear to consider possible effects on important prey species 

 and feeding areas, and thus the possible indirect effects on 

 endangered whale species occurring in or near the proposed 

 lease sale area. The Commission recommended that, if the 

 Service had not already done so, it assess the possible indirect 

 effects of the proposed sale on endangered cetaceans, 

 particularly humpback whales, and advise the Minerals Management 

 Service of its findings. 



On 25 July, the National Marine Fisheries Service responded 

 to the Commission's 24 May letter. In its response, the 

 Service indicated that its Opinion addressed only leasing and 

 exploration activities (not possible development activities) 

 associated with Lease Sale #91. The response also noted that 

 the Service had considered indirect (food chain) as well as 



180 



