MARINE MAMMAL COMMISSION — Annual Report for 1991 



taken or planned to take to consider an Appendix HI 

 listing. On 25 April 1991, the Service responded to 

 the Commission, stating that it was taking no further 

 actions in pursuit of either an Appendix 11 or Appen- 

 dix m listing. The Service noted that the annual 

 subsistence harvest bans the commercial use of fur 

 seal products, which accomplishes the intent of an 

 Appendix III listing under the Convention. 



North Pacific Fur Seal Research Program 

 and Conservation Plan 



The National Marine Fisheries Service's North 

 Pacific fur seal research program is directed by the 

 National Marine Mammal Laboratory. According to 

 a prospectus prepared by the Laboratory for its 16-17 

 October 1991 program review, the goals and objec- 

 tives of the fur seal research program are to monitor 

 changes in population dynamics by: (1) determining 

 pup production as an index to population change; (2) 

 comparing historical, on-land habitat use of fur seals 

 to present use by monitoring rookeries and counting 

 harem and idle bulls; (3) identifying migration pat- 

 terns and at-sea foraging areas; and (4) detecting signs 

 of disease in sampled dead animals. According to the 

 laboratory, the purpose of the research program is to 

 implement the North Pacific Fur Seal Conservation 

 Plan by studying fur seals throughout the eastern 

 North Pacific Ocean. However, a conservation plan 

 for fur seals has yet to be published by the Service, 

 despite the obvious need based on the observed 

 decline in fur seal numbers in the North Pacific and 

 the fact that it is required by Federal law. 



As discussed in previous Annual Reports, the 

 Pribilof Islands fur seal population was designated as 

 depleted under the Marine Mammal Protection Act by 

 the National Marine Fisheries Service in June 1988. 

 The Commission had recommended such a designation 

 in 1984 and again in 1985 and 1986. By letter of 29 

 November 1985, the Commission also reconmiended 

 that the Service prepare a conservation plan to provide 

 a basis for identifying and directing priority research 

 and management actions needed to restore the popula- 

 tion. It was reconunended that the plan be similar to 

 the recovery plans required for endangered and 

 threatened species under the Endangered Species Act, 

 and an annotated outline was provided. 



In the 1988 amendments to the Marine Mammal 

 Protection Act, Congress required that conservation 

 plans be developed for all species or populations of 

 marine mammals listed as depleted under the Act. 

 With respect to the North Pacific fur seal, the amend- 

 ments explicitly directed the National Marine Fisher- 

 ies Service to prepare a conservation plan by 31 

 December 1989. A draft plan was prepared by the 

 National Marine Mammal Laboratory and forwarded 

 to the Commission for comment on 27 March 1990. 



On 23 April 1990, the Commission provided the 

 Service with extensive comments on the draft plan. 

 The Commission noted that the plan provided useful 

 information on research concerning past exploitation, 

 life history, population status and trends, and possible 

 causes of decline. The Commission also noted, 

 however, that the plan did not sufficiently develop 

 recommendations for ftirther research and manage- 

 ment activities or indicate how such activities would 

 contribute to the recovery and conservation of the fur 

 seal population. The Commission made several 

 specific recommendations to improve the plan by 

 advising the Service to, among other things: (1) deve- 

 lop a clear statement of goals and objectives; (2) pro- 

 vide a clear description of the rationale, nature, and 

 scope of recommended actions; (3) prepare a step- 

 down outline to illustrate the relationships among 

 research and management tasks needed to achieve the 

 plan's objectives; and (4) prepare an implementation 

 schedule setting priorities and estimating costs for 

 undertaking the recommended actions. 



Having received no reply to its 23 April 1990 

 letter, the Commission, on 4 December 1990 and on 

 13 March 1991, again wrote to the Service seeking a 

 response to its questions and comments on the draft 

 plan. On 25 April 1991, the Service replied that it 

 had received substantial comments on the draft plan 

 circulated in March 1990, and that it had forwarded 

 all comments to the National Marine Mammal Labora- 

 tory for review. The Service also indicated that the 

 emergency listing of the Steller sea lion as threatened 

 under the Endangered Species Act in the fall of 1990 

 had caused the plan to be delayed, but that after the 

 conclusion of the 1991 fur seal field season, the plan 

 would be finalized and distributed for public com- 

 ment. As of the end of 1991, the Commission had 

 not received the conservation plan. 



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