Chapter III — Species of Special Concern 



levels of incidental take in commercial fisheries and 

 subsistence hunting in Canada as well as in Alaska. 

 The Commission also noted that the draft assessment 

 was based on subsistence harvest information from 

 Alaska that was neither complete nor accurate. For 

 instance, the Commission cited harvest data showing 

 that the known retrieved harvest from the stock by 

 Alaska natives ranged from 25 to 83 during the period 

 1987-1993 and, at the same time, the Canadian Native 

 take ranged from 106 to 171. The Commission 

 concluded that, although not based on the best avail- 

 able information, the statement that the current level 

 of take is below the potential biological removal level 

 appears correct. It suggested that the final stock 

 assessment should provide more up-to-date informa- 

 tion on population size as well as levels of subsistence 

 take in both Alaska and Canada. 



With regard to the Chukchi Sea stock, the Com- 

 mission noted that the draft assessment did not clearly 

 identify the range of the stock. Also, it appeared that 

 the estimate of population size was not based on the 

 most up-to-date information, and the estimated aver- 

 age annual Native subsistence harvest appeared to be 

 based on data for a single year, and was not a multi- 

 ple-year average. The Commission also noted that the 

 assessment appeared to be inconsistent in some 

 conclusions. On one hand, the draft indicated that, 

 given the uncertainty concerning the minimum popula- 

 tion estimate, it was not possible to predict the impact 

 of human- related removals from the stock. On the 

 other hand, the draft concluded that the stock should 

 be considered stable. The Commission recommended 

 that the Service obtain more up-to-date information on 

 Native subsistence harvest and that the assessment be 

 expanded to identify the uncertainties concerning the 

 status and management of the stock and what would 

 be needed to resolve them. 



With respect to the Norton Sound/Yukon Delta 

 stock and the Bristol Bay stock, the Commission 

 similarly noted that there was not sufficient evidence 

 to judge the validity of the Service's conclusions and, 

 again, the estimate of Native take appeared to be 

 based on one year, not an average. It suggested that 

 the final stock assessment be expanded to identify any 

 uncertainties, and the measures needed to resolve 

 uncertainties, concerning the status and management 

 of the stock. 



With respect to the Cook Inlet stock, the Commis- 

 sion suggested that the final assessment provide more 

 detailed descriptions of fisheries and the incidental 

 take of beluga whales in those fisheries, and also 

 identify uncertainties concerning the stock size, stock 

 productivity, and the numbers of animals being and 

 killed or injured incidental to the various fisheries. 



Finally, the Commission recommended that, if it 

 had not already done so, the Service consider develop- 

 ing a conservation plan for the stocks of beluga 

 whales in Alaska as well as the development of a 

 cooperative agreement with the Alaska Beluga Whale 

 Committee to help implement the plan. 



Subsequently, a number of Alaska Native organiza- 

 tions raised concerns about the Service's final stock 

 assessment reports for some Alaska marine mammal 

 species subject to subsistence harvests but not to 

 significant interactions with commercial fisheries. 

 They expressed concern that, for stocks with no 

 known significant fishery-related mortality or with 

 uncertain stock status, classification as a strategic 

 stock focused undue attention on Native subsistence 

 harvests as a primary cause of the strategic determi- 

 nation. 



The Service wrote to the Commission on 28 

 March, relating the concerns expressed by Alaska 

 Native groups. In its letter, the Service noted that it 

 interpreted the primary intent of the 1994 amendments 

 and the guidelines for determining potential biological 

 removal levels as addressing marine mammal mortali- 

 ty and injury incidental to commercial fisheries. The 

 Service expressed the view that it would be more 

 appropriate to develop a management program to 

 address subsistence harvests and the status of stocks 

 subject to subsistence harvests through a co-manage- 

 ment process. Thus, for certain stocks subject to 

 subsistence harvests in Alaska, the Service planned to 

 defer determinations as to their status and their 

 potential biological removal level pending analyses of 

 sustainable harvest levels using information gathered 

 through the co-management program and further 

 research on the affected stocks. The Service indicated 

 that the stocks to be addressed in this manner would 

 include those that (1) are not listed as endangered or 

 threatened under the Endangered Species Act or 

 depleted under the Marine Mammal Protection Act; 



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