numbers of sea otters moved each year to allow the Service to 

 "carry over" otters not moved under the previous year's quota. 



The Commission reviewed the draft of the proposed revisions 

 and, by letter of 16 November 1989, relayed its comments to the 

 Service. In its letter, the Commission expressed concern about 

 the lack of sufficient information to support the proposed 

 changes. The Commission recommended that the background section 

 be expanded to indicate the numbers of otters moved during each 

 of the first two years, the age composition of the translocated 

 otters, and the fate of the otters. The Commission further 

 recommended that a discussion section be added to explain why the 

 regulatory changes were needed or desirable, why the Service 

 believed that reproduction and/or weaning would be enhanced as a 

 result of the proposed changes, and how the objectives of the 

 translocation would be furthered by the amendments. 



The Commission noted that many, if not all, of the proposed 

 changes had been recommended by the Southern Sea Otter Recovery 

 Team, and that mention of this fact in the draft revisions would 

 lend scientific weight to the proposals. In addition, the 

 Commission noted that the Recovery Team had recommended that 10 

 multiparous female otters, thought to be pregnant, be 

 translocated during year three, but that the draft rule did not 

 propose implementation of this recommendation. The Commission 

 suggested that it would be desirable to expand the proposed 

 revisions to permit implementation of this recommendation and, at 

 a minimum, the Service should explain why it had chosen not to 

 adopt this recommendation. The Commission further suggested that 

 the Service's proposed rule include a discussion of the Exxon 

 Valdez oil spill and the effects that a similar spill would have 

 had on sea otters, had it occurred off California, as had been 

 discussed by the Recovery Team. Inclusion of this discussion 

 would help support the Service's decision to continue with the 

 translocation beyond the second year even though success to this 

 point has been limited. The Commission suggested that the 

 Service should also explain why it thinks that allowing more than 

 70 animals a year to be translocated in year three will enhance 

 the chances for successfully establishing a sea otter colony at 

 San Nicolas. 



Update of the Southern Sea Otter Recovery Plan 



As noted earlier, the Southern Sea Otter Recovery Plan was 

 adopted by the Fish and Wildlife Service in 1982. Some of the 

 research and management actions recommended by the Plan have been 

 fully implemented, while others have been partially implemented 

 or not implemented at all. There is a need, therefore, to review 

 and update the Plan. 



The Fish and Wildlife Service recognizes the need to review 

 and to update or revise the Plan as necessary. As a first step 



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