Wildlife Service acts as the lead agency on U.S. delegations to 

 such meetings. In preparation for the Seventh Conference of 

 Parties, the Fish and Wildlife Service published a 14 September 

 1988 Federal Register notice soliciting suggestions for 

 additions, deletions, or reclassifications of species listed on 

 the appendices. In response, the National Marine Fisheries 

 Service proposed that North Pacific fur seals be added to 

 Appendix II and that northern elephant seals be removed from 

 Appendix II. 



On 18 May 1988, the National Marine Fisheries Service 

 designated the Pribilof Islands' population of North Pacific fur 

 seals as depleted under the Marine Mammal Protection Act. By 

 Federal Register notice of 31 August 1988, the Service indicated 

 that the population was being considered for listing as 

 threatened under the Endangered Species Act. The decline of the 

 Pribilof Islands' population from 2.2 million in the 1950s to 

 about 800,000 currently led to those actions and also prompted 

 the Service to seek an Appendix II listing for the species. 



In proposing the Appendix II listing, the National Marine 

 Fisheries Service noted that fur seal parts taken commercially 

 prior to 1985 under the Interim Convention on Conservation of 

 North Pacific Fur Seals may be traded without restriction. 

 However, the Service stated, international demand for seal bacula 

 (seal sticks) and skins could lead to significant illegal trade. 

 Among other things, the Service noted that: (1) Aleuts have, as 

 recently as 1988, retained seal sticks from the subsistence seal 

 harvest, "apparently intended for sale to Korean importers"; 

 (2) an illegal shipment of fur seal skins from the 1985 subsis- 

 tence harvest was seized by the Service after the skins were sent 

 to a commercial processor; (3) no inventory of skins and seal 

 sticks taken in the commercial harvest was ever maintained, 

 making it difficult to determine if shipments of fur seal parts 

 entering international trade are legal; and (4) foreign fishermen 

 engaged in high seas driftnet fisheries may be taking substantial 

 numbers of North Pacific fur seals, parts of which have the 

 potential to enter international commerce. 



On 1 June 1989, the Commission recommended that the Fish and 

 Wildlife Service, on behalf of the United States, propose to the 

 Seventh Meeting of the Conference of Parties that North Pacific 

 fur seals be added to Appendix II. In doing so, the Commission 

 agreed with the National Marine Fisheries Service that, because 

 seal parts taken in the commercial harvest are indistinguishable 

 from those taken in the subsistence harvest, the potential for 

 illicit trade involving this species is great. In addition, the 

 Commission speculated that a CITES listing may facilitate legiti- 

 mate trade by enabling Aleuts and others seeking to export seal 

 parts to obtain documentation attesting to the legality of their 

 shipments. It was also noted that listing fur seals on Appendix 

 II may discourage high seas fishermen from engaging in pelagic 



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