mid-1950s and 1985, counts declined by 70 percent between 1985 

 and 1989 (from 25,759 animals to 7,759 animals). 



One of the possible causes of the decline examined at the 

 1986 workshop was fisheries-related mortality, including 

 entanglement in lost nets, and incidental and intentional taking 

 by commercial fishermen. While information on incidental take in 

 foreign fisheries and entanglement was not sufficient to explain 

 observed declines and the number of animals killed annually by 

 domestic fishermen was unknown, participants concluded that the 

 combined take by all fisheries could account for a large portion 

 of the observed declines. A second cause considered by 

 participants to be a possible contributor to the decline was 

 disease. No new information is available to alter or confirm 

 these possibilities. 



In response to the decline in Steller sea lion numbers, the 

 National Marine Fisheries Service published an advance notice of 

 proposed rulemaking to designate the species as "depleted" under 

 the Marine Mammal Protection Act on 6 May 1988. The Commission, 

 in consultation with its Committee of Scientific Advisors, 

 commented in support of the proposed action by letter of 8 July 

 1988. In its letter, the Commission noted that available 

 information clearly justified listing Steller sea lions in at 

 least some areas as depleted. The Commission recommended that 

 the Service immediately list the species as depleted and that a 

 Conservation Plan (i.e. , a plan similar to recovery plans 

 required under the Endangered Species Act) be developed and 

 implemented for the species. 



As discussed in Chapter II, in November 1988, the Marine 

 Mammal Protection Act was amended. Among the changes made in the 

 Act was the addition of a new section concerning the preparation 

 of conservation plans for depleted marine mammals. The new 

 section directed the Secretary of Commerce to prepare a 

 Conservation Plan for Steller sea lions by 31 December 1990. On 

 6 December, 1988, the Commission wrote to the Service to provide 

 recommendations for implementing the Act's new requirements. 

 With respect to Conservation Plans, the Commission noted that 

 much of the information and analysis needed to prepare a Plan for 

 Steller sea lions had recently been compiled in the Steller sea 

 lion account prepared for the Commission in Selected Marine 

 Mammals of Alaska: Species Accounts with Research and Management 

 Recommendations . It therefore noted that the Service should be 

 able to complete a plan for Steller sea lions within three to six 

 months . 



During 1989, the Commission did not receive a draft 

 Conservation Plan for Steller sea lions from the Service and the 

 Service did not act on its pending depletion finding. In view of 

 the continuing population decline, the Environmental Defense Fund 

 petitioned the Service on 21 November 1989 for an emergency 



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