fur seal population data, the maximum net productivity level for 

 fur seals would be 60 percent or more of carrying capacity. In 

 the late 1970s and early 1980s, the estimated size of the 

 Pribilof Islands' fur seal population declined to about 871,000 

 animals or less than 50 percent of its estimated size (1.8 

 million seals) in the early 1950s. 



In view of the population's continuing decline, the 

 Commission recommended in 1984 and again in 1985 and 1986 that 

 the National Marine Fisheries Service designate the Pribilof 

 Islands' population of North Pacific fur seals as depleted. The 

 action was taken after the Humane Society of the United States 

 and Friends of Animals/Committee for Humane Legislation filed 

 suit against the Secretary of Commerce, seeking to compel the 

 issuance of the depletion finding. By letter of 29 November 

 1985, the Commission also recommended that the Service prepare a 

 conservation plan to provide a basis for identifying and 

 directing priority research and management actions needed to 

 restore the population. It was recommended that the plan be 

 similar to the recovery plans reguired for endangered and 

 threatened species under the Endangered Species Act. By letter 

 of 6 December 1985, the Commission provided the Service with a 

 preliminary plan outline. 



On 18 May 1988, the National Marine Fisheries Service 

 published a Federal Register notice announcing that, effective 17 

 June 1988, the Pribilof Islands' population of North Pacific fur 

 seals would be added to the list of depleted species under the 

 Marine Mammal Protection Act. By the end of 1988, however, the 

 Service had not completed a conservation plan for the fur seal 

 population as recommended by the Commission. 



As noted in Chapter II of this Report, the Marine Mammal 

 Protection Act was amended on 2 3 November 1988. Among other 

 things, a new section was added to the Act reguiring the 

 preparation of conservation plans for species listed as depleted. 

 With respect to North Pacific fur seals, the new section 

 explicitly directed the Service to prepare a conservation plan by 

 31 December 1989. At the end of 1989 the Service had not 

 released a draft plan to the Commission or other interested 

 parties. It was the Commission's understanding that a draft plan 

 was being reviewed within the Service. 



International Cooperation 



As noted above, the Interim Convention on the Conservation 

 of North Pacific Fur Seals expired in 1984. As discussed in the 

 previous Annual Report, consideration was given to negotiating a 

 new fur seal convention in 1987 and 1988. However, the Service, 

 in consultation with the Commission, suspended efforts to pursue 

 a new agreement in July 1988 and no further action was taken on 

 the matter in 1989. 



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