sealing or seeking markets for parts from seals that are inci- 

 dentally taken, and that CITES reporting requirements would yield 

 needed information on the extent of international trade and may 

 provide insight into the numbers of fur seals taken in driftnets. 



Accordingly, the proposal to list North Pacific fur seals on 

 Appendix II was among those submitted by the Fish and Wildlife 

 Service for consideration by the Seventh Conference of Parties. 

 Nevertheless, on 11 July 1989, the Service wrote to the National 

 Marine Fisheries Service, suggesting that "some of the intended 

 purposes of this potential listing might be accomplished better 

 in other ways." In addition, the Fish and Wildlife Service asked 

 for "specific documentation . . . that trade may be occurring that 

 rises to a level threatening the existence of the [species]." 

 The Fish and Wildlife Service also recommended that greater 

 efforts should be made to obtain data on the extent of the take 

 of fur seals in high seas driftnet fisheries and that existing 

 stocks of legal (pre-1985) seal parts be documented. 



Questions regarding the advisability of listing fur seals on 

 Appendix II were raised in comments submitted to the Fish and 

 Wildlife Service by the State of Alaska, Alaska Natives, and at 

 least one environmental group. These guestions were precipi- 

 tated, in large part, by a critique of the proposal prepared by a 

 National Marine Fisheries Service scientist, which presented 

 contrary information on the present status of the Pribilof 

 Islands* pupping colonies, the levels of incidental take in high 

 seas driftnet fisheries, and the potential for parts from 

 incidentally taken seals entering into trade. 



After reviewing this new information, the Commission, on 

 5 October 1989, wrote to the National Marine Fisheries Service 

 pointing out the need for a detailed summary and analysis of 

 recent fur seal population data, an assessment of the existing 

 and potential future demand for fur seal skins and bacula, and 

 further analysis of the possibility that incidental taking in 

 high seas fisheries could lead to a directed fishery or to 

 entangled animals being killed and retained. In light of the 

 limited time available to provide this information, the 

 Commission recommended to the National Marine Fisheries Service 

 that: (1) the listing proposal be withdrawn; (2) the National 

 Marine Mammal Laboratory provide a detailed description and 

 analysis of data on the status and trends of the Pribilof 

 Islands' fur seal population through at least 1988; and (3) a 

 workshop be held in advance of the next research season to review 

 the population and other assessments done by the Laboratory 

 staff. While recommending that the Appendix II listing be 

 deferred, the Commission advised the Fisheries Service that a 

 listing on Appendix III may be warranted, pending re-evaluation 

 of the Appendix II proposal. 



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