B-11 



Five, Enforcement . 



Provision should be made for effective enforcement and 

 pGlicmq of any arrangements. We feel that zhe draft EIS 

 does not make detailed reference to this very important 

 question. Tne appointment of independent ooservers and 

 their rignt to carry out inspections should be written into 

 the Convention. Flexible settlement of dispute provisions 

 should also be included. 



Six , Links with the International Whaling Commission 

 and the Convention for the Conservation of Antarctic Seals . 

 Provision should be made in the Convention for full coordina- 

 tion between the activities of these agreements, if the regime 

 is to meet its objective of providing for the "effective con- 

 servation of the marine living resources of the Antarctic eco- 

 system as a whole". We notice that the draft EIS leaves this 

 task — the establishment of coordination — to a standing body 

 to be created under the convention. But we feel that the 

 coordination must be provided for in the Convention itself. 



Finally, International Community interests. 



Steps should be taken to protect the interests of the 

 broader international community in these marine living 

 resources . 



We regret to note that the proposed federal action does 

 not address this point. On present indications the regime 

 will provide for no more than freedom of access for those 

 able to develop the resource. 



In reference to the point that was made by Mr. Scully 

 earlier, I don't think that it's premature to raise this 

 point now because we recognize that what's being established 

 is a conservation regime. But as the draft EIS notes on 

 page 54, U.S. interests in the conservation of Antarctic 

 marine living resources include the rational development of 

 new sources of protein and the prevention of international 

 conflict over Antarctica as well as a commitment to maintain- 

 ing the Antarctic environment. If we postpone this issue, 

 it may make it politically impossible to negotiate any 

 proposal to ensure that this source of protein is used to 

 maximum benefit. In order to accommodate these concerns, 

 we feel that three steps should be taken: 



- The Convention should include a general provision 

 recognizing the interests of the international community — 

 or, at least, agreeing not to jeopardize those interest — 

 along the lines of the recommendation on mineral resources 

 quoted earlier . 



