scheduled for 12-16 April 1982 in Ottawa, Canada. The 

 Commission consulted with the Service and participated in a 

 24 February preparatory meeting to discuss these proposed 

 positions. An important issue concerned an analysis of data, 

 being carried out by U.S. scientists in preparation for 

 the Annual Meeting, which indicated that entanglement of 

 fur seals in fishing net fragments and discarded packing 

 bands may be a far more significant mortality factor than 

 had previously been believed and may be a primary cause of 

 the on-going decline in the North Pacific fur seal population, 

 It was estimated that the annual mortality rate due to 

 entanglement may be as high as five percent of the population 

 as a whole. 



This was recognized to be a serious problem and one 

 that warranted thorough discussion and consideration at 

 the April meeting of the parties to the Convention. The 

 Department of State, following consultation with the 

 Commission and the National Marine Fisheries Service, on 

 24 March 19 82 notified the other parties to the Convention 

 of the United States' concern and its intention to raise 

 the issue of pelagic entanglement both at the meeting 

 of the Standing Scientific Committee and at the plenary 

 sessions. It asked the other party governments to be 

 prepared to discuss the matter and noted that the United 

 States considered it especially important to assess 

 possible effects of continued harvest, coupled with 

 mortality due to entanglement, on size and productivity 

 of the fur seal population before reaching a final 

 determination on 1982 harvest levels. 



The Commission subsequently drafted two position 

 papers, one on pelagic entanglement and one on setting 1982 

 harvest levels, and on 1 April 1982 forwarded these to the 

 National Marine Fisheries Service with the recommendation 

 that they be adopted as the U.S. position for the Fur Seal 

 Commission meeting later that month. The Commission noted 

 that the position paper on entanglement would have to be 

 supplemented by completing an analysis of the U.S. legal 

 position prohibiting the discard of such material. Further 

 analyses would also be needed and determinations would need 

 to be made on whether the fur seal population currently is 

 being maintained at its maximum sustainable productivity 

 level; whether it is declining and, if so, by how much per 

 year; how continued harvest might affect population 

 trends; and whether the size and age/sex composition of 

 harvests should be modified so as to contribute to the 

 recovery of the population. The Commission recommended that 

 the Service take the necessary steps to make these 

 determinations and complete the required analyses in advance 

 of the 1982 fur seal harvest. 



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