Table 3. California sea otter population counts 
by the Fish and Wildlife Service and 
the California Department of Fish and 
Game, 1982-1992 
Independent 
Year Otters Pups Total 
1982 Spring 1,124 222 1,346 
Fall 1,194 144 1,338 
1983 Spring 1,131 120 | ph 
Fall 1,062 164 1,226 
1984 Spring 1,181 123 1,304 
Fall _ — _ 
1985 Spring 1,124 236 1,360 
Fall 1,066 155 221 
1986 Spring 1,345 225 1,570 
Fall 1,088 113 1,201 
1987 Spring 1,430 220 1,650 
Fall 1,263 104 1,367 
1988 Spring 1,505 219 1,724 
Fall _ _ — 
1989 Spring 1,574 290 1,864 
Fall 1,484 115 1,599 
1990 Spring 1,466 214 1,680 
Fall 1,516 120 1,636 
1991 Spring 1,700 241 1,941 
Fall 1,523 138 1,661 
1992 Spring 1,810 291 2,101 
Fall 1,581 134 1,715 
plan and in August 1991 submitted it to the Com- 
mission and others for review and comment. The 
Commission, in consultation with its Committee of 
Scientific Advisors, reviewed the draft revision and 
provided comments to the Service by letter of 8 No- 
vember 1991. In its comments, the Commission 
noted that the draft Recovery Plan revision appeared 
to reflect four conclusions: 
e the Exxon Valdez oil spill had demonstrated that 
(a) the entire southern sea otter range, including 
21 
Chapter III — Species of Special Concer 
San Nicolas Island, could be contacted by a single 
large oil spill in or near the population’s California 
range, and (b) efforts to contain a large oil spill 
and to capture and rehabilitate oiled otters are 
likely to be unsuccessful; 
¢ efforts to establish the reserve breeding colony at 
San Nicolas Island have thus far been unsuccessful, 
and if successful in the future will not provide an 
adequate basis for removing the southern sea otter 
from the List of Endangered and Threatened 
Species; 
¢ the only effective way to eliminate the risk of an 
oil spill endangering the southern sea otter popula- 
tion is to substantially increase the population’s 
range and size; and 
e the risk of endangerment as a result of oil spills 
will not be eliminated (i.e., become insignificant) 
until the population’s range has expanded north to 
the Oregon border and the population numbers at 
least 5,400 animals (60 percent of the estimated 
carrying capacity of the species’ potential range in 
California, excluding San Francisco Bay and the 
area south of Point Conception). 
The Commission noted that, while these conclu- 
sions seem intuitively reasonable, they were not ade- 
quately supported by the information and analyses in 
the draft Recovery Plan revision. For example, the 
draft revision did not indicate why the Fish and 
Wildlife Service and/or the Recovery Team believed 
that the threat posed by oil spills could not be effec- 
tively eliminated by altering tanker routes or taking 
other steps to reduce the risk of an oil spill in or near 
the California sea otter range, or by developing a 
more effective oil spill response plan and pre-position- 
ing containment and clean-up equipment to reduce the 
possibility of sea otters’ being impacted if an oil spill 
does occur. Further, the draft revision provided no 
explanation for the apparent determinations that 
(1) nothing can or should be done to expedite natural 
range expansion, and (2) only the present California 
sea otter range and coastal areas north to the Oregon 
border (excluding San Francisco Bay) should be 
considered in determining the optimum sustainable sea 
otter population. On a related matter, the Commis- 
