fisheries that have developed in the absence of sea 
otters; (2) incidental take in gillnet and other fisheries; 
(3) oil and gas development and transportation; 
(4) logging, mariculture, and other coastal develop- 
ment; (5) Native subsistence hunting; and (6) the 
increasing tourist industry in Alaska. The reality of 
these threats is illustrated by the 1989 Exxon Valdez 
oil spill, which is estimated to have directly killed 
3,500 to 5,500 sea otters and may have long-term 
adverse effects on sea otter habitat in Prince William 
Sound and adjacent areas. 
Recognizing the threats and possible conflicts being 
generated by increasing human populations and 
development in Alaska, the Commission in 1984 
initiated efforts to assess the state of knowledge and 
identify conservation issues regarding sea otters and 
nine other species of marine mammals that occur 
commonly in Alaska waters. This effort led to the 
publication in 1988 of species accounts, with research 
and management recommendations, for each of the ten 
species (see Appendix B, Lentfer 1988). 
As noted in Chapter VIII, the Marine Mammal 
Protection Act, as amended in 1988, directs that the 
Secretaries of the Interior and Commerce develop 
conservation plans for depleted marine mammal 
species and populations. In amending the Act, 
Congress also suggested that the Secretaries consider 
developing plans for non-depleted marine mammals 
when doing so would benefit the species’ conservation 
objectives. The Commission wrote to the Fish and 
Wildlife Service on 11 January 1989 suggesting that 
the Service prepare conservation plans for walruses, 
polar bears, and sea otters using the above noted 
species accounts as source documents. The Service 
advised the Commission on 3 March 1989 that it had 
begun developing a walrus conservation plan and 
intended to begin developing conservation plans for 
polar bears and sea otters in the near future. Efforts 
to develop the conservation plans, however, were 
delayed by the Exxon Valdez oil spill. 
These efforts were discussed with representatives 
of the Fish and Wildlife Service during the 1991 
annual meeting of the Commission and its Committee 
of Scientific Advisors in Bellevue, Washington. 
Service representatives indicated that limited staff and 
23 
Chapter III — Species of Special Concern 
other constraints were delaying plan preparation. To 
help, the Commission offered to provide assistance by 
developing draft plans that could be used to expedite 
the planning process. The Service accepted the offer. 
With regard to sea otters, the Commission orga- 
nized and held a meeting in Anchorage, Alaska, on 
25-26 September 1991 to identify key conservation 
issues from the perspective of different organizations. 
The meeting involved representatives of the Fish and 
Wildlife Service, the State of Alaska, the Native 
community, the fishing industry, and the environmen- 
tal community. Following the meeting, the Commis- 
sion prepared a working draft conservation plan and 
provided it to the meeting participants for review and 
comment. 
Based on the comments received, the working draft 
was revised, and by letter of 5 May 1992 the Com- 
mission forwarded the revised draft Alaska sea otter 
conservation plan to the Fish and Wildlife Service. In 
its letter, the Commission noted that the draft plan 
provided a comprehensive review of activities affect- 
ing or potentially affecting sea otters and their habitat 
in Alaska, and identified research and management 
actions necessary to meet the intents and provisions of 
the Marine Mammal Protection Act. 
The Commission noted its understanding that the 
Service had constituted an advisory group to help 
identify and resolve potential conservation problems 
regarding sea otters in Alaska. The Commission 
recommended that the Service provide the draft plan 
to the advisory group for its review and comment and 
use the draft plan and the comments received as the 
basis for preparing a final draft conservation plan for 
Alaska sea otters. The Commission further recom- 
mended that the final draft plan be circulated to the 
Commission and others for agency and public review 
prior to its adoption. 
The draft conservation plan prepared by the 
Commission identified a number of research and 
management actions that should be afforded high 
priority. In its 5 May letter, the Commission noted 
that, while some of these activities may already be 
underway, it was not clear precisely what was being 
done or whether it was sufficient. For instance, with 
