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6. 



4. The use of historic carryina capacity wherever possible as a 

 basis for making decisions on Optimal Sustainable Pop ulations (OSP) 

 of marine mammals . 



The MMPA provides for making determinations that specific stocks of 

 marine mammals are at their Optimal Sustainable Populations (OSP) . 

 However, for many populations, OSP will be difficult and expensive 

 to determine, and for others, nearly impossible. For populations 

 that are nearing OSP, with sufficient data on abundance and 

 recruitment, the Act requires determination of carrying capacity. 

 NMFS has proposed using current carrying capacity to make OSP 

 determinations. This is not acceptable. 



The oceans are not as healthy or abundant in resources as they once 

 were. We need to work to improve their quality. Accepting current 

 carrying capacity means accepting stocks which are limited in 

 growth by quality of habitat, rather than encouraging movement 

 toward restoration of their historic abundance. 



An example of the problem of using current carrying capacity to 

 determine OSP can be seen in the case of the northern Right Whale. 

 This critically endangered mammal has a population of less than 500 

 individuals. Intensive study has not seen any real increase in 

 this population, despite the fact that there is no direct 

 exploitation of its members. In wildlife management, populations 

 which are stable over a long period are generally considered to be 

 at carrying capacity. No serious scientist or manager would argue 

 that Right whales are at OSP, simply because we know that the 

 oceans once sustained thousand more of them. However, it could be 

 argued that this lack of growth in population during the last fifty 

 years, may mean that they are at "current carrying capacity". This 

 case is representative of others where it can be clearly seen that 

 use of historic carrying capacity is necessary in order to assure 

 proper calculation of OSP. 



Therefore, we propose that the MMPA should retain the use of 

 historic carrying capacity wherever possible as a basis for 

 making decisions on Optimal Sustainable Populations of 



marine mammals. 



