BOSTON PUBLIC LIBRARY 



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Th« U.S. population of tho ««Jt Indlin manatae U cli««lf1«<l •« • J'?*!**' 

 subspecies and numbers «pprox1mately 1,465 individuals. Host ^-^'^^^nQ 

 populations outside of Florida are thought to be small and dec! ning In 

 size due to poaching. Incidental take In nets, habitat degradation, and 

 other threats. Thus, th« species* long term survival may depend on the 

 success Of efforts to protect it in the southeastern United States. 



In 1990. 216 dead manatees were salvaged In the southeastern U.S.; in 1991, 

 181 were salvaged. Nearly one-third of these deaths wro human-related. 

 most due to iwtorboat collisions but sow were the result of tangling in 

 rets or in trap lines. Considering Its low reproductive "^••, ^„i« "" 

 likely the species can sustain this level of mortality and "nt nue to 

 surviVe. The Service has taken the position In our Section 7 biolooical 

 Spi^ions under the ESA, that the incidental take of "je manatee would 

 present a Jeopardy situation. Therefore, we believe that any an*iytical 

 system that purports to designate any level of incidental take for the 

 mnatee would K in violation of that section of the ESA Both the Revised 

 Manatee Recovery Plan and the draft revision of the Southern Sea Otter 

 Recovery Plan iaentify recovery tasks which spec fically address the need 

 to reduce the incidental take to levels approaching zero. 



Another concern expressed in the Deoartmenfs' January 28 letter is the 

 failure of the docunent to ecknowledge the Service's ■anagement 

 resDonsibility for the species under our jurisdiction, including our 

 recovery responsibility under the ESA. Despite our noting this in our 

 coments on the original draft, the omission persisted In the revised 

 version. Furthermore, the revised draft includes revised formulae which 

 translate into even higher Potential Biological Removal (PBR) levels than 

 thosp in the original draft. For manatees the PBR increased from 2 to U; 

 for southern sea otttrs the PBR increased from 9 to 58. These levels would 

 exceed the jeopardy level for these species and therefore heighten my 

 concern for the future of these species under the proposed regime. 



The Service is opposed to any sanctioning or perceived sanctioning of 

 incidental take Sf these species by coorerclal fishing activities. Although 

 we prefer exclusion of endangered and threatened species under Service 

 jurisdiction from the proposed regime, we would be willing to discuss 

 alternatives that effectively accomplish the same result, to the extent 

 they were not precluded by special legislation such as the sea otter 

 translocation law. 



hope this helps to Illustrate and emphasire our position regarding 

 ^elusion of these species from NMFS's Incidental take proposal. I -ould 



I 



exci -- -^ - 



be very happy to discuss this further if you wish. 



Sincerely. 



**^*^ DIRECTOR 

 Enclosure 



