70 



the state appear to be significantly depressed, they are not on 

 the NMFS list. However, the NMFS list does include spotted seals, 

 ribbon seals, and killer whales; species that have virtually no 

 lethal fishing mortalities or interactions, and which appear to 

 have robust populations. 



2 . Potential Biological R emovals 



In contrast, the definition of "potential biological removal" in 

 the draft bill is far too detailed and restrictive. It is derived 

 from the definition provided in the NMFS proposed regime, and does 

 not take into account the actual data that are and are not 

 available on marine mammal stocks in areas like Alaska. Because 

 the status of many stocks is uncertain, the NMFS method would 

 calculate potential biological removal using minimum population 

 estimates, very conservative growth rates, and unrealistically low 

 recovery factors. This could result in the calculation of a very 

 low potential biological removal for stocks that are actually 

 large and healthy, but have not been adequately studied. Under 

 this regime it would then appear that there is a critical 

 conservation problem when one in fact did not exist. Unnecessary, 

 and perhaps counterproductive, restrictions on fisheries or other 

 activities could result. 



The actual potential for a stock to withstand removals by humans 

 is a complex function that depends on many biological and 

 ecological factors. These factors will vary for each stock, and 

 therefore the calculation of realistic potential biological 



