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removal levels cannot be done with a single standard formula. The 

 specific methods to be used to calculate removal levels should not 

 be detailed in the MMPA or committee language, but rather should 

 be left to the discretion of the scientific working groups, 

 conservation teams, and the Secretary. 



3. Pinniped Interaction Taskforce 



The draft legislation includes provisions that would establish a 

 pinniped interaction task force to deal with the issue of 

 pinnipeds damaging salmonid fishery resources. However, no 

 authority is granted to the Secretary to authorize Federal or 

 state wildlife managers to lethally remove nuisance pinnipeds. 

 Similarly, there appears to be no process for an applicant to seek 

 and receive redress when methods of non-lethal deterrence have 

 been exhausted and lethal removal is the only realistic solution 

 to the problem. 



This type of interaction is not a serious problem in Alaska at 

 this time. However, when migratory salmon species are being 

 affected elsewhere on the west coast, this could have major 

 implications for Alaska's commercial fishermen if the fish stocks 

 are depleted to the point that they require protection under the 

 Endangered Species Act. There is therefore a pressing need to 

 develop effective mechanisms for dealing with nuisance animal 

 situations . 



