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intentional lethal removal of pinnipeds should be 

 available to Federal and State wildlife managers when the 

 animals are dangerous or are causing undue damage to 

 other marine resources. We believe that lethal removal 

 may not be appropriate for marine mammals listed as 

 endangered or threatened under the Endangered Species 

 Act, designated depleted under the MMPA, or identified by 

 the Secretary as a "critical stock" under the proposed 

 MMPA §118 conservation program submitted to you under 

 separate cover. 



That concludes our response to the issue of whether to form 

 task forces to manage pinnipeds identified as habitually exhibiting 

 dangerous or damaging behavior that cannot otherwise be deterred. 

 For the record, the Commission would briefly like to comment on a 

 number of problems that the task force process, as proposed, may 

 not effectively handle. It is with respect to these areas where 

 the Commission radically departs from the views of many 

 environmental organizations, such as the Center for Marine 

 Conservation or the Marine Mammal Center. 



First, the pinniped task force process set forth in the 

 attachment does not adequately respond to the key structural defect 

 in the MMPA, that is, the use of "optimum sustainable population" 

 as the scientific measure of the health of a particular marine 

 mammal population. 



The increasing abundance of marine mammals on the West Coast 

 is causing serious problems which must be resolved if the MMPA is 

 to maintain its popular support in coastal regions. Examples 

 include: 



o Sport charter boats have been forced to abandon 

 traditional fishing grounds because California sea lions 

 take more fish from the lines than clients can reel in. 



o Docks are overrun by lounging animals, even to the point 

 of damaging facilities such as the new floating pier at 

 Charleston, Oregon. 



o Recreational fishermen in bays of southwest Washington 

 lose up to 60 percent of troll-hooked fish to harbor 

 seals, yet they are prohibited by law from using non- 

 lethal deterrents. 



o In Bellingham Bay drift gillnet and set net fishermen are 

 losing 30 to 50 percent of their fall Chinook salmon 

 catch to harbor seals. 



o Sea lions feed on precious wild stocks of steelhead and 

 chum salmon 4 miles up the Nisgually River. 



