150 



4) Should the Task Force address solely interactions with salmonids ? 



As previously stated, we believe that the task force should consider those situations in which 

 marine mammals may be threatening survival of a fish stock. This need not be limited to 

 salmonids if pinnipeds are posing a threat to a non-salmonid population of wild fish. 



5) What kind of research is necessary? 



Some research exists relative to the impacts of various sources on the decline of fish stocks. 

 This research should be expanded. Before the Task Force can adequaterly determine the extent 

 of the impact of pinnipeds, it is necessary to understand the interplay of a variety of factors 

 including fishery takes, habitat degradation, interactions with hatchery fish and others. Once 

 these interactions are understood, it may be possible to determine whether proposals to mitigate 

 pinniped interactions will have any meaningful effect. 



6) Adequacy of support in the development of non-lethal deterrents. 



We do not feel that there has been adequate support. Furthermore, the past five years of the 

 exemption program, which allowed lethal takes to protect gear and catch, encouraged lethal 

 interactions. For these reasons we proposed and continue to support directed funding to 

 establish a mitigation research program. 



7) Monitoring of extent of direct interactions at sea. 



It is not clear which interactions are meant in this question. If this question refers to 

 interactions of pinnipeds with fish stocks at sea, then I believe that the Task Force could require 

 such monitoring, but research indicates that interactions take place in coastal areas or in rivers 

 and lakes. If the question refers to fisheries takes of these depleted fish stocks, then monitoring 

 could be germane in this situation as well. Research has shown (see end note below)that the 

 second most frequently cited reason for the decline of fish stocks is over-exploitation by 

 commercial fisheries. These takes should continue to be monitored and regulated. 



8) Should intentional lethal takes of pinnipeds be allowed? 



Any intentional lethal take should be prohibited unless it is to protect life and limb; or if it is 

 a permitted take which has been approved by the Task Force to prevent interactions from 

 threatening the survival of a fish stock. If the removal of individually identified pinnipeds will 

 safeguard the survival of a fish stock, then such a removal by agovemment agent is justified. 

 However, predator control program (eg. coyote control) have shown themselves to be a failure 

 in most instances, except where individually identified animals are posing a unique threat, and 

 their removal will end that threat. 



We would like to add an additional comment on pinniped interactions. A research study was 

 done by the Endangered Species Committee of the American Fisheries Society. (Nelson, W., J. 

 Williams and J. Lichatowich. 1991 . Pacific Salmon at the Crossroads: Stocks at Risk from 

 California, Oregon, Idaho and Washington. Fisheries. Vol. 16, No 2. pp 4-21.) In their review 

 of 214 stocks of fish that were potentially endangered, the Committee found that habitat loss 

 and destruction were the greatest reasons for declines in fish stocks. Specifically water 

 diversions for agriculture, construction of dams and flood control devices, and siltation due to 

 forestry practices were the biggest threats. Second to habitat destruction was over-exploitation 

 by commercial fisheries. The third greatest factor was interaction with hatchery raised fish. 



