27 



the opportunity to become rangers and guides for the preserve. Since March 

 3, 1869, the islands of St. Paul and St. George of the Pribilof Islands have been 

 a "special reservation for government purposes." The entire group of islands 

 (St. Paul, St. George, Walrus, Otter, and Sea Lion Rock) was included in this 

 reservation on April 21, 1910. This status of a special reservation is stiU in 

 effect. Section 404 calls for the establishment of a Pribilof Islands Commission 

 which, among other things, is to help promote tourism. It is difficult to imagine 

 that even througli the work of the Commission, a large enough tourist industry 

 could be created on the Pribilof Islands to make the ranger and guide proposal 

 feasible as an alternative source of income for the Aleuts. Even if by some 

 means a large tourist industry could be created, the demand for rangers and 

 guides would be so minimal that only a few Aleuts would be thus employed. 

 Furthermore, it should be remembered that the seals, presumably the main 

 tourist attraction, are on the islands only a few months each year. During 

 the remainder of the year, the seals are out in the Pacific Ocean and the islands 

 offer very little, if anything, to attract tourists. We believe the net result 

 would probably be that most of the Aleuts on the Pribilof Islands would be 

 forced to either leave their homes on the islands to seek employment elsewhere, 

 or go on welfare. 



In summary, in our opinion, passage of so drastic a measure as a total ban 

 on the taking of marine mammals is not needed since regulatory authority over 

 many mammals already exists. However, as noted above, in those cases where 

 adequate authority does not exist, we have requested additional r^ulatory and 

 research authority in our report on H.R. 10420. 



Further, this bill would have a depressing economic effect on certain small 

 segments of our population, and would be catastrophic for the Aleuts of the 

 Pribilofs. Finally, passage might well cause the resumption of i)elagic hunting 

 for fur seals with probably disastrous results to the very animals that the 

 bill is intended to protect. 



We have been advised by the Office of Management and Budget that there 



would be no objection to the submission of this reix)rt to the Congress from 



the standpoint of the Administration's program. 



Sincerely, 



WnxiAM N. Letson, 



General Counsel 



General Counseh. of the Department of Commerce, 



Washington, D.C., September 10, 1911. 

 Hon. Edward A. Garmatz, 



Chairman, Committee on Merchant Marine and Fisheries, House of Representa- 

 tives, Washington, D.C. 



Dear Mr. Chairman : This is in response to your request for comment on H.R 

 10420, a bill "to protect marine mammals ; to establish a Marine Mammal Com- 

 mission ; and for other purposes." 



This Department believes that regulations imixxsed on the taking of marine 

 mammals should be based on data from careful studies of the population 

 dynamics and other aspects of such mammals. We believe that with appropriate 

 amendments, H.R. 10420 could provide for such study and at the same time grant 

 the appropriate regulatory authority. To this end we enclose a revised version 

 of the bill incorporating our suggested changes. 



Set forth below are some of the major problem areas we see in the present 

 version of H.R. 10420 : ^ 



This Department takes exception to the assignment of program responsibility 

 in section 3(3). The National Oceanic and Atmospheric Administration of the 

 Department of Commerce is charged with a variety of responsibilities relating 

 to the marine environment and the utilization and conservation of living marine 

 resources pursuant to Reorganization Plan No. 4, October 3, 1970 (84 Stat. 2090). 

 The allocation of authority over marine mammals embodied in this Plan should 

 be maintained until such time as the proposal of this Administration for the 

 creation of the Department of Natural Resources has been acted upon. Accord- 

 ingly, the revised bill defines "Secretary" in section 3(g) thereof so as to retain 

 the present allocation of authority between the Secretary of Commerce and the 

 Secretary of the Interior. 



1 All references in the following discussion are to H.B. 10420 as introduced unless ex- 

 pressly stated otherwise. 



