37 



elusions of those who seek to end the fur seal harvest. To the contrary, available 

 evidence indicated that international cooperation had resulted in a larger, more 

 healthy herd. Commenting to the last Congress on legislation identical to H.R, 

 4370, we noted that : 



discontinuance (of the fur seal harvest) would have serious biological and 



economic effects. The Aleuts living in two communities on the Pribilofs would 



be deprived of employment. The State of Alaska would no longer receive its 



70 percent share of the proceeds from sales of Alaska sealskins. The limited 



support capacity of the Pribilofs would be overtaxed causing a substantial 



loss of pups due to parasitism, injury, and malnutrition. Japan and Canada 



would be denied a share of the land harvest as promised by agreement and 



might well resort to the wasteful killing of fur seals in the open sea. 



The OflBce of Management and Budget has advised that there is no objection to 



the presentation of this report from the standpoint of the Administration's 



program. 



Sincerely yours, 



W. T. Pecoea, 

 Under Secretary of the Interior. 



U. S. Depabtment of the Intebiob, 



Office of the Secretakt, 

 Washington, D.C., Septemier 9, 1971. 



Hon. Edward A. Gabmatz, 



Chairman, C(mimittee on Merchant Marine ami Fisheries, 



House of Representatives, 



Washington, D.G. 



Deab Me. Chaibman : This is in response to your request for our comments on 

 H.R. 6554, H.B. 6558, and H.R. 8183, similar bills to be cited as the "Ocean 

 Mammal Protection Act of 1971". 



Consistent with a Congressional declaration that ocean ma mma ls, including 

 seals, whales, walrus, manatee, sea otters, sea lions, polar bears, porpoise and 

 dolphins, are being "ruthlessly pursued, harassed, or killed" and may therefore 

 become rare or extinct, these bills contain provisions that would greatly enlarge 

 Federal responsibility for conservation of such animals, regardless of their status 

 as endangered si)ecies. 



Specifically, H.R. 65.54 would (1) with certain limited exceptions, make un- 

 lawful the taking of ocean mammals on land or sea by vessels or persons subject 

 to jurisdiction of the United States; (2) express the sense of Congress that the 

 Interim Convention on the Conservation of North Pacific Fur Seals not be con- 

 tinued upon its termination in 1975 ; (3) provide that, pending termination of the 

 Convention, the United States not harvest its quota of North Pacific Fur Seals, 

 and that the quotas of Japan and Canada be honored either by in lieu payments 

 or direct shipment of skins; (4) establish a Pribilof Islands National Seal 

 Rookery Reserve and Bird Sanctuary to be administered by this Department; 

 and (5) direct the appointment of a Pribilof Islands Commission to assist in the 

 development of a substitute economy for the Pribilof Islands. In addition, H.R. 

 6554 would repeal relevant, but inconsistent, provisions of the Fur Seal Act of 

 1966 (16U.S.C. llTlef segr.). 



We defer to the Departments of State and Commerce concerning effects of this 

 legislation upon efforts to regulate by international agreement the taking of 

 pelagic mammals. As the Committee is aware, primary responsibility for im- 

 plementation of the Convention and for administration of the Pribilof Islands 

 was transferred to the Department of Commerce by Reorganization Plan No. 4 

 of 1970. We offer comment, however, based on experience with implementation of 

 the Convention and our interest in effective management of wildlife resources. 



It is clearly a basic premise of H.R. 6554 and related bills that an absolute 

 unilateral prohibition against the killing of all ocean mammals will assure their 

 protection, and that such cessation of the harvest is a sound objective. We do 

 not agree. To meet a legitimate public concern for preservation and protection 

 of endangered species, the Congress has enacted legislation that authorizes the 

 Secretary of the Interior to undertake a program for conservation of animals 

 so classified. Further, the Secretary has exercised regulatory authority to prevent 

 the importation of species foimd to be threatened with extinction. We refer, of 

 course, to the Act of October 15, 1966 (80 Stat. 926), as amended by the En- 



