38 



dangered Species Conservation Act of 1969 (16 U.S.C. 668aa et seq.), for which 

 your Committee was largely responsible. 



The list of species threatened with worldwide extinction now includes several 

 species of whale, the Dugong (sea cow), and Florida Manatee. Other species 

 named by H.R. 6554 are neither threatened with extinction, nor subject to 

 ruthless harassment, as the bill would find. Some of the subject species, notably 

 fur seals and whales, are protected to some degree by international convention. 

 Others are protected by State regulation. We recognize that some species not 

 now threatened with extinction will become endangered in the absence of effec- 

 tive international regulation. 



H.R. 6554 is unsound in other respects. With some exceptions, individual 

 States, and not the Federal government assert jurisdiction for management of 

 resident birds and mammals, including seals, the manatee, sea otter, sea lion, 

 walrus, and polar bear. Enforcement under section 206(a), diffused among five 

 Departments, would be unwieldy, if not entirely unworkable. The substitute 

 economy envisaged by section 303, for the Pribdlof Islands would fail, we be- 

 lieve, because the season is too short, the climate too severe, and transportation 

 too expensive to attract tourists in numhers suflicient to supi>ort the native 

 population. If the fur seal industry were terminated, as H.R. 6554 proposes, it 

 would be necessary to relocate all or most of the Aleut inhabitants. 



A sound approach to management of ocean mammals requires further research 

 and strengthened international regulation of those practices which threaten 

 species not already classified as "endangered". This approach would serve to 

 reaflBlrm our concern for the worldwide protection of wildlife. We think it im- 

 portant to strengthen, rather than abolish, the existing international institu- 

 tions which make such protection possible. 



The OflSce 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, 



Habeison Loesch:, 

 Assistant Secretary of the Interior. 



U.S. Depabtment op the Interior, 



Office of the Secretary, 

 Washington, D.C., September 8, 1971. 

 Hon. Edward A. Gaematz, 



Chairman, Committee on Merchant Marine and Fisheries, 

 House of Representatives, 

 Washington, D.C. 



Dear Mr. Chairman : This responds 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". 



H.R. 10420, which would be cited as the "Marine Mammal Protection Act of 

 1971", contains a declaration of congressional purpose relative to the conserva- 

 tion of marine mammals, and would direct that the Secretary of the Interior 

 undertake a comprehensive program for the regulation of taking all such animals 

 on the high seas, within the territorial sea of the United States, and within the 

 contiguous fisheries zone. Title I provides more si)ecifieally for the establishment 

 of limitations on the numbers of each species which may be taken consonant 

 with a need for its preservation, for the issuance of permits as a prerequisite of 

 any taking, except by Indians, Aleuts, or Eskimos under certain circumstances, 

 and for cooperative arrangements between the Secretary and the States that 

 "prescribe the circmnstances under which marine mammals which pass through 

 or reside within the territorial waters of any State may be taken". The Secretary 

 would also be directed to review management of the fur seal harvest on the 

 Pribilof Islands and to provide an alternate means for satisfaction of obligations 

 imder the International Convention for the Conservation of North Pacific Fur 

 Seals, if he determines that the Pribilof harvest should be curtailed or ter- 

 minated. 



Title II would establish a Marine Mammal Commission composed of three 

 members appointed by the President, and would, in turn, require that the Com- 



