523 



The kill during the past year exceeded by 100,000 the sustainable yield 

 estimate of David Sargeant, while hooded seals have been all but extir- 

 pated from these waters. 



Since we consider it particularly important that hair seals products 

 be banned from import in any form, we were pleased to learn, through 

 the testimony of spokesmen for the fur industry, that hair seal prod- 

 ucts were considered of little importance, and that no objection would 

 be entertained to their being banned. 



Corroborating this, I have received a cable from John Walsh of 

 ISPA reporting only 7,250 units of hair seal skins were exported to 

 this country- from Canada in 1970. The remainder, which comes in, 

 enters in the form of finished products from England in direct com- 

 petition with various U.S. finished goods. 



We see no reason at all for any whale products to be imix)rted into 

 this country. In view of the appalling tragic decimation of all com- 

 mercially exploitable whales, we consider a total ban on all cetacean 

 products to be absolutelv imperative. 



It should be noted that'despite the fact that eight great whales have 

 been put on the endangered list, products from these species continue 

 to enter the country under 37 endangered species permits, most of 

 which are scheduled to expire December 1 of this year. 



By our calculation, over 30,000 tons of sperm oil have entered, or 

 will enter, this country this year. Kal Kan has additionally imported 

 11.5 million pounds of sperm and baleen whale meat under ES Per- 

 mit 24. ^. ^. , . 



Mr. Chairman, a great deal of the controversy surrounding this legis- 

 lation centers about the term "management,'' which has become a shib- 

 boleth for some, and a rallying point for others. We are ad^^sed that the 

 committee will report out a "management" bill. 



If management means, as it has in the past, "management for the 

 benefit of commercial vested interests," it will be difficult, if not im- 

 possible for us to support legislation developed around such a concept. 



But, if management in this case is management aimed entirely at 

 benefiting the marine mammal populations being considered, alto- 

 gether divorced from any commercial consideration, we have no ob- 

 jection to the term, and endorse the concept. 



Most successful cases of management of marine mammals under 

 this definition have consisted of leaving the animals alone. The 

 case of the northern Elephant seal, which has increased from a rem- 

 nant in the late 19th century, after being nearly exterminated by 

 M'halers, to as high as 30,000 today, illustrates this well. 



The imbalanced and rapidly deteriorating state of marine ecosys- 

 tems may necessitate intervention. If this is to be done, however, let it 

 be done after it has been firmly and openly established that such man- 

 agement is (a) necessary to the survival and well-being of the overall 

 population and (h) is not related to any commercial process, and will 

 not benefit vested commercial interests. 



We feel that any legislative approach should begin on the basis of 

 a complete ban on killing, capturing or molesting the animals. If anv 

 killing, capturing or molesting is to occur, the onus of proof should 

 rest entirely on those wishing to perform such acts. Let these persons 

 demonstrate conclusively that it is in the overall best interests of the 

 animals being so managed that such acts be committed. 



