Resource Development Council

RDC Comment Letter:
Eastern DPS Steller Sea Lion

October 14, 2010

Kaja Brix
Alaska Region, NMFS
Protected Resources Division
P.O. Box 21668
Juneau, AK 99802

Re: Five Year Review of the Steller Sea Lion Eastern Distinct Population Segment

Dear Ms. Brix:

The Resource Development Council (RDC) is writing in response to the National Marine Fisheries Service (NMFS) five-year review of the Eastern Distinct Population Segment (DPS) of the Steller sea lion.

RDC is a statewide, non-profit business association comprised of individuals and companies from Alaska’s oil and gas, mining, forest products, tourism and fisheries industries. RDC’s membership includes Alaska Native corporations, local communities, organized labor and industry support firms. Our purpose is to encourage a strong, diversified private sector in Alaska and expand the state’s economic base through responsible resource development.

RDC supports the State of Alaska’s petition (August 30, 2010) to delist the Eastern DPS of the Steller sea lion. Overall, this population has been increasing since the 1970s.

Delisting Factors for Consideration

Of the five factors considered for delisting, the Eastern DPS sufficiently meets or exceeds the minimum requirements.

Factor A: Evidence suggests the Eastern DPS is not nutritionally limited, and the destruction, modification, or curtailment of its habitat or range is sufficiently reduced.

Factor B: Harvest of the Steller sea lion for subsistence purposes is scarce. Other harvest, including incidental take in fisheries, illegal shooting, take during scientific research, and other human-caused mortality is minimal.

Factor C: Predation, historically by killer whales, is not outside the normal range.

Factor D: Existing protections are in place to prevent decline in the population. The Marine Mammal Protection Act, the Magnuson-Stevens Fishery Conservation and Management Act, as well as federal, state, and local government policies provide sufficient protections for the Steller sea lion.

Factor E: Manmade or natural factors impacting the Eastern DPS have been sufficiently reduced or no longer pose a threat. Efforts by local groups and government agencies, including outreach and education, have come forward to conserve and protect the Steller sea lion.

In conclusion, the Eastern DPS of the Steller sea lion is increasing, warranting delisting, as protection under the Endangered Species Act (ESA) is no longer necessary. RDC supports the continued monitoring and management of the Eastern DPS through existing measures outside the ESA.

Thank you for the opportunity to comment on this important issue and for your consideration of our comments.

Resource Development Council for Alaska, Inc.

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