September 3, 2010
Dr. Jim Balsiger, Regional Administrator
Alaska Region, NMFS
Attn: Ellen Sebastian
P.O. Box 21668
Juneau, AK 99802
Re: Steller Sea Lion Draft Biological Opinion
Dear Dr. Balsiger:
The Resource Development Council (RDC) writes in response to the request for comments on the Draft Biological Opinion (BiOp) for the western distinct population segment 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 endorses the recently submitted comments related to the Steller sea lion by the State of Alaska, and the Reasonable and Prudent Alternative (RPA 4) proposed by the North Pacific Fishery Management Council.
RDC is concerned about the lack of scientific basis for the new restrictions proposed by the National Marine Fisheries Service (NMFS) in the BiOp. Based on the best available data, there is no clear evidence the Steller sea lion is facing nutritional stress. Indeed the population is increasing in most areas, indicating additional measures, such as fishery closures, are unnecessary. Further, RDC continues to endorse additional funding for research.
In addition, RDC encourages NMFS as it finalizes the Environmental Assessment/Regulatory Impact Review to carefully consider the potential economic impact to Alaskan communities from the new restrictions. These restrictions could result in the loss of approximately 1,000 jobs and millions of dollars, with likely no added benefit to the Steller sea lion.
Thank you for the opportunity to comment on this important issue and for your consideration of our comments.
Resource Development Council for Alaska, Inc.