July 16, 2013

James W. Balsiger, Ph.D.
Administrator, Alaska Region
National Marine Fisheries Service
P. O. Box 21668
Juneau, AK 99802

Via: http://www.regulations.gov

Dear Mr. Balsiger, The Resource Development Council for Alaska, Inc. is writing to comment on the Draft Environmental Impact Statement (DEIS) for Steller sea lion protection measures for groundfish fisheries in the Bering Sea and Aleutian Islands management area.

RDC is a statewide, non-profit, membership-funded organization founded in 1975. The RDC membership is comprised of individuals and companies from Alaska’s oil and gas, mining, timber, tourism, and fisheries industries, as well as Alaska Native corporations, local communities, organized labor, and industry support firms. RDC’s purpose is to link these diverse interests together to encourage a strong, diversified private sector in Alaska and expand the state’s economic base through the responsible development of our natural resources.

RDC believes that due to lack of key information in the DEIS, a preferred alternative cannot and should not be chosen at this time. Accurate scientific analysis is an essential element in order to fully comply with the National Environmental Policy Act, and RDC considers the science being used in this DEIS to be unsound.

The DEIS relies on data from a flawed 2010 Biological Opinion (BiOp), which assumes more fishing in the area is directly related to negative impacts on Steller sea lions. However, the National Marine Fisheries Service’s (NMFS) own commissioned independent reviews of the BiOp raised significant concerns about the flawed science applied by NMFS, specifically, that there is no scientific support that fisheries jeopardize Steller sea lions through competition for prey resulting in chronic nutritional stress and reduced natality.

NMFS has stated that new information available since the completion of the 2010 BiOp is significant and may result in different metrics for evaluating fisheries mitigation measures.

RDC requests that NMFS repeal its fishery restrictions handed down in 2011 and reinstate the prior regulations until the future BiOp on Steller sea lion mitigation measures is available and reviewed appropriately.

Thank you for the opportunity to provide comments on this important issue.