Oceana / Greenpeace / World Wildlife Fund combined comments on the SSL BiOp

"We must move toward viable sustainable fisheries, that could include fixed gear fisheries such as longline, pots, and jigs, that can support local communities. Where tradeoffs are possible, NMFS should favor these more sustainable alternatives. The agency cannot simply weaken the proposed RPA to allow additional fishing for Steller sea lion prey, but it can consider strengthening other protections to allow these fisheries to continue and to continue to develop in a sustainable manner.

"For example, NMFS could strengthen protections by addressing overall harvest levels, further reducing the biomass taken from the western Aleutian Islands by the cod and Atka mackerel trawl fisheries. While it is difficult to determine the importance of the various components of the Steller sea lion diet, an approximation of the prey biomass increased through harvest restrictions multiplied by caloric values for prey (i.e. those calculated by Loggerwell and Schaufler 2005) could give NMFS a metric to evaluate small changes to the RPA designed to move toward sustainable fisheries. NMFS must also consider the inherent characteristics of the trawl fisheries (a large pulse harvest on aggregated schools), which provides few options to minimize impacts."

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