Comment from Richard Steiner

May 22, 2008 Assistant Regional Administrator Protected Resources Division NMFS, Alaska Regional Office, P.O. Box 21668, Juneau, AK 99802 RE: RIN 0648-AV36 – ribbon seal listing, ice seal status review comment Dear Assistant Regional Administrator, In response to your solicitation for comment on the above referenced action, I support the petition presented by the Center for Biological Diversity (CBD) to list the ribbon seal (Histriophoca fasciata) under the ESA. As well, I support the listing under the ESA of all other sea ice- dependent species within the jurisdiction of the NMFS, including the three ice-seal species for which you are conducting a status review - bearded (Erignathus barbatus), ringed (Phoca hispida), and spotted (Phoca larga). The CBD petition is well prepared, scientifically robust, and presents incontrovertible and persuasive reasoning that ribbon seals are in serious jeopardy due to global warming and loss of sea ice habitat. Additionally, NMFS is to be commended for pro-actively initiating the status review of the other three sea ice dependent seals. Even the conservative climate models forecast a continuing and even accelerating loss of arctic sea ice habitat, and thus it is clear that all species dependent on that habitat are in serious jeopardy. Although the CBD petition states that “the ribbon seal faces global extinction in the wild by the end of this century,” I believe that, given the accelerating tempo of sea ice loss, even this is too optimistic a projection. I feel that, unless drastic turnaround in sea ice decline takes place, ribbon seals and other ice-dependent seals could be globally extinct by mid-century. As such, all should be listed as Endangered under the ESA. To avert ecological collapse in the Arctic Ocean ecosystem, including the extinction of the many marine species present there today, the U.S. government must immediately initiate a dramatic reduction in greenhouse gas emissions, advocate a global reduction of greenhouse gas emissions by at least 80% below current levels, and initiate other mitigation measures to protect the many Arctic marine species at risk from climate change. The listing of these four seal species as Endangered under the ESA will help further these critical goals. Also along these lines, I propose that the administration change the name of your agency from the National Marine Fisheries Service (NMFS) to the National Marine Ecological Service (NMES), to more accurately encapsulate the ecosystem mandate you will need to be operating within. Sincerely, Richard Steiner, Professor University of Alaska Marine Advisory Program 2221 E. Northern Lights Blvd., Suite # 118 Anchorage, AK 99507 Ph: 907-786-4156 Fx: 907-786-6312 afrgs@uaa.alaska.edu