Authorizations and Permits for Protected Species (APPS)

Status of the Affected Species
The Eastern Pacific Stock of NS in US waters includes the Pribilof Islands and has been designated as 'depleted' under the MMPA. The western DPS of SSL in US waters includes the Pribilof Islands and has been designated as ‘endangered’ under the ESA and as ‘depleted’ and ‘strategic’ under the MMPA. The Pribilof Islands stock of harbor seals is not classified as a strategic stock under the MMPA. No harbor seal stocks in Alaska are designated as ‘depleted’ under the MMPA or listed as ‘threatened’ or ‘endangered’ under the ESA.

There is no intentional lethal take is proposed. Mortality during capture, restraint and disentanglement, although rare is possible. If such an event occurs, a full necropsy will be conducted as soon after death as possible. All ECO staff are trained by MMSN (K. Burek Huntington) to conduct a full necropsy. Necropsy information will be important to determine whether entangled NFS died as a result of injuries related to their entanglement or due to the stress of capture and handling. It is also possible that these two factors may interact. If an accidental mortality occurs, capture operations will be suspended pending consultation with the NMFS permit office.

Anticipated Effects on Animals
Effects on Target Animals: The effects of all take activities for each project including capture, tagging and instrumentation will have a short-term effect on individual animals by disrupting their daily activities, but no long-term effects are anticipated. NFS return to their normal daily activities within 0.0 to 2.5 hours and abandonment of the rookery has never been observed due to the research activities requested in this permit application (Gentry et al. 1977). 
UAS Aerial Survey: The physical response by an animal in recognition of sUAS would likely range from adjusting body posture, vocalizing, or moving short distances away. In rare cases individual NFS, SSL, and harbor seals may enter the water and would likely return to land within an hour of disturbance. We anticipate minimal incidental disturbance during surveys due the small size and low noise intensity of sUAS. UAS were not considered in the SSL and NFS Research Final PEIS (NMFS 2007), although methods and potential effects on animals for analogous aerial survey and land- or skiff-based observations were considered, and the effects were found to be negligible. A subsequent EA completed in 2014 provided additional analysis to assess the effects of UAS on SSL and supported the conclusion that impacts were minimal (and less than the manned aerial and vessel-based survey methods that UAS are replacing). MML examined takes of harbor seals on Otter Island relative to a sUAS flying along shore at various altitudes (MML, unpub. data). Based on their examination there was no visible reaction by the seals to the sUAS at any altitude, and it was determined that UAS could be a valuable tool for monitoring harbor seals in the Pribilof Islands when compared to shore-based observer counts.
Effects on Non-Target Animals: NFS tend to occur in large groups on the rookeries and haulouts. Thus, even activities focused on specific individuals, or areas of the rookery or haulout, may cause incidental disturbance of non-target animals. Incidental disturbance involves a physical response by an animal in recognition of research activities on the breeding area or haulout site. This response ranges from adjusting body posture towards the researchers momentarily, to moving away from the rookery. Adult female NFS with pups return to the rookery after a disturbance within 2.5 hours (Gentry et al. 1977).
The number of incidental disturbance takes of SSL is based on their predictable haulout patterns. Research activities may result in incidental disturbance of both sexes, all ages, and all reproductive statuses of SSL. However, most of the disturbance will be to juvenile and idle males on hauling grounds.
SSL and harbor seals may be incidentally disturbed during all NFS research activities. Since SSL and harbor seals occur very irregularly at the NFS research sites, it is hard to predict when, where and how many may be disturbed. We will avoid disturbing SSL and harbor seals that are sighted on or near NFS rookeries and haulouts by moving around them or working at other locations when possible. Harbor seals are found on Otter Island. Although research is conducted infrequently at Otter Island, and observations of harbor seals at other research locations are rare, it is possible that harbor seals may be incidentally disturbed during the conduct of NFS research activities. We anticipate no long-term or population level effects of incidental disturbance on non-target marine mammals including NFS, SSL or harbor seals.
The Pribilof Islands are home to many seabirds. Research activities proposed in this permit overlap with the breeding season of some marine sea birds. However, because their habitat requirements differ greatly, there is very little spatial overlap between nesting marine birds and NFS rookeries and therefore very few birds are encountered. Occasionally, birds may rest at areas along the edges of rookeries and in these cases a small number of the following species may be incidentally disturbed: northern fulmar (Fulmarus glacialis), red-faced cormorant (Phalacrocorax urile), black and red-legged kittiwake (Rissa tridactyla and R. brevirostris), least and crested auklets (Aethia pusilla and A. cristatella), tufted and horned puffins (Fratercula cirrhata and F. corniculata), and common and thick-billed murres (Uria aalge and U. lomvia). However, NMFS (2007) found that under Alternatives 3 and 4 for the implementation of the NFS research program, direct, indirect and cumulative effects of the combined research program on any shore bird or sea bird would be negligible, thus we assume this to also be true for ECO projects detailed in this application.
Mortality Effects on Population: The research proposed here is the minimum required to continue to monitor the health of the population and to determine and mitigate influences that may be compromising population health in the Bering Sea ecosystem. We anticipate no population level effect resulting from the research proposed in this application on NFS. While research effects at the population level are difficult to detect, and to assess relative to other natural or anthropogenic effects, there has been a long history of intensive research conducted on the Pribilof Islands that would suggest minimal effects from research. At many points during this history the research was far more intensive, and experimental in nature, than the research proposed in this application.
Incidental Effects: As noted above, except for disentanglement captures (currently covered under our Stranding Agreement), there will not be directed takes and therefore both direct and indirect effects are expected to be minimal, if any. The disentanglement captures will be conducted in a manner that reduces disturbance to adjacent NFS and minimizes disturbance to rookery and haulout areas. Incidental harassment of individual NFS close to those being targeted for capture will be of short duration (i.e. < 1 hour). See Measures to Minimize Effects below for details on methodology to minimize negative effects.

Humane Take and Measures to Minimize Negative Effects
Measures to Minimize Effects: During land- and boat-based aerial surveys, pilots will follow ACSPI sUAS Standard Operating Procedures to minimize effects on animals. Some disturbance to nearby animals will occur during population/habitat surveys and the disentanglement captures which are conducted on an opportunistic basis (ca. once or twice per week during peak activity seasons). The slow crawling approach technique minimizes the number of NFS that are harassed in this way. While slowly moving towards an entangled NFS, we are normally between 5 to 30 m from NFS. Those NFS directly in the approach path are able to move away in a slow relaxed manner, thus it is possible to avoid animals initiating panic “running”. In addition, once captured, the target NFS is moved away from the initial area, allowing any incidentally harassed seals to quickly resume normal activities. In addition, in situations where capture attempts will cause unacceptable disturbance to haulouts, sightings will be recorded (and animals photographed) and the location of entangled NFS will be monitored to the greatest extent possible to increase the likelihood of future capture opportunities. To avoid disturbance to rookery areas, attempts to capture entangled NFS pups will be made primarily when pups are hauled out in areas on the edges of the breeding rookeries. Slow crawling also makes it possible to approach the target animal closely prior to capture, thus minimizing the number of nearby NFS disturbed. Finally, restraint of the captured NFS will occur out of line-of-sight of the group so that activities may quickly return to normal. 
Project personnel will collaborate with NMFS scientists and managers to develop, refine, and share data being collected from the projects proposed here to ensure compatibility with future management and research. Project personnel will work in coordination with other researchers conducting permitted research activities on rookeries when surveys will occur concurrent with these other research activities. Surveys in the fall may result in the harassment of non-pups and pups. We anticipate harassment may occur during our approach to vantage points for surveys. Project personnel and NMFS staff will develop a data collection protocol and train project personnel to assess each survey vantage point. Our intent will be to minimize the potential for harassment to occur while still collecting useful data to meet our objectives and test the hypotheses associated with the expanded projects we anticipate conducting prior to the expiration of our permit.
Monitoring Effects of Project Activities: The only activity expected to have an effect is disentanglement captures. Round-up surveys of juvenile and adult males will have a short-term and small energetic cost on those individuals herded inland. Numerous studies have investigated the effects of roundups and have been unable to detect any long-term redistribution of NFS as a result of round-ups (see NMFS 2014). Capturing, weighing, and restraining tagged and disentangling entangled animals will have an effect on them initially. Following disentanglement, the NFS will be released and be monitored during reintegration with the other NFS. Our protocol is to remain with the NFS until it begins to walk towards other NFS or towards the water. This is normally an immediate behavior. Reintegration into the group is not critical for the NFS’s well-being (NFS are solitary for the majority of their lives) and so is not an essential part of the post capture protocol. If the NFS does not immediately move towards other NFS or towards the water one of the capture team will remain with it for up to one hour. No direct intervention is deemed necessary or will be attempted. No drugs or other substances with lasting effects will be administered so recovery from capture is expected to be immediate. Prior to all capture attempts a count will be made of the number of NFS in the capture area. A second count will be made following the release of an entangled NFS (or after an unsuccessful capture attempt) to ascertain the number of NFS that left the area due to capture disturbance. Records of repeat observations of disentangled or tagged NFS will provide us an indication of the duration and extent of effects experienced by those individuals captured.

Alternatives: Other than disentanglement through direct intervention, there are no alternatives that we are aware of. Without such direct intervention, most cases of entanglements are expected to be lethal.
There should not be any significant take associated with ECO observations under normal circumstances. As more NFS return to the island in June and July of each year the chance of incidental disturbance increases as ECO staff observe NFS activity and movement on the rookeries and haulouts. To minimize disturbance, particularly to breeding areas, surveys will be conducted from vantage points overlooking the haulouts to the greatest extent practical. During these surveys, individuals move slowly while keeping a low profile, stop if animals show any signs of detecting our presence, pay close attention to wind direction to avoid NFS smelling our nearby presence, and wear clothing that blends into the surroundings. ECO staff will work in coordination with other researchers conducting permitted research activities on NFS rookeries when conducting observations that may cause a disturbance to NFS.
Take estimates of NFS associated with the proposed surveys are estimated below. We expect any incidental disturbance take associated with these activities to be low level harassment, such as a change in behavior or change in activity level for a small number of animals present, but have made allowance for the maximum numbers that could be disturbed during these activities if, for example, the animals move away from the approaching personnel.
The spring survey for timing of first arrival will occur when adult male NFS are the most likely age and sex class to be present on St. Paul Island. Juvenile males may intermittently arrive and depart rookeries during the early spring, but the majority of juvenile males begin to arrive onshore during the last week of May (Gentry 1981). Females do not return to the island until mid-June (Bartholomew and Hoel 1953). It is likely that some adult male NFS at the survey sites will be incidentally taken by harassment on multiple occasions. Upon first arrival onshore, adult male NFS may depart the rookery due to human presence or human scent, but once territoriality is established are highly resistant to disturbance during the spring (Gentry 1998). Territorial males may change the time spent in certain behaviors due to human presence, but they will not depart from the rookery, unless forced (Gentry 1998). Adult male counts will be conducted beginning in late April until 5% of adult males counted during the most recent census have arrived.
To minimize disturbance, particularly to breeding areas, surveys will be conducted from vantage points overlooking the haulouts to the greatest extent practical. Take may occur from the sight, scent or sound of human presence. The number of requested takes by harassment for the timing of departure survey is based on observed recent trends in abundance, seasonal behavior and attendance patterns and study locations and focal observation points. The take estimates for these surveys are combined with our number of animals authorized to be taken due to incidental disturbance from other studies.

Co-management agreement with NMFS: In June 2000, the ACSPI entered in to a co-management agreement with the National Marine Fisheries Service for the management of marine mammals on St. Paul Island. The activities described herein are in fulfillment of our co-management responsibilities for which funding has been available through an annual competitive grant process. These include our Population/Habitat Program, Biosample Program, Disentanglement Program, and Island Sentinel Program.
Other funds: No additional supplementary funds are utilized by any project/programs.

Samples sent to collaboration researchers are responsible for disposition after completion of use. The ECO established agreements for collection of various marine mammal samples with some of the following researchers and organizations: MML; ADF&G; UAF; UNT; UCSD; Duke University and AMMTAP and may establish additional agreements. All bones from stomachs, colons, and scats will be archived in ECO or shipped to MML in Seattle, W.A. for identification and storage. All vibrissae, hair, liver, blood, and muscle samples will be collected and retained at ECO or shipped to a lab (e.g. MML, UAF) for stable isotope and mercury analysis. NFS teeth will be shipped to Matson's Laboratory for independent aging and returned to ECO for archival. The lower canine teeth will be archived by ECO. Teeth from other subsistence hunted and dead stranded marine mammal species on St. Paul, including SSL and harbor seals will be retained by ECO. Serum/ plasma from blood from NFS and SSL may be sent to ADF&G, MML, UAF or other labs for analysis and/or archival. Blubber and liver samples will be shipped to Hollings Marine Laboratory for long term banking in the NMMTB through AMMTAP. ECO will continue its collaborative research efforts with MML and with AMMTAP through Amanda Moors and Rebecca Pugh of the NIST.
Additional specific programs may request biosamples in the next five years. Therefore, ECO requests this permit administer the authority to collect and receive hard and soft parts from subsistence hunted and dead stranded NFS, SSL, and harbor seals for future researchers and research projects on a case-by-case basis, in consultation with the NMFS permit office. In addition, we request the authority to collect hard and soft parts from unidentified dead stranded cetaceans or pinnipeds, consistent with the provisions of our MMSN stranding agreement.

Results will be published and made available in the appropriate referred scientific journals or as technical reports at the discretion of the ECO staff as time and funding allows. All publications will be in compliance with any funding requirements. Samples sent to and analyzed by external researchers may result in additional publications that will be reported as part of this permit as available.