Notes for a presentation to the Office of the Ombudsman, Namibia, Windhoek

by

Sheryl Fink
Seal Program Director International Fund for Animal Welfare 40 Norwich Street East, Guelph, Ontario, Canada NIH 2G6 Tuesday, 20 September 2011
Original: English

Check against delivery Mr. Ombudsman, fellow stakeholders; Thank you for the invitation to appear before you today. My name is Sheryl Fink, and I am the Director of the Seal Program at the International Fund for Animal Welfare (IFAW). I have been working on the issue of seal hunting for IFAW since 1998 and have attended the commercial seal hunt off the east coast of Canada for ten years, under the authority of an observation license from Canada’s Department of Fisheries and Oceans. On behalf of IFAW, I would like to thank you sincerely for this opportunity to present our position on the hunting of Cape fur seals in Namibia. We welcome this discussion and are encouraged that the Office of the Ombudsman has seen fit to undertake this consultation process. IFAW works to improve the welfare of wild and domestic animals throughout the world by reducing commercial exploitation of animals, protecting wildlife habitats and assisting animals in distress. IFAW seeks to motivate the public to prevent cruelty to animals and to promote animal welfare and conservation policies that advance the well being of both animals and people. We have offices in 15 countries globally, including South Africa, and operate projects in more than 40.

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IFAW has publicly opposed the hunt for Cape fur seals since July 1990, and the hunting of seals in Namibia remains an issue of prime concern both to our organization and to our 1.2 million supporters worldwide. Our concerns regarding the Namibian seal hunt are three-fold. First: The methods of killing are not in line with the generally accepted and humane methods of killing animals. Second, there are concerns that the hunt is not being conducted in a manner that is biologically sustsainable. And third, if the Namibian seal hunt is being conducted as a cull - ostensibly to benefit fisheries - that the necessary scientific assessment has not been done that would indicate that a reduction in seals would benefit fish stocks or the Namibian fishing industry. It has been requested that our presentations be limited to the facts which “speak for themselves”. Therefore I shall rely on the facts, as they exist, and as they are available to us. 1. Concerns about humane killing. The methods used for the killing and skinning of Cape fur seals in the Namibian hunt have been most recently evaluated by the Scientific Opinion of the European Food Safety Authority (EFSA) as part of its investigation on the animal welfare aspects of the killing and skinning of seals.1 The Opinion noted that the Namibian hunt for Cape fur seal pups causes considerable disturbance to breeding colonies, as well as fear, distress and other forms of suffering to the animals; that both targeted and non-targeted animals may sustain injuries before they are killed or escape; that not all animals which are clubbed or shot are killed or rendered irreversibly unconscious; and that pups were frequently not properly bled after stunning, resulting in animals regaining consciousness or remaining conscious for some period of time. In order for an animal to be killed humanely, most veterinarians recommend that a three step process comprised of stunning, checking for irreversible unconsciousness, and bleeding out be conducted.2 Under this process, animals should be effectively stunned with a single blow,3 a test for irreversible unconsciousness should be immediately conducted, and this should be followed by bleeding out to ensure death. The first step of effective stunning often appears to be unachievable in the Cape fur seal hunt due to the mobility of pups. As pups at the age of slaughter are highly mobile, they often attempt to run away from hunters, and several strikes may be necessary to ensure that an animal has been rendered unconscious. Since the probability of accurately striking a moving target is lower than for a more stationary one, there is a high likelihood of ineffective stunning. Veterinarians observing the Cape fur seal hunt in the early 1970s found that stunning was often ineffective and that, in many cases, several blows were required before an animal was rendered unconscious.4,5,6 Video recording7 and direct observation8of more recent hunts suggest that this situation has not changed significantly since the 1970s.

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It is also obvious from video evidence that seals are subject to a significant level of stress as a result of the hunting methods used. According to the Regulations governing the Namibian seal hunt,9 pups are to be rounded up into a large group and driven away from the water’s edge, followed by the release of small groups of animals that move towards the sea. Pups are required to be struck on the top of the head with a club as they are released between rows of clubbers. During this process, nursing mothers are separated from pups and may flee into the sea, which disrupts and may even prematurely end the nursing process. Pups may die when forcibly weaned at this stage. Lactating cows are also negatively affected when their pups are killed, as a result of the close bond that exists between them.10 When pups are herded into groups, they are tightly packed together and may be held for more than 30 minutes. During this time and before they are stunned, they may vomit milk or die from overheating or suffocation.11,12,13 The stress associated with repeated disturbance over a 4 month period can be defined as chronic, and may lead to disruption of normal physiological function and suppression of the reproductive and immune systems. Bulls are killed via a shot to the head, but as the first bullet may not always kill, a struck animal may flee, injured and suffering, into the sea. The hunting of bulls often creates additional disturbance in crowded seal colonies and, as adult males try to flee, pups may be crushed causing injury or death.14 Unlike Canada, Namibian authorities do not routinely permit independent animal welfare experts to observe or document the hunt and review whether or not it is conducted in a humane manner. However, the available video evidence and veterinary studies indicate that the high likelihood of seals being killed inhumanely, and the stress and physiological disruption caused by the current killing methods used, indicate that this hunt poses serious animal welfare concerns, concerns that have been recognized and criticized by the international community. IFAW’s position, informed by the above analyses, is that there is sufficient evidence that the hunting of seals in Namibia should be ended on the basis that it does not meet internationally recognized requirements for humane killing, as determined by EFSA and other expert bodies. Further, given the methods used in this hunt and the biological characteristics of Cape fur seals, it is almost certain that the Namibian seal hunt can never meet these internationally recognized requirements for humane killing. 2. Sustainability We acknowledge that the Government of Namibia has a policy of sustainable utilization, enshrined in its constitution15 and in the Namibian Government’s Vision 203016 However, there is currently no assurance that Namibian Cape fur seal hunt is being conducted in a manner that is biologically sustainable. Namibia does not provide up-todata data and analyses with which to evaluate the sustainability of its hunt.

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Following convention, scientific data concerning the abundance of Cape fur seals, population trends, and their interactions with other species should be made available for independent scientific assessment and scrutiny. Currently we cannot - as requested in the letter of invitation to this meeting - let the facts speak for themselves on this matter, because the facts are simply not available. Nation states that exploit and export wildlife – especially wildlife species that are listed on CITES appendices, such as Cape fur seals - have a responsibility to make scientific data available to the international community in an open and transparent manner. Furthermore, it is widely agreed that commercial exploitation in the 21st century must be conducted according to specified management rules.17,18 Namibia’s (and, for that matter, Canada’s) commercial seal hunt does not currently meet this standard, and neither clear objectives nor management rules for the hunt are available.. Despite claims to the contrary, we can find no scientific evidence that the Cape fur seal population is growing rapidly. Even though it was predicted that the seal population would double between 1990 and 2000, pup counts suggest that there has been little change in the overall population of Cape fur seals since 1993, when it was estimated at about 2 million animals.19 Concern has recently been expressed for the conservation status of the population, which has been subject to mass die-offs and continued hunting.20,21 Exploitation of Cape fur seals off the eastern cape of South Africa appears to have had permanent impacts on the population.22 Cape fur seals are also threatened by global warming. As climate change appears to be affecting the distribution and abundance of fish, this leads to change in food availability for fur seals which may ultimately affect their ability to thrive and survive. In addition, there is evidence that global warming could result in increased mortality due to overheating of Cape fur seals at northern edges of their range,23 including Namibia, and loss of habitat could also be predicted, due to sea level rise.24 One thing that governments can do to counteract the threats posed by global warming is to reduce other, non-climate related threats, such as hunting. A responsible government, incorporating a precautionary approach – as promoted by IFAW, World Wildlife Fund, and numerous governments around the world25 -- would take steps to reduce the threats to the Cape fur seal population that are caused by the environmental uncertainty due to global warming by ceasing commercial exploitation. The impact that changes in fish distribution and abundance can have on seals was visible in 1994 and 1995 when warm, nutrient-poor water invaded the Benguela region and resulted in massive fish mortality. As a result, Cape fur seal pup mortality was high and their growth rates very low. Thousands of adults died of starvation, and abortions of pregnant cows were widespread the following year.26 Pup survival from 1994 and 1995 was reportedly almost zero.27

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The concern has also been raised that the killing of large male bulls is also not conducive to the stability and health of the Cape fur seal population, since mature bulls are better able to hold their territories and secure matings with cows, whereas younger, less experienced males may increase territorial conflict.28 While it is claimed by the Ministry that the selecting of bulls of the appropriate size is practical, the profitability of larger males makes such selective killing unlikely, and the accidental killing of cows reveals that targeting males of specific size and age may be unfeasible in practice.29 It has been publicly stated that the government of Namibia will increase seal quotas next year.30 There are no data or scientific assessment to support increasing the quota at this time. Nor have any assessments – presuming that they exist – been provided for independent scientific scrutiny. There is the additional problem that the Cape fur seal population is shared with South Africa. There is no evidence to indicate that South African scientists, who have considerable knowledge of this population, have shared their data and expertise or collaborated in any assessment process. In conclusion, there is no available evidence that would suggest the current levels of exploitation in Namibia are biologically sustainable. The data are simply not available. The uncertainty surrounding abundance estimates, the unknown effects of the bull hunt, and the likely consequences as a result of global warming exacerbate the need for precaution and scientific information. If the government of Namibia truly wishes to kill seals under the guise of sustainable utilization, then it falls on the government to show that current removal levels (including bycatches and other sources of human induced mortality) are, in fact, biologically sustainable. 3. Seals and fisheries interactions Officials with the Government of Namibia have publicly claimed that the killing of seals is being conducted to benefit fish stocks.31,32,33 However, the interactions between fur seals, humans and fish stocks are complex and not well understood, and there is no evidence supporting the simplistic assumption that a reduction in the number of fur seals will result in increased fishery yields or reduce other perceived conflicts between fur seals and fisheries. Modeled effects of large scale reductions (up to 95%) in the Cape fur seal population result in only small to moderate benefits to commercially important fish stocks.34 And the possibility remains that reducing the numbers of Cape fur seals might actually be detrimental to fishing interests.35 In Canada, there are recurring calls from the fishing industry to cull grey seals, in the belief that they are preventing recovery of cod stocks. And yet this year it was revealed that one of the few areas where commercially important cod stocks are now increasing is in the very waters that support the highest productivity of grey seals.36 Several studies conducted to date have found that the impact of seals on fisheries in various ecosystems is trivial37,38,39,40or that the presence of marine mammals may in fact have a positive impact on fisheries.41 Some scientists believe that where marine mammals occur at high densities, they play an important role in the cycling of nutrients such as nitrogen in

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marine ecosystems.42 Indeed, culls of marine mammals can often have unforeseen, unexpected, and unintended consequences, which may be both positive and negative, depending on the management objective. 43,44 The decisions to cull marine mammals is a political one, but it is a decision that can be informed by science in order to reduce the potential for these unexpected, potentially detrimental effects on non target species. If a cull of seals is to be considered, there is a protocol for the scientific assessment of such proposals, produced for the United Nations Environment Programmes Marine Mammals Action Plan that should be consulted.45 Other considerations The announcement that quotas for Cape fur seals will be increased next year has been accompanied by the claim that more jobs will be produced.46 The example of Canada shows, however, that increased quotas do not necessarily translate into an increase in the number of jobs for sealers, nor greater income earned by individual sealers. In 2011, Canada increased its quota for harp seals to 400,000 animals while the number of active sealers dropped to an all-time low of an estimated 225 active sealers.47 Over 30 countries currently have bans on the trade in seal products,48 and markets for seal products appear to be limited or declining. Although it has been claimed that research into new innovations such as transplantation of trachea and heart valves is promising, these initiatives are currently showing little success49 despite significant financial investment and markets for these products may never be realized.50 Canada’s commercial seal hunt currently requires more in government financial support more than it actually earns,51 and it appears that there is a gradual acceptance amongst sealers and east coast communities that commercial sealing is not an industry with strong future growth.52 IFAW believes that seal watching and ecotourism present better employment opportunities for Namibians than seal hunting, and that if conducted correctly, it is also biologically sustainable. Over 20 years ago, IFAW produced a report on the Namibian seal hunt that sought to answer a question posed by Hennie Fourie, then Namibia’s Director of Tourism and Resorts for the Ministry of Wildlife: Are seals worth more when utilized as a tourist attraction or when hunted? At the time, the answer was that the value of seal watching appeared to equal or exceed the value of seal hunting. 53 A more recent study concludes that seal watching in Namibia may be worth 300% more than seal hunting and has far greater opportunities for growth.54 Conclusion. 1. There is no evidence that the hunting of Cape fur seals in Namibia meets international requirements for humane killing. 2. There is no evidence that the hunting of Cape fur seals in Namibia is being conducted on a biologically sustainable basis. 3. And there is no evidence to support claims that killing seals will benefit fish stocks or the Namibian fishing industry.

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We feel there is sufficient evidence that the Namibian seal hunt should end immediately based on the animal welfare concerns. Failing this, IFAW strongly encourages the Government of Namibia to conduct an open and transparent, scientific assessment of the anticipated impacts of culling Cape fur seals. This assessment should address concerns over the animal welfare aspects of the killing methods, the conservation status of the Cape fur seal population, and the potential impacts on fisheries. IFAW would be pleased to contribute to such an assessment. Due to the potential for current hunting quotas to be biologically unsustainable and the real possibility that current hunting levels are having a negative effect on fish stocks, we would recommend that - a moratorium be placed on the as a precautionary approach – the a moratorium on the hunting of Cape fur seals be implemented in the interim. Again, thank you for inviting IFAW to appear before you today. As noted at the outset, we strive to advance the well-being of both animals and people. As such, we are interested in ways that IFAW might support Namibia in finding alternatives to seal hunting, solutions that will also create jobs and economic benefit for Namibians. We hope this first meeting opens the door to an ongoing dialogue, and we look forward to a positive and transparent working relationship with the Namibian government. Thank you for your time, and I wish you well in your deliberations on this important issue.

EFSA. 2007. Scientific Opinion of the Panel on Animal Health and Welfare on a request from the Commission on the Animal Welfare aspects of the killing and skinning of selas. The EFSA Journal 610:1123. 2 Smith, B., Caraguel, C., Crook, A., Daoust, P-Y, Dunn, J.L., Lair, S., Longair, A., Philippa, J., Routh, A. and Tuttle, A., 2005. Improving humane practice in the Canadian harp seal hunt. A report of the Independent Veterinarians’ Working Group on the Canadian harp seal hunt. BL Smith Groupwork. 26 pp. http://ivwgonline.org/IVWGReportAug2005.pdf Burdon, R.L., Gripper, J., Longair, J.A., Robinson, I. and Ruehlmann, D., 2001. Rapporteur: Fielder, J.. Veterinary Report Canadian commercial seal hunt Prince Edward Island, March 2001, Canada. Report of an International Veterinary Panel, 36 pp. <http://www.ifaw.org/ifaw/dfiles/file_95.pdf>. Accessed 17/12/2007; Butterworth, A., Gallego, P., Gregory, N., Harris, S., Soulsbury, C., 2007. Welfare aspects of the Canadian seal hunt: Preliminary report, 30 pp and Final report, 45 pp. Document submitted to EFSA, 2007. 3 Burdon, R., J. Gripper, J.A. Longair, I. Robinson, and D. Ruehlmann. 2001. Observation of the Canadian Commercial Seal Hunt. Prince Edward Island, Canada. Report of an International Veterinary Panel, March 2001. 36 pp. Available at http://www.ifaw.org/ifaw/dfiles/file_95.pdf; The AVMA notes that “A single sharp blow must be delivered to the central skull bones with sufficient force to produce immediate depression of the central nervous system.” American Veterinary Medical Association. 2007. Guidelines on Euthanasia (Formerly the Report of the AVMA Panel on Euthanasia). June 2007. http://www.avma.org/issues/animal_welfare/euthanasia.pdf. See also Kirkman and Lavigne 2010. 4 McDonald LE. 1974. Report to the Endangered Species Division of the National Marine Fisheries Service, National Oceanic and Atmospheric Administration, Washington DC on visit to South and Southwest Africa fur seal harvest sites; 1974. 5 Wass WM. 1974. Letter to the Endangered Species Division of the National Marine Fisheries Service, National Oceanic and Atmospheric Administration, concerning impressions of seal harvesting in South and South West Africa. Washington DC. 6 Wass, WM. 1975. Report of observations and recommendations concerning harvesting of fur seals in South and South West Africa. Report to the Endangered Species Division of the National Marine Fisheries Service, National Oceanic and Atmospheric Administration, Washington DC. 7 IFAW (International Fund for Animal Welfare), 1994. Seal Culling Namibia, Cape Cross Culling, Fur Seal Slaughter. DVD. International Fund for Animal Welfare, Yarmouth Port, MA. Submitted to EFSA, 2007.

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Kirkman, S.P., 2006. Warfare to Welfare: Southern Africa’s Dynamic Seal-Human Interface. Report prepared for the International Fund for Animal Welfare (IFAW). Searth Ecological Consulting. South Africa. 9 Namibia. Ministry of Fisheries and Marine Resources. Regulations relating to the exploitation of marine resources. Government Gazette of the Republic of Namibia, No. 153 Namibia: Windhoek [document on the Internet]; 2001 Dec 7 [cited 2010 Jan 31]. Available from: http://209.88.21.55/opencms/export/sites/default/grnnet/MFMR/Laws_and_Policies/docs/MarineRegulations. pdf 10 Rand, R.W., 1959. The Cape fur seal, Arctocephalus pusillus, distribution, abundance and feeding habits off the south western coast of the Cape Province, Division of Sea Fisheries, South Africa, Investigational Report, 34, 1-75. 11 European Food Safety Authority. Scientific opinion of the Panel on Animal Health and Welfare on a request from the Commission on the Animal Welfare aspects of the killing and skinning of seals [homepage on the Internet]. The EFSA Journal. 2007;610:1–123 [updated 2008 Feb 15; cited 2010 Feb 1]. Available from: http://www.efsa.europa.eu/EFSA/efsa_locale-1178620753812_1178671319178.htm 12 Best PB. Sealing practices and humaneness of the harvest. Report of the Subcommittee of the Sea Fisheries Advisory Committee appointed at the request of the Minister of Environment Affairs and Water Affairs, to advise the Minister on the scientific aspects of sealing. Cape Town: Sea Fisheries Research Institute; 1990. 13 Kirkman, S.P., 2006. Warfare to Welfare: Southern Africa’s Dynamic Seal-Human Interface. Report prepared for the International Fund for Animal Welfare (IFAW). Searth Ecological Consulting. South Africa. Paper submitted to EFSA by IFAW Southern Africa, Capetown, SA, 2007. 14 See EFSA 2007. 15 Constitution of the Republic of Namibia, Chapter 11, Article 95 16 Government of the Republic of Namibia. 2004. Namibia Visio 2030; Policy document for lomng-term national development summary document. Namprint, Windhoek, Namibia. 17 Cooke J, et al. “Management rules for marine mammal population: A response to Lonergan” Marine Police 36 (2012) 389 -392. 18 Leaper, R., Lavigne, D. M., Corkeron, P., and Johnston, D. W. 2010. Towards a precautionary approach to managing Canada's commercial harp seal hunt. – ICES Journal of Marine Science, 67: 316–320. 19 Kirkman, SP, WH Oosthuizen, MA Meyer, PGH Kotze, J-P Roux, and LG Underhilll. Making sense of censuses and dealing with missing data: trends in pup countrs of Cape fur seal Arctocephalus pusillus pusillus for the period 1972-2004. 20 Roux J-P. 1998. The impact of environmental variability on the seal population. Namibia Brief 20: 138– 140. Biological Sciences. 21 The IUCN red list of endangered species notes that “hunting levels might not be sustainble in Namibia.” Hofmeyr, G. & Gales, N. 2008. Arctocephalus pusillus. In: IUCN 2011. IUCN Red List of Threatened Species. Version 2011.1. <www.iucnredlist.org>. Downloaded on 16 September 2011. 22 Stewardson, CL. 1999. The impact of the fur seal industry on the distribution and abundance of

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Roux, J. P. "The Impact of Environmental Variability on the Seal Population." Namib.Brief.20 (1998): 138,138-140. Biological Sciences. Web. 16 Sep. 2011. 24 Lavigne, D.M. “The Pinnipeds.” In The Global Guide to Animal Protection. Ed. A. Linzey.. Champaign IL: University of Illinois Press, Champaign IL. (in press), See also Stewardson 1999. 25 See “WWF’s Approach to Building Resilience to Climate Change”. Available at http://assets.panda.org/downloads/resiliencebrochure9605.pdf. Accessed 16 September 2011. 26 Wickens, Patti. 1995. Namibian Sealing Debacle: An Environmental Disaster and Managerial Blunder. African Wildlife 49(3): 6-7. 27 Mecenero, S., S. P. Kirkman, and J. P. Roux. "A Refined Fish Consumption Model for Lactating Cape Fur Seals (Arctocephalus Pusillus Pusillus), Based on Scat Analyses." ICES Journal of Marine Science 63.8 (2006): 1551,1551-1566. Biological Sciences. Web. 16 Sep. 2011. 28 Pallett, John. 2000. An Assessment of Seals and Sealing in Namibia: A report to the Wildlife Society of Namibia. Unpublished document available upon request.

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Cape fur seals Arctocephauls pusillus pusillus on the eastern cape coast of Sourht africa. Transactions of the Royal Society of South Africa, 54(2): 217-245.

See Pallet J. 2000. An assessment of seals and sealing in Namibia. A report to the Wildlife Society of Namibia. December 2000.
Kaira, C. 2011. Seal cull quota in Namibia to incrase next year, Namibian Says. Bloomberg Businessweek 4 August 2011. http://www.businessweek.com/news/2011-08-04/seal-cull-quota-in-namibiato-increase-next-year-namibian-says.html
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Bernhard Esau, Fisheries and Marine Resources Minister. Quoted in: Hartman, A. 2011. More seals to die next year. The Namibian. 8 April 2011. Available at: http://www.namibian.com.na/news/fullstory/archive/2011/august/article/more-seals-to-die-next-year/ 32 Bernhard Esau, Fisheries and Marine Resources Minister Quoted in: 2011. Boycott or not, seal cull starts today! The Windhoek Observer. September 13, 2011 Available at: http://www.observer.com.na/archives/968-boycott-or-not-seal-cull-starts-today 33 Kaira C. 2011 Namibia Sets Seal Cull at 86,000 to Protect Fishing. The Bloomberg Businesweek. July 01, 2011, Available at: http://www.businessweek.com/news/2011-07-01/namibia-sets-seal-cull-at-86-000-toprotect-fishing.html 34 Roux, J-P, LJ Shannon. 2004. Ecosystem approach to fisheries manangement in the northern Benguela: the Namibian experience. African Journal of Marine Science, 26 (1): 79-93, see also Kirkman 2007. 35 Punt and Butterworth 1995. See also: Yodzis, P. 2001a. Must top predators be culled for the sake of fisheries? Trends in Ecology & Evolution 16:78-84. 36 Frank, KT, B Petrie, JAD Fisher, and WC Leggett. Transient dynamics of an altered large marine ecosystem. Nature. Published online 27 July 2011. 37 Corkeron, P. 2009. Marine mammals’ influence on ecosystem processes affecting fisheries in the Barents Sea is trivial. Biology Letters. 38 Trzcinski, KM, R Mohn and WD Bowen. 2006. Continued decline of an Atlantic cod popoulation: How important is gray seal predation? Ecological Applications 16(6): 2276-2292. 39 Punt, A.E. and D.S. Butterworth. 1995. The effects of future consumption by the cape fur seal on catches and catch rates of the cape hakes. 4. Modelling the biological interaction between cape fur seals Arctocephalus pusillus pusillus and the cape hakes Merlussius capensis and M. paradoxus. South African Journal of Marine Science 16:255-285. 40 Brian R. MacKenzie, Margit Eero, Henn Ojaveer. Could Seals Prevent Cod Recovery in the Baltic Sea? PLoS ONE, 2011; 6 (5): e18998 DOI: 10.1371/journal.pone.0018998 41 Li, Lingo, C. Ainsworth, T. Pitcher. 2010. Presence of harbour seals (Phoca vitulina) may increase exploitable fish biomass in the Strait of Georgia. Progress in Oceonography 87:235-241. 42 Roman J, McCarthy JJ (2010) The Whale Pump: Marine Mammals Enhance Primary Productivity in a Coastal Basin. PLoS ONE 5(10): e13255. doi:10.1371/ journal.pone.0013255. 43 Roux, J-P and LJ Shannon. 2004. Ecosystem approach to fisheries management in the northern Benguela: the Namibian experience. African Journal of Marine Science 26(1), 79-93. 44 Fisheries and Oceans Canada, Canadian Science Advisory Secretariat, Zonal Advisory Meeting of October 4-8, 2010 on Impacts of Grey Seals on fish Populations in Eastern Canada. 45 United Nations Environment Programme. 1999. Protocol for the Scientific Evaluation of Proposals to Cull Marine Mammals: A Report of the Scientific Advisory Committee of the UNEP Marine Mammal Action Plan. Nairobi: United Nations Environment Programme, Greenpeace International, International Fund for Animal Welfare, Worldwide Fund for Nature. http://www.ifaw.org/Publications/Program_Publications/Seals/asset_upload_file777_61691.pdf 46 Bernhard Esau, Fisheries and Marine Resources Minister. Quoted in: Hartman, A. 2011. More seals to die next year. The Namibian. 8 April 2011. Available at: http://www.namibian.com.na/news/fullstory/archive/2011/august/article/more-seals-to-die-next-year/ 47 Fisheries and Oceans Canada, personal communication. In 2011, only 225 sealers took part in Canada’s commercial seal hunt, despite a quota increase to 400,000 animals and significant political investment in the industry. 48 Including the 27 members of the European Union. The United States has had restrictions on the marketing of seal products since 1972. 49 See Agathos, EA, P Tomos, E Lachanas, H Gakiopoulou, A Pantopoulou and D Perrea. 2010. Experimental replacement of pig trachea with novel bioprothesis from harp seal. Asian Cardiovasc Thorac Ann. 18:557-562; Agathos, E. Andreas; Shen, Ming M; Katsiboulas, Michalis M; Koutsoukos, Petros P; Gloustianou, Georgia G. ASAIO journal (American Society for Artificial Internal Organs : 1992) 57. 4 (2011 Jul-Aug): 328-332. Currently only one sealing vessel from the Magdalen Islands, Canada, profits from the research into heart valves, the initial research conducted does not meet required standards and up has had to be redone, and research at the University of Laval is at a very preliminary stage (Fisheries and Oceans Canada, personal communication). 50 Cape Breton Post. 2011. Seals and Innovation. Editorial. 7 September 2011, p A6. 51 Anon. 2009. Ending seal hunt makes economic sense, prof says. University of Guelph News Release. 27 July 2009. Available at http://www.uoguelph.ca/news/2009/07/wwww_2.html; Livernois, John, 2010. The economics of ending Canada's commercial harp seal hunt, Marine Policy, Elsevier, vol. 34(1), pages 42-53. 52 IFAW 2011 poll of sealers communities (unpublished), Interview with sealer re seal meat deal to China, CBC Fisheries broadcast January 2011 (available on request).

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Natural Habitat Wildlife Adventures. 1992. Seals and Tourism in Namibia. Report prepared for the International Fund ofr Animal Welfare by Natural Habitat Wildlife Adventures, One Sussex Station, Sussex, New Jersey, 07641. May 1992. 32 pp. 54 Economists at large. 2011. The economics of seal hunting and seal watching in Namibia. Report commissioned by Humane Society International, World Society for the Protection of Animals, Bont voor Dieren (NL) and Respect for Animals (UK) http://www.wspa.ca/latestnews/2011/namibian_seals_wanted_alive_not_dead.aspx

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