THESE COMMENTS on
The USFWS Proposed Beluga Special Rule
[Federal Register, June 29, 2004 (Volume 69, page 124)]
ARE PRESENTED JOINTLY
IWMC World Conservation Trust (IWMC)
Sturgeon Stewardship Council (SSC)
* FWS has already received reliable information from Caspian states that the beluga sturgeon is not endangered. This proposal cannot be justified on population levels.
* FWS has not explained how the rule would enhance the recovery of beluga sturgeon in the wild. The rule is more likely to enhance the depletion of beluga stocks.
* The proposed ruling does not define a process for how the FWS will come to its conclusion that a country has/ has not met the specified schedule. The proposed rule gives total discretion to FWS officials and their decision will inevitably be extremely subjective. How will the paperwork be reviewed and assessed and what opportunities will Caspian
States and other interested parties have to respond to questions raised by the FWS review process?
* The proposed ruling relies entirely on the completion of reports. Would it not be better for FWS officials to travel to the Caspian states to properly evaluate the situation on the ground rather than rely on the efficient production and exchange of all paperwork?
* The FWS has not explored other means that could encourage the conservation of beluga sturgeon such as the provision of technical assistance, grants, and other mechanisms. Constructive measures are more likely to aid sturgeon conservation than import bans, which simply create other problems (expanded black market, diversification into other overseas markets).
IWMC and SSC conclude that the rules, as designed, will not assist in the conservation of the beluga sturgeon, but to the contrary, will create situations whereby illegal activities will be encouraged.
Switzerland, 28 July 2004