Mr. Robert Gabel
Chief, Division of Scientific Authority
U.S. Fish and Wildlife Service
4401 N. Fairfax Drive, Room 750
Arlington, Virginia 22203

September 2, 2003

Dear Mr. Gabel:

The Wildlife Conservation Society, SeaWeb, and the Natural Resources Defense Council submit the attached documents in response to the request for comments on Report on results of Complex Interstate All-Caspian Sea Expedition on the Assessment of Sturgeon Species Stocks, 2002, published in the July 2, 2003 Federal Register (68 F.R. 39507).

The Caviar Emptor campaign, a partnership of our organizations, has reviewed the above-mentioned report, which presents the results of a survey conducted in the Caspian Sea during 2002 (hereinafter referred to as 2002 report). This report bears on Caviar Emptor's December 8, 2000 petition to the U.S. Fish and Wildlife Service (FWS) to list beluga sturgeon (Huso huso) as an endangered species under the U.S. Endangered Species Act. Action on our petition has been repeatedly delayed, most recently by the publication of the July 2, 2003 request for comments on the above mentioned report.

We also enclose several media clips from the Caspian region, which further reinforce the evidence that Caspian Sea sturgeons are in serious trouble. The decline in sturgeon populations is evidenced by the inability of the Caspian States to meet their sturgeon catch quotas for the spring fishing season of 2003. Officials in Azerbaijan, Russia and Kazakhstan have noted that sturgeon catches for spring 2003 have been very disappointing. According to several sources in the region, as of the early June conclusion of the fishing season, Azerbaijan and Kazakhstan had only fulfilled 50% of its sturgeon catch quota, despite having extended their fishing seasons for nearly a month. In Russia, the fisheries only fulfilled 66% of their quota.

Moreover, illegal fishing, ineffective management and lack of enforcement funding have severely hampered efforts to halt the downward spiral of sturgeon. The attached report by an environmental prosecutor in Kazakhstan underscores the scale of illegal fishing in Atyrau, Kazakhstan.

Select translations and the full Russian texts of a report on the Spring 2002 Caspian sturgeon stock survey are also attached. As illustrated in Table 43 of the translations, most of the 30 beluga sturgeon found in the survey were juveniles, with an average age of 9.8 years. Only 2 fish reached sexual maturity (at the age of 16). This demonstrates that the beluga population remaining in the Caspian Sea is extremely vulnerable, consisting principally of young fish that will take up to 15 years to even begin reproduction. If no drastic measures are taken to protect the further depletion of the species, these juveniles may never have a chance to reach sexual maturity to help the species' survival.

As our attached analysis indicates, the report on the 2002 sturgeon stock assessment reinforces and deepens Caviar Emptor's concern that beluga sturgeon are on the brink of extinction. We strongly urge FWS to issue a final rule listing beluga sturgeon as an endangered species without further delay.

Thank you for considering these comments.

Vikki Spruill
Sunny Wu
SeaWeb

Lisa Speer
Natural Resources Defense Council

Ellen Pikitch
Wildlife Conservation Society

Attachments:
1. Ellen Pikitch, Comments on “Report on Results of Complex Interstate All-Caspian Sea Expedition on the Assessment of Sturgeon Species Stocks, 2002”
2. TIME magazine, “A Rare Treat Heads to Extinction,” January 20, 2003
3. Oxana Martynuk, translations of several articles published in Ak-Zhaik (daily newspaper in Atyrau, Kazakhstan)
4. Agence France Presse, “Massive sturgeon, caviar haul for Russia border guards in Caspian,” June 14, 2003
5. Agence France Presse, “Six Russian servicemen arrested for illegal caviar trade,” August 18, 2003
6. Moscow Times, “Kazakhs Crack Open Secrets of Caviar,” August 1, 2003
7. London Times, “Trouble on the open market as Russia runs short of caviar,” July 11, 2003
8. London Times, “It might be a bowl of posh fish eggs to you,” July 26, 2003
9. Times of Central Asia, “Illegal fishing on the rise in Kazakhstan,” July 9, 2003
10. 2002 Report by Batyr Djazbayev, Atyrau Oblast Environmental Prosecutor
11. Select Translations of Caspian Stock Survey Spring 2002 Report (original Russian document attached in full texts).