November 19, 2020

Wilbur Ross Secretary of Commerce

U. S. Department of Commerce
1401 Constitution Ave., NW
Washington, DC 20230

Chris Oliver
Asst. Administrator for Fisheries
NOAA Fisheries Service Headquarters
1315 East West Highway
Silver Springs MD 20910

CEO, Steve McIvor

World Animal Protection
535 Eighth Avenue, 3rd Floor
New York, NY 10018

Re: Petition to List the Sea Otter as Endangered or Threatened

Dear Secretary Ross and Assistant Administrator Oliver and Mr. McIvor:

We the undersign do hereby petitions the Secretary of Commerce, acting through the National
Marine Fisheries Service (NMFS), an agency within the National Oceanic and Atmospheric
Administration (NOAA), to list the Sea Otter (Enhydra) as "endangered" or "threatened" under
the U.S. Endangered Species Act, 16 U.S.C. §§ 1531 et seq. We request that NMFS list the
species throughout its entire range and designate critical habitat for the species in Pacific waters.

The International Union for Conservation of Nature (IUCN) has determined that a population
reduction of at least 50% of this species has occurred over three generations, and 60 years.
(IUCN Red List 2015). Population reduction of the Sea Otter (Enhydralutris) has largely been
caused by humans. Conflict with humans, through shootings, fishing gear entanglements and
boat strikes, take a toll on sea otters, but oil spills, pollution, disease and loss of kelp pose major
threats. Sea otters are a "keystone species" which means that they can keep the numbers of
urchins in control. Sea urchins, which are grazers upon kelp could cause too much damage on
the environment. As urchin density decreases from sea otter predation, so does the grazing
pressure on kelp and as a result kelp forests flourish in the presence of sea otters.
 Please do not hesitate to contact me at (710) 123-4567 if you need more
information. My address appears below and on the cover sheet of the petition.

Sincerely,

Alexis A. Rice

Alexis A. Rice
Gerard Prep School
263 Jackson Street
Lawrenceville, GA 30046

Michael Ray Harris Wildlife Law Program Friends of

Animals Western Region Office 7500 E. Arapahoe
Road, Suite 385 Centennial, Colorado 80112

Manda Neuman University of Denver Sturm College of

Law J.D. Candidate, 2020 2255 E. Evans Avenue
Denver, Colorado 80210

Elizabeth Holland Wildlife Law Program Friends of

Animals Western Region Office 7500 E. Arapahoe
Road, Suite 385 Centennial, Colorado 80112

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 PETITION TO LIST THE SEA OTTER (Enhydralutris)
AS AN ENDANGERED, OR ALTERNATIVELY AS A
THREATENED, SPECIES PURSUANT TO THE ENDANGERED
SPECIES ACT