Orca Network Comments
on the
NMFS Recovery Plan for Southern Resident Killer Whales (SRC)

January 25, 2008
On January 24, 2008 the Northwest Region of the National Marine Fisheries Service announced availability of the Recovery Plan for Southern Resident Killer Whales.

General comment:

~The plan covers most areas of concern, usually in a general way, allowing further refinements as more information becomes available.

Habitat Use

~The plan calls for further research effort to establish winter food sources/habitat. Pacific Coast to central California and related salmon runs should be included as Critical Habitat.

~A recovery team was established which contains both Canadian and U.S. representatives, including NMFS staff. The importance of Fraser River salmon to the So. Resident orcas is noted.

~Include Hood Canal as critical habitat - Southern Residents (J pod) have been documented in Hood Canal. Chum runs could be important food source, may have been historic food source (compare to Dyes Inlet where the Chum run provided food for SRC).

~Address Military Exclusionary Zones - the Admiralty Inlet region is very important habitat for SRC during fall/winter travels into Puget Sound. If the exclusionary zone is mandatory for military use, NMFS should work with the Navy to agree the military exclusionary zones exempt ONLY military activities from the Critical Habitat designation, not other federal activities (this could help protect SRC's from possible tidal energy project in Admiralty Inlet).

Fish

~Address importance of Columbia/Snake River system and associated Chinook runs to SRC to incorporate revision of Columbia/Snake River System biological assessment to include new information on removal of Snake River dams.

~Include shoreline areas as Critical Habitat to give more strength to existing protective measures in place for endangered salmon runs, and some runs (such as fall Chum) that are important prey for SRC but are not listed as endangered and therefore not under protection.

~Address need to enforce existing regulations protecting nearshore habitat less than 20' deep.

~Take hard look at harvest and make difficult choices. If we want salmon in our future, we need to decrease harvest levels, and set aside an allotment or quota of Chinook for the orcas.

~Address Pacific Salmon Treaty - ask for inclusion of quota of Chinook for orcas, work with BC, Alaska, Oregon & California to look at all runs important to SRC.

~Look at the timing and location of all salmon runs important for the SRC - which runs should be preserved/restored first as an important food source for SRC's at critical times of the year.

~Ban fish farms, or push for fish farms to be isolated from seawater in tanks.

Toxics

~Ban PBDE's. In 2007 Washington State passed a bill regarding use of PBDEs. The bill outlines a process to phase out use of PBDEs in common household products because of the high levels of these contaminants in the environment and people and the developmental effects that have been observed from exposure to PBDEs.

~Enforce existing regulations, increase fines for polluters (considered). "Inadequacy of Existing Regulatory Mechanisms. Current levels of contaminants in the environment indicate that previous regulatory mechanisms were not sufficient to protect killer whales. While the use of PCBs and DDT is restricted or prohibited under existing regulations, they persist in the environment for decades and are also transported via oceans and the atmosphere from areas where their use has not been banned. In addition, there are new emerging contaminants that may have similar negative effects that are not currently regulated."

~Prioritize clean-ups based on location and damage to fish/orcas.

~Strengthen regulations on chemical use, ban the worst chemicals, stricter testing regulations for new chemicals before releasing them into the environment, including their interaction when mixed with other chemicals (partially included).

~Homeowner and business owner education/awareness campaign, such as Whale and Salmon friendly lawn/garden signs and info.

Education

"Education and Outreach: Enhance public awareness, educate the public on actions they can participate in to conserve killer whales and improve reporting of Southern Resident killer whale sightings and strandings."

~Add Orca Network to organizations currently providing education and awareness about the SRC. Orca Network provides current information through our whale sighting network and website on the travels and health of the SRC, up to date news, issues, events, research, and action items to help the SRC, educational events, ferry naturalist presentations, workshops, publications, and a network for discussion of issues about SRC and related topics.

~Address need to change the way people think about orcas. Over the previous decades the public perception of the killer whale, now referred to as orcas, has changed considerably. In recent years scientific literature has reflected knowledge gained since field studies began in the early 1970's. However, the conventional understanding of orcas still does not take into account the species' observed cultural capabilities. Greater awareness of such highly evolved adaptations, without parallel except in humans according to some published authorities, could enhance public appreciation for orcas and help motivate greater efforts to protect their habitat.

~Campaign for homeowners to reduce toxic chemical use in home and garden

~Encourage approaching business owners, investors, and developers to provide background information and motivation toward efforts to protect and restore watershed and marine habitats.

Vessels

~Promote shore-based whale watching (add Orca Network to list of organizations that do this)

~Educate recreational boaters, sports fisher persons, and the maritime industry about be whale wise guidelines (included).

~Increase awareness of the orcas through the Orca Network Whale Sighting Network to educate boaters and create a peer-pressure through the network that motivates boaters of all kinds to behave better around the whales - they know they are being watched and reported on. Including boaters in the Whale Sighting Network helps increase whale sighting reports, creates awareness and results in support from the boating community to help the orcas and behave better around them.

Noise

~Encourage use of bio-diesel and electric for all kinds of boats/vessels, as well as quieter engine technology.

~Address Navy Sonar - include continental shelf waters for protection from sonar use; encourage mitigation of potential injurious effects; support consideration of international accords to eliminate need for active sonar sweeps (partially included).

~Address seismic airguns, off-shore exploration along Pacific coast - upcoming tests in BC (included).

Climate Change

~Study and model effects of climate change and ocean warming on SRC, their prey & habitat, and research mitigation methods (included).

Oil Spills

~Support more effective oil spill prevention such as year around stationing of rescue tug at Neah Bay, tug escorts from entrance of Strait of Juan de Fuca, containment preparedness at loading docks, etc (included).

Reintroduction of Lolita to the Southern Resident Community

~Support reintroduction of the female L pod member called Lolita to her natal matriline. Her continued use of L subpod dialect calls indicates her retention of her natal habitat and cultural knowledge learned in her four to six years prior to capture. Wording should reflect that the example of Keiko, often used to claim that returning orcas to the wild doesn't work, overlooks the fact that Keiko was never taken to the vicinity where he was captured off the east coast of Iceland (he was allowed to swim off the south coast of Iceland, 200 miles from where he was captured) so the orcas he found, but never remained with, were probably unrelated to him. The key to any return to the ocean is to return the whale to its family, or it won't succeed. As we all know, Lolita's family is seen on a regular basis in the Pacific Northwest.

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