Tell the Pacific Fishery Management Council: Save orcas and salmon from overfishing!

Unchecked overfishing on the West Coast is starving endangered orcas by wiping out the Chinook salmon they rely on. And the Pacific Fisheries Management Council -- the agency that should be protecting the salmon -- is failing to stop it.

Will you take action to stand up for wild salmon and orcas?

Comments

To whom it may concern:

As someone who cares about the West Coast's endangered Southern Resident killer whale and salmon, please consider my comments in response to agenda item H.3 Situation Summary: Southern Resident Killer Whale (SRKW) Consultation.

While I am thankful the SRKW Ad Hoc workgroup has spent a lot of time to Draft a Range of Alternatives and Recommendations, I believe the Council can take even stronger action to adopt a proper alternative.  This can include a threshold, or floor, for low Chinook salmon abundance that automatically triggers a pre-identified response. That said, along with the alternatives for immediate action, the Council must commit to improving measures to monitor and manage salmon stocks for the benefit of Southern Residents. Current data collection and analysis fail to ensure that fishery impacts do not jeopardize Southern Resident killer whales.  To address this, I support four measures being adopted by the Council:

I.	SRKW Need Immediate Fishing Mitigation Measures to Increase Salmon prey

II.	The Highest Salmon Abundance Threshold Could Minimally Protect Southern Residents While the Workgroup Continues to Improve Its Impacts Analysis

III. Management Measures Must Be Triggered Automatically

IV.	The Council and NMFS Must Improve Monitoring and Management of Salmon Stocks to Benefit Southern Resident Killer Whales

Now only 74 Southern Resident killer whales remain in the wild. This is their lowest number in four decades. The Southern Resident killer whale recovery goal as defined by NOAA, is not being met and neither are the recovery goals of threatened Chinook prey. The health of Southern Resident killer whales is strongly tied to Chinook salmon abundance on the West Coast. Scientists have found a strong correlation between coastwide Chinook abundance and Southern Resident health indicators: as Chinook abundance declines, the Southern Residents health declines.  This is partly because orca babies are starving to death. There were no successful Southern Resident births from 2016 to 2018. The Council should analyze and consider benefits to Southern Residents from no ocean salmon harvest, and/or closing the fishery unless the pre-season estimate of Chinook considers abundance thresholds that ensure adequate prey availability. We support tribal treaty laws and recognize that these management measures will be subject to sovereign nation consultation and potentially modified later.

To ensure protections for Southern Resident killer whales, thresholds should trigger automatic management actions. Further limiting non-treaty Chinook quotas to allow more quota allocation in later months, and implementing non-treaty Area closures. The draft alternatives do not identify how the Council or NMFS would select the management measures. We strongly recommend that the Council choose alternatives with pre-set management measures. For example, the Council should consider an alternative in which when the salmon abundance reaches the threshold, NMFS prohibits ocean salmon fishing in the proposed Southern Resident killer whale critical habitat, and delays the opening of commercial and recreational ocean fisheries. This management measure should be tied to the threshold selected.

To implement a time and area closure in Southern Resident killer whale foraging hotspots, the Council and NMFS must require vessel monitoring systems on commercial ocean salmon fishing vessels and collect refined spatial data on ocean salmon recreational fisheries to better understand the overlap of ocean salmon fisheries and Southern Resident foraging areas.  We also urge the Council and NMFS to (1) collect stock-specific harvest information, (2) disclose incidental salmon mortality in other fisheries, and (3) analyze fishery operation transformations that potentially could recover salmon stocks and benefit Southern Resident killer whales.  First, we ask the Council to direct NMFS to develop and implement a genetic stock identification sampling program for ocean salmon fisheries to improve the scientific basis for Pacific salmon management and to advance Southern Resident killer whale conservation. Second, we ask the Council to recommend that NMFS document the data they use for the rate of incidental salmon mortality in this and other fisheries that is used in abundance models. As part of this improvement in transparency, NMFS should describe the geographic range of salmon catch assessed.

Finally, the Council and NMFS should analyze the impacts of moving non-treaty PFMC ocean salmon fisheries in the EEZ in both Alaska and the West Coast. This analysis would show whether: (1) the PFMC ocean salmon fisheries can collect more information, which could lead to salmon recovery (for example, by more closely tying the catch to separate salmon stocks), (2) there would be benefits to Southern Resident killer whales that justify such a change or whether concentrating fishing in foraging hotspots will impact behavior, (3) potential impacts to treaty fisheries could be assessed and minimized, and (4) understanding whale migratory patterns by requiring fishing boats to record if they see the whales. This includes encouraging fishing operations to use satellite data to try to see where the whales may be foraging and the voluntary avoidance of fishing nearby under a rolling hot spot plan.

Thank you for your consideration of my comments.

Sincerely, 
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{user_data~City}, {user_data~State} {user_data~Postcode}

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