Tell the NMFS to save orcas from extinction and stop overfishing and bycatch!

There are only 75 Southern resident killer whales remaining in the wild, and these critically endangered species are nearing extinction.

After the deaths of orca babies Cappuccino and Marina last year, along with the loss of several new calves, researchers have raised the alarm about the lack of salmon driving the Southern Resident orca to extinction. But the National Marine Fisheries Service -- the agency tasked with protecting the salmon -- is failing to stop it.

The fishery agencies must rein in overfishing and give orcas a fighting chance to survive. But the only way the agency will act is if it hears from you.

Comments

Dear National Marine Fisheries Service,
  
As someone who cares deeply about the West Coast endangered Southern Resident killer whale and salmon, please consider my comments.

While I am thankful the Pacific Fisheries Management Council and National Marine Fisheries Service have accepted public comments on these issues, the Fisheries Service must take even more decisive actions to protect Southern Resident Killer Whales (SRKW). This should include adopting the strongest measures it is considering as well as additional measures to protect salmon. The Fisheries Service 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.	Management Measures Must Be Triggered Automatically
III.	The Council and NMFS Must Improve Monitoring and Management of Salmon Stocks to Benefit Southern Resident Killer Whales
IV.	Salmon bycatch in the Pacific Whiting fishery must be held accountable.  Consideration of closing non-treaty salmon fisheries without proper genetic stock identification and oversight, must be considered in the PFMC and North Pacific Fishery Management Council fisheries off the coast of Alaska

Only 75 Southern Resident killer whales remain in the wild, their lowest number in four decades. The Southern Resident killer whale recovery goals, as defined by NOAA, are not being met, and neither are the recovery goals of threatened Chinook prey. The health of Southern Resident killer whales is closely 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. Additionally, the Council should analyze and consider benefits to Southern Residents from reduced ocean salmon harvest (beyond three miles from the coast) and/or closing the fishery unless the pre-season estimate of Chinook considers abundance thresholds that ensure adequate prey availability and proper oversight. We support tribal treaty laws and recognize that these management measures will be subject to sovereign nation consultation and potentially modified later.
To guarantee protections for Southern Resident killer whales, thresholds should trigger automatic management actions. It should consider further limiting non-treaty Chinook and other salmon quotas and implementing non-treaty area closures as needed. For example, the Council should consider that when the salmon abundance reaches the threshold, NMFS prohibits ocean salmon fishing in Southern Resident killer whale critical habitat and delays the opening of commercial and recreational ocean fisheries for non-tribal treaty 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 Fisheries Service must require vessel monitoring systems on commercial ocean salmon fishing vessels and collect refined spatial data on ocean salmon commercial and 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 properly 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 are used in abundance models. As part of this improvement in transparency, NMFS needs to describe the geographic range of salmon catch assessed.

Finally, the Council and NMFS should analyze the impacts of moving non-treaty PFMC ocean salmon fishery in the EEZ in both Alaska and the West Coast. This analysis would show whether: (1) the PFMC ocean salmon fishery 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 migratory whale patterns by requiring fishing boats to record if they see the whales and where and/or using satellite data to try to see where they may be foraging and close nearby fisheries under a rolling hot spot plan.

Please do your part and stop pushing Southern resident orcas toward extinction. 
  
Sincerely,

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

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