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SIGN NOW: Demand that NMFS reins in greedy overfishing corporations that are depleting Chinook salmon and pushing endangered orcas to starvation! >>

Why Your Actions Matter

Your Actions Back Us Up in Court

Your comments give us standing in key lawsuits, including ones that have scored big wins for people and the planet.

Every Comment Must Be Read

Law requires federal agencies to pause their actions and consider your comments.

Elected Officials Listen

Elected officials need your vote, so they take your messages seriously.

Comments

Dear NOAA/NMFS,

As someone who cares about the West Coast endangered Southern Resident killer whale and salmon, please consider my comments.

The Pacific Fisheries Management Council and National Marine Fisheries Service must take even more decisive action to protect the Southern Resident Killer Whales (SRKW). Only 73 Southern Resident killer whales remain in the wild, near 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 no 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. 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 to allow more quota allocation in later months and implementing non-treaty area closures. 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 Council and NMFS 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.

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 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 the rolling hot spot plan.

Please do your part and stop pushing Southern Resident orcas toward extinction.

Sincerely,

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