Support Coastal Critical Habitat for Orcas

The National Marine Fisheries Service just proposed expanding Southern Resident killer whale critical habitat to include over 15,500 square miles of coastal waters! These highly intelligent, critically endangered, and culturally revered mammals declined in population to just 73 after this summer’s loss of three individuals. Noise pollution, combined with a scarcity of Chinook salmon and exposure to toxic contaminants, is pushing these orcas into extinction. Protecting critical habitat will push the federal government to address these threats.

These West Coast orcas depend on salmon availability in the ocean, which is why the federal government has proposed critical habitat stretching from Point Sur, California, through the northern boundary of Washington State.

Please submit your support for this designation to the National Marine Fisheries Service by December 18. Tell the Fisheries Service to finalize the critical habitat expansion as soon as possible.

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Subject:

NOAA-NMFS-2014-0041

Dear NOAA National Marine Fisheries Service,

Thank you for proposing to expand critical habitat for the Southern Resident killer whales (SRKW) to include marine waters from Monterey Bay in California through Cape Flattery in Washington State. I fully support the proposed critical habitat expansion and urge the government to take expedient action to finalize the proposed rule.

Protecting this full range as critical habitat reflects new and best available science as new sightings and data show that SRKW regularly forage in the coastal waters off Washington, Oregon, and California and is essential to help get the southern resident orcas off the path to extinction and on the way to recovery.

The final rule designating critical habitat identified three essential habitat features essential to the conservation of the SRKW: (1) Water quality to support SRKW growth and development; (2) prey species of sufficient quantity, quality, and availability to support individual growth, reproduction, and development, as well as overall population growth; and (3) passage conditions to allow for migration, resting, and foraging.

However, the proposed rule exempts the Navy's Quinault Range Site off the coast of Washington from being designated as critical habitat due to national security. The Quinault Range Site includes part of two “high-use foraging” areas, as recognized by NMFS in the Biological Report, and completely bisects the proposed expanded critical habitat area.  From the tagging data, about half the time that K and L pods spend in coastal habitat is in Area 1 (Washington and Northern Oregon inshore habitat). This exemption could impact their foraging ability in an area and season when nutritional stress is a significant concern and impact their ability to migrate up and down the coast. Therefore the exempted area is in conflict with the third essential habitat feature: “passage conditions to allow for migration, resting, and foraging.”

The proposed rule should include a narrow area sufficient in width between the shoreline and the eastern border of the Quinault Range Site to ensure orca migration along the coast and for foraging for limited prey.

The science also shows that sound from vessels and other sources undermines orcas’ ability to echolocate to forage for salmon as well as to communicate and navigate. The Washington Governor’s Orca Recovery Task Force and the ESA Recovery Plan have noted that noise and disturbance are key threats hindering orca recovery and have recommended decreasing, not increasing, military noise.  To sufficiently protect SRKW, NMFS must include sound as a fourth essential feature. Urge them to ensure that it is at least retained as an explicit factor in the prey and passage essential features.

I am grateful that NMFS has engaged and consulted with Tribes to ensure that this rule does not impact Tribal Treaty rights and usual and accustomed fishing areas.

Again, fully support the proposed critical habitat expansion and urge the government to take expedient action to finalize the proposed rule.

Regards, Your Name

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