Just back from the meeting in which NOAA invited the public to comment on the proposed rules for vessel-orca interactions. Before a captive audience of Pacific salmon and rockfish, the 2.5 hours of public comment was dominated by the commercial whale watch, recreational and commercial fishing, and kayaking industries. It seems like a repeat of the Anacortes meeting, described in this Anacortes Now article, except that tonight NOAA’s facilitator kept nearly everyone abiding by the ground rules.
Overall, there were strong objections to the entire suite of alternatives — from the 200 yard viewing distance to the no-go zone. People for Puget Sound went on record saying that a no-go zone was a step too far. And Ken Balcomb voted for no action.
I was left with a profound disappointment that so many felt so unfairly burdened by the proposed rules. If the people who most intimately and consistently share the southern resident’s habitat aren’t willing to make a sacrifice to preserve the basis of their livelihoods, how can we expect the public to act selflessly for our regional icons: the orca and the salmon?
From the captains and operators of the whale watch fleet I heard dire forecasts of impending economic doom, though they would be unlimited by NOAA in 100’s of square kilometers of critical habitat, including areas that might conceivably have been included in a no-go zone: Hein and Middle banks and the rest of the west side of San Juan Island. From the recreational and commercial fishers I heard that the west side of San Juan Island is sacred salmon fishing ground, though NOAA did not ban them from Eagle Point, Salmon Bank, or Turn Point. And from the kayakers I heard dismay, when I can imagine trips around Henry Island or through Cattle Pass that offer adventure and orca-viewing on par with what the central west side offers. While some speakers had delved deeply into the text of the rules and the scientific literature, many made specious assertions about the underlying science and countered with unconvincing anecdotes and generic concerns about correlation not implying causation.
I failed to finish my comments in the allotted 2 minutes. Those that I fit in are below within the notes I took during the comment session. But my closing thought was this: What could we humans accomplish on the tough problems of salmon and pollutants if we first succeeded in sacrificing together to reduce this most-tractable extinction risk — vessel interactions. On a night when I expected suggestions for how to do more to help the whales, I heard only selfish whining.
For those unfamiliar with the extant and proposed regulations, here is a wiki of rules guiding vessel interactions with killer whales.
Live blog from Seattle Aquarium
These are rough personal notes (not quotes!) taken on the fly during the meeting. NOAA has the complete record.
19:15 Overview by Lynne Barre
19:30 Public comment begins
19:31 CCA opposes impacts on recreational fishers
19:34 Bob Franks, commercial fisher from Gig Harbor: In 1989, there were 72000 boat hours/year and SRKWs were fine. Now we’re at 1200 boat hours/year and SRKWs are in decline. Where are the data that implicate commercial fishing vessels?
19:37 Frank, Fidalgo Chapter Puget Sound Anglers: 1/2 mi standoff will have dire consequences for recreational fishers.
19:39: VP of Puget Sound Anglers: While fishing on west side I’ve seen orcas foraging all around us without concern. Sport fishers are the eyes and ears of the salt water. They carry on as if we’re not there. Recreational fishing has no adverse impact on these wonderful marine mammals.
19:42: Ken Balcomb: We noted KWs swam down sound past all fishing vessels twice per year and came down for Sea Fair (4000 boats). In all these years there has been no evidence of a boat hitting a killer whale. “My vote is that we take no action, alternative one. I think we should collectively shelve it somewhere between Alice in Wonderland and Don Quixote.”
19:45: Mark Anderson: There is a scientific consensus that the orcas are starving. The three legged stool has only two legs now: lack of fish and vessel interactions. UW study showed mortality goes up with boat concentration. Economic impact is likely bigger than in the rule’s analysis.
19:48: Bob Keiko, Purse Seine industry rep, Fraser sockeye/pink fishery rep: This no-go zone is a prime fishing area. Fraser Pink and sockeye migrate through the Straits and their first land impact is the west side of San Juan Island. The commercial fishery is limited to ~5 days/year. It’s wrong to assume that the fleet can just go somewhere else to fish.
19:51: Larry Carpenter, owns 2 boat dealerships, spent 1000s of days on west side San Juan Island. Chinook returns are adequate for fishers and killer whales due to 30% reduction of Canadian catch on outer Vancouver Island. Foraging and pollution conditions are improving. We in the recreational fishery are a huge part of the solution.
19:53: Roland Skogley, citizen:
19:56: Cedric Towers, Vancouver Whale Watch operating 7mo/yr; Pacific Whale Watch Association wants to stick with 100yd global standard. Educational value from professional naturalists is lost at 150-250 yards. We’ve been experimenting all summer. I’m going to be out of business. Customers say they aren’t interested in watching from 200 or 250 yards.
19:59: Speaker for the sea kayak fleet: The no-go zone eliminates nearly all kayakers from west side San Juan Island. Kayaks are the only silent vessels and our viewing is comparatively brief.
20:00 Rick Thompson, Canadian whale watcher for 10 yrs, 30 yrs commercial fisherman: I don’t see many changes and they seem well-fed this year by the spring returns of this year and last. My company has 25 people and our oral survey suggests 80% of our customers would forego whale watching at >100yds.
20:03: Ann individual kayaker
20:05: Kayaker for 17years west side San Juan Island: Ban of kayaking isn’t fair
20:11 Rain, Seattle resident
20:17 Peter, whale watch operator: This is onerous. We educate 10’s of 1000s of people per year.
20:18 Troy, 30 years fished west coast, fought rock cod fishery closures in CA: you’ve managed to pull groups together that don’t like each other.
20:21 People for Puget Sound: restoration of salmon run, reduction of toxins, countering of sonar-like noises. We agree that vessels are a risk. We support 200yd, but think no-go zone is too far. Where is the orca in the orca recovery plan?
20:23 Anna Hall biologist and Prince of Whales captain for 15 years: I’m in full support of species protection as well as the public education that happens on the whale watching boats. Consider the PWWA proposal.
20:26 Eric Shore, owns Anacortes Kayak Tours and has 20yrs on west side of SJI, about 1000 days with whales.
20:27 Alan McGilvry: “The science is anecdotal, it’s not reproducible, and doesn’t follow scientficic method. The whale watch industry is part of the solution and we’re here for you.”
20:30: Another whale watch Captain for 25yrs in Floriday, Hawaii, NW 129 people/day
20:32: Dan Kukat, owner of Springtime Charters for 15yrs, charter fishing for 20years. Canada commends U.S. fishery conservation: Unless there’s food on the table, none of us can live. Basic economics and passenger testimony say these rules will raise impacts on killer whales by diminishing public education and awareness of the real risks.
20:35 Ken, Seattle Resident: Gas works park contamination sample.
20:36: 20yrs boating interactions mostly with J pod: J pod increase since 1970s.
20:38: Works for Clipper Navigation and long career on water: Please don’t restrict others from seeing them up close.
20:39: Darrel Bryan, CEO Victoria Clipper: How were oral comments in Anacortes not fully recorded? Why was procedure changed during the meeting? Did NOAA leave the rule open to legal challenge by altering the rule-making process?
20:42: 47 yr WA resident, sport fisher on west side every summer: What scientific proof do you have that killer whales are not getting enough food on this route. Orcas are operating in no-go zone because that’s where the fish are. Pinks come in on in-coming tide and are often scattered by killer whales. What impediment do few sports fishermen pose if orcas can operate during commercial openings. In 1962 there were no salt-water fishing licenses! We have less fish than in 1962 and all we have is more and more restrictions.
20:45 James Dale, 5 star whale watching: I’ve supported recovery planning process for 15 yrs, but am concerned we’re going to get distracted by these regulations from truly meaningful actions.
20:47 Dan, Save our wild salmon
20:51 Shane Aagergard, owns Island Adventures
20:54 Angler expert: economic impacts on recreational fishers may be underestimated
10:56 West side resident: supports 200yd, why is acoustic
10:58 Fred Felleman, west side home-owner and orca biologist: Now there are more boats than whales. Clearly marine education on the water is a contributor. Congratulations to NOAA on attracting substantially more public comment than in recent Navy EIS comment meetings. Go slow, not no go.
…
21:08 Peter Henke: Enforcement is lacking and enforcement boats have been wreckless.
…
21:21 WW operator: I’m torn because sometimes it is a zoo out there, but I see a lot of good educational value.
21:23 Annette sea kayaker
21:25 Commercial non-treaty fisherman supports access to no-go zone
21:25 Kowichan Bay operator:
21:27: Peter, Westcott Bay resident: supports all aspects of rule; easy to document inappropriate
21:31; Shane Elwin: Illegal to pursue so supports limits on commercial whale watching. Relax rules re kayaking.
21:34: Sarah sea kayak guide:
21:36 Thomas Star, Water Trail: We need better enforcement.
21:38: Derrick Mitchell, kayaker
About 5 others, including me.
~21:46 Scott Veirs, WA resident for 15 yr, PhD oceanography, 5 seasons running Beam Reach, co-author of “KWs Speak up”: Will provide written comments, but want to speak as father of 2 young children who love the orcas. Who is speaking conservatively for the whales? Whale watch and fishing interests are clearly much better organized than orca-advocacy community! Why not support a refuge for SRKWs? Though Beam Reach may be impacted as a business, I support 200 yard limit and no-go zone. In fact, I ask why the no-go zone does not include the Eagle Point to Salmon Bank, a region which many consider a foraging hot spot along the west side. BR has not joined the PWWA because the Association does not strike an acceptable balance between (what appears tonight like) economic greed and ecological value, and does not take a precautionary approach.
21:53: Finished with public comment.
Here is the 9/30/09 Times article with interesting comments: Feds may expand restrictions to keep humans from whales
Thanks for posting the summary of last nights hearing. Correction: People For Puget Sound stated that the proposed “no-go Zone” is not ready for prime time and needs further consideration.
This is Rein, Seattle resident, and here is my written testimony for all to read:
I have been a regular visitor to San Juan Island for many years and have had the extreme pleasure of viewing these magnificant creatures. Two particular instances include;
• an inverted tailflop display by one orca off Lime Kilm State Park; and
• the movement of a dozen orcas off Andrews Bay in the late evening hours, free of any vessel presence
More recently I spent this past weekend (Sept 26-27, 2009) on San Juan Island.
From the west side of the island were we stayed, I witnessed the immense popularity of recreational salmon fiishing along Haro Straits. Dozens of recreational fishing vessels were vying to catch salmon along a narrow strip of water. A few commerical whale watching outfitters were also present, and when you see those vessels you can be assured there are orcas nearby.
Sure enough, a moment later, I spotted several orcas making their usual (emphasis added) way north, most likely following their scant number of prey. To my naked eye, and untrained eye for that matter, they appeared dangerously close- less than the 100 yard regulation that is now in place.
With the large presence of fishing boats and whale watching boats, how could anyone expect the orcas to have a safe passage through this mine field of vessels. I was disgusted.
But wait there is more! What horrified me the most, I then saw a commercial fishing vessel speeding directly against the coarse the orcas and in their path. Did they bother to go outside the path of orcas, salmon, and fisherman as the other commerical fishing vessel was concurrently doing? Apparently not!
The next day the vessel onslaught continued with recreational fishing boats, commercial fishing boats, kayakers, and in addition, a cargo vessel. The APL Germany, chugging along close to the shoreline, way too close and out of the shipping lane! The vessel’s coarse was again in the same pathway of the orcas following the salmon!
Due to these two recent instances, I do not agree with the proposed exemptions for commercial fishing boats, government vessels, cargo ships, research vessels and vessels owend by shoreline property owners, as all vessels have an negative impact on orca behavior, espcially on their feeding habits. I have included with my testimony research literatue pertaining to vessel impacts to orcas.
Although vessel operational changes are part of the solution, NOAA continues to delay on more critical actions that are needed to protect and recovery Puget Sound’s resident endangered orca whales, such as: restoration of salmon runs through removal of dams; restoration of habitat, land use restrictions, water quality improvements and changes in harvest and hatchery practices; reduction of toxic pollution that impacts the food web; and reduction of noise impacts from sonar and other activities.
Until these fundamental problems are addressed by NOAA/NMFS, the orca population will cease to exist in the decades ahead.
With regard to the vessel proposal, I support the distance (200 yards) and no intentional parking in the path of traveling whale and the concept of a “no-go zone” on the west side of San Juan Island akin to the Robson Bight protected area in British Columbia.
Enforcement is a key pragmatic issue that should be addressed regarding both existing and proposed regulations. Without a much-improved strategy for education and enforcement, it makes no sense to increase restrictions as it would be guarentted to fail. One of the major vessel issues is inappropriate and harassing behavior by recreational boaters who are apparently unaware of the existing limits.
I can only hope that your proposal is heavily supported by follow through and enforcement.
Scott, thank you for voicing this opinion which is shared by many, myself included. Everyone seems to be focusing exclusively on the dire economic impact that codifying guidelines (developed based on available and emerging science) will allegedly have. I’ve seen forecasted losses from $37k to $7.5m-I wonder what those “forecasted losses” will be when we have no whales in the water at all.
It is easy to point fingers and say “fix the salmon problem.” What has not proven easy is how to even begin to address that multi faceted issue much less obtain funding while reducing our regional footprint in the interim. I am amazed, as you are —that, and I quote you- as it is worth re-reading…
If the people who most intimately and consistently share the southern resident’s habitat aren’t willing to make a sacrifice to preserve the basis of their livelihoods, how can we expect the public to act selflessly for our regional icons: the orca and the salmon?
Thanks Scott, for taking notes and posting this comment page.
Starting from the value that we want the best possible environment for the Southern Residents, including the most plentiful Chinook runs, the cleanest, healthiest water, and the least noise and vessel disturbance, there’s a need to balance between avoiding all disturbance and the benefits of instilling an appreciation in whale-watchers of the astounding natural history of Orcinus orca, and the need for all of us to restore habitat by dismantling some dams, protecting shorelines, opening tidelands and estuaries, maintaining buffers around streams and wetlands, reducing harvest, by-catch, toxic pollution, stormwater run-off and careless logging, plus restoring streams and rivers, strengthening the ESA, NEPA, Clean Water and Air laws, improving global environmental cooperation and effectively addressing global warming, and more issues than I can remember at any one time. Bringing up these issues leads to even more sticky problems like birth control and consumption restraint. In short we need to wake people up to how we have mis-managed our natural heritage, how we’ve denied the relationship between ourselves and the natual world, considered ecosystems as warehouses for commodities that belong to us, and believed our job is to exploit, manipulate, disturb, simplify or manufacture nature to satisfy our short-term desires.
Right, this is an ambitious message to try to broadcast, even on a whale watch boat where passengers are often transfixed on the wonders of those magnificent, powerful and graceful beings as they glide so effortlessly, play so enthusiastically and bond so lovingly in traditional extended families. But speaking as a naturalist myself, it sometimes happens, but the perspective of how the experience is interpreted sometimes gets lost when people feel backed into a corner with their self-interest and deeply held opinions.
So on one hand I’m sorry to see such distance between the watchers and the whales that people can no longer can feel the orcas’ presence and so may not open their hearts and minds to the behavioral changes that could help provide the whales the best environment possible. At the same time I’m aware that the narration can sometimes sound more like a Disney World trip than a visit to the world of the orca, which makes that whole argument moot. Overall, I’m not sure of what the right distance is, especially since that depends largely on the skills, knowledge and message of the naturalists, but 200 yards seems worth a try, and the distance itself teaches respect.
This only begins to address the many complexities and implications of these proposed regs, so rather than try to deal with the effects on kayakers, fishers of all sorts, boaters, the problem of adequately funding enforcement, the greater economy, etc. etc., I’ll refer to the comments by People for Puget Sound, which pretty well cover the important issues in a thoughtful, balanced way.
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OK, more dialog. This is a good thing. I think I have a unique perspective on this entire situation, and while I have share some of my thoughts on this hot-topic, I will post them here for you to read as well.
What makes my perspective unique? I have been a shore-based whale watcher. I have been a shore based docent of sorts, teaching about orca life histories. I have worked as a marine naturalist (and am still working) for 6+ years. I have also worked as a volunteer for Soundwatch for 13 years. I have volunteered on several different research vessels. So I have seen this issues from many sides of the coin so to speak.
I applaud all those who worked so hard to try and figure out a recovery plan for the Southern Resident Orca Whales. Please don’t take any of my comments as a slight to your hard work and efforts to craft a set of regulations to effect positive change in the protection of these Endangered animals. But I do have some concerns about the methodology of the usage of some older data. Mainly the energetic studies done from 2001-2005 in the presence of whale watch vessels. A bit of background for my concern—during this time period, the accepted practice was to place your vessel ahead of whales, and if they were approaching your vessel, then you shut down and allowed them to pass. So you end up with many vessels parked in the path, and I can clearly see how this would change the breathing rates and speed of whales in the presence of vessels. However, the last 2 years has had a new standards of practice in place in which vessels were required to move their vessels out of the path of whales. Has a newer study been done to measure respiratory rates and speed since the new guideline was adopted?
Now onto the meat (my apologies to the vegetarians and vegans out there) of the issues. First off is the 200 yard guideline. As a marine naturalist, I have NO PROBLEM WHATSOEVER with this guideline. Anyone who says they can’t operate a viable wildlife trip under this guideline is fooling themselves. I have had customers oohing and ahhing at seeing whales at 200+ yards for years. If we educate the public that this is a standard practice, they will accept it. It’s not that big of a deal.
More onerous is the mandatory half-mile “no go zone”. For years, the main “support vessel” for lack of a better term for the whales has been Soundwatch. Day-in and day-out, Soundwatch has been on the water more than any other vessel, trying to protect the whales through education. It is my personal belief (and should not reflect on anyone else) that instead of a half-mile buffer, we should instead try and focus on enforcing the existing guidelines we have now. This can be achieved through a three prong effort—Education from Soundwatch; Consistent Enforcement from NOAA, WDFW, San Juan Sheriff; and greater accountability of the whale watch industry. Soundwatch is already a regular presence, but it would be great if they could have more consistent funding so they can continue with the good work they do. As for enforcement, they need to coordinate so that we can have someone out on the water (or available for immediate dispatch if needed) on a regular basis. This can be further funded through ticketing vessels who are flaunting the rules. To combat the boater who says “Oh, I was unaware of the rules (and ignorance is no excuse), have the State of Washington include the Be Whale Wise Guidelines & state law handout with every boater registration sticker. Lastly, the commercial whale watch boats need to be held accountable for their actions, and the easiest way to do this is through a permitting system. Each company is issued a certain number of permits to operate in areas where orcas can be found. Those who operate their vessels within the guidelines will continue to have the privilege of a permit. Those who regularly rack up incidents will have their permits revoked and can no longer operate in the area. Much like a drivers license–get too many points and you lose your license. This way you are punishing an operator who choses to ignore the guidelines while allowing those companies who operate properly to continue to educate their passengers about this beautiful area and the amazing wildlife.
An additional area that needs to be addressed (and I apologize for being long-winded, but this is an important issue to me and has been building up for awhile now)–the sport fishermen in this area need to get involved in the process. I have talked to several long-time island fishermen who are angry about this. They feel they aren’t bothering anyone, they’ve been fishing for decades, etc. I don’t know what the whales think of you guys, but I know it is important to make yourself heard. Be a part of the process. Help craft some guidelines that you can live with and will help the orcas live too.
For too long, too many people have politicized the whales. We need to come together, whether you are a tour operator, a sport fisherman, an anti-operator group, a private citizen who loves the whales, a researceher–whatever group you fall in—put aside the differences, sit down together and come up with a compromise we can all agree to as a starting point. Have a plan that we can revisit and change what is not working, keep what seems to work.
Thank you for allowing me to vent, and sorry for taking up so much space.
Thanks for sharing in such detail what happened at the Seattle meeting. I just wanted to respond to a couple of your comments.
I don’t think it’s 100% accurate to say that those who spend so much time with the SRKWs aren’t willing to make sacrifices for their long-term survival. I think a more accurate statement would be that people aren’t willing to make sacrifices unless those sacrifices are grounded on solid scientific fact. Many of statements in the NOAA proposal make strong claims that are not backed by the studies they cite. If you talk directly to the many researchers who performed the studies, they will give you a much more uncertain perspective of their findings. I understand the value of a precautionary approach, but that’s not how the proposed regulations come across. I fail to see how they proposed regulations will do anything to directly improve survival of the SRKWs relative to what the science is telling us.
They kayakers are undoubtedly getting the worst deal out of this as there are NO studies looking at the effect of kayaks on local killer whales. The citation in the proposal refers to kayak impacts on terrestrial Steller sea lion haul-outs in Alaska. While the idea of day trips around Henry Island or near Cattle Pass (aside from the dangerous currents there) sound nice, the reality is there are not many launch points available to commercial kayak companies outside of San Juan County Park, and both the kayak industry and the county park system will suffer directly from the no-go zone, and the total indirect economic impact will be even bigger than that.
Anyway, I won’t get too long-winded here, but I think its too bad that many comments came across to you as selfish whining. I have spent a lot of time talking to many different people with all sorts of varying views on this, and while by no means do I agree with everyone’s opinions, it has been very clear to me that everyone involved cares very deeply about these whales.
I think it’s important to recognize that the commercial fishermen have, in fact, sacrificed over the years. Maybe more is required – I’m not opining on that. But both the number of fish caught and the percentage of salmon available for harvest are much, much lower than they were 30 years ago, with obvious impacts to fishermen and their communities. Fishermen are not taking near the number of fish they used to (which was obviously too many, of course). Sad to say, the dams’ share of the “harvest” has only declined a small fraction.
Thank you all for your comments, I realize it’s a difficult subject that is fueled by much emotion and concern by all… I am also thankful for the coverage that Scott has provided on the meeting and the opportunity for discussion.
I would like to leave the science aside for the moment, as one from the general public, I am simply unable to judge this especially since scientists are not all in agreement, it leads many of us in circles so I will address this from a different POV; continuity of enforcement.
If recovery efforts are to be taken seriously (addressing the vessels for the moment), then certain measures must be covered such as; strong enforcement present on the water and in the ww fleet itself. Lack of presence (and continuity of) means the issue is not worthy of protection, and violations will continue no matter what the new guideline says. I feel the newly proposed guidelines are unfair, because not all boats are included and therefor should be (with the exception of large shipping lane traffic). While vessels will be the argument for sometime around the idea of disturbance, we should (at the same time) further the efforts to encourage other changes, consume differently and think about where their garbage is ending up (inside the salmon and ocean life consumed by orcas, wild animals and humans). This is a very complex problem and it’s going to take more then NOAA’s efforts to fix this…
I would say we’re dealing with a “clash of the titans” here while egos of the human species battle it out, we’re going to miss the opportunity while only focusing and spinning in circles on this one part of the issue. It’s got to be addressed further then this… and it’s going to take a massive shift to be successful, this is not just about orcas, this is about the planet. If we could, we’d ask the whales but we can’t so I suggest asking the children instead (free of ego and selfishness), after all it’s the world we’re leaving in their hands….
(I document orcas from boats and shoreline and am used to working with far distances and heavy photographic equipment so I can adapt with no problem to this, but my concern is around the proposed guidelines causing much stress in a different way while making little impact or change (especially if enforcement is not stepped up), therefor I feel enforcement is our focus here along with a modified guideline of no boat start up or movement within 200 yards, being 100 yard distance from the animals – shut down).
Please note that I am a member of the public voicing a concern, I am not a scientist. I am trying to come at this from a non biased point of view. Thank you and I look forward to seeing how this progresses.
If enforcement is a problem that needs to be addressed due to funding and/or manpower, why not approach it in another way?
Whether or not these proposed rules pass there needs to be a stronger enforcement presence on the water as much as possible. Put observers on a commercial whale watch boat randomly. Even if the fleet of whale watch boats knows what’s going on, just the fact that there is enforcement watching is enough to cut back on violations. Private boaters will soon learn they too are being watched by someone with a camera and a clipboard and I guarantee this segment of the boating public will do a better job. The observers can simply be trained citizens that know what and how to report an infraction. Observers are on fish boats in the Bering Sea to regulate the catch limits on US and foreign vessels. It seems to work well there as it would here.
In addition, I feel that if the commercial fleet had some sort of certification such as in the Florida Keys with a program called Dolphin Smart, more credibility and “trust” could be granted permitting a commercial vessel to approach the 100 meter limit.
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More blogs and articles:
People for Puget Sound press release —
http://www.pugetsound.org/pressroom/press-releases/092309orca
Candace Calloway Whiting —
http://blog.seattlepi.com/candacewhiting/archives/178908.asp
http://blog.seattlepi.com/candacewhiting/archives/181297.asp
Carole May —
http://www.examiner.com/x-15967-Puget-Sound-Marine-Life-Examiner~y2009m10d7-NOAA–Thoughts-on-the-new-regulations-for-southern-resident-orcas
http://www.examiner.com/x-15967-Puget-Sound-Marine-Life-Examiner~y2009m10d4-NOAAs-proposal-on-vessel-traffic–the-southern-resident-orcas
http://www.examiner.com/x-15967-Puget-Sound-Marine-Life-Examiner~y2009m10d1-New-Proposed-NOAA-regulations–A-Counter-proposal-from-the-Pacific-Whale-Watch-Association
Thanks for all the links Scott, I hope to find more interesting information on the topic here in the future and have it linked in a variety of locations.