Category Archives: policy

Canadian Navy responds to scientists’ stop-sonar letter

This morning we received the first official response to the letter from 20 marine scientists regarding silencing sonar in the Salish Sea.  The response (below) came from the head of the Canadian Navy — Peter MacKay, the Minister of National Defence in Canada — 60 days after receipt of the scientists’ letter.  It implies that discussions have been initiated between the Department of National Defence (DND), the Department of Fisheries and Oceans (DFO), and Environment Canada.  This seems to set the stage for re-evaluating how (or even whether) the Canadian Navy trains in the habitat of marine species of concern.

Dear Mr. Veirs:

Thank you for your email of March 1, 2012,
concerning military sonar operations in
the Salish Sea. 

I understand your concerns about the conduct of
military operations and training exercises and their
effect on critical habitat and the Southern Resident
Killer Whale population. To that end, subject matter
experts from the Department of National Defence (DND)
are working in consultation with staff at Fisheries
and Oceans Canada and Environment Canada. The goal is
to ensure that the best possible practices are in
place so that our activities are conducted in a
responsible manner with relation to the Fisheries Act
and the Species at Risk Act.  

Defending Canadians is a top priority for the Government
of Canada, and the Royal Canadian Navy (RCN) needs to
conduct regular exercises in our national maritime
approaches. These activities ensure RCN overall readiness
and familiarity with its primary area of operation. Being
conscious of our responsibilities to Canadians, the
environment, and its inhabitants, DND is dedicated to
continuously improving operational policies and procedures
to responsibly manage the impact of military activities.
This management will be based on the best scientific
information available at the time. 

I trust this is of assistance, and thank you for your
interest in the recovery and preservation of the Southern
Resident Killer Whales. Your recognition of the importance
of the national security role of the RCN is appreciated.

Sincerely,

Peter MacKay
Minister of National Defence

Canadian recovery plans need public comment

Thanks to Cathy Bacon for forwarding this notice regarding Canadian “action plans” for recovering the northern and southern resident killer whale populations. It will be interesting to see to what extent managing salmon (farmed or wild) for killer whales is mentioned in the plans… Discuss here and comment officially when you can!

> From: “XPAC Species at Risk”
> Date: January 18, 2012 11:35:42 AM PST
> Subject: Resident Killer Whale Action Planning process Consultations
>
> Microsoft Word PictureFisheries and Oceans Canada Pêches et Océans Canada
>
> January 18, 2012
>
> Picture (Metafile)
>
> To: Stakeholders, Interested Individuals, and Organizations:
>
> Re: Northern and Southern Resident Killer Whale Action Planning process Consultations
>
> Fisheries and Oceans Canada (DFO) is pleased to invite you to participate in consultations on the development of the Northern and Southern Resident Killer Whale Action Plan. We are interested in your feedback as we develop and prioritize actions in support of recovery of Resident Killer Whale populations in Canadian Pacific waters.
>
> The Minister of Fisheries and Oceans Canada is required to develop a recovery strategy and action plan for all threatened or endangered aquatic species listed under the Species at Risk Act (SARA), and appreciates your input. Northern and Southern Resident Killer Whales are listed as Threatened and Endangered respectively, and a recovery strategy for these populations is posted on the SARA National Registry: http://www.sararegistry.gc.ca/species/speciesDetails_e.cfm?sid=699
>
> If you would like to know more about the Northern and Southern Resident Killer Whale populations and how their recovery may affect you, or if you would like to provide comments on the draft actions supporting recovery of these populations, we will be conducting meetings during the month of February (open house from 6:00 pm to 7:00 pm; public meeting from 7:00 pm to 9:00 pm).
>
> February 2, 2012 Victoria, BC The Maritime Museum of BC
> February 9, 2012 Vancouver, BC Vancouver Maritime Museum
> February 23, 2012 Port Hardy, BC Quarterdeck Inn Marina Resort
>
> Please see http://www.pac.dfo-mpo.gc.ca/consultation/sara-lep/index-eng.htm for further information, or contact us directly at the numbers below.
>
> Sincerely,
>
> Sheila Thornton Paul Cottrell
> SARA Recovery Planner Marine Mammal Coordinator
> Fisheries and Oceans Canada Fisheries and Oceans Canada
> 200-401 Burrard Street 200-401 Burrard Street
> Vancouver, BC V6C 3S4 Vancouver, BC V6C 3S4
> Tel: 604-666-2043 Tel: 604-666-9965
> Fax: 604-666-3341 Fax: 604-666-3341

Klamath River dam removal proposed

Things are really looking up for the salmon-eating killer whales of the west coast.  For the third time this fall, progress in removing dams on west coast salmon rivers has been made.  First there was press regarding the beginning of the removal of the Elwha dams.  Then news came of preparations for dam removals on the White Salmon (including this Yakima Herald story about trucking fall chinook above the dams).

Now coverage is emerging about the draft EIS/EIR regarding removal of 4 hydroelectric dams on the Kalamath River in California.  The document was made available on September 21 and is open for public comment for 60 days (until November 21).  Copco No. 1 (pictured in the AP photo below) is one of the dams that may be demolished.

Recent press, including a 9/27 piece in India Country Today Media Network and a 9/22 story in SFGate, contain potentially good news for endangered southern resident killer whales which spend some of their winter months hunting in along the west coast in the migratory path of adult Kalamath salmon.  If things don’t get bogged down at the Federal level, the proposed plan may be approved by the Secretary of the Interior as soon as March, 2012.

The India Country states:

Over the past century, the number of salmon in the run has dwindled from millions of fish to less than 100,000 in most years.

And when the dams are gone, fisheries are expected to double in size.

Notable quotes from SF Gate:

Dismantling the four hydroelectric dams on the Klamath River would open up 420 miles of habitat for migrating salmon…

The long-awaited environmental report on what would be the biggest dam-removal project in California history predicted an 81.4 percent increase in the number of chinook salmon and similar increases for steelhead trout and coho salmon.

The dams – Iron Gate, Copco 1, Copco 2 and J.C. Boyle – have blocked salmon migration along the California-Oregon border since the first one was built in 1909 and have been blamed for much of the historic decline of chinook and coho salmon and steelhead trout in the Klamath.

The ultimate goal is to restore what has historically been the third-largest source of salmon in the lower 48 states, behind the Columbia and Sacramento rivers.

 

 

 

Ruckelshaus suggests whale watchers be more precautious

Today Tacoma’s News Tribune offers a story about the imminent issuing of new rules for watching southern resident killer whales.  This story confirms Donna Darm’s recent mention of the regulations being currently under review at OMB.  It remains to be seen whether the rules will be issued in time for the whale watching industry and killer whale researchers to plan accordingly for the upcoming season.

While the story isn’t quite accurate about the state of bioacoustic science, it does contain a fascinating juxtaposition of quotes — from former EPA administrator and Puget Sound Partnership Leadership Council Chair Bill Ruckelshaus, and former President of the Pacific Whale Watch Association Shane Aggergaard.  (Why wasn’t current President Bill Wright quoted?)  This exchange of perspectives reminded me that someone needs to create a synopsis and analysis of the diverse public comments on the proposed vessel regulations, particularly those (30 Mb of) comments from the whale watch industry.

Underwater noise pollution affects calls but not clicks (yet)

The article states that “Research shows engine noise can interfere with the whales’ ability to find food.”  That’s a little unclear.  What has been shown for southern residents (Holt, et al., 2009) is that underwater noise from nearby boats makes killer whales call louder.  If those calls are important for foraging, then the boat noise could affect the whales’ ability to find food.  The greater potential impact of vessel noise on their ability to forage is masking of the echolocation clicks they use to target salmon.  That is a focus of on-going observational and modeling efforts.

Ruckelshaus pwns Aggergaard

My favorite quote is from Bill because it suggests that the whale watching industry should take a broader, longer view of conservation science and policies:

Anytime you have an endangered species you always have somebody who is adversely impacted by the efforts to save the species, and they are very skeptical about the science that shows what they’re doing is causing any harm. The whale watch boats are equally dependent on the health of the orcas as are people who are concerned about them as a species.

He didn’t quite deliver the punch line for which I was hoping: a sustainable whale watching industry would lead in the reduction of all risks identified in the recovery plan — not just donating time and money to save Pacific salmon or working to clean up persistent pollutants, but proactively reducing potential vessel effects in accordance with all available science and the precautionary principle.  Why not support the proposed vessel regulations — even propose to strengthen them (e.g. by adding a 7 knot speed limit within 400 yards throughout their critical habitat despite enforcement logistics), enjoy the short-term PR benefits of setting a stellar example, invest in binoculars and range finders, and then work with NOAA to abate the economic impacts (relax the rules, re-hire workers, grow the fleet) later if recovery occurs and new research justifies being less conservative?

Instead the Association has been vociferous about weakening the rules, questioning or cherry-picking the science, and down-playing vessel impacts. Their public comments include:

“the equation seems simple as too few fish, likely means too few whales” [pg. 3 of 250 pg PDF]

“So let’s get effective Killer Whale Viewing Regulations in place and let’s put all of our collective energies
into the really important steps of Salmon Stock Restoration and Pollution Clean-up and Prevention. All the
houses around us are burning and we are keeping our house safe by spraying the roof and walls with a
garden hose.” [pg. 6]

BP threatens Northwest’s orcas

Heraldnet.com
This morning, John Burbank scribed a disconcerting account of oil politics in the southern residents’ backyard.  The following paragraphs provide a glimpse into how the complex interactions of the petroleum industry and our State political system increase risks for killer whales in the Northwest.

BP also has its own salaried lobbyist dedicated to keeping watch over the Legislature. Their man in Olympia is William Kidd, whom BP pays $120,000 a year to prevent any new taxes or regulations from becoming law. He also has an expense account to wine and dine legislators. For example, Kidd took Rep. Jeff Morris, D-Mount Vernon, out to dinner on July 12 in Boise. He took Morris out to dinner again on July 14. And again on Sept. 2. And again on Nov. 4 and Nov. 5 in Regina, Saskatchewan. And again on Dec. 8 in San Diego. (Lobbyist expenses are public records in Washington, and available at www.pdc.wa.gov. )

What’s all the interest in Jeff Morris? He is the speaker pro tem, sort of like vice president of the House of Representatives. He also sits on the House Technology, Energy and Communications Committee, which deals with energy production. He is the CEO of Energy Horizons, which is sponsored by the oil company ConocoPhillips, and by the giant utility Pacificorps, among others. Morris’ district includes Anacortes, home of two oil refineries, and is close to two more refineries, including the BP refinery in Blaine recently cited for 13 serious safety violations.

So why not wine and dine Rep. Morris and make sure that a word here or there could cast doubt about legislation for cleaning up Puget Sound? It is money well spent. BP refines 225,000 barrels of crude oil a day in Washington. The Clean Water Act would have cost BP at least $200,000 a day in new fees. Paying Kidd $120,000 a year and picking up the meal tabs for a few legislators was a wise investment — for BP, not for us. Not for Puget Sound. And not for our future.

We have at least 5 refineries in western Washington: 2 in Anacortes (Tesoro and Shell), Tacoma (U.S. Oil & Refining), 1 in Blaine (BP’s Cherry Point Refinery), and 1 in Ferndale (Conoco Phillips).  Anyone know how much oil is transported to/from each of these facilities, and by what means (tankers, pipeline, rail, truck, etc)?

State of the Sound by Bill Ruckelshaus

Sound Waters 2010 meeting, Coupeville, WA

It is possible to make progess!

  • We’ve largely brought point-sources under social control.  40 years ago, 85% of pollution was from big industrial or municipal sources, while 15% was from non-point sources.  Now the percentages are reversed.
  • The Clean Air Act helped.  Think of the people in Denver that can see the mountains now, and the people in Los Angeles who can see each other.
  • The Clean Water Act helped.  We don’t have rivers catching on fire any more.

It is much more difficult to detect and manage the non-point pollution sources!

  • We must raise awareness to solve these legacy problems.
  • We’ve found there are two things people really don’t like in urban planning: sprawl and density!
  • Jim Wilcock (prominent farmer) and Billy Frank (Nisqually tribe) showed that effective lowland development and estuary restoration is possible in Puget Sound.  They’ve been in process of implementing their plan for 20 years and they’ve received the most stimulus money of all Puget Sound organizations (though the Nisqually isn’t the most important river).  They have a plan, they agree on solutions, and they are good at seeking funds from the Government.
  • Sammish River has a fecal coliform problem that has shut down Taylor Shellfish multiple times.  The pollution could be coming from many possible sources: cows, ponies, buffalo farm, septic systems, geese…  You can guess what happens: everyone says it’s the geese.  Mac Kaufman of Dept. of Ecology is able to broker solutions, but many regulators aren’t so skilled.  But the fundamental problem in these non-point source solutions is that Americans are happy to agree there is a problem that should be solved, but are rarely willing to change their behavior.
  • Here on Whidbey you have some good plans (e.g. Salmon Recovery Funding Board projects).

Questions:

  • Dick Feely: How are climate change (sea level rise, ocean acidification) being addressed by the Partnership?  The Partnership’s contribution to reducing carbon flux to the atmosphere will be small compared to other entities.  The UW climate solutions group is trying to tell us what the Northwest effects will be and we will try to help mitigate the impacts.
  • What is the status of the stormwater cleanup bill the State government is considering?  We’re thinking about it.  There has been no decision to increase the tax, but many think it should go into the general budget to fund services that are being cut due to the economic downturn.  Some may be spent on environmental cleanup and that may increase proportionally over time.  (Heather Trim of People for Puget Sound helped answer this.)
  • Are brake pad manufacters supporting the brake pad legislation?  Heather says some are and some aren’t.  Bill says: It will be easy if there is an alternative.
  • In 1970 when I moved here, if you drove to Everett to Tacoma there were only a few cars on the road.  Now it’a a mess.  What are you doing about it, Bill?  Why don’t we just jump to abortion!?  We’re not alone in not having figured out what to do… but if I hear anymore about what to do about the viaduct…  My first time I was at EPA I learned that Americans feel really strongly about their cars.  I think you have a better chance of regulating them in the bedroom.  I spent 65% of my time on automobiles that first time.  Legislators know about that attitude.
  • Mayor of Oak Harbor: Do you see a time in the future when the effort of organizing entities around the region will manifest in a simplification of the permitting process?  There is no reason for the permitting process to be as antagonizing as it is.  We also need more than the 6 regulators that Dept. of Ecology has covering river water quality.  Rationalizing our permitting process is hard in part because of the vast complexity of the rules and it just gets worse as more people live together in higher impact ways.
  • I’ve been unimpressed with Federal funding of the killer whale recovery plan and Lubchenko’s approach to (not) solving the Columbia salmon problems.  What are prospects for Federal funding over next 3 years given the Nation’s economic difficulties and the recent surges in National leadership related to ocean conservation (Pew reports, National Ocean Policy)?  We may actually do best at intermediate levels of funding.  We got 20M last year and are looking at 50M this year, though Obama has 20M requested in budget.  So, maybe we’ll be static for a bit and optimistic that this Administration holds great promise for reinforcing promising efforts should the economic climate (and budgets related to marine conservation) improve.

Orca refuge: a gift for endangered killer whales

Mother and calf seeking refuge

This Friday, January 15, 2010, is the deadline for public comment on the proposed orca conservation area along the west side of San Juan Island. All marine conservationists should consider commenting on these precedent-setting rules: comment via email | comment via web form.  (Official background and the PDF of proposed rule are on the NOAA web page.)

If you are short on time, you can simply sign the petition in support of the proposed rules.  The petition will be submitted to NOAA by the comment deadline.

Give a New Year’s gift to the southern residents  — comment on these precedent-setting rules before midnight (EST for web submittal; PST for emailed comments) this Friday, January 15, 2010: comment via email | comment via web form.

“Current regulations in the U.S. to protect marine mammals stem from the whaling era and focus on prohibiting individual acts that harm marine mammals.  If our society is to protect marine life from today’s threats, the regulatory process will need to change to protect the quality of habitats on which marine mammals depend.” — Peter Tyack, Physics Today, November, 2009.

Researchers call for orca conservation zone in B.C.

Dec 23 Vancouver Sun article about a forth-coming science paper that proposes a conservation zone that overlaps with the proposed orca sanctuary boundaries:

Wildlife researchers have identified the key feeding area for a critically endangered population of killer whales near Vancouver Island and proposed the creation of a unique, miniature conservation zone for the few square kilometres encompassing the animals’ favourite seafood restaurant.

The international team of scientists, including University of British Columbia biologist Rob Williams and colleagues from Britain and the U.S., spent four months in the summer of 2006 painstakingly monitoring the movements of a three-pod population of killer whales in waters off B.C. and Washington state that numbers just 87 individuals — so few that every animal has been identified from distinctive markings.

The researchers found the whales were about three times more likely to feast on Chinook salmon — their preferred meal — in a narrow coastal strip south of Washington’s San Juan Island than anywhere else in their summer range.

In an article published in the latest issue of the journal Animal Conservation, the scientists propose strict protections on this whale-dining “hot spot,” arguing that the no go zone is small enough to establish a practical system for diverting all boat traffic but large enough to guarantee the whales unfettered feeding.

“Protecting even small patches of water can provide conservation benefits, as long as we choose the spots wisely,” said lead researcher Erin Ashe, a biologist at Scotland’s University of St. Andrews, in a summary of the study.

Seattle Metropolitan on orcas raising their voices

WhalesInteresting to see the Holt et al, 2009, paper still in the popular press.  This article provides a nice summary and connects the study to the proposed orca-vessel regulations.

http://www.seattlemet.com/issues/archives/articles/orcas-salmon-1109/

NOAA vessel rules rejected at Seattle Aquarium

Comment crowd and Lynne

Audience, Lynne, and the big tank of fish

<More photos>

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.