Proposed Southern Resident Critical Habitat Expansion: Public Comments Needed

NOAA is currently considering a petition to expand the critical habitat for the endangered Southern Resident Killer Whales. Public comments are due by June 24 - amazingly, they have received fewer than 200 comments as of this post, while the recent petition to include Lolita under the ESA listing generated almost 20,000 comments. Please consider taking a moment to send in your thoughts: the result could mean expanding the SRKW critical habitat from just Washington inland waters to including most of the outer coast where they are known to forage. Some potential talking points:

• We have more data than ever before to show where SRKWs are spending the entire year (including satellite tag data from recent years)
• It's important to protect their year-round habitat, not just their summer habitat, if they are to recover
• SRKWs are spending less time in inland waters than they used to, particularly in the spring, making it even more necessary to extend habitat protection to the rest of their range

All the info you need can be found here. The top link on the page will take you to the comment form.

Here are the comments I submitted this afternoon:


Since 2006 when the original Southern Resident Killer Whale (SRKW) critical habitat was designated, we have obtained much more data showing how, where, and when these orcas use the outer coast. Our knowledge of coastal habitat use by SRKWs has increased dramatically via NOAA's winter coastal cruises, satellite tagging, acoustic monitoring, and additional well-documented public sightings. I strongly believe these data are sufficient to warrant NOAA accepting the proposed petition and expanding the SRKW critical habitat from the inland waters of Washington to include the proposed range on the outer coast from Cape Flattery, WA to Point Reyes, CA.

Endangered species only have a chance at recovery if we consider them in an ecological context, including protection of the entire habitat that makes up their range. Presently, SRKWs only have their core summer habitat protected. It is unreasonable to expect them to recover unless we extend protections to include what we now know are important areas for them for much of the year. Researchers have believed in the importance of the outer coast to SRKWs for decades, and data collected in the last eight years have done nothing but support what we have long suspected. This additional information makes it apparent that the proposed outer coast critical habitat range is essential to the whales' survival and recovery, meeting the ESA definition of critical habitat.

Additionally, in recent years (since about 2007), SRKWs have been spending less time in inland waters, particularly in the spring months (see attached graphs). Figure 1 shows a dramatic decline in SRKW visits to the Salish Sea in the month of April, and Figure 2 shows a similar trend for the month of May, both potentially correlated to depressed Chinook salmon spring returns to the Fraser River. Quite simply, if the whales are spending less time in the Salish Sea, their present critical habitat, they are spending more time elsewhere, making it even more important to protect these habitats that are serving an increased importance to them. 

I hope you will take all the additional data collected into consideration and will make the decision to expand the SRKW critical habitat as proposed in this petition.

You may recall the graphs I'm referring to as I've posted them recently on this blog. Here they are again:

Figure 1: Number of days Southern Residents were seen in the Salish Sea in the month of April (blue), with data from The Whale Museum's Orca Master data set (1990-2012) and Orca Network sighting reports (2013-2014). Total escapement of Fraser River spring Chinook of both the age-1.3 and age-1.2 runs combined (orange). The Chinook abundance numbers were estimated off graphs in the Pacific Salmon Commission technical reports. Circled in green is where I things seemed to change – in 2007.

Figure 2: Number of days Southern Resident Killer Whales were present in the Salish Sea in the month of May (blue) from The Whale Museum's Orca Master data set (1990-2012) and Orca Network reports (2013-2014) with a red trendline. Average catch per unit effort (CPUE) for the month of May for Chinook Salmon on the Fraser River's Albion Test Catch fishery (orange) with a green trendline. Notes on CPUE data: No test catch data available from 2007. 2001 data is from 25 days, 2002 data is from 24 days, all other years are an average of all 31 days of May.

The Sonar Issue Intensifies

Last month I posted a blog about L112 Sooke, a young Southern Resident killer whale that washed up on a beach on the Washington coast. Initial findings led many to wonder if maybe she was killed by Navy sonar activity in the Strait of Juan de Fuca. Since, then the Navy sonar issue has intensified and is getting more and more media attention.

An MRI was done on the head of L112, and while results from that test have not been revealed, a cranial necropsy was also conducted at the Friday Harbor Labs. (If you are interested in that kind of thing - it's not for the squeamish - video clips from the cranial necropsy can be seen here.) The scientists involved in the necropsy found trauma in the tissues of the head and evidence of hemorrhaging, though no official cause of death will be released until all tests are completed. Ken Balcomb, director of the Center for Whale Research, had some strong words about the issue in this San Juan Journal article. "It didn't die of disease or starvation. Clearly the the animal was blown up," said Balcomb, who was present for a beaked whale stranding that was also related to military activities.

As it is sounding more and more likely Sooke died of trauma related to sonar use, the question is looming: how many of her other family members have met similar fates? While it is not uncommon for members of K and L Pods, who were in the area during the sonar incident, to spend long lengths of time out of the Salish Sea this time of year, none of them have been seen again since Sooke was found. Until they are seen again, we won't know if Sooke was the only casualty. Candace Whiting ponders the same question in this Seattle PI blog.

Meanwhile, the Everett Naval Station has been conducting sonar exercises from their dock in Puget Sound, which has also been creating a stir. On multiple occasions the sound has been heard in the air or reverberating through the hulls of ships. While the Navy claims this is a standard procedure, it is being heavily criticized for coinciding with the arrival of the gray whales and occurring right in some of their prime feeding grounds in Puget Sound.

With all of these issues in the news, it's somewhat appropriate that there also happens to be a public comment period as the Navy seeks to reauthorize their training ranges in Oregon, Washington, and California. The draft Northwest Training and Testing Environmental Impact Statement can be read here. The proposed actions they hope to undertake are summarized here.

For some additional information on how sonar kills whales, as well as some suggested comments, check out the succinct summary posted by Candace Whiting on her blog.

I really hope many of you will take some time to learn a little more about this issue and submit your comments before the April 27th deadline. You can submit your comments online here. As is beginning to come to light with Sooke, this is a very real issue that could have some very serious impacts on our local marine mammals, including the endangered Southern Resident killer whales. Military exercises are a necessary event, but they can be done in areas and at time where their impact on cetaceans is limited. They don't need to happen in the Salish Sea, a habitat for so many marine mammal species. Please take a moment to make your voice heard!

Satellite Tagging of Southern Resident Killer Whales

With the endangered listing of the Southern Resident population of killer whales they have received even more attention from researchers to fill in the gaps in our knowledge about them and ensure they receive adequate protection. One of the first issues to come up was vessel regulations regarding boater behavior around the whales. There was a public comment period about this issue that received much attention, and a hearing in Friday Harbor back in October 2009. Originally we expected the new regulations to be announced for the 2010 whale-watching season, but the announcement was postponed and I imagine we will find out what NOAA has decided before the 2011 season is set to begin. Now, there is a public comment period open in regards to another issue: satellite tagging the Southern Resident Killer Whales.

Many people are surprised to learn that we don't know where this population of whales spends its time for much of the winter months. While their daily movements are monitored closely while they're in inland waters, as soon as they head out to the Pacific Ocean sightings are scarce with weeks or even months passing between encounters. We know the whales range over much of the outer coast from northern British Columbia to Monterey, California, but how far offshore they go, where their important feeding areas are, and how often they frequent different regions is for the most part unknown. It is important to learn where these whales are in the winter so the area designated as their critical habitat can be defined to give them more protection.

While long-term satellite tags have been used more widely on large cetaceans, a relatively non-invasive long-term tag for smaller cetaceans is a fairly new technological advancement. Suction cup tags have been placed on Southern Residents, but they typically stay on for a matter of hours rather than weeks. Recently satellite tags have been used more widely on small cetaceans, but there has been a hesitation before using them on this endangered group of whales to learn more about the risks involved. Earlier this year, Brad Hanson, one of the lead cetacean researchers in the region, applied for an amendment to his permit from NOAA that would allow him to deploy six satellite tags on Southern Residents.

This has raised several concerns about the public administration of whale populations. One of the biggest concerns people have is about the wounds caused by the tags, which contain a pair of titanium darts that embed more than 2.5 inches into the skin. The tags eventually fall off (11 transient killer whales have been tagged on the west coast since 2008, and the tags transmitted for anywhere from 16-94 days), but can leave open wounds and scars as evidenced by follow-up monitoring. Such wounds are potentially an entry point for disease, and with a population of fewer than 90 animals, the loss of even one animal is a huge impact.

It's important, I think, to consider that these animals receive similar injuries to their fins and bodies in their everyday life. This wound on the dorsal fin of K21 Cappuccino, as seen earlier in 2010, looks just as bad or worse than some of the post-tagging wounds:

I had to think long and hard about this issue, but I believe that the benefits of learning where these whales spend time in the winter outweighs the risk of tagging. Here's a copy of the public comments I submitted with some more details of my thoughts:

I support the proposed satellite tagging of Southern Resident killer whales as a means to gather important data that is currently lacking, particularly when it comes to designating the winter portion of the critical habitat for this endangered population of orcas. I understand this is the most feasible method to gather this data, and respect all of the precautions that are being taken. I think it is especially important to deploy the tags at the appropriate time of year to get the required data, and to monitor the tagged whales’ health to the best ability possible, both of which were indicated in the proposal. However, after reading the amendment request I found myself with the following questions:

1. Will the number of tags to be deployed (6) provide sufficient data to begin designating critical habitat for these whales? Satellite tag data was key in designating the critical habitat of Hawaii’s false killer whales, but 23 satellite tags were deployed on that population.

2. The request states: “The only alternative method for obtaining information on offshore movements is through boat-based photo-identification, which is severely limited in scope by sea conditions and range of small vessels.” At the Marine Naturalist’s Gear –Down in Friday Harbor on November 5, 2010 I learned from a talk given by Candice Emmons that acoustic detection of Southern Residents has been attempted via remote hydrophones along the outer coast since 2005 in addition to these boat-based surveys. What information has been learned through this technique and why isn’t this a sufficient method to determine the winter range of the Southern Residents?

3. When you are dealing with a small population size, which individuals will be targeted for potentially invasive research is a key issue. Even though the short- and long-term impacts of satellite tagging are deemed minimal, implanting tags is not a zero-risk operation and the appropriate individuals should be selected for deployment. I have questions regarding the individuals that are listed as candidates for tagging in Table 2. While post-reproductive females no longer play a direct role in increasing population size, they play a cultural role of undetermined importance to the community as a whole. With the loss of several of these older females in recent years, I would propose that the targeted females are of post-reproductive age, but perhaps not older than the age of 70 given the unknown importance of this small segment of the population. I have also heard that some of these older females have not been successfully biopsied or suction cup tagged, and if this is the case they may not be the most approachable whales for satellite tag deployment. Additionally, I think post-reproductive age females under 70 that have never been seen with a calf (such as K40) and reproductive age females that have not been seen with a calf for a decade or more should be the highest ranked candidates for tagging. Given the small population size and the limited number of breeding age males, I would also propose that no more than one male per pod be tagged.

4. Finally, I don’t feel that sufficient justification was given for the increase in suction cup tag deployment from 10 to 20. While the data gathered from these tags is interesting, this research is invasive and it has not been demonstrated here as being critical to filling the data gaps in our knowledge of this endangered population of whales. Unless such justification occurs, I don’t believe it is necessary to increase this type of tagging.

If you have your own thoughts or opinions on this issue I strongly encourage you to send in your own comments. You can read the federal register for the proposed amendment here. The modification request can be read in more detail on NOAA's site here, where under attachments you can also download a pdf of the amendment proposal (the second of the three downloads) submitted by Brad Hanson, which I found to be the most informative read. The public comment period is open until December 23rd, and you can submit your comments via e-mail to NMFS.Pr1Comments@noaa.gov. They request that you include File No. 781-1824 in the subject line.

This December 10th article in the Victoria Times Colonist and this December 5th article in the Kitsap Sun also provide you with some more good information.

Transient IDs and Navy Sonar Incident and Comment Period

After comparing notes with other whale reports I've been able to figure out the identity of all the transients ("Ts") I saw on Monday. The two females and calf were the T123s. T123 is the mother and the calf is T123B, a newly documented whale probably just a few months old. While both mom and youngster were around in the porpoise hunt, my photos revealed that it was T123's older daugther, nine year old T123A, that was the primary participant and the whale that launched the porpoise out of the water. It's amazing to me that we know enough about these whales - even the relatively mysterious transients - for me to be able to figure out the exact whale it was in that photo. Thanks, of course, to others who were there being able to ID the group of three as the T123s, and to T123A having a distinct notch on her fin I can just make out in that photo. Here's another photo showing her and her notch:

T123A

The other group of Ts was indeed male T14 with four of the T49s - specifically, T49A, T49A1, T49B, and T49B1. The complicated transient whale nomenclature actually encodes the whales genealogy in their names, since their pods are more fluid than those of the resident whales. So T49B was the second offspring of T49, and T49B1 is the first offspring of T49B.

Finally, I must say a word about a bizarre incident that occurred the night of the 7th-8th. Starting at about 7 PM and continuing until after 4 AM, a strange human voice and sonar pings were audible on the Lime Kiln and Orcasound hydrophones. It turns out the sonar pings were coming from the US Navy submarine the USS San Francisco, and the strange voices were underwater communication occurring between the submarine and an accompanying surface vessel. You can hear a sample of the sounds that occurred here.

Navy sonar is a great concern when it comes to marine mammals, because animals in the presence of sonar have demonstrated physiological and behavioral responses the intense sounds including disorientation, panic, hearing loss, tears in the ear, brain hemorrhaging, and stranding, in some cases resulting in the death of the animal. The last major incident in the area involving Navy sonar occurred in May 2003 when J-Pod was in the area - a scary situation in which these endangered whales showed unusual behavior where they came close to shore (where the acoustic impacts of the sonar were lessened) and repeatedly spyhopped, apparently to get their ears clear of the water. That incident resulted in the deaths and stranding of at least several harbor porpoises, and you can read about it and see evidence of porpoise brain hemorrhaging at the Center for Whale Research's report on the Shoup.

Luckily there have been no reported strandings in response to this most recent incident and no orcas were believed to be in the immediate area at the time, although several transient groups were reported in the region in the days preceding and following the incident. Still, it is a grim, timely reminder that the US Navy is exempt from the Marine Mammal Protection Act, and is currently seeking to expand its local training range to include a huge portion of vital killer whale and marine mammal habitat. They are currently seeking public comment on their Environmental Impact Statement (EIS), and their proposal in includes minimal mitigation measures to prevent harm to marine mammals.

Obviously, this is an issue close to my home and my heart. I strongly encourage you to submit public comments supporting the "No Action Alternative", which keeps the current training area in place. They simply have not invested the resources in studying the impacts to marine mammals and do not have the measures in place to ensure marine mammals are not within lethal range of their sonar and explosive detonations during training activities. The EIS document itself is imposing, but you can read up on this issue and learn everything you need to know to comment via Orca Network's informational page about this public comment period. Comments are due April 13th!

We need to take into consideration our nation's security and I understand the need for the Navy to undergo training exercises. Still, this is such a vital yet fragile marine ecosystem, and one serious incident involving sonar and the Southern Resident whales could easily spell their extinction. Hopefully under President Obama, we can begin to improve international communication so that disagreements are resolved at the bargaining table and not at war, and these sorts of training exercises will be less necessary and perceived as less vital for maintaining our country's safety. Obama appointed Jane Lubchenco to head the National Oceanic and Atmospheric Administration (NOAA), and she is a respected marine biologist who has critiqued the government's dealings with oceanic issues in the past. She recognizes that we, as a people, along with all life on earth, depend on healthy oceans to survive on this planet. Hopefully we, as a nation, will move towards an attitude that preserves our marine resources and helps them to thrive, from orcas and harbor porpoises to krill and plankton. I understand the need for military operations, but it's hard for me to justify some of their short-term goals when looking at the long-term impacts it could have on ocean life.