Below you will find my letter submitted to NOAA and MMPA regarding a research project to be conducted in the Gulf of Alaska which is required under the Marine Mammal Protection Act. It was not until Tuesday of this week that I became aware of this project. Therefore anyone reading this will be unable to submit their comments, as I have done. In searching the internet, outside of the letter submitted by the Whale Museum regarding a similar grant project intended to impact the Southern Resident Killer Whale Pod of Puget Sound, file no 781-1824, enters were scarce.
At this point internet wise I feel connected in degree but am really disappointed that so little was made of this issue in this domain. No question whales our important to the health and well being of the oceans and the planet as a whole. The Marine Mammal Protection Act is being circumvented by military testing and training needs, an issue that needs serious consideration and soon.
RE: Opposition to Permit Number: 15616 Project Title: Photoidentification, biopsy, and tagging of cetaceans in Alaskan waters
Chief, Permits, Conservation and Education Division Office of Protected Resources
National Marine Fisheries Service, NOAA
Office of Protected Resources
1315 East-West Highway
Silver Spring, MD 20910
Phone: (301)713-2289 Fax: (301)713-0376
In December 2010 I submitted a letter opposing tagging of Puget Sound Orca populations using barbed darts among other contentious issues. Recently I became aware of another attempt to use this same invasive method in attempt to track these mammalian creatures.
The application states, “ The attachment of LIMPET tags results in short-term scarring from the time of attachment (approximately 1 month) and then for a short period (< 1 year) until complete healing occurs. Based on the follow-ups of killer whales tagged in 2006 and 2007, which received extensive field time for post-tagging follow-up photos, 20 of 29 whales were resighted after tag loss. Wound healing followed the expected course of hemostasis, inflammation, proliferation, and remodeling. In most cases the remodeling has progressed to the stage of complete repigmentation (from white to grey to black) within 3 – 6 months after tag loss. In all cases the wounds healed quite well – there was no evidence of any prolonged infection nor were there any wounds that never healed. In most cases the wound was not visible within 1 year after tag loss.”
My search has revealed a different assessment based on materials previously submitted to this agency by the Board of Directors the Whale Museum, Friday Harbor, Washington, relative to MMPA File No. 781-1824. In that document pictures were included that show some barbs passing completely through the dorsal fin in one case, and of puncture wounds that had not healed within a reasonable period of time on another member to the Southerns Resident Killer Whale Pod.
When you attempt to represent the emotional response of Orcas when being tagged or biopsied as inconsequential, I take further offence. It remains to be seen but the evidence is still accumulating as to just how intelligent and adept their brains have become. In your application you identify non invasive methods which would result in a greater accumulation of data and less physical risks. Both surface photographic identification and acoustical underwater monitoring have proven very effective. These non invasive methods have resulted in a huge amount of data. What appears to be missing is the inclusion of this information in subsequent grant requests. In other words why more funding when previous grant findings have not been utilized to improve survival potential for these creatures.
The method used to attach these double barred hooks is questionable based on the sea conditions, marksmanship, and distance between hunter and prey needed for a successful tagging. One NOAA hired researcher described his experience as challenging, given the parameters mentioned above. Once the firing has occurred and it is not successful, the chase is on. The experiences orcas’ have had with man are suddenly turned upside down as they frantically attempt to escape. The Humane Society would consider this cruelty to animals and subject to punishment by law.
I am alarmed further that the resident pod of Prince William Sound Orcas is not put off limits for any form of tagging. When the population is already so small, with only 8 surviving members from a listed 20 in 1984, and no record births since the Exxon Valdez oil spill, let them be. Actually I have found no mention of this grant tagging any of this pod specifically so hopefully you have already eliminated this stock from your plan.
Edward W. Johnson