Dear Chair Gorelnik, Council Members and Mr. Thom:
Critically endangered Southern Resident killer whales have declined nearly 25 percent since 1995, and the science shows that unless we act soon to increase prey availability these orcas will go extinct. As fishery managers responsible for the management of ocean salmon fisheries off the U.S. West Coast, you play an essential role in Southern Resident recovery. We are deeply concerned, however, that current fishery management by the Pacific Fishery Management Council (PFMC) and National Marine Fisheries Service (NMFS) does not include any conservation measures to ensure imperiled orcas are protected during times of low Chinook salmon abundance. We urge you to adopt and implement strong actions to provide Southern Resident orcas with the best chance of survival.
On average 99 percent of the Southern Resident orca diet is salmon, particularly Chinook salmon. It is well documented that the lack of adequate prey, both the limited abundance of Chinook and their reduced size, is the primary threat to the orcas’ recovery. Ocean salmon fisheries target many of the same salmon that these orcas depend on. As such, the PFMC and NMFS should be doing everything in their power to ensure Southern Resident orcas have enough salmon to reproduce, grow and thrive.
While there are many reasons salmon in the Pacific Northwest are in decline, including dams and habitat loss, reducing directed ocean salmon catch levels and protecting the orcas’ foraging hotspots are important measures that can be taken now to increase prey availability. We urge you to address Southern Resident orca recovery in fishery management by taking the following actions:
- Adopt a critical Chinook salmon abundance threshold—based on the maximum abundance of Chinook in the late 1990s (Alternative 3.1.2.d)—below which would trigger reduced ocean salmon fishery catch limits and time and area closures in areas where orcas are known to feed.
- If Chinook abundance falls below the recommended threshold, the proposed Southern Resident killer whale critical habitat off the northern Oregon and Washington coast should be closed to recreational and commercial salmon fishing. This would protect the orcas’ high use foraging habitat in areas where they have been observed year-round, while ocean fisheries outside this area and in rivers and estuaries would remain open. The time and area closures in your current range of alternatives are inadequate for protecting the orcas’ foraging habitat.
- Update the Pacific Coast Salmon Fishery Management Plan with an objective of managing and regulating salmon fisheries in a manner that accounts for the needs of Southern Resident orcas and ensures their protection into the future. Right now, your salmon plan has zero goals or actions for addressing the prey needs of orcas.
Southern Resident orca and wild salmon recovery requires solutions that are big, bold and comprehensive. Please make responsible fishery management part of the solution.