Public Comments needed NOW on gray whale hunt

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===== A message from the 'makahwhaling' discussion list =====

 

FROM WASHINGTON CITIZEN'S COASTAL ALLIANCE

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COMMENT LETTERS: WRITE THEM NOW!

 

Rarely does the federal government ASK its citizens for their opinion:

usually it goes to great lengths to make sure those opinions are stifled.

But now we have the opportunity to speak, and to make sure our opinions go

on record against the Makah whale hunt.

 

As we've indicated, the Draft Environmental Assessment for the Makah whale

hunt was issued this last week by National Marine Fisheries Service. There

is a public comment session in Seattle on February 1, but most importantly,

YOU HAVE ONLY UNTIL FEBRUARY 16 TO SUBMIT WRITTEN COMMENTS!

 

This is an incredibly important stage for the Makah whaling fiasco, and it

is VITAL that each of you submit a comment letter. In fact, we are going to

ask each of you to make a commitment to pass this information along to TEN

friends, family members or other concerned citizens, asking THEM to submit

comment letters, as well. It's THAT important.

 

Here's the drill:

 

1) Below are some key points to emphasize in your letter: we have gathered

these from a number of key activists who " know the ropes. " Feel free to use

any- or all- of them.

 

2) Take the time to read through the Draft Environmental Assessment (online

at www.nwr.noaa.gov), and if you are having problems downloading or viewing

it, please contact us: we'll assist to make sure that you get the

opportunity to read it. You can also view a plain-text version of the EA at

www.stopwhalekill.org/dea, www.stopwhalekill.org/dea1, and

www.stopwhalekill.org/dea2

 

3) Even if you can not afford a great deal of time to engage in this

project, you MUST send something- anything, even a postcard that simply

states " I insist that you choose Alternative 4. " (The " no whaling "

alternative)

 

4) For a comprehensive example of a comment letter, we direct you to Breach

Marine's letter of 1997 in response to the original Makah EA:

http://members.aol.com/breachenv/dea-resp.htm

 

4) MAKE SURE THOSE LETTERS ARE RECEIVED NO LATER THAN FEBRUARY 16!!!

 

5) YOU NEED TO SEND THEM TO:

 

Cathy E. Campbell

NOAA/NMFS

Office of Protected Resources, 13th Floor

1315 East-West Highway

Silver Spring, MD 20910

 

Mark the outside of the envelope with " Comments on Makah EA " (per the

Federal Register)

 

NO E-MAIL COMMENTS WILL BE ACCEPTED.

 

Folks, we can not emphasize enough how important it is for you to WRITE

THOSE LETTERS. And of course, if you can attend the public hearing in

Seattle on February 1, by all means do so!!! BUT GET THOSE LETTERS SENT

ASAP!

 

Here are a number of key ideas to consider in your comments: They are not

meant to substitute as YOUR particular wording, but they might help generate

a few thoughts!

*****

 

 

IDEAS FOR YOU TO CONSIDER IN YOUR LETTER

 

 

* In the past, NMFS has lied, distorted information and failed to reveal

essential facts in this matter. How then, can that agency be trusted to

really take a " hard eyed, clear look " at this issue now?

 

* The time period allocated for comments is far too short, denying adequate

opportunity for public comment on an issue which has been the centre of

public , political, media and legal controversy.

 

* In permitting the Makah to kill gray whales, the Government has

transformed the US into a whale killing nation. The importance of this

issue to the general public should provide a moral injunction on the Federal

Government to allow adequate and proper discussion and debate.

 

* The US government failed to listen the concerns of LOCAL residents on this

issue by not holding a public comment hearing in Port Angeles. Many

residents of Port Angeles and Clallam County can not possibly attend a

hearing in Seattle on a weekday night.

 

* The draft EA makes no adequate case for not killing whales other than a

concern that Indian tribes may sue the Government. Since the

government has funded the Makah with taxpayers' money, it would be appear to

be legally discriminatory to refuse to fund taxpayers who object to whales

being killed. What kind of precedent would be set by this decision - the

Government would no longer take action against any group, in case they sued

the Government ?

 

* The EA completely ignores the very high and ongoing death rate of gray

whales from starvation. It also ignores the importance and severity of the

mortality figures, the low calf counts and the evidence of starvation.

 

* The benthic amphipods on which the gray whale depends for a food source

has not been properly surveyed since the mid eighties. In spite of the fact

that the draft 5 year plan recommends regular monitoring, no such monitoring

has taken place.

 

* The draft 5 year plan was never formally adopted as a management program.

Almost all the recommendations which were made by the team of specialists

have been ignored. ( " A 5 year plan for research and monitoring of the

eastern pacific population of gray whales. Prepared by the Gray Whale

Monitoring Task Group, NMFS, NOAA October l993 " )*

 

*There was no public comment allowed on the 5 year status review held in

Seattle in l999.

 

* The EA completely ignores the basic ecological requirements of the gray

whale, ie security of food source, status and security of habitat,

population dynamics, mortality and the evidence of starvation. Since the

mortality rate has been way over the birth rate in the last two years, the

population cannot possibly be at the claimed 26,000 level. In l998, eight

hundred gray whales had died of starvation by July, the figure was much

higher by the end of the year.

 

* Scientists say that it is difficult to calculate the number of gray whales

that have perished in the deep ocean when looking at the high number of

grays whose bodies have washed ashore. The most conservative say the number

of shore deaths can be multiplied by a factor of three to estimate the true

death rate. Others say it could be much higher.

 

* Where is the evidence of the aerial population studies that NMFS has been

undertaking for the last year up and down the gray whale migration route ?

 

* The US delegation at the IWC meeting in Adelaide, Australia, took every

step to stop the Makah issue from being raised. Australian government

officials have said that the US indicated it would not support a South

Pacific Sanctuary if Australia raised the Makah issue. A Makah elder was

not allowed to come to the US cocktail party, although the Government paid

for several whaling members of the tribe

to attend. A key Australian scientist who has recently created an heuristic

model of the gray whale was also refused entry,and was denied the

opportunity to discuss the issue with US scientists on the delegation.

 

* How has the EA managed to ignore evidence given by the Russian delegation

at IWC Adelaide that ten gray whales killed in their waters stank like

medical waste and that the meat could not be eaten, not even by dogs. Why

has the EA ignored this evidence especially since NMFS is on record as the

agency in the US doing testing on the meat of these whales ?

 

* How has global warming affected the Bering Sea ? Why has this issue been

ignored by the EA ?

 

* To date, the US government STILL has never released any real proof that

this hunt has been approved by the IWC. Other than a vague press release in

1997 released by the US, there has never been any written proof of IWC

approval. In fact, many delegations (and the ex-Secretary) of the IWC have

repeatedly stated that the hunt has NOT been approved by the IWC. Ask for a

return to the IWC to take up the matter of the Makah hunt proposal as

defined in the category of Aboriginal Subsistence Whaling and whether the

Makah are so recognized by the IWC.

 

* The Ninth Circuit Court of Appeals ruled that' " time here is not of the

essence " .. so why is NMFS allowing such a short comment period. Object to

the short comment period, pointing out that this along shows bias in the

process.

 

*The EA is OVERLY NARROW: Ignores the impact on all whales, not just Eastern

Pacific gray whales, implicit in the U.S. violation of the IWC guidelines

governing Aboriginal Subsistence Whaling in permitting the Makah hunt. The

EA further undermines IWC protections in promulgating U.S. misinterpretation

of the 1997 IWC Resolution (13)(b)(2) amending the Schedule of the

International Convention on the Regulation of Whaling (ICRW), assuming

" recognition " of Makah's aboriginal subsistence need, when in fact the

Resolution was written and amended expressly to deny the Makah a hunt as

such need had not been recognized

 

*The EA is CURSORY and INCOMPLETE: Nowhere mentions the documented evidence

of the Tribe's commercial intent, the fact that the makah were whaling

commercially at the time of the Treaty of Neah Bay, the negative impacts on

fishing, tourism, and resort businesses on the Olympic Peninsula in the

summer and fall of 1999.

 

*The EA is NOT OBJECTIVE and seeks to support a foregone conclusion.

 

*Ask for a full Environmental Impact Statement (EIS), which is lengthy, but

is the only real way to " clearly " look at this issue, and will consider all

issues the EA does not.

 

* MOST IMPORTANT: Make sure your comment letter indicates that you fully

expect- and demand- that the US government follow " Alternative 4, " the

alternative which allows NO WHALING. Alternatives 1, 2 and 3 are simply not

acceptable. If you can do nothing else, submit a brief letter or postcard

stating that you prefer " Alternative 4. "

 

We'll pass along more ideas over the next week or so, and feel free to

contact us if you have any problems or questions, but please get those

letters written now!!!

*****