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• Main Author: Michael Payne
• Other Authors: The Pennsylvania State University CiteSeerX Archives
• Format: Text
• Language: English
• Published: 2009
• Subjects: Chul; Barrow; bowhead whale; Savoonga; Alaska
• Online Access: http://citeseerx.ist.psu.edu/viewdoc/summary?doi=10.1.1.184.359; http://www.nmfs.noaa.gov/pr/pdfs/permits/shell_openwater_comments.pdf

Inc.'s (hereafter "Shell") application for an Incidental Harassment Authorization ("IHA") to the National Marine Fisheries Service ("NMFS") pursuant to the Marine Mammal Protection Act ("MMPA") for oil and gas related activities in the sensitive Chitkchi Sea. See 74 Fed. Reg. 26,2 17 (June 1,2009). These comments are submitted on behalf of the Alaska Esl<imo Whaling Commission ("AEWC"). AEWC represents the eleven bowhead whale subsistence hunting villages of Barrow, Nuiqsut, Kaktovilt, Pt. Hope, Wainwright, Kivalina, Wales, Savoonga, Gambell, Little Diomede, and Pt. Lay. Our communities depend upon the marine n~alnnlals at stake in this application and the environment that supports them, which is changing rapidly as a result of climate change. We rely on the migration of bowhead whales and other marine nla~nmals througl ~ the Chul<chi and Beaufort Seas to feed our people and to preserve our society and culture. The ran~ifications of improperly managed oil and gas related activities place our continued nutritional and cultural silrvival at great risk. The AEWC sees the Chultchi Sca as the valuablc and unique resource that it is and on behalf of our whaling captains, wc are responsible for protecting our Ini~piat way of life it supports. The potential for any take of marine matnmals by Shell in the waters that support our communities must be scrutinized with extreme care. In submitting its application, the corporation failed to comply with applicable statutory and regillatory application requirements and has otherwise failed to demonstrate that its activities comport with the requircments for issuing an IHA. For its part, NMFS failed to issue a draft autl~orization for public review and comment, has accepted many of Shell's assertions that arc contrary to both scientific reseal-ch and agency expe-