Takes of Marine Mammals Incidental to Specified Activities; Taking

• Main Authors: Mr. Michael Payne, National Marine, Fisheries Service, Dear Mr Payne
• Other Authors: The Pennsylvania State University CiteSeerX Archives
• Format: Text
• Language: English
• Published: 2011
• Subjects: Chukchi Sea; Barrow; bowhead whale; Chukchi; eskimo*; Savoonga; Alaska
• Online Access: http://citeseerx.ist.psu.edu/viewdoc/summary?doi=10.1.1.227.9805; http://www.nmfs.noaa.gov/pr/pdfs/permits/shell_chukchi_exploratory_comments.pdf

Thank you for the opportunity to comment on the application of Shell Offshore, Inc. (Shell) to the National Marine Fisheries Service (NMFS) for an Incidental Harassment Authorization (IHA) pursuant to the Marine Mammal Protection Act (MMPA) for oil and gas related activities in the Chukchi Sea. See 76 Fed. Reg. 69958 (November 9, 2011). These comments are submitted on behalf of the Alaska Eskimo Whaling Commission ("AEWC"). The AEWC represents the eleven bowhead whale subsistence hunting villages of Barrow, Nuiqsut, Kaktovik, Pt. Hope, Pt. Lay, Wainwright, Kivalina, Wales, Savoonga, Gambell, and Little Diomede. The AEWC was formed by the whaling captains of our constituent villages in 1980 for the purpose of protecting our bowhead whale resource and subsistence hunt. We carry out responsibilities through locally delegated tribal authority and through federal authority delegated pursuant to the NOAA-AEWC cooperative agreement. Alaskan Native subsistence takes of marine mammals are exempt from the Marine Mammal Protection Act's (MMPA) moratorium on the take of marine mammals. 16 U.S.C. § 1371 (b)(1). In addition, Congress has given our subsistence livelihood priority over other uses of the marine environment, requiring that other users mitigate the impacts of any activities with the potential to adversely affect the availability of our subsistence