Monday, January 5, 2015

NMFS to address massive takes of marine mammals in lawless Cook Inlet waters

NMFS to address massive harassment of marine mammals in lawless Cook Inlet waters by industrial activities

Plight of the critically endangered Cook Inlet Beluga Whales needs a Recovery Plan to end racist and discriminatory policy and regulation blaming Alaska Native Hunters as scientist continue to call for more information before issuance of harassment authorizations from federal government.



RE:  Notice of Intent to Prepare and Environmental Impact Statement on the Issuance of Take Authorizations in Cook Inlet, Alaska


To:  Jolie Harrison, Chief, Permits and Conservation Division, Office of Protected Resources, NMFS


Dear Ms. Harrison,


INTRODUCTION:
Alaska's Big Village Network (ABVN) is a free association of indigenous peoples creating communities of inclusion with non-indigenous peoples for the holistic betterment of community well-being and health for future generations.   

ABVN supports self-sufficiency and self-determination of Tribal Governments in Alaska as local authorities on jurisdictional tier with State and Federal agencies.   Furthermore, ABVN supports and advocates for Alaska Native hunters and fisherman (fisherwoman) to continue indigenous peoples way of  life for cultural and physical survival in Cook Inlet. 

 ABVN is guided by traditional wisdom of the indigenous elders and supports inclusion of indigenous science and Traditional Knowledge in decision-making processes.


COMMENTS:


Alaska's Big Village Network (ABVN) supports the preparation of a programmatic Environmental Impact Statement (EIS) to address human-derived impacts on marine mammals in Cook Inlet; particularly, the critically endangered Cook Inlet Beluga Whale.  

ABVN recommends no further issuance of harassment authorizations until finalized review and issuance of the Cook Inlet Beluga Whale Recovery Plan with full participation of Tribal Governments, Alaska Native hunters, and indigenous peoples in Cook Inlet.   

ABVN recommends review of the Cook Inlet Marine Mammal Council's Ordinance on monitoring, management, mitigation and recovery of the Cook Inlet Beluga Whale


Despite Alaska Native and Tribal stand-downs on subsistence harvest for the last 15 years, many industrial activities have increased and continued to operate without full analysis of effects of multiple activities over multiple years.   Environmental Justice implications to subsistence hunters have arisen a number of times due to the federal and state regulatory policies and procedures; or lack thereof of EIS and IHA permitting process' for full inclusion of tribal authorities.    Alaska Native subsistence hunters continue to have high levels of scrutiny and restrictions, while industry and municipalities continue to have exemptions on environmental laws and regulations as noted by other commenter such as Cook Inlet Keeper and the Marine Mammal Commission.


As NMFS develops the scoping analysis, I highly recommend including the white paper submitted by the Center for Water Advocacy to the Obama Administration titled “Water Justice in Alaska Native Communities” for a more comprehensive look on mechanisms and authorities for Tribal and Alaska Native inclusion. [ http://www.centerforwateradvocacy.org/files/61501_61600/61508/cwa_wp_water-justice-in-alaska.pdf ]


The values and issues of marine mammals to Alaska Native hunters and fisherman are of significant spiritual, social, economic, cultural, mental and environmental status that needs further review by indigenous communities and formal consultation with Tribal Governments.   ABVN supports continued policy and development for an adequate process to maximize inclusion of tribal communities and Alaska Native peoples.


CONCLUSION:

Alaska's Big Village Network incorporates comments from the Marine Mammal Commission and Natural Resource Defense Council for further details and scope of the issues to be addressed.
Sincerely,
Carl Wassilie
Yupiaq Biologist