NOAA is proposing to prohibit all vessels from travelling within 1/2 mile of shore along most of the West coast of San Juan Island between May 1st and Sept. 30th (when Orcas are commonly found in the area). If you may want to paddle in this area you may want to comment to orca.plan_at_noaa.gov as well. Below is the e-mail I sent to NOAA. A copy of e-mail sent to orca.plan_at_noaa.gov follows: Half Mile No-Go Zone May Kill Paddlers or Rowers~ Im the lead author of the kayaking safety book, Sea Kayakers Deep Trouble. "Sea Kayaker's Deep Trouble" is mostly a collection of accident reports involving sea kayaks (along with an analysis of their causes) written for Sea Kayaker magazine. My understanding, from listening to a presentation and talking to an Orca researcher at a recent kayak club meeting, is that the resident Orcas are under stress from the shortage of their only food, Chinook salmon. Not only are the Chinook salmon numbers greatly reduced, but the average size of those Chinook remaining is about 1/2 of what they used to be. That means that an Orca must now catch at least twice as many salmon as before to get the same amount of food. It appears that the main stress that boaters may be adding to this grave situation is that the noise from their fast running engines and propellers may be interfering with the Orca's ability to echo-locate their prey. The smaller private boats with high speed engines are considered by the researchers to be the biggest additional stress. Also, I understand that while the proposed new regulations double the stand aside distance to only 200 yards, keeping powerboats at least 400 yards away would have been a much more preferable regulation to the researchers. It appears to me that some compromise between the whales needs and the wants of those exploiting the Orcas' presence for commercial gain is being attempted with the new proposals. Under the proposed rules, it appears power boaters and whale watching commercial interests are being catered to while those boaters under human power will have their very lives threatened by trying to comply with the new rules even though they are unlikely to be causing any problem at all for the Orcas. I doubt that anyone involved with the proposed no go zone has considered the effect it will have on the operators of human powered craft. I predict that, if adopted, the proposed no go zone may result in the deaths of some paddlers or rowers. Under the present proposal this is likely to happen precisely because the paddlers or rowers attempted to comply with the no go zone rules you are proposing and stayed = mile or more from shore. The distance they would have to go to reach the next possible landing site and stay within the rules is also further than many under human power may be able to safely travel, even under ideal conditions. If the wind or wave conditions deteriorat e they will have to make the choice of violating the no go zone rule or struggling on in dangerous conditions. Even if they sensibly choose to violate the no go zone, they will still be starting from = mile away from the safety of shore in bad conditions. A strong offshore wind in this situation could easily doom them. If the engine and propeller noise seems to be interfering with Orca feeding success (as the researchers believe) the answer seems quite simple to me. As soon as Orcas are spotted all engine powered craft within a 1/2 mile radius need to stop or at least drop their engine speed to an idle (unless the boater will somehow be in physical danger from doing so). A major problem seems to be high speed powered craft "descending" on the Orcas whenever they are spotted by anyone who transmits the sighting to others. So another possible solution might be to make it illegal to use a radio, phone, or any other communication device to contact others about the presence and location of Orcas. Given the choice, I suspect that whale watchers in power boats would prefer knowing about the presence of whales in the area and would more likely accept a restriction of something like a 5 knot speed limit if heading in the direction of Orcas from less than a mile away and an idle only requirement whe n within 1/2 (or at least <) mile from Orcas. One problem is that many private boaters and some whale watching groups already regularly violate the much less restrictive rules, as they stand today, and are likely to continue to do so with whatever new rules are established. So from an enforcement perspective I can see the value of a distinct 1/2 mile wide no go zone. The no go zone should be adequately marked to provide a clear line that must not be crossed. Because human powered craft are easily distinguished from engine powered craft, making a small near shore exception to the no go rules for the safety of those operating human powered craft shouldn't add to the stress on the whales or create any enforcement problems for authorities. Since from a safety and aesthetic standpoint most human powered boaters prefer to stay near shore anyway, a no go zone in the area of highest Orca concentration should be fine with us as long as the near shore area was left open to human powered craft. As a kayaker, I think limiting us to staying within 100 yards of shore in the no go zone would be acceptable. Maybe that distance could be flexible if the paddlers or rowers are attempting to avoid being too near other marine mammals, such as when nearing a seal or sea lion haul out. That way the safety of paddlers and rowers would be enhanced by the new rules rather than the no-go zone being life threatening. I say enhanced because paddlers and rowers would have to stay near shore in that area and they would no longer be at risk of being run down by power boaters not looking where they are going when distracted by the presence of Orcas. If later, human powered boaters, or groups of them, seem to be causing a problem the rules could be amended to address the problems that they might be causing. The present no go zone proposal essentially amounts to a ban on the one group of boaters least likely to be causing the Orcas any problem at all. I doubt that either Orca researchers or power boaters would see much problem with allowing the near shore zone exception for human powered watercraft. I suspect that the power boaters would be glad to get them out of their way. If some researchers think human powered boats may be having some deleterious effect on the whales I would have no objection to adding a rule that says we must move to as near to shore as safely possible if Orcas are sighted (or out from in front of them if they are approaching). Sincerely yours, *************************************************************************** PaddleWise Paddling Mailing List - Any opinions or suggestions expressed here are solely those of the writer(s). You must assume the entire responsibility for reliance upon them. All postings copyright the author. Submissions: PaddleWise_at_PaddleWise.net Subscriptions: PaddleWise-request_at_PaddleWise.net Website: http://www.paddlewise.net/ ***************************************************************************
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