Deantha Crockett's Testimony - July 19, 2007, Homer, AK

Good Evening.

My name is Deantha Crockett.  I am a Projects Coordinator for the Resource Development Council.  I am also a born and raised Alaskan. 

RDC is a business association that has a very diverse membership.  Our members include individuals and companies from oil and gas, mining, forestry, fishing, tourism, all of the regional native corporations, labor, as well as many Alaskan communities including Anchorage, Kenai Peninsula, and Mat-Su, all of whom will be impacted by an ESA listing of the Cook Inlet Beluga Whale.

It is on behalf of our many members that I give my testimony today. Despite the obviously VERY different and diverse characteristics of our members, the proposed ESA listing of the Cook Inlet beluga is an issue all of our members are aligned in opposition to.

In 2000, NMFS declared the Cook Inlet beluga whale as depleted, citing a 50% population decrease in the past 5 years.  NMFS identified the primary factor of the decline as over-harvesting by subsistence hunters.  At that time, they were not recommended for an ESA listing, and the subsistence harvest was limited to two animals per year.

RDC believes it is inappropriate for NMFS to so quickly abandon the conservation measures already in place under the Marine Mammal Protection Act.  We believe NMFS must utilize all available research and data when making its decision, as is required by the ESA.  Data from studies funded by the private sector show a growing population, and this data should not be ignored.  In addition, the MMPA requires NMFS to complete a conservation plan for Cook Inlet Belugas, and this never occurred.  The proposed listing indicates the draft conservation plan is comprehensive and provides recommendations to foster recovery, yet it was never implemented.  Rather than proceed with an uninformed ESA listing, the agency ought to identify the gaps in its understanding and pursue actions to address that lack of information.

A recent study has shown over 40% of the population is subadult and not yet capable of sexual reproduction.  Also, NMFS is unable to accurately count the subadult whales due to their camouflaging color, making it impossible to develop a precise population estimate.

If this proposed rule is finalized, critical habitat will be designated.  These designations will have significant adverse affects without providing a corresponding benefit to the whales.  Impacts to human activities including shipping, oil and gas exploration, oil and gas development, commercial and sport fishing, among other activities, would be significant and far-reaching.  Meanwhile, in its proposed listing NMFS states, “No information exists that beluga habitat has been modified or curtailed to an extent that is likely to have caused the population declines observed within Cook Inlet.”

The peak population of beluga whales in the 1970s, as identified by NMFS, is one that grew with all of the current activities in the Inlet.  RDC believes an ESA listing for the Cook Inlet Beluga whale is unwarranted at this time.  An ESA listing will only lead to additional permitting hurdles and subsequent costs with no added benefit to the reovery of the beluga stock.

In addition to my comments, RDC will be submitting additional written testimony.

Thank you.