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I disagree with the killing of sea lions by the NMFS, the have failed to meet legal standards and to demonstrate necessary criteria for killing sea lions.

Even though the Bonneville Dam task force was provided with information that shows some sea lions eat many more salmon than others, the criteria for killing a sea lion is any animal who has been seen eating salmonids between January 1 and May 31 of any year and has been seen below the dam for any 5 days (either consecutively, or within a season or over multiple years). This low threshold means that those killed may not even be those who eat the most fish.

The NMFS cannot satisfy the MMPA requirement that the predation is having a ?significant negative impact? on the decline or recovery of the fish. They estimate that sea lions eat between 2-4% of the runs but admit that the dam itself kills 2-16% of the adult fish and ?harvest? by fishermen is allowed at levels between 4-17% each year. It is not clear why these higher levels are allowable but levels of 4% or less from sea lion predation warrant lethal measures. The Marine Mammal Commission recommended that NMFS calculate the extent to which pinniped predation increases extinction risk or delays the recovery of salmon, but NMFS declined to do this.

The NMFS acknowledges that the number of sea lions proposed to be killed is a small fraction of those in the river who can move upstream to replace them. They estimate over a thousand sea lions between the mouth of the River and Bonneville Dam.

The NMFS cannot say to what degree killing the sea lions will help the fish. After estimating that the number of fish that will be saved is only a 0.5%-7% maximum improvement, they then admit ?actual numbers may be lower because eventually new sea lions would likely take the place of those that have been removed.? (EA page 5-1) They also admit that because of this uncertainty they cannot project ?a reliable estimate of any decrease in pinniped predation (and corresponding increase in salmonid survival.? (EA page 4-11)

posted 5 years, 2 months ago
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