Tag Archives: NOAA

Another Southern Resident killer whale is losing body condition, and researchers are concerned about the pregnant females

K25 has lost body condition

Will we lose Scoter (J25) next? NOAA and partner organizations are watching him carefully as they consider options to increase the volume of Chinook salmon that can be made available to the orcas. Biologists report that it is not unusual for a male to die once their mothers are gone, especially when fish are scarce. Scoter’s mother died in 2017.
Also of concern is the question of how viable the expected calves will be, based on data that show 70% of the Southern Resident orca births have failed to produce healthy calves during recent years. (Read more on the pregnancy failures),
NOAA’s announcement:

Scientists from NOAA’s Fisheries Southwest Fisheries Science Center are currently working in collaboration with SR3: SeaLife Response, Rehabilitation and Research The previous link is a link to non-Federal government web site. Click to review NOAA Fisheries disclaimer to collect aerial photogrammetry images in an ongoing study to monitor the growth and body condition of endangered Southern Resident killer whales. These data support management actions to ensure an adequate supply of their Chinook salmon prey. In the shorter term, the aerial perspective also offers important insights into the health of individual whales. Earlier this month, this collaborative study provided key information on the condition of an ailing young whale, J50 The previous link is a link to non-Federal government web site. Click to review NOAA Fisheries disclaimer , and her mother, J16. In recent days, the photogrammetry team have documented another SRKW individual to be in notably poorer body condition compared to recent years.
K25, a 27-year old adult male has been documented in aerial photographs since 2008.
This year, his body profile is thinner than previous years (see images [above]). This change coincides with the loss of his mother, K13 in 2017, and likely reflects the challenges he faces without her help in capturing and sharing prey. Males rely on help from their mothers, and other family members, to meet their increased energy demands, and long term demographic monitoring The previous link is a link to non-Federal government web site. Click to review NOAA Fisheries disclaimer has shown that adult males have an increased mortality risk following their mother’s death, highlighting K25’s current vulnerability.
Offering a more hopeful outlook for this group, aerial images collected this week have also documented K27, K25’s sister, to be heavily pregnant, along with a number of other females in all three pods (J, K and L) within the population. Whales carry their baby weight below the ribcage, just like humans, enabling later-term pregnancies to be reliably documented from aerial images of body shape (see images [above]).
Unfortunately, there is currently a high rate of reproductive failure The previous link is a link to non-Federal government web site. Click to review NOAA Fisheries disclaimer in this population, and K27 has been documented to have aborted a fetus The previous link is a link to non-Federal government web site. Click to review NOAA Fisheries disclaimer in recent years. Follow-up monitoring by our colleagues at the Center for Whale Research The previous link is a link to non-Federal government web site. Click to review NOAA Fisheries disclaimer will determine the success of these pregnancies

Seaworld, salmon, senators and saving orcas – NOAA’s role has limits

Playful whales in happier times.

“There are no silver bullets”

The patience and equanimity of the NOAA officials was impressive at the recent public meetings that were held to discuss the status of the endangered Southern Resident killer whales. After sharing details, the staff opened the mic to the public – NOAA was there to listen, and listen they did as the public poured out concerns, demands, and judgments primarily on the lack of sufficient salmon and on the presence of SeaWorld in the medical treatment given to the now deceased orca calf, Scarlet (J50).
Wild salmon and captive cetaceans are only partly under NOAA’s authority so a few details may have escaped mention during the meetings.

SeaWorld’s role

SeaWorld has more than earned their place as the captivity whipping boy, and they deserve the huge pit of costly reparations that need to be made to save the endangered Southern Resident orcas.
But the Salish Sea is an unofficial sanctuary where captures and harming of almost everything that swims there is either regulated or protected. As the result of a lawsuit, SeaWorld is specifically forbidden from participating in captures or keeping a whale taken from Washington State waters. They were run out of Alaska when they tried there, and British Columbia, Canada also gave them the boot.

This file photo shows orca whales from the J and K pods swim past a small research boat on Puget Sound in view of downtown Seattle. (AP Photo/NOAA Fisheries Service, Candice Emmons, file).

Does the fact that SeaWorld contributed to the whale population loss mean that SeaWorld shouldn’t help fix the situation? Of course not – that would be like preferring to die over being saved by a doctor because of ethnicity, religion, or gender bias. Whether we like it or not, SeaWorld has expertise in marine mammal rescue and rehabilitation and regularly saves the lives of the whales and dolphins that turn up on our shores.

The salmon question

NOAA’s jurisdiction over salmon is complicated, in part thanks to President Nixon’s feud decades ago with his Secretary of the Interior. Nixon put the newly created National Oceanic and Atmospheric Administration (NOAA) under the purview of the Department of Commerce instead of the Interior:
From Science Magazine:

President Barack Obama today confirmed the rumored political shenanigans surrounding the creation of the National Oceanic and Atmospheric Administration (NOAA) 4 decades ago.
Give you a few examples. There are five different entities dealing with housing. There are more than a dozen agencies dealing with food safety. My favorite example—which I mentioned in last year’s State of the Union address—as it turns out, the Interior Department is in charge of salmon in fresh water, but the Commerce Department handles them in saltwater. (Laughter.) If you’re wondering what the genesis of this was, apparently, it had something to do with President Nixon being unhappy with his Interior Secretary for criticizing him about the Vietnam War. And so he decided not to put NOAA in what would have been a more sensible place.

NOAA has done the best conceivable job in the effort to save Scarlet, and while they work with SeaWorld the language NOAA uses in the discussions is straightforward and to the point.
It may be belated, but NOAA has stepped up to the plate.

Congress is paying attention

Great news – on September 10th Senator Murray and other senators quietly announced that the ongoing legislative effort to protect salmon-killing and unneeded dams that passed in the House basically died an ignoble death in the Senate.
From Save Our Wild Salmon:

As a result of our/your collective work, politics and policy in the Northwest is shifting. Kudos are especially due to Senator Patty Murray who led this regional fight to stop the Salmon Extinction Act (HR 3144) and Rider (Section 506). Senator Murray recognized these bills for what they were: harmful to salmon and harmful to regional processes and discussions occurring today to address the problems that face salmon, orca and Northwest communities. HR 3144 and Section 506 are both highly divisive to the Northwest communities that must work together on shared solutions to common problems. Thanks and praise are also due to other key elected officials who worked vigilantly to prevent these bills from becoming law, including Reps. Adam Smith, Pramila Jayapal, Earl Blumenauer, Derek Kilmer, Denny Heck, and others.
Importantly, when HR 3144 came to the House floor for a vote, all the Democratic lawmakers in Oregon and Washington voted the right way – against it – with one exception – Rep. Kurt Schrader from Oregon.

From Senator Murray’s website:

The future of the Columbia River is critically important to the Pacific Northwest economy and to our way of life, which is why I have long insisted that we keep politics and partisanship out of this and allow the ongoing legal process to play out. I am glad this deal does exactly that. Nothing in this report, and nothing in the bill itself, would insert Congress or partisan politics into the process or would interfere with the court-mandated comprehensive review that everyone can participate in and accounts for all uses of our river system.
“Throughout this process, it has been and will continue to be important that we make sure scientific questions remain in the hands of scientists and not politicians. I continue to stand ready to work with any Republicans who are willing to work with me to forge consensus around these important Pacific Northwest issues and not just politicize the process, facts, and science.

Saving these whales is going to take all of us working together but Congress can do the most when it comes to turning things around quickly. Ken Balcomb at the Center for Whale Research thinks we have only 5 more years to turn the salmon famine around before the whale population won’t be able to rebound.
He also thinks that a few of the orcas are pregnant…and they need food now.


Saving J 50 (Scarlet); public meetings will be held by NOAA September 15th and 16th

J 50 (Scarlet) loves to breach and when she was healthy breached once 50 times in a row. Photo credit: Clint Rivers

This announcement by NOAA, DFO Canada, and their team gives us hope that not only are they doing everything possible to save J 50 (Scarlet), but whatever actions they take will be in the best interest of  both her health and her family ties.
The scientists don’t have much time to act, yet they want the public to understand what it will take to help this naturally lively whale who is so imbued with character and once had energy to spare, and whose survival may be key in the restoration of the Southern Resident killer whale population.
NOAA has arranged two public meetings in Washington State for next weekend (September 15th and 16th), but if you can’t attend, any live streams, audios, or reports will be updated here.
J 50 (Scarlet) has lost significant body condition since May. Photo credit:  SR3/NOAA

UPDATE from NOAA:  September 11, 2018

J50’s condition in recent weeks has underscored the urgency of recovering the endangered Southern Resident killer whale population.  NOAA Fisheries and our partners have been exploring and taking action to save J50 because of her importance as a contributing member of this population, and particularly to J Pod.

The public has a stake in the J50 response and the recovery of Southern Resident killer whales and we understand many people are concerned.  We want to know what people in the region think about this effort and potential steps so we are holding two public meetings in Washington State to hear the public’s views:

  • Saturday, Sept. 15, at 7 p.m. in Friday Harbor at Friday Harbor High School
  • Sunday, Sept. 16, at 1 p.m. in Seattle at University of Washington, Haggett Hall Cascade Room

J50’s condition has declined over recent months to the point where she is emaciated and often lagging behind her family. Field treatment has not improved her condition, and veterinarians believe they have exhausted all reasonable remote treatment options and her survival is unlikely.


The next steps could include further intervention, such as a rescue operation and conducting a hands-on physical examination. That could lead to more in-depth diagnoses, rapid treatment, and return to the water or short-term rehabilitation and care to improve her chances of survival, with the ultimate goal of reuniting her with her family.

Two objectives will determine any further intervention to help J50:

  • providing appropriate conservation medical actions for J50 to  protect her potential contribution to the recovery of the population, and
  • avoiding harm to the rest of J Pod and the Southern Resident population of 75 whales.

No rescue would proceed while J50 remains with J Pod and her family group. Response teams would act to rescue J50 only if she becomes stranded or separated from the rest of J Pod such that any risks of the intervention to the rest of J Pod are minimized.

The overriding priority of any rescue intervention would be to evaluate, treat, and rehabilitate J50 in a manner that would support the greatest chance of her survival while ensuring her return and reunification with her family as soon as possible so she can contribute to long-term recovery of the population.

If veterinarians and other experts who assess J50 in the field determine that she cannot be treated or rehabilitated, teams would promptly return her to J Pod to spend the rest of her life with her family.

Photo: J50/Scarlet swims near Point Roberts, Wash., on Aug. 10. (Photo by Katy Foster/NOAA Fisheries, under permit 18786.)

Updates on the sick orca calf J 50 (Scarlet) – she’s thin but she’s a fighter (9 Sept 2018)

Rest assured, government agencies in Canada and the US are committed to doing what they have been tasked by law to do in treating this sick young whale. Scarlet has amazed researchers in her tenacity and ability to stay with her family – albeit at her own pace – as she continues to lose body condition.
NOAA, DFO Canada, the Center for Whale Research and others are working around the clock to monitor and to strategize urgent care procedures for little Scarlet, one of the last members of the endangered Southern Resident killer whales.
The team’s priorities are clear:
First, do no harm. Under the US Endangered Species Act:

“…all federal agencies shall seek to conserve endangered and threatened species and shall use their authorities in furtherance of the purposes of the ESA…It also requires these agencies to ensure that any actions they fund, authorize, or carry out are not likely to jeopardize the survival of any endangered or threatened species, or to destroy or adversely modify its designated critical habitat (if any).

Second, preserve the population’s viability. Under Canada’s Species at Risk laws:

In preparing a recovery strategy, action plan or management plan, the competent minister must consider the commitment of the Government of Canada to conserving biological diversity and to the principle that, if there are threats of serious or irreversible damage to the listed wildlife species, cost-effective measures to prevent the reduction or loss of the species should not be postponed for a lack of full scientific certainty.



“Biologists are mobilized and responding to an emaciated and ailing three year-old killer whale (born December 2014), J50 also known as Scarlet, of the critically endangered Southern Resident population. J50 appears lethargic at times with periods of activity, including feeding. Scientists observing her agree that she is in poor condition and may not survive. Responders from NOAA Fisheries and partner organizations are exploring options ranging from no intervention to providing medical treatment, potentially delivered in a live Chinook salmon, which has never before been attempted in the wild. Potential treatment may include medication and nutrition.” Updates are from NOAA.
September 8:
J50 was seen lagging a half-mile to a mile behind the rest of her family group at times on Friday (9/7), and her body condition is not improving. She appeared to have lost more weight and looked very thin.
With growing concern, we are working with Fisheries and Oceans Canada (DFO) to evaluate options. Our highest priorities are to do all we can to ensure J50 remains a contributing part of the Southern Resident killer whale population and to prevent any harm to her and her family under any potential response scenario.
That is the bottom line.

J50’s deteriorating condition. (Photo: Katy Foster)

September 6:
Results are back from fecal and breath samples the team collected from a small group of J Pod whales, including J50.
Based on genetic analysis, we determined that the fecal sample (collected 8/17) likely came from J16, J50’s mother. This sample showed evidence of parasitic worms. Since J16 catches fish that she then shares with J50, the veterinary team prioritized treating J50 with a dewormer, following antibiotics.
A second fecal sample was identified as coming from J27, an adult male. Researchers at our Northwest Fisheries Science Center extracted DNA from the breath sample collected on 8/9.
While the sample was small and yielded little DNA, researchers are adapting their analysis to make the most of the available material.
J50 is still keeping up with her pod (Photo: Katy Foster)

September 4:
Biologists observing J50 on Monday (9/3) noted she was remarkably active and engaged with J Pod despite her severely emaciated condition.
J50 stayed close to her mother, J16, and continued the longer dives expected of healthy whales. Veterinarian Dr. Martin Haulena of the Vancouver Aquarium provided J50 another dose of antibiotics through a dart, following up the initial dose administered on 8/9.
The treatment priority has now shifted to administering a dewormer, also through a dart, to reduce any parasitic burden on J50’s system.

September 3, 11:45 a.m.:  Good news!
Multiple organizations are reporting that J50 has been spotted with J Pod in the Salish Sea this morning. We will continue efforts to assess the health of J50 and treat her according to the priorities outlined by the team of veterinarians and scientists.
September 3: J50 was not seen returning from open waters off the West Coast of Vancouver Island to the Salish Sea with J Pod this weekend (9/1-2). Biologists from The Center for Whale Research, Soundwatch,  and the University of Washington spent much of the day Sunday with other members of J Pod, including J16, her mother, and J50 was not seen with them.
The team has several boats on the water today to look for her. One of the last sightings by DFO on Thursday (8/30) reported that J16 and J26, J50’s brother, were lagging behind most of J Pod by about three nautical miles, and J50 was lagging about a half-mile behind them. Sometimes she got closer, but she looked to be struggling to keep up.
The standard for determining the loss of any of the Southern Residents is to spot a whale’s family group multiple times without them. This rule may be relevant for J50 in order to confirm her status given how far behind the other whales she had followed at times.

Killing seals to save orcas is dangerously short-sighted and won’t work

Not that long ago, fishermen killed Southern Resident killer whales because the whales were eating Chinook salmon…let that sink in while we explore whether killing marine mammals has ever worked in the long haul to save salmon populations.
In a few days the annual slaughter of dolphins in Taiji, Japan, will begin its six-month bloodbath. Among the reasons that fishermen hunt down and kill dolphins is the industry’s deeply held belief that marine mammals compete for fish.
Can that happen in the Salish Sea? As disturbing as it is to think about, the answer is yes – dolphins and porpoises have no substantial protections and their “takes” are managed by NOAA.

Japan’s example

After countless decades of the slaughter and subsequent reduced dolphin populations, Japan’s fisheries catch has spiraled down to an all-time low. Japan’s solution? They’ve added even more dolphin species to the kill list this year.
By the 1970s Japan had already driven the indigenous Japanese sea lion to extinction and to this day they continue to cull Steller sea lions annually.

Western Steller Sea Lions are listed as vulnerable in the Threatened Wildlife of Japan Red Data Book. Hattori and Yamamura (2014) reported that over 200 Steller Sea Lions were culled annually between 1960-1993 to reduce predation on commercial fish stocks.
Recent work indicates that the annual culling was then reduced to a limit of 116/year until 2010 at which time a new 5 year quota of 1,030 culled Sea Lions was imposed. This resulted in an increased annual average take (Matsuda et al. 2015).

Despite the culling, the Japanese fishing industry is on a steep decline – their catch of 12.8 million tons of fish in 1984 was down to 4.3 million tons in 2017, an all time low.

Killing seals to save a few fish

If the concept of killing off marine mammals to leave more salmon for fisheries has failed in Japan (where salmon catch declined by 27% last year), why would we assume that culling marine mammals would succeed in restoring Chinook salmon for the endangered Southern Resident orcas?
With proposals on the table to extend the killing to all pinnipeds (seals and sea lions) in Puget Sound and other areas of the Salish Sea, how long will it be until demands are made to cull dolphins and porpoises as well?
Does the idea of killing one kind of marine mammal to save another make any sense whatsoever when there is no evidence that it will succeed longterm?
It may seem unthinkable, but if we allow the government to permit the killing of one marine mammal species to save another by attempting to control fish predation, it is a slippery slope to go from seals and sea lions to dolphins.

Harbor seal  Photo Credit: Kachemak Bay Wilderness Lodge
Yet that is a solution being bandied about by special interest groups concerned with the Chinook salmon population – they want to take out sea lions and harbor seals as a quick solution to what is really a complex problem.
There may be some logic to culling if the seals and sea lions were directly eating the orcas, though even if that were the case and we decided to cull orca predators we would have to start with the most effective and damaging predator.
And that would be us.

Southern Resident orcas were once killed by fishery interests

There are living members of the Southern Resident orcas who were once shot at, harpooned, and subjected to the noise of seal bombs by fishers who resented the competition for salmon. The US Navy gunned down an entire population of fish-eating orcas in Iceland to “help” the fishing industry there.
As the Southern Resident orca population decreased in the Salish Sea due to culling (either by being killed or captured for display, similar to what goes on in Taiji), Chinook salmon still continued to dwindle. Killing the orcas didn’t bring back salmon. Nor will killing pinnipeds.


But fishing is not the only way that humans are driving the abundance and evolutionary biology of salmon – we have added evolutionary pressures by altering the environment as well.
Dams not only impede the salmon’s journey, but dramatically alter stream and river ecology. Salmon must navigate challenging hatching conditions, endure siltification of their natal streams and rivers, and withstand marginal water temperatures – then survive being flung through the dam turbines on their seaward journey.
They must escape predators that gather at the dams, and the young salmon must cope with the lake conditions present in the manmade reservoirs created by the dams (which gives a huge advantage to some of the predatory fish species and is not natural to the salmon). Finally, the young fish encounter estuaries that are often inadequate in both food and places to hide.
Research shows that the battering the young salmon take on their way to sea increases their mortality while at sea – this means that the debate over how accurate the statistics are on how many smolts initially survive the dams is a small part of the equation since they are more likely to die at sea.

Abstract.—The numbers of Snake River salmon and steelhead Oncorhynchus spp. have substantially declined since the completion of the Columbia River hydrosystem. We used analytical approaches to identify management options for halting the decline of these stocks, such as removal of Snake River dams and improvements to the existing hydrosystem. The benefits these actions are predicted to have in terms of salmon recovery hinge on whether the mortality that takes place in the estuary and early in their ocean residence is related to earlier hydrosystem experience during downstream migration. Evidence from the literature demonstrates numerous mechanisms that would  explain this delayed mortality in relation to a fish’s experience passing through the hydrosystem. Spatial and temporal comparisons of stock performance provide indirect evidence of delayed mortality and evidence that delayed mortality is linked to hydrosystem experience. Recent mark— recapture data also provide evidence of differences in delayed mortality by route of passage through the hydrosystem. The different types of evidence discussed here suggest that the delayed mortality of Snake River fish is related to the hydrosystem.

On their return trip, the salmon must battle the same conditions, and again must make it past those dams, increasing the time they must spend in getting to their natal streams.
And then there are the bears…do we kill them too?

Photo Credit: Tahitia Hicks / AP

The Southern Resident Killer Whale Task Force

Government tends to balk when the cost of acting is high – whether that cost is in dollars, jobs, energy, or security – because it is also our government’s job to protect us and to oversee the growth of our nation in the long term. Our government tends to favor a cost/benefit analysis, and this can be detrimental when swift action is called for with respect to environmental issues, such as in taking decisive action to restore our salmon fishery.
For years Washington State has performed controlled culling of the sea lions that congregate at certain dams but only after other methods were exhausted. Now Congress has bills in the works which will allow loose control over whether the killing is humane and reduces oversight as it increases the number of animals that can be culled.
Governor Jay Inslee’s establishment of the Southern Resident Killer Whale Recovery and Task Force is an inspiring and bold move to come to terms with conflicting beliefs, and it’s possibly our last opportunity to step back, look at the big picture, and think about future generations.
The process has underscored to me how open and willing those of us who live in this region are to pitch in and look for resolution when it comes to salmon and orcas, a subject where the potential for conflict is high. Our personal lifestyles and regional self-interests are deeply challenged as we weigh the needs of the whales against our own – yet what has become clear is that we are unified in a desire to “get ‘er done”.
We seem to be on the road to solutions, the quickest of which would be to increase salmon passage on the lower Snake River dams.
But let’s leave the seals and sea lions alone.

Reference links:

War of the Whales: A True Story

Congress plans to kill male California sea lions and undermine NOAA Fisheries management

Killing the animals that co-evolved with salmon won’t help restore fish populations – we need to remove just a few of the 15 dams on one of the rivers that flow into the Columbia River.

Female California sea lions remain in southern California and points south, all year. Photo credit: NOAA

Male California sea lions migrate south in the breeding season, and some stop in the Columbia River to eat salmon on the way down to California.     Photo credit: Bridget Samuels via Flickr

A branded male sea lion. Photo credit: Pillip Colla

Following the breeding season, male California sea lions leave the Channel Islands and other rookeries and migrate north, eventually seeking out protected inland waterways in the winter. The females remain in the general region of the rookeries, and so aren’t among the sea lions that Congress aims to wipe out.
The crime? Eating salmon that congregate at dams – specifically those on the Columbia and Willamette river systems. Two bills – one that passed in the House of Representatives, and another working its way through the Senate – remove any semblance of management and open the door to wholesale slaughter of pinnepeds.
Presently the fisheries services must prove that a sea lion is actually eating salmon before he is euthanized. This involves branding the animal if he lacks identifying marks, then keeping track of him.
To get around that, the new bills define ‘identifying marks’ as being in the river past more than 112 miles from the ocean. In other words, he just has to be a sea lion. For the Senate bill, it just has to be a pinneped, meaning harbor seals. Neither bill specifically excludes the endangered Steller sea lions.
The bills increase the number of animals that can be killed, who can kill them, and where.
The senate bill expands the prey issue from salmon to any species of fish.
The sea lions will still catch salmon entering the rivers, though they may need to work a little harder. It is pointless to try and wipe them all out, even if it made any kind of logical sense. From TDN.com:

[Dr. Naomi Rose], a biologist with the Animal Welfare Institute said Tuesday that killing more sea lions will not reverse the decline of wild salmon runs.

“The main problem is that this is not going to solve the problem,” Naomi Rose, the institute’s marine mammal biologist, said in an interview. “This is an example of lawmakers scapegoating these natural predators to satisfy the anger that constituent groups feel toward salmon decline.”
Rose said wild salmon numbers have fallen mostly due to a loss of habitat and the construction of dams on the Columbia River.

Killing more sea lions could even make the problem worse, she said, because sea lions consume other species of fish that eat young salmon.
The decline of salmon, one of the region’s iconic species, has been attributed to a host of factors: overfishing, habitat destruction, construction of the hydroelectric dams and predation by Caspian terns and cormorants.
Sea lions historically have shared the salmon’s ecosystem, but their numbers have rebounded while the fish runs are still far below their historic, pre-dam levels.
So the mammals’ impact on salmon runs is more pronounced, especially because manmade structures like fish ladders have made it easier for the sea lions to catch them. TDN.com

The Senate bill:   https://www.congress.gov/bill/115th-congress/senate-bill/1702/text
The House bill:   https://www.congress.gov/bill/115th-congress/house-bill/2083
Information on California sea lion migration:  Migration Patterns of Adult Male
California Sea Lions (Zalophus californianus)
Removing the four lower dams on the Snake River:  DamSense.org

This rescued killer whale calf is thriving 15 years later – “Celebrate Springer!” events

Fifteen years ago, Springer, an orphaned and lost orca calf was successfully rescued, rehabilitated, and returned to her wild family.
“Springer’s story is an inspiration on many levels,” said Paul Spong of OrcaLab. “It proved that an orphan orca, alone and separated from her family, can be rehabilitated and returned to a normal productive life with her family and community; and it showed that disparate parties with diverse interests can come together and work together for the common goal of helping one little whale.”

Graeme Ellis: Springer and calf Spirit, 4 July 2013

“The Springer success story continues to be an inspiration for all of us working on conservation in the Salish Sea,” said Lynne Barre, the lead for orca recovery at NOAA Fisheries’ West Coast regional office in Seattle. “The partnerships created during Springer’s rescue provide a strong foundation for international cooperation as well as coordination between government, state, tribal, and non-profit groups to benefit both Northern and Southern Resident killer whales.”
Fifteen years later, Springer is still healthy and in 2013 had her first calf, Spirit. They are most often seen on the north central British Columbia coast and occasionally return to Johnstone Strait in summer.
“Springer’s reunion is an unqualified success – the only project of its kind in history,” said Donna Sandstrom, director of The Whale Trail and organizer of the Vashon Island event. “To get the little whale home, we had to learn how to work together, as organizations, agencies and nations. Above all, we put her best interests first. Community members played a key role in shaping Springer’s fate. We hope her story inspires people to join us in working on issues facing our endangered southern resident orcas today, with the same urgency, commitment, and resolve.”
The 2002 Springer rescue team will reconvene in programs and events in Puget Sound, Georgia Strait and Telegraph Cove in May, June and July to give first-hand accounts of how Springer was identified, rescued and rehabilitated. She was taken by jet catamaran to the north end of Vancouver Island and reunited with her Northern Resident family.

Celebrate Springer!” begins on May 20 on Vashon Island near the waters were Springer was found. The Vashon Theater program of “Springer’s Story” will feature members of the rescue team, a dance performance by Le La La Dancers, who were present at Springer’s release, and followed by a late afternoon Whale Trail sign dedication at the Point Robinson Lighthouse.
The event will continue in June and July with programs at NOAA Fisheries, Whale Trail Orca Talk, Whale Trail sign dedications, and conclude with a three-day program at Telegraph Cove, British Columbia, where Springer was released in 2002 and rejoined her Northern Resident family.
For more information, check out the Celebrate Springer Facebook page and The Whale Trail.

“Celebrate Springer!” partners include NOAA Fisheries, Fisheries and Oceans Canada, OrcaLab, Whale Interpretive Center, Vancouver Aquarium and The Whale Trail.

With the Inclusion of Lolita, the Endangered Wild Orca Population is Now 79…But This Video May Surprise You

“The 2005 endangered listing for Southern Resident Killer Whales, a distinct population of killer whales in the Pacific Northwest, excluded captive animals. In 2013, People for the Ethical Treatment of Animals and other groups petitioned NOAA Fisheries to drop the exclusion so the listing would also include Lolita. In early 2014 NOAA Fisheries proposed to drop the exclusion. Since then the agency has further reviewed scientific evidence and more than 17,000 public comments to arrive at a final decision.”  (NOAA).

While Lolita is now aboard NOAA’s ark, she is no closer to swimming with her wild family members  – which is ironic considering her inclusion just increased the population by one percent, about the same factor as the birth of their latest calf. But then again, had Lolita not been taken in the first place or even returned at a younger age most likely she would have had several calves.

Instead, she fell down a bureaucratic rabbit hole into a tiny tank, where the only people who are concerned for her right to adequate space and companionship seem powerless to help her.

NOAA also seems fairly powerless to help Lolita, according to their recent press conference, but they did an excellent job of presenting the facts and explaining what the endangered species classification can, and cannot, do for Lolita. Their audio news conference was edited for this video, but all the pertinent information is present.

I just wish I could have detected a tone of sympathy for Lolita or regret by NOAA at their powerlessness but to be fair these are very competent individuals reporting in their official capacity.


Whales, Dolphins, and Ocean Noise: ‘Absence of Evidence is not Evidence of Absence’

Whales and dolphins are known to strand due to sonar and seismic exploration.
Whales and dolphins are known to strand due to sonar and seismic exploration.

Your input is needed to balance that of the oil industry and special interests on the issue of ocean noise – March 13, 2014 is the deadline to make comments on the government’s proposed guidelines on ocean acoustics and marine mammals.
Because this is a complex issue involving a lot of science and technical language, reading all of the documents can be off-putting and discouraging but it is worth the effort to skim through them.  However, if you are short on time the information below will give you a great start and can be checked back through the links provided.


Your input is vital! The oil industry would like a proposed 24 hour time period for measuring the sound levels their activities generate reduced significantly to as little as three hours – which means they would only have to measure a portion of the recommended time.
NOAA has repeatedly requested more input on this point (please scroll to the bottom to the section on the public meeting), and it is important to share your thoughts as counter-point to industry input such as this statement by a researcher contracted by the oil industry. (See full remark below).

This leads me to ask “what problem is NOAA trying to solve by this aggressive  approach?” Is there any evidence at all that the present guidelines leave whales with hearing loss from shipping, low-frequency active sonar, seismic arrays, and others? Have whale populations declined in areas where these sources are used? Unless there is evidence of either effect, then it is best to discard this graph and continue to use the present guidelines until empirical data become available on hearing in low-frequency cetaceans. (Gentry)

Fortunately, when dealing with wildlife the government has taken the stance that the benefit of doubt should go to the animals, particularly if there are threatened or endangered species involved (which sadly is true in all the oceans). You can use this point as an argument in your comment to the government.
Background on the Endangered Species Act:

5. Assess species responses to exposure.
Actions potentially resulting in habitat modification or destruction are indirect effects – as these effects may ultimately cause demographic effects on individuals or populations of a listed species. In this case the assessment must determine if a species habitat is likely to change in response to action-related changes in the quantity, quality, or availability of one or more of the resources that comprise its habitat.
To meet the statutory requirement to insure a proposed action is not likely to cause JAM, the agency conducts its analysis to avoid concluding that the action had no effect on listed species or its habitat when, in fact, there was an effect. This approach minimizes the likelihood of making a false negative conclusion (absence of evidence is not evidence of absence). In doing so, the agency must use the “best scientific and commercial data available,” and in cases where information is incomplete, clearly articulate the rationale for reaching a conclusion (thus avoiding being found to have made an arbitrary or capricious conclusion). At times, this approach to error may lead to different conclusions than would a more traditional scientific approach to hypothesis testing, but it is in compliance with direction from the ESA and the courts to provide the benefit of the doubt to the species.
6. Assess risk: to individuals, populations, and to species.
a. Would the response of the individuals exposed to the action be sufficient to reduce the fitness of those individuals?
b. Would changes in the fitness of these individuals be sufficient to increase the extinction risk (or reduce the probability of persistence and recovery) of the populations, given what is known about the species?
c. Would changes in the extinction risk (or persistence) of those populations be sufficient to increase the extinction risk of the species, given its status?

Below are excerpts from the relevant documents, but you can stop reading here and just use the information on endangered species above since it is applicable.

One additional point – walruses, polar bears, otters, and manatees are NOT included in NOAA’s document and so your comments on these species will not be included for consideration.  They will only consider arguments that address points covered in the document.

Please go here to enter your comment, the full draft can be found here. Reference comments from the documents are below, you might them helpful in writing your comments.


 NOAA’s remarks taken from the Peer Review Report:
(“Thresholds” refers to the sound levels that cause temporary hearing impairment (‘TTS  is Temporary Threshold Shift’) or permanent hearing loss (PTS is ‘Permanent Threshold Shift’)).

  • There will not be implementing regulations in association with this document.
  • These thresholds are to be used more before the activity occurs. So when applicants come and they have to estimate how many marine mammals are going to be harassed…this more of a tool to be used beforehand rather than out in the field.
  • So whatever process applicants are undergoing now in order to estimate the distribution or presence of marine mammals when they come in for authorizations under the MMPA would be the same using these thresholds. It is just that the science used in calculating these  thresholds is different.
  • So on a case-by-case basis, I would assume that applicants are doing the best  they can to estimate the distribution and presence of marine mammals, but there is no guidance additional within this document for that kind of estimation.

NOAA is continuing our examination of the effects of noise on marine mammal behavior and will focus our work over the next year on developing guidance regarding the effects of anthropogenic sound on marine mammal behavior. Behavioral response is a complex question, and additional time is needed to research and appropriately address the issue.
This guidance on behavior, when available, will also be subject to future peer review.

Input  was made by these four peer reviewers:

Klaus Lucke, Ph.D., Wageningen University and Research (The Netherlands)  “Results of masking modelling indicate that airgun sounds can lead to a reduction in communication range for blue and fin whales 2000 km from the source depending strongly on the frequency content of the vocalization.” Conference abstract, page 180
Paul Nachtigall, Ph.D., University of Hawaii Loud anthropogenic sounds have been associated with whale strandings. Loud impulsive sounds may contribute to behavioral disruption and hearing deficits.” Conference abstract, page 113  {This preliminary study showed that some cetaceans may be able to mute the effects of noise when given a warning noise.}
Doug Nowacek, Ph.D., Duke University “The critical elements of a robust mitigation and monitoring plan for responsibly conducting marine seismic surveys include obtaining baseline ecological data; substantial advance planning, communication, and critical review; integrated acoustic and visual monitoring during operations; and systematic analysis of results to inform future planning and mitigation.” Abstract
Aaron Thode, Ph.D., Scripps Institution of Oceanography  “Call localization rates (CLRs) were compared before, during, and after periods of airgun use between sites near seismic activities (median distance 41-45km) and sites relatively distant from seismic activities (median distance >104km). At the onset of airgun use, CLRs dropped significantly at sites near the airguns, where median received levels from airgun pulses (SPL) were 116-129 dB re 1 Pa (10-450 Hz). Abstract   {This study was done on bowhead whales.}

The bulleted points below were taken from the Peer Review document – they are not in order since the remarks were not identified by reviewer (but are by one of the individuals above, or by a NOAA representative, so are somewhat anonymous).
These remarks were selected to represent the issue that seems to be most important for the public to comment upon, the 24 hour recovery period. (cSEL is ‘cumulative Sound Exposure Level’). NOAA repeatedly requested that this issue be addressed during the comment period.

  • I feel the report has so many caveats on this subject as to render this definition worthless:
    “The 24-h baseline accumulation period is generally considered a conservative baseline for accumulation time under most situations. However, flexibility may be required. For example, if specific information on residence time of individuals, likely swim speeds for transient species, more specific details on the sound-producing activity (e.g., specific times when activity temporarily ceases),”
  • Just about every oil and gas industry survey is going to try to reduce this period of time to the time it takes for a migrating animal to swim past a spatially compact activity.
  • I think a sentence should be added that if the primary behavior of marine mammals in the area is migration, the cSEL duration can be restricted to three hours. Areas that cover feeding and mating should remain at 24 hours. This is much simpler than requiring an applicant to estimate swimming speed, swimming depth, whether animals is assumed to deviate or avoid course, etc. Restricting duration to 3 hours also makes the behavioral and TTS criteria more consistent.
  • → Response: NOAA appreciates your input on this particular topic and anticipate there will be additional comments provided during the public comment period. The proposed 24-h accumulation period may not be appropriate for certain sound sources or species. We are planning to call particular attention to this topic during the public comment period.
  • Additionally, your comments seem to focus strictly on seismic activities. However, the proposed accumulation period is for all PTS onset acoustic threshold levels for various sources (e.g., sonar, pile driving, drilling, etc.). Thus, there are multiple considerations needed based on whether a source is stationary or mobile and based on the species and specific context of exposure.
  • Proposed solution: Provide specific guidelines whether cSEL covers only proposed activities or whether it covers all independent activities (including shipping) during that time. State whether NOAA will reduce the cSEL threshold if multiple permits working in the same area are received.
  • Another issue with defining cSEL duration to be 24 hours is what to do when multiple uncoordinated activities are present. For example, multiple seismic surveys? Shipping vessel transits? NOAA should also state intentions what it plans to do if multiple organizations submit requests to operate in the same region, with each showing individual cSELs below TTS, but cumulative cSEL from all operations exceed TTS.
  • Response: Currently, the PTS onset acoustic threshold levels are being proposed for discrete activities and not multiple activities occurring in a single area. This will be clarified in the text (footnote #15).


Input from those attending the public meeting:
JESSICA LEFEVRE [Jessica S. Lefevre is an attorney in private practice specializing in natural resource issues, including the mitigation of local impacts resulting from resource development. She has served ascounsel to the Alaska Eskimo Whaling Commission since 1985]:

I think we might encourage you to do that, if it is possible, and we also will  put in a request for an extension. This is pretty important and a lot of information to get on top of. Those are procedural questions. My substantive question is: Could you talk a little bit how the cumulative SEL can be used to account for multiple, repeated exposures, where you’ve got an animal going past one site and then moving along encountering a second site? It just we have not had a lot of time to spend with this and that is one of the questions we’re trying to wrap our heads around. Thanks.
[MODERATOR]: I think terms of the nature of that comment, what I would suggest is that you provide information that you think it is not clear how we are proceeding in accumulating sound from multiple exposures, and we will make sure we clarify that in the final document. Thank you.

SCOTT SLAUGHTER: I am Scott Slaughter, and I am commenting today on behalf of The Center for Regulatory Effectiveness  [“CRE was formed by former career officials of the White House Office of Management and Budget. The head of the firm is Jim Tozzi.It has been criticised as a front organisation for industries which seek to undermine the regulatory process, notably by Chris C. Mooney in his book The Republican War on Science.[1]  Wikipedia].

…Given this absence of harm in the real world, the government should carefully consider the benefits and costs of regulating oil and gas  seismic. In particular, the government should consider the requirements of Executive Orders 12866 and 13563 when regulating oil and gas seismic. Under Executive Order 12866, the Guidance should go to OMB to review standards that require a benefit-cost analysis be performed. Suggest that the government solicit public input performing cost-benefit analysis. We thank you for the opportunity to present these comments, and we look forward to the government’s response.

ROGER GENTRY: I’m Roger Gentry..G-E-N-T-R-Y. I’m with ProScience Consulting and the Joint Industry Program. [“The JIP is a cooperative effort, established in 1991, by a number of petroleum and chemical companies to consolidate independent construction cost surveys soliciting similar information from contractors”.]

I’m going to read my statement.
My written comments covers three pages, but I’ll just here discuss the guidelines for low-frequency cetaceans. The frequency weighting function shown in Figure 2 [page 16 of NOAA’s draft acoustic Guidance ] are basically invented because there are no empirical data to support them.
It is probably invalid to use mid-frequency cetacean equal loudness contours to set points “a” and “b” on that graph. The overall effect of this weighting function is much more  aggressive than the approach presently in place, especially in the Arctic guidelines. It implies that low-frequency cetaceans are much more sensitive to acoustic exposure than is formally believed, and it does so with supporting data.
This leads me to ask “what problem is NOAA trying to solve by this aggressive  approach?” Is there any evidence at all that the present guidelines leave whales with hearing loss from shipping, low-frequency active sonar, seismic arrays, and others? Have whale populations declined in areas where these sources are used? Unless there is evidence of either effect, then it is best to discard this graph and continue to use the present guidelines until empirical data become available on hearing in low-frequency cetaceans.
Several funding groups are interested in obtaining these data, and current development suggests they will be available in five to six years when the next version of these guidelines should appear. NOAA wisely declined to set guidelines for behavioral effects due to poor data and should make an equally wise decision to not to set guidelines for low-frequency cetaceans in total absence of data. Thank you.

DAVID ZEDDIES: Hi. David Zeddies. Last name Z-E-D-D-I-E-S. I’m at JASCO Applied Sciences. [JASCO Research is an international company with over 25 years experience providing consulting services to the Marine Industrial, Oceanographic, Oil & Gas, Fisheries, Defense and IT sectors.] 

I want to make a quick technical comment on the 24-hour integration period, and it starts with..we have a pretty good idea why you want to do that. There are natural breaks in the operations or you want to give some sort of method for allowing recovery to occur, but 24 hours is an arbitrary number that is really not based in any type of biology that I am aware of. There is some scant studies on that, but basically thereare better ways of doing it. Agent-based models we have will give you a natural indication of how long the animals..you expect the animals to be in that area. So instead of setting a guideline that strictly writes down the number ..in a 24-hour period, you could ask people to estimate the time the animals would be in that area, and there are also better ways of allowing for recovery periods. That would be as part of the cumulative SEL measurement. You could integrate..you could use a function that would allow for some recovery period.

ROBERT SUYDAM  [Senior Wildlife Biologist, Department of Wildlife Management, North Slope Borough] :

Thank you. My name is Robert Suydam. My last name is spelled S-U-Y-D-A- M. First, I would like to kinda re-emphasize what Dr. Ketten and Dr. Gentry mentioned about a section on needed research I think would be helpful in the document and then a couple of other points. One that Jessica LeFevre mentioned, the cumulative impacts issue of multiple operations that I know that frequently in the past NOAA has not ..dealt with each operation separately and not really addressed cumulative impacts from multiple operations on individual animals. So adopting new guidance criteria, I think needs to figure out how to address that issue of multiple operations that are occurring in one location. So, I think additional guidance is needed there. I would also like to comment on the guy from JASCO, sorry I didn’t catch his name that the 24 hour integration period for cumulative SEL seems a bit arbitrary and some additional support is needed for..in the document for why the 24 hour integration period is the appropriate one and not either a greater period or shorter period. So that would be helpful.
Another issue that really wasn’t addressed in the Guidance is the issue of impulsive sound versus non- impulsive sound. Of course with seismic sound, they are impulsive when they are close, when an animal is close to the seismic source, but they become more non-impulsive the farther you are away from an airgun. Of course, the loudness of the sounds changes, as well, but maybe trying to figure out if having  this dichotomy of impulsive vs. non-impulsive is really the best way to go or whether there needs to be some other category in between there? And then, I guess a question that I had: I understand that the  Guidance is really about assessing what the effects are on the marine mammals prior to the operations that I am at a loss to figure out at least how cumulative SEL is going to be actually monitored for what animals are actually taken. So I think the Guidance, the new Guidance would really benefit by having a section on how monitoring would occur to actually figure out if the projections of exposures to marine mammals are realistic.
[MODERATOR]: Thank you very much. I would just like to reiterate that any input that anyone may have on the accumulation duration, we would much appreciate that. Thank you.


NOAA’s New Noise Guidelines for Marine Mammals – What You Need to Know

In order to make comments on this draft during the next 30 days, you can view the document here (note: there is a list of acronyms on page VII, and a glossary of terms on page 61 – both very helpful!) then place your comment here (which is document  NOAA-NMFS-2013-0177). You have until January 26th, 2013.
Please remember, NOAA will only take seriously comments that address the specific document, which in this case is the science behind the numbers but is also the lack of a broader scope.  NOAA promises to release the peer reviewer reports and NOAA’s response to those reports, but they are not up at the present time.
article-2449077-18956B9700000578-858_634x430 pilots in spain
By the title “Draft Guidance for Assessing the Effects of Anthropogenic Sound on Marine Mammals“, you might think that NOAA is establishing guidelines for assessing the effects of anthropogenic (manmade) sound on marine mammals.  Guess again.
The promise:

 This guidance is intended to be used by NOAA analysts and managers and other relevant user groups and stakeholders, including other federal agencies, when seeking to determine whether and how  their activities are expected to result in particular types of impacts to marine mammals via  acoustic exposure.

What they deliver:

This document outlines NOAA’s updated acoustic threshold levels and  describes in detail how the thresholds were developed and how they will be revised and updated in the future.

Not included:

NOAA currently is in the process of developing  new thresholds for onset of behavioral effects. When that process is completed, TTS [Temporary Threshold Shift, which are temporary hearing losses] will be  addressed for purposes of take quantification. In the meantime, the TTS thresholds presented represent the best available science and will be used in the comprehensive effects analyses under the MMPA [Marine Mammal Protection Act} and the ESA [Endangered Species Act] and may inform the development of mitigation and monitoring.

In other words,the draft does not cover behavior in any new way, and disregards any science that correlates certain types of sound with strandings and deaths, nor does it address the compounding effect of so many sources of noise invading the marine environment for lengthy time periods.
It is a myopic look through the lens of hard science on how sound effects different species of marine mammals, and although it is based on solid science the data points are few, and NOAA set clear guidelines for updating as new research is published.
Having so little data available, NOAA basically relies heavily on Marine Mammal Noise Exposure Criteria:  Initial Scientific Recommendations in setting the guidelines for PTS (Permanent Threshold Shift, which is permanent hearing loss):

Thus, NOAA accepts the recommendation made by Southall et al. (2007) as guidance for determining PTS onset for impulsive signals for all cetacean [dolphin, porpoise, whale] and underwater pinniped [seals, sea lions, walruses) species, resulting in an approximate 15 dB difference between TTS [temportary] and PTS [permanent] onset.

That study was published in the journal Aquatic Mammals, which is “Supported through Joint Sponsorship by the European Association for Aquatic Mammals, the Alliance of Marine Mammal Parks and Aquariums,
and the International Marine Animal Trainer’s Association.”
From a technical standpoint  NOAA’ draft is a huge step forward in delineating more species-specific guidelines, yet there are no teeth in the document to force compliance with the new standards.

 NOAA recommends that Federal agencies and prospective  applicants evaluating these types of impacts for the purposes of engaging in the aforementioned statutory processes also use these thresholds in the manner described here. However, this guidance does not create or confer any rights for or on any person, or operate to bind the public. An alternative approach may be proposed (by Federal agencies or prospective applicants) and used if case-specific information/data indicate that the alternative approach is likely to produce a more accurate estimate of Level A Harassment, harm, or auditory injury for the project being evaluated and if NOAA determines the approach satisfies the requirements of the applicable statutes and regulations.
The National Research Council (NRC 2004) provided basic guidelines on National Standard  (NS2) under the Magnuson-Stevens Fishery Conservation and Management Act, section 301, which stated “Conservation and management measures shall be based upon the best scientific information available.” They recommended that data underlying the decision-making and/or  policy-setting process be: 1) relevant, 2) inclusive, 3) objective, 4) transparent and open, 5) timely, 6) verified and validated, and 7) peer reviewed.

Of the ten candidates for peer review, NOAA selected four, all specialists in the ability of marine mammals to hear. None of the behavior experts were included, and no one addressed the effect of sound on the animals outside of the hearing structures themselves – so tissue damage resulting directly from noise, or from rapid decompression during escape from sound sources are included.

The following website contains updated information on the peer review process including: the  charge to peer reviewers, peer reviewers’ names, peer reviewers’ individual reports, and NOAA’s response to peer reviewer reports http://www.nmfs.noaa.gov/pr/acoustics/guidelines.htm.

Below are some samples from the document – which, while long, is logically laid out and easy to navigate (but very science dense).

NOAA has compiled, interpreted and synthesized the best available science to produce new thresholds for the onset of both temporary and permanent hearing threshold shift (“TTS” and  “PTS”, respectively) in marine mammals from underwater sound. In the regulatory context, NOAA uses this information to help quantify “take” and to conduct more comprehensive effects analyses under several statutes.
For applicants/users that have the ability to model moving animals and/or  sources and the accumulating sound at each receiver, NOAA proposes that 24-hours or the length of activity, whichever is less, be used as the accumulation time. 24 hours has been used in other noise assessment planning applications (e.g., community noise planning for aircraft, vehicular traffic, and railway noise) and provides a reasonable outer bound in situations where the model will be able reflect realistic changes in relative distance between the source and likely exposed marine mammals over the course of a day.
However, for models that do not incorporate animal movement, it is not appropriate to make the assumption that animals will remain at a constant distance from the source accumulating acoustic energy for 24 hours. Additionally, if sound accumulation cannot be modeled, an alternative method must be used. For situations where modelling of movement and sound accumulation are not possible, an alternate method that is intended to address the accumulation of sound energy over time, but instead provides a distance from the source (“SEL threshold distance”) that is  simpler to apply in exposure modeling (i.e., would be used in calculations in the same way distance is used to calculate exposures above previous NOAA sound pressure level thresholds) should be used. Based on what we know about typical animal movement and avoidance, we propose a 1-hour accumulation period be used to calculate the “SEL threshold distance”. This “SEL threshold distance” is calculated by determining the distance from the source at which an animal would have to remain for 1 hour in order to accumulate sound to the designated threshold.  While, animals may move closer and farther from the source, this distance is considered a reasonable and conservative approximation.
The 24-hour (for models able to account for movement and sound accumulation) and 1-hour (for models not able to account for movement and sound accumulation) accumulation periods are considered a conservative baseline for accumulation time under most situations. The use ofmodels able to account for movement and sound accumulation may also allow for the inclusion of additional details to provide a more realistic results based on the accumulation of sound (e.g. information on residence time of individuals, swim speeds for transient species, or specific times when activity temporarily ceases). Alternatively, there may be case-specific circumstances where the 1-hour accumulation time should be modified to account for situations where animals are expected to be in closer proximity to the source over a notably longer amount of time, based on activity, site, and species-specific information (e.g., where there is a resident population in a small and/or confined area and a long-duration activity with a large sound source, or a continuous stationery activity nearby a pinniped pupping beach).
NOAA’s previous acoustic threshold levels are expressed as root-mean-square (dBrms), which  uses a different metric from peak sound pressure levels (dBpeak) and SELcum that are being recommended for our TTS and PTS onset acoustic threshold levels. Thus, we recommend caution when comparing past acoustic threshold levels to the acoustic threshold levels presented in this document as because they are based on different metrics, they are not directly comparable. For example, a 180 dBrms level is not equal to a 180 dBpeak level. Furthermore, theSELcum metric incorporates time and is an energy level with a different reference value (re: 1μPa2-13 s), thus it is not directly comparable to other metrics that describe sound pressure levels (re: 1 14 μPa).