To: Carl Benz August 12 1996
Asssistant Field Supervisor,
US Fish and Wildlife Service
2493 Portola Rd, Suite B
Ventura, California
Re: Draft Southern Sea Otter Recovery Plan
or Southern Sea Otter (SSO) Delisting Proposal
In the grand overview of all environmental protection, conservation and restoration endeavors, species preservation may be the most important. With the removal of human impacts, forests may someday recover from immense destruction, toxic pollution and even nuclear pollution may dissipate eventually (over the course of tens of thousands of years).
But once a species is lost - it is lost literally forever - FOREVER. Never to breathe another breath for the millions or billions more years the earth could continue to animal support life. No matter how well science can advance we can not revive dinosaurs or even put a tree back on its stump and expect it to live.
Living in the north Pacific for perhaps tens of thousands of years, the southern sea otter can fairly safely be said to have faced extinction only as a result of human activities.
The Southern Sea Otter should not be delisted or have its status changed at this time. While this may be an appropriate time to establish numbers of otters for the different risk thresholds, because of many critical uncertainties, those number should be adjusted UP a considerable amount from the proposed numbers.
Table of Contents
Threat and Recovery Analysis:
Uncertainties
1) Genetic Narrowness of original 50 Southern Sea Otters.
2) Computer / Software Models have a high amount of uncertainty.
3) The Population Dynamics of SSO are unknown.
Other Threats
4) Threats other than oil spills.
5) Pesticide and Other Toxic Runoff Into Sea Otter Habitat
Higher Risk
6) High Shipwreck Incidence in SSO habitat.
7) An Exxon Valdez size oil spill is not worst case.
8) One bad event vs Two or more near simultaneous bad oil spills.
9) One bad event vs Two or more near simultaneous bad events.
10) Oil Shipments will increase - not stay the same.
Recovery Suggestions:
11) Greatest threat off Ano Nuevo.
12) Oil Spill Prevention method, could pay for itself.
13) Why is cold habitat unrecognized as desirable.
14) Miscellaneous
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Threat and Recovery Analysis: (Recovery Criteria)
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The recovery criteria numbers are too small. They are significantly, perhaps magnitudes, too small when held up with the empirical evidence of otter deaths due to actual oil spills. Additionally there are many, large ADDITIVE uncertainties in the chain
of evidence presented, all of which will necessarily increase the critical threshold population numbers by large amounts, indeed probably at least - an order of magnitude over what has been proposed.
Biology has not yet advanced to the stage where we can quantify even a few of the myriad factors affecting population and mortality of a species much beyond the tenuous grip of mere possibility. We have much farther to go before we can claim certainty or even probability in these matters. Thus estimates on such issues are by definition - highly speculative.
On page 12 you recognize that the Exxon Valdez oil spill killed "at least several thousand sea otters", yet you have set their delisting, threatened and endangered criteria numbers below the known number killed as a result of this hideously harmful empirical (non-computer model) experiment.
It is completely reasonable to request you revise the numbers for endangered, threatened and delisted upwards to AT LEAST DOUBLE the numbers of the sea otters estimated as killed in Prince William Sound incident plus add in an ample margin for conservative caution.
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UNCERTAINTIES:
1) Genetic Narrowness of original 50 Southern Sea Otters.
Genetic diversity is important in a species to provide extinction resistance due to disease.
A) The threshold number of mammals that Franklin (1980) asserts is a minimum number has NOT been studied and calculated specifically for sea otters, let alone Southern Sea Otters. In the absence of this certainty, conservative caution must be used regarding the base number of 500 animals. I recommend this base number of animals be doubled to 1000. If this is uncomfortable - please have Franklin comment.
Please revise the numbers for endangered, threatened and delisted upwards appropriately and use ample margin of conservative caution.
Since 500 animals cloned from one animal have a significantly higher risk of extinction than 500 animals from a population of millions, * please change the definitions of endangered, threatened and delisted to include the variable of genetic diversity or variability.
Declining vs Rising Population
B) Even if assuming that 500 is a valid number, there is a large significant, measurable difference in genetic variability when you reach that 500 by a decrease or an increase in species populations.
When arriving at the 500 animals through population LOSS, you could have as many as 500 genetically distinct animals.
When arriving at the 500 animals through population GAIN, you could have as few as 2 genetically distinct animals (with minor mutations).
*Please refute or affirm this with detailed arguments.
Since the SSO reached its current population numbers from population gain and in the absence of better data, we must assume worst case for genetic diversity. In the absence of this certainty, EXTREME conservative caution must be used.
When arriving at the 500 animals through population gain from the original (estimated) 50 animals, you may have a MAXIMUM of 49 genetically distinct animals (with minor mutations) or as few as 2 genetically distinct animals.
Fifty genetically distinct animals is a magnitude less than the 500 genetically distinct animals used as an assumption for the basis of conclusions in this plan. Two genetically distinct animals is ANOTHER MAGNITUDE FEWER animals.
In the light of such uncertainty, EXTREME conservative caution must be used.
The minimum numbers of animals for endangered and threatened thresholds must be increased by at least that first magnitude, and possibly by the second magnitude.
In light of this uncertainty alone and ADJUSTING FOR ONLY ONE MAGNITUDE:
Please adjust the Endangered threshold number from 1850 to 18,500.
Please adjust the Threatened threshold range from 1850-2650 to 18,500 - 26,500.
Please adjust the Delisted threshold number from 2650 to 26,500.
Combining this with the uncertainty from "A" you should double the above numbers as follows:
Please adjust the Endangered threshold number from 1850 to 37,000.
Please adjust the Threatened threshold range from 1850-2650 to 37,000 - 53,000.
Please adjust the Delisted threshold number from 53,000.
Genetic diversity CAN be measured and even compared between species. Only after specific, not sample, measurements show 1000 animals of distinct wide genetic diversity should these numbers be reduced.
Please revise the numbers for endangered, threatened and delisted upwards appropriately and use ample margin of conservative caution.
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2) Computer / Software Models have a high amount of uncertainty.
I put into the record most of the following quotes from MIT's Prof John D. Sterman's essay "A Skeptics Guide to Computer Models."
"Computer models are so poorly documented and complex that no one can examine their assumptions. They are black boxes."
"They are so complicated that the user (that includes us reading the results) has no confidence in the consistency or correctness of the assumptions."
"They are unable to deal with relationships and factors that are difficult to quantify, for which numerical data do not exist, or that lie outside the expertise of the specialists who built the model."
(From the SSO Recovery Plan - Appendix B page 3) "Each LE was tracked for 21 days, UNTIL BEACHED, or until out of the model domain."
The limiting criteria above "UNTIL BEACHED" is an example of a weak assumption. It is well known that "beached" oil from a spill indeed remains toxic, deadly, difficult to quantify and may resume floating with the next tide.
Resuming with Sterman's comments:
"No one can (or should) make decisions on the basis of computer model results that are simply presented, "take 'em or leave 'em." The primary function of model building should be educational rather than predictive."
In direct contrast to Prof Sterman's guidance, I find the several computer model results are presented in exactly this disapproved fashion - "take 'em or leave 'em." Numbers are taken directly from the model results as though exact fact - without margin of error.
To the contrary there is a large and probably unquantifiable margin of error in all computer models used as a basis for conclusion in this Plan - OSRISK, SPHAREA and the endangered animal models used by Franklin, Frankel & Soule.
Please revise the numbers for endangered, threatened and delisted upwards appropriately and use ample margin of conservative caution. Lacking better data, please use a 50% margin of safety on this factor.
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3) The Population Dynamics of the SSO are unknown.
The Population Dynamics of a species is the understanding of how a species population fluctuates in quantity and health with the varying phenomena of its habitat.
Though there are usually an uncountable number of variables, the major factors can often be understood after observing a number of a species living within a range to affect each other over a minimum of one lifespan e.g. a grove of trees or a community of sea otters.
SSO have only been listed for about one long lifespan - some 19 years. In that time there have been significant changes in human impact variables and natural variables. The effects of both natural and human impact variables are at best minimally studied.
It is unlikely that most major phenomena affecting SSO population dynamics are understood today.
Please revise the numbers for endangered, threatened and delisted upwards appropriately and use ample margin of conservative caution. Lacking better data, please use a 25% margin of safety on this factor.
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OTHER THREATS
4) Threats other than oil spills.
This analysis is incomplete until it substantively evaluates other threats to the SSO. The SSO was originally depleted to near extinction due to an industry that has no connection to oil spills - hunting.
Hunting
While you identify vindictive shooting of the SSO, no analysis is made of the original threat - hunting for profit. Please do so. As you know many endangered animals are hunted for less profitable reasons than could the sea otter.
Known Disease
Some 40 percent of Southern Sea Otters have an infection at time of death. Perhaps disease alone, or pollution enhanced disease may exceed oil spills as a threat to the animal. Please revise your analysis and conclusions to adequately prepare for this additional significant threat.
Un-Known Disease
Adjacent to the SSO habitat is the home of the native Monterey pine (pinus radiata. Ten years ago a NEW disease called pitch canker (fusarium subglutanins) was introduced to the native stands and threatens to kill, or weaken so other diseases can kill, 85% of the remaining radiata.
A previously unknown disease can just as easily threaten the SSO to the same degree. Please evaluate such a threat and please revise the numbers for endangered, threatened and delisted upwards appropriately and use ample margin of conservative caution.
Other possible categories of threats include physical (other than hunting e.g. sound such as ATOC), chemical, temperature, electrical, biological (other than disease), legal, political.
Please give at least a brief discussion of the other possible threats.
Please revise the numbers for endangered, threatened and delisted upwards appropriately for each of the above threats and use ample margin of conservative caution. Lacking better data, please use a 75% margin of safety on this factor.
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5) Pesticide and Other Toxic Runoff Into Sea Otter Habitat
The Plan leaves Toxic Runoff (Pesticides and fertilizers) undescribed and unanalyzed.
A golfer in Washington DC died from exposure to Chlorothanlonil on a golf course, one of most common golf course pesticides. Nemacur (phenamiphos) another common golf course pesticide killed thousands of fish in Florida.
Muhammed Ali's speech & coordination problems were caused by pesticides - Waco Tribune Herald 2/26/94
"Recent study by Golf Superintendent Assoc of America noted an alarmingly high rate of cancer deaths among former members" -WSJ may 2 1994
Golf Courses are "Green Graveyards". Because of pesticides, insecticides, herbicides and fungicides nothing lives on a golf course but turfgrass. No birds, no animals, no insects. They may live right next to the fairways, tees and greens, but they do not live on the turfgrass.
Please note a study of 87 golf courses by the Attorney General of New York State, "Toxic Fairways", found 6 of the most common pesticides "are known to be capable of CONTAMINATING GROUNDWATER after NORMAL applications FOLLOWING LABEL DIRECTIONS." (emphasis added)
According to the Wall Street Journal (May 2 1994) about 18 pounds of pesticides are applied per acre of Golf Course. There are 17 Golf Courses within 15 minutes of Monterey. All drain into Southern Sea Otter habitat. Several more, north of the Monterey Peninsula, drain into SSO habitat.
Typical Poisons used in Golf Courses are Phosporus, Mercury, Arsenic, Nemacur (phenamiphos), ethelyene dibromide, Chlorothanlonil and Diazanon insecticide. Diazanon insecticide - which killed 50 birds near a single application - was only banned after a 5 year battle with chemical manufacturer Ciba Geigy. Fertilizers are also toxic pollutants.
*Please quantify, for risk assessment purposes, all chemicals (chemical name and Brand name) and the yearly amounts (in pounds) applied on golf courses which drain into Southern Sea Otter habitat.
Please investigate and quantify the impacts to the Southern Sea Otter and its habitat from pesticides and fertilizers in runoff from existing golf courses.
Lawn Pesticides:
Please investigate and quantify the impacts to the Southern Sea Otter and its habitat from pesticides and fertilizers in runoff from the landscaping of private home gardens.
*Please describe, or if too difficult estimate, the toxicity limits to the Southern Sea Otter for each chemical described above in terms of Carcinogenic, hazardous, poisonous, and lethal doses.
*If there are no studies of toxicity for a specific chemical - please explicitly note that.
*Please obtain and study a Material Data Safety Sheet (MSDS) for each chemical applied to Golf Courses upstream of SSO habitat, just as required for every chemical used in a school laboratory.
Please identify other poisons and potentially deadly toxics transported by ship along SSO habitat.
Please revise the numbers for endangered, threatened and delisted upwards appropriately and use ample margin of conservative caution. Lacking better data, please use a 75% margin of safety on this factor.
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HIGHER RISK
6) High Shipwreck Incidence in SSO habitat.
Appendix B Page 6
"The likelihood of spills was assumed to be uniformly distributed along each of these routes."
Due to persistent, intense fog and severely rocky shores SSO habitat has a notably higher incidence of shipwrecks and collissions.
A study of shipwrecks on the California coast should reveal two things.
1. An unusually high number and percentage of shipwrecks in SSO habitat.
2. A high volume of tanker traffic carrying oil and other toxic and poisonous materials which if spilled would kill significant numbers of sea otters.
Please perform such a study.
Please identify other toxics and poisons including radioactive materials being shipped off the SSO habitat and which could kill sea otters.
Please revise the numbers for endangered, threatened and delisted upwards appropriately and use ample margin of conservative caution. Lacking better data, please use a minimum 25% margin of safety on this factor.
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7) An Exxon Valdez size oil spill is not worst case.
Obviously an oil spill could exceed the size and sea otter death toll of the Exxon Valdez.
The Plan discusses in depth "worst case scenario" of an Exxon Valdez size spill (page 12 Appendix B), yet fails to examine a "worst case scenario" of the SIZE of an oil spill.
Please revise the threats to Southern Sea Otters to determine a worst case oil spill.
Please revise the numbers for endangered, threatened and delisted upwards appropriately and use ample margin of conservative caution. Please revise the numbers for endangered, threatened and delisted upwards appropriately and use ample margin of conservative caution. Lacking better data, please use a 10% margin of safety on this factor.
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8) One bad event vs Two or more near simultaneous bad oil spills.
The models estimate one oil spill will exceed 1000 barrels averaging every 5 years (pg 7).
Just as it is foolhardy to walk across a river knowing only that it has an average depth of 3 feet, it is similarly inappropriate to assume those (100+ barrel) oil spills will occur like clockwork - every five years. It is far more likely that oil spills could occur closer together than otters would have time to recover to their full population numbers.
In the light of such uncertainty, EXTREME conservative caution must be used.
Please re-evaluate the risks to Southern Sea Otters if two major oil spills occur at the most-harmful-interval. The most-harmful-interval may be two consecutive years during pupping season.
Please revise the numbers for endangered, threatened and delisted upwards appropriately and use ample margin of conservative caution. Lacking better data, please use a 40% margin of safety on this factor.
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9) One bad event vs Two or more near simultaneous bad events.
Please describe what long range population numbers and range fluctuations this Plan assumes. Please place special emphasis on timeframe (in years) and other unexpected events AFTER an initial oil spill.
According to the text on page 13 this study appears to expect threats to happen in this fashion (once delisted):
a) The number of Southern Sea Otters is above the delisting population amount.
b) A single harmful event occurs resulting in Southern Sea Otter deaths, but never sufficiently harmful so the population falls below "a genetically viable population".
c) Over an undefined number of years Southern Sea Otter population rises back above the viable population number so that the otter population can remain non-extinct.
* Please confirm, clarify or deny that this is the set of assumptions used.
If this is so, this model does not account for simultaneous harmful events - whether similar in category (e.g. 2 oil spills) or 2 different events (e.g. a new disease and an oil spill).
It is not impossible, indeed it is quite possible that a second or a third, harmful event can happen BEFORE the SSO population can recover from the first harmful event.
Threats are likely to be additive not necessarily overlapping.
* Please evaluate this and incorporate this into your conclusions. Please revise the numbers for endangered, threatened and delisted upwards appropriately and use ample margin of conservative caution. Lacking better data, please use a 50% margin of safety on this factor.
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10) Oil Shipments will increase - not stay the same.
Appendix B page 5 "...the 1992 volumes [of oil] were multiplied by 30 to arrive at a total projected volume transported along these routes over a 30 year period."
Clearly over the next 30 years US population will increase and so will oil volume and number of oil tankers alongside SSO habitat. Whether these increases will be proportional to expected population increase is uncertain, but some reasonable correlation should be established.
Please revise the numbers for endangered, threatened and delisted upwards appropriately and use ample margin of conservative caution. Lacking better data, please use a 15% margin of safety on this factor.
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RECOVERY SUGGESTIONS:
11) Greatest threat off Ano Nuevo
What seems properly confirmed from the computer models are the generalities "the number of sea otters likely to be contacted by a spill decreases with increasing distance from shore." And "Spills originating in the area off Point Ano Nueveo represent the greatest threat in terms of the number of sea otters that would be contacted."
Thus the most significant single step which can be taken is to move oil tankers significantly offshore off Point Ano Nuevo.
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12) Oil Spill Prevention method, could pay for itself.
For Oil Spill prevention and for Oil Spill reduction in severity, please include and evaluate in detail the following method under "II Recovery" B2 where it says "A plan is needed ..."
For Oil Spill prevention and for Oil Spill reduction in severity, please revise section B21 to insert the words "prevent and" so the sentence reads: "Oil spill risks within ... developed to effectively *prevent and* minimize oil spill risk ..."
For Oil Spill prevention and for Oil Spill reduction in severity, please include and evaluate in detail the following method under "II Recovery" B21 where it says "...a plan developed to EFFECTIVELY minimize oil spill risk to the California Sea Otter
Population."
For Oil Spill prevention and for Oil Spill reduction in severity, please include and evaluate in detail the following method under "II Recovery" B212 where it says "Take actions identified in task 211 to minimize the risk of tanker accidents..."
OIL-TANKER SPILLS PREVENTED
WITH AIRCRAFT TECHNOLOGY
(c) Copyright 1990-1996 David Dilworth
FINANCIAL BURDENS
Insurance companies fight to keep from paying billion dollar settlements such as that following the EXXON Valdez incident in Alaska. Oil tanker ship owners can not be eager to sign bigger and bigger checks for the rapidly increasing insurance premiums for oil tanker spills.
Both of these industries stand to realize significantly lower costs and correspondingly higher profits when a reliable, inexpensive improved method of preventing and reducing tanker oil spills is realized.
VISION
Ideally, when an oil tanker runs aground or into another ship it shouldn't spill any oil at all - no matter how severely the hull is damaged. A viable solution should not be expensive, yet should return a significant reduction in oil spill reality and liability. How could that be achieved?
AIRCRAFT PROTECTION
Military and general aviation aircraft have used rubberized fuel tank bladders (liners) since the late 1940's primarily to reduce the possibility of fire and explosion. The liners also reduce fuel leakage.
RACE CAR FIRE PROTECTION
Until the mid 1970's, gas tanks for racing cars were simply a rigid metal tank welded or riveted together. The same as any Ford or Chevrolet you buy today. Nearly every time one of those racing cars hit something in an accident, the metal fuel tank cracked or leaked gas onto red-hot exhaust pipes. More often than not a large fire ensued. Many drivers were severely burned in accidents. Dozens burned to death.
To combat this problem fuel-tank-liners were introduced in the 1970's. A fuel-tank-liner is like a very tough water-balloon. It is a rubberized liner put inside your gas-tank to store the fuel. They are made from the same tough and flexible material used in white-water river rafting boats. Now, when a race-car hits something, the external metal tank might be torn, split, cracked or broken - but because of the inner liners' flexibility, only rarely will the liner itself tear and allow fuel to leak. When they do leak, the amount is minimal in all but the most severe accidents.
In the years since the fuel-tank liner has been in use in racing cars, dozens of drivers have been spared from burning to death. Fuel tank liners are required equipment today. Death from fires in racing automobiles is a fraction of that before the 1970's. The increase in fire safety for race car accidents is a direct result of the fuel-liners not allowing as much fuel to leak.
KITCHEN ENGINEERING
Take two wine glasses. One glass is filled with water. The second glass has a food-baggie in it and the baggie is filled with the water. Next, with a sharp ice-pick, strongly poke each glass. The first glass will break and all the water will spill out. The second glass will also break, but very little water will leak out compared to the glass without the baggie. At worst - a small hole will be poked in the baggie or torn by the sharp edges of the remaining glass. The water that does leak will leak at a significantly slower rate than that of the unprotected glass.
A small commercial example of this bladder/liner principle is the "Wine-in-a-Box" which has a double layer plastic container (mylar for strength and polyethylene for elasticity) inside a cardboard box. If you drop this filled "box" from a height such as 100' onto sharp rocks, the cardboard box may be damaged, but the inner liner will rarely tear or burst. If the liner does tear, the amount of wine spilled and the rate it escapes will be small.
WHAT ABOUT LINERS FOR OIL TANKERS?
Now, suppose two supertankers run aground on the rocks at Waikiki Beach in Honolulu, Hawaii. Which one do you suppose would leak less oil? A tanker with a big tough baggie (bladder/liner) inside its hull? or the tanker without such protection?
BUT SHIPS ARE SO MUCH BIGGER ... (Can you scale it up?)
An oil-tanker hull is thicker than a wine glass, a race car fuel tank or the skin of an airplane wing, but the principle is identical - just bigger. They all have a rigid shell with a tough flexible bag inside to hold the liquid. Even though supertankers hulls are inches of steel, when they run aground (468 times in 1988*) or into each other (371 times in 1988*) they are almost as fragile or brittle as a drinking glass.
WHAT ABOUT DOUBLE HULLS?
Double Hulls for oil-tankers are a hot item in the press today. Unfortunately, they are extremely expensive. Retrofitting takes a profitable ship is out of commission for 6-8 months. And double-hulls have yet to demonstrate they can significantly reduce or prevent oil spills.
Consider this experiment. Lets repeat the test of dropping the "Wine-in-a-Box" 100 feet onto sharp rocks, but this time let's simulate double-hulls by making a second-hull of cardboard and removing the plastic "baggie" so the wine is up against bare cardboard only protected by the double-hull cardboard.
Now let's drop it once again 100 feet onto sharp rocks. How much wine do you think will escape this time compared to the test with the normal cardboard "Wine-in-a-Box" with its double plastic liner?
COSTS
The fuel liner cost for a $150,000 small private plane (like a Bonanza) is between $4000 and $6000. Oil tanker liner costs could be expected to be scaled up in relation to liner surface area. One could also expect a large percent reduction in fabrication and insurance costs because of the less stringent regulations on ships vs aircraft.
INSTALLATION & MAINTENANCE
Aircraft installation is made very difficult by the requirement that the liners be rolled up and pushed through tiny holes in bulkheads. Because of the wide hull openings, this is not expected to be a problem with ship installation. Aircraft fuel liners are generally easy to repair. Because of the relative ease of access, tanker liners should be even easier to repair.
IMMEDIATE RESULTS
Liners should significantly reduce the amount of oil spilled in two ways. First, when there is a tanker grounding or collision, the likelihood of the liner leaking should be on the order of one tenth the amount of an un-linered ship. Second, if they ever do leak, the leak should be much easier to stop because the leak is so much slower.
With a significantly reduced probability of oil loss from an accident, insurance for oil tankers might be enough less expensive that the liners could pay for themselves in a few months in reduced insurance premiums.
It is entirely possible liners could be retro-fitted into any existing oil-tanker in a few days. To save time and money it is likely they could even be installed while an empty ship is at sea in transit.
FIRE SAFETY
Additionally, they should greatly reduce the risk that a fire would ever start, like the front page and evening news tanker in the Gulf of Mexico in June 1990. Additionally liners should minimize the size of a fire should one start.
PROBLEMS
Perhaps no oil transport scheme will ever be 100% safe from spills. Certainly there will be some problems developing the liners, but all the concerns identified to date are relatively simple engineering problems which have mostly already been solved by the aircraft industry. For example sloshing is reduced with the use of internal baffles. All major conceptual roadblocks have been solved by the aircraft and auto racing industries. The 40 year track record of the liners in aircraft speaks for itself.
SUMMARY
Liners could make current shipping of oil significantly less expensive for ship owners through lower premiums and eliminating the need for retrofitting double hulls. Tanker accidents should be less expensive for insurance companies because the smaller and slower leakage would reduce environmental damage, maximize oil recovered and reduce the risk of fire and environmental or medical lawsuits.
In summary, Liners versus Double hulls in oil tankers - (These are seat of the pants engineering estimates only)
* Could reduce yearly spill volume from all tankers using them by as much 90%.
* Could cost as little as 1/20 of double hull retrofitting. $1.5 million US vs $30 - $90 million for double hull retrofit.
* Could be installed as much as 20 times more quickly.
This technology has been used with unarguable success for more than 40 years in military and private aircraft, and for 20 years in the automobile racing industry. Its use in Oil Tankers, or at the very least - its testing, is seriously overdue. The pros and cons need to be formally discussed ASAP.
*U.S. Coast Guard statistics
David Dilworth
Box 1495, Carmel CA 408/624-6500 June 10, 1990
(c) Copyright D.J.Dilworth 1990,1991,1992,1993,1994,1996
- All Rights Reserved
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October 17 1990:
California Congressman Leon Panetta has asked the U.S. Coast Guard for an evaluation of this concept's merits. The Coast Guard awaits a reply from the National Academy of Sciences (NAS). I've spoken to NAS's Don Perkins, the person responsible for the NAS report. "The NAS report will not recommend investigation of this potential because it hasn't been tested. The Coast Guard won't test it until NAS recommends it (Catch-22)."
Contacts:
Mark Van Haberback Coast Guard, Washington DC
Dan Perkins NAS (National Academy of Sciences -DC)
Robert Blumberg Dept State, Oceans & Intl. Envir & Scientific Affairs
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13) Why is cold habitat unrecognized as desirable habitat for SSOs?
A. Sea Otters as a species have the most dense populations in the cold water and climate of the north pacific coast.
B. Sea Otters as a species do not live below 20 degrees north latitude.
C. As one swims through the ocean south from the SSO habitat, the ocean and air get warmer.
D. Sea Otters as a species do not live in the southern hemisphere.
E. In order to migrate to the southern hemisphere Sea Otters would have to swim through warmer water.
F. Translocation of Southern Sea Otters to Santa Barbara Islands was (warmer water than either here or off Washington state) unsuccessful.
G. Translocation of Northern Sea Otters off of Washington state (cooler water than either here or Santa Barbara Islands) was successful.
Is it possible that sea otters are somehow uncomfortable living in warmer water? The reasons could include either uncomfortable body temperature (due to world class fur insulation) or a dearth of desirable food which lives in that warmer water.
It seems reasonable that a more potentially successful translocation effort would be to the NORTH - towards colder water such as northern california beyond San Francisco. At the same time this would lessen the risk to the population from a single oil
spill by considerably widening their territory.
The plan rejects this possibility without explanation. Please explain using detailed evidence and reason.
Please evaluate this cold water translocation suggestion as mitigation.
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14) Miscellaneous:
Please graph the data on page 1 of appendix A.
Thank you sincerely for taking the time
to read and respond to my comments,
-David Dilworth
Box 1495, Carmel, Ca 93921; (408) 624-6500